Insights

Hello, and welcome to the Rambo webinar series on PFAS enterprise risk. My name is Scott Hader. I'm a principal at Rambo. Before we get started, we're just gonna touch on a few housekeeping issues. This webinar is being recorded. So following the presentation, you will receive an email with a link to the recording and also a link to, the slides. So you have a copy of the slides. If you have comments or questions, during the presentation, everyone on entry is muted, but you can add your questions to the comment box on the lower right hand corner of your screen. And we've saved some time at the end of the presentation to go through your questions. If we don't get to your question, we will send out a Q and A with our responses as an additional link with the presentation following this webinar. And finally, this is the first of a three part webinar series. All three webinars focus on strategies for assessing PFAS enterprise risk. This first one is a general overview. The second one will focus, which will be on February nine, will focus on facilities and operations. And then the third presentation in the series will be occur on March ninth, and it'll focus on products and supply chain. So we'll take a quick look at the agenda here. So we'll start off with, just a regulatory overview for PFAS, and then we'll dive right into PFAS enterprise risk and talking about strategies for assessing the enterprise risk. And then we do have some case studies. And again, we'll, we'll, have a time for q and a, following the presentation. So we have three presenters today. Both John Cusperson and Jana Pattari, serve as the North America PFAS team leaders for Ramble. Mister Cusperson is a principal with Ramble, and he has over thirty four years of environmental consulting experience. And his sole focus during this past eleven years has been PFAS. And during this time, he has supported hundreds of projects across North America involving various PFAS issues. Doctor Pattari has more than twenty years of professional and academic experience in environmental remediation, fate, and transport of contaminants. And finally, doctor, Brian Drollette, is an experienced environmental forensic scientist specializing in complex environmental chemistry problems. From contaminant site assessment, emerging contaminant liability response, cost allocation, and more, he advises clients on risk mitigation, regulatory compliance, and litigation matters. So we'll hand it off to John. Good morning, everybody, and welcome. Glad you're joining us for this interesting topic today. I'm gonna stop start by giving just a backdrop that'll be probably a review for some people, but but necessary for the slides going forward. So here is a timeline that we put together, and this is not completely comprehensive by any means. And in here, you will notice some highlighted in red and some highlighted in green. The red is really focusing more EPA actions and state criteria, and the green's more pro product related. So, you know, going back, there was the UCMR three where that samples large municipalities, water supplies across the country. And then based on the results of that, determine what our new emerging contaminants that they're going to focus on. And during that process, they elected that PFAS was not one of them. So a lot of states were made to deal with this on their own in this time period with issues in their states, largely DOD sites and other large industrial sites. And then with all of that, EPA came out with the lifetime health advisories, which was seventy parts per trillion for PFOS, PFOA, or a combination of the two. And then right after this too is when we first started to see the transition into PFAS and products where California had materials on their prop sixty five list. And then shortly after that, you know, Washington banned a triple f and PFAS and food packaging. And through the course of this, you'll see that there were many periods of time where states kinda continue to evolve. So around two thousand twenty is when we first started seeing promulgated drinking water criteria in several states, not all of them by any means. And that was the path for, you know, trying to get some semblance of what was gonna be acceptable. In two thousand twenty one, the EPA came out with the piece PFAS strategic road map. You know, the previous administration you'll see over these four years made a lot progress with EPA. And this got into all sorts of compliance series too, you know, with TRI, you know, with their de minimis definition changing. You know, we saw Tosca as well continue to evolve. But we saw EPA finalized and promulgated the MCL's maximum containment levels for six PFAS. And also during that time, we saw that the hazardous substance designation was made in CIRCLIF for PFOS and PFOA. That has a lot to do with property transactions and also Superfund. So when we skip a little bit ahead, we also now see with the new administration some rapid changes and some rollback on PFAS regulations. And one of the proposals out there already is to rescind the MCLs for four of the compounds, leaving just PFOS and PFOA. And also during this time, you know, Maine made the first step in a ban for PFAS and biosolids. Many states now have varying kinds of rules and regulations on concentrations that could be land applied, and we continue to see states that are putting full out bans on PFAS and products. So what is what do we what do we know looking forward in this environment? I think there's a lot of uncertainty, and we don't know how the EPA is gonna respond going forward under the new administration. We do see that states are continuing with their regulatory enforcement, and that's expanding as time goes on, as they're starting to realize that EPA may not be taking the lead again, and they need to step back into that role. We're obviously gonna see the product bands continue. That's becoming a very large issue for for many of of our clients. And the last thing is biosolids management too. That's definitely a tricky topic that we're not sure how that's gonna be held. So I wanted to go through some ways that the regulatory agencies are identifying facilities. The first and and easiest is, you know, they're looking at targeting industries that are kinda known for having PFAS in in in their prod products. And, also, some states were doing PFAS use surveys like New Jersey, and they're asking a whole litany of questions of, is there any PFAS in the materials, in your process, you know, how you handled it, and that led to them then beginning to enforce sites. With wastewater, we're really starting to see now that there is discharge compliance to the wastewater treatment plants and what levels of PFAS they will allow. Wastewater treatment plants, many of them also can set their own discharge levels. And this is also leading then to these municipalities looking upstream and identifying industrial sources. You know, Michigan had done that. And last I looked, it was over three hundred and fifty industries that were identified. Stormwater continues to be an issue. And where stormwater really becomes an issue is in states that do have water quality criteria. Many do not yet. But we're also just seeing in general that many states are asking for PFAS to be added to the sampling even though there's not a criteria. And once you have it in there, that may lead to them asking questions to assess or reduce. And lastly, drinking water, obviously, you know, there's been a big push to protect both municipal and facility industrial facility drinking water supplies, and they have been putting requirements out to have those sampled. And lastly, we're seeing many lawsuits come from cities or municipalities going back to industries that may be discharging to their water supply. In all of this, you know, the identification of this in any of these ways or others, you know, that is the door opener for the agencies then to require things such as, you know, PFAS sampling of discharge points or monitoring well networks you have, assessments for PFAS investigation, and even into remedy. So what are some states doing to address PFAS? First is we're seeing standards, and and that could be in many different ways. That could be a criteria. That could be an action level or notification level. And we're seeing the soil criteria over the last number of years being rescinded from a lot of states. There are very few states that have PFAS soil criteria, and many of them are focused on direct contact. Statewide sampling events. We've all heard this and seen this. You know, large municipalities across the country within a state are all being sampled by the state municipal water wastewater treatment plants. They are also being sampled by the states, especially it's in states where there's discharge criteria. And we're also seeing background concentrations. Many states are taking attempt at this. And once they find this, you know, if they find hotspots, they're kind of looking at who's responsible for that. Then we'll talk about a triple f. And, you know, we we have seen a triple f use in training or testing prohibited, and many states are banning the use of of a triple f. And we're also seeing states with collection programs to collect up foam from municipalities such that it does not enter the environment. Obviously, we're seeing two. We talked about our product restrictions. Part of the issues with that is there there's such a broad definition of PFAS, which Brian will get to later. And what we're seeing is we're seeing a lot of bans on consumer products unless there's an un quote, unquote, unavoidable use, where there are some things products we've made that cannot function without PFAS at this time. So they're looking for replacement technologies. And lastly, we're seeing a lot more litigation and enforcement. We're seeing consent orders in, many states right now, either from the state or the municipalities. But typically, these are being sent to sites where they're not moving forward quick enough or there's a disagreement what who's responsible for what and and moving forward. And we're also seeing a lot of that, deal with natural resource damages. So with that, I'm gonna turn it over to my colleague, Yana, that's gonna start talking about enterprise risk. Right. Thank you very much, John. I appreciate that. There are several potential risk implications that arise from the increasing regulatory scrutiny on PFAS that John just described. These include regulatory and compliance risks, business and financial risks, stakeholder reputational risks, operational risks. There may be risk associated with mergers and acquisitions, and then finally, litigation risks. And I will address and talk a little bit about all of these in the following slides. In terms of the regulatory and compliance risk, as John mentioned, PFAS use emissions and discharge and disposal are increasingly regulated. Those regulations may lead to request to sample for PFAS or to assess PFAS use at facilities. If PFAS are found, facilities may need may be required to further characterize, mitigate, or address PFAS in their discharges or already present in the environment. And then the variable global federal and state regulations may also be challenging from compliance perspective in having to keep track of different requirements and associated associated timelines. In terms of operational risks, operational or supply chain disruptions may lead to operational risks. Also, for example, in the face of the restrictions on the PFAS on the use of PFAS materials, companies may need to find alternatives for or stop using PFAS containing materials altogether. That may then affect product formulations or manufacturing processes or even locations where manufacturing is occurring. There's also voluntary phase outs that are happening and market pressures that may affect the availability of PFAS materials and products potentially also causing disruptions in the supply chain. The new replacement materials may need to be requalified or approved, which may also lead lead to some delays. But there's also a potential for regrettable substitutions. What is replacing PFAS may also have harmful effects. In terms of mergers and acquisitions, both property and business transactions will include and do include now a focus on PFAS. As John mentioned, because of the CIRCA hazardous substance designation, PPOS and PFOA are now routine parts of phase one assessments in property transactions. For business transactions on PFAS, varying definitions of PFAS may be scrutinized. And based on our experience in supporting these types of due diligence assessments, there are number of key questions that the buyers are asking the target companies do it during due due diligence. And these include, for example, what is the target's awareness of PFAS and associated regulations? What is the target's knowledge of PFAS in historical or current operations and then potential pathways of release into the environment? And what are any activities or status of activities defining replacements for PFAS? So there's also business and financial risks. So companies may be held liable for environmental impacts from historical or current use of PFAS leading to potential legal and cleanup costs. Those associated liabilities may be large enough, may be large, and may even lead to potential business closures or bankruptcies. Also, addressing PFAS contamination can be costly, may require sophisticated technology and long term efforts. And in some cases, cleanup periods for PFAS can be decades longer than for legacy contaminants, mainly arising from those very low thresholds that we have for PFAS. The stakeholder concerns and reputational risks are really arising from increasing awareness of PFAS and potential health impacts. As John was describing, there are now investigations and reports of detections of PFAS in the environment and consumer products. For example, through the state led drinking water sampling programs or publications on PFAS in consumer products. Also, potential or perceived lack of regulation of PFAS may increase stakeholder stakeholder concerns. And then lastly, of course, as John mentioned, there's always the litigation risks. Businesses may face lawsuits from states, communities, individuals, or organizations that are affected by PFAS in the environment. And in our experience, we we have supported some of these some of these litigation from the technical perspectives. There are variety of lawsuits that we've seen taking place. For example, natural resource damages, product liability, cost recovery, or toxic torts. And, hopefully, the the last webinar in our three part series will dive a little bit deeper into these litigation risks. With that all being said, not all of these risks will be relevant to all industries. So your company's risk profiles is going to be very much specific to your operations, the processes that are being used or products or raw materials that are being used, where your markets might be, and also like locations where the facilities are present. Looking proactively into PFAS risks can help companies to reduce potential PFAS liabilities in the future. Also, the proactive assessment can help improve business business operations, including future proofing them. And that may be relevant in the face of the voluntary phase outs of PFAS containing materials or the PFAS restrictions at various jurisdictions. Addressing PFAS may also be important in terms of aligning with ESG or sustainability goals that a company may have committed to. And then lastly, addressing PFAS proactively may be a way to increase trust with stakeholders. And with that, I will turn this over to my colleague, Brian, to discuss strategies for assessing PFAS enterprise risk. Excellent. Thanks, Yana, for that overview of PFAS enterprise risk. Now that we've understood what some of those risks can be and some of the benefits of identifying them, I'd like to spend some time discussing how we as practitioners do these assessments and some of the strategies behind our work. When we're trying to understand what kind of liabilities might be present, one of the first things we do is actually define the risk itself and also our risk tolerance. Defining risk can come in many different forms, like Yana previously covered, from reputational risk to business interruptions. But believe it or not, when it comes to PFAS, the sky is not falling. There are pragmatic ways to look at your facility and contextualize the risk. And I'll keep coming back to that theme of contextualization, really focusing on what matters. Risk can be different in an industrial manufacturing setting versus a warehousing operation. It's not a one size fits all approach, and we need to consider factors that are relevant to the business. We also need to, upfront, define our objectives of the assessment or what PFAS related questions we're trying to answer. Conducting an assessment for regular regulatory reporting under TRI is typically different than addressing customer inquiries about potential PFAS and products. And as part of our defining of the risk itself, it might make sense to conduct the assessment under attorney client privilege for those added protections that might allow you to go above and beyond, say, you know, what an agency might be asking for. And finally, one of the biggest questions we always get is whether we should collect samples or not. Sometimes that's warranted, but many times, though, we can gather a lot of information and assess enterprise risk without ever taking a sample. And I'll focus on some of those strategies in the next two slides. One of those strategies is a nonintrusive operational assessment. And by nonintrusive, I basically mean we're not generating new data by sampling. You can think of a PFAS operational assessment as a PFAS focused phase one. The objective is to learn as much as possible about PFAS within the facility context without ever generating new data. After we've contextualized what it is we need to know, the operational assessment has a few different scopes. One is to have a PFAS subject matter expert walk the facility with a knowledgeable site rep, and they're getting the ins and outs of the raw material usage, the chemical handling and storage, processes that might use PFAS or even generate PFAS. They're seeing where late waste leaves the facility and more. The auditor should be able to pick up on PFAS associated processes or materials in real time. So having a fundamental understanding through an on-site audit can be key. But as I've highlighted on the top left here, we also need to contextualize the relevant regulations that apply to our facility and our jurisdiction. As we heard from John earlier, the federal and state regulatory landscape surrounding PFAS is always changing, and staying on top of it can be a full time job. So one of the solutions we've come up with is what we call PFAS GlobalView. PFAS GlobalView started as an internal effort for Rambault practitioners to stay on top of their regulatory landscape and provide an internal resource to our colleagues. And it's since grown to a team of over thirty subject matter experts who monitor and record every new and proposed PFAS regulation both here in the US and across many international jurisdictions. And it's also evolved into a client facing web tool for you to use and explore. PFAS GlobalView breaks down the regulatory landscape into jurisdictions and topic areas. This example of the US shows where states have guidance or laws and regulations for site investigation and remediation, for example. We track all of this across over a dozen topic areas from biosolids land application regulations to firefighting foam restrictions to wastewater and storm water regulations. It's been a very useful tool for us as practitioners to inform our clients about what the relevant regulations are for their operations. Because, again, when it comes to navigating PFAS enterprise risk, we need to define what that risk is, and one way to do so is by identifying, relevant regulations. Another key topic in our strategy to assess enterprise risk is to actually consider the PFAS that matter. Here on the screen, we have two very different molecules. The one on the left is a fluorinated gas. It's used in a lot of aerosol products, and it's a refrigerant. You probably have it in your car's air conditioning system. Because it has this single fully fluorinated carbon atom, it's considered PFAS by some of the broadest definitions like the OECD definition, and it even meets the structural definition of PFAS under TOSCA eight a seven. But when you and I look at this molecule, that's not really what comes to mind when we're thinking of PFAS. Contrast that with the molecule on the right, which is PFOS, universally accepted as a PFOS, very strictly regulated in commerce in the environment, and most compliance regulations include this molecule when they address PFOS. So, technically, they're both PFOS. And if you're conducting an operational assessment where you're trying to answer the question, do I have PFAS in my operations? Then you should be considering both of these molecules. And you're probably going to find examples of the one on the left in some of your products. But in reality, only one of these molecules are really what we typically care about and has that higher regulatory scrutiny attached to it, and that's PFOS on the right. So part of our exercise in defining risk and risk tolerance is contextualizing the PFOS we need to focus on. Another aspect of the nonintrusive operational assessment is conducting a thorough review of relevant project documents, which could come in the form of safety data sheets, purchasing records, chemical inventories, waste manifests, you name it. Within these documents can lie key information about PFAS in ways you might not expect, and sometimes they can be quite relevant. Finding strategies to do that efficiently has been a goal of our team here at Ramall over the past few years. We've developed this automated framework, which is not based on AI, but rather on authoritative lists of PFAS published by EPA under various regulatory contexts and with lists curated by Rambl's subject matter experts using acronyms, trade names, and keywords of materials that represent PFAS. An example list demonstrating its comprehensiveness is the PFAS that are designated as sarcohazardous substances. We know that PFOA and PFOS were both designated as hazardous substances, but that designation also includes their salts and structural isomers too. You might be surprised to know that there are ninety eight unique chemicals that meet that hazardous substance definition of PFOS and PFOA and their salts and structural isomers. So we're looking for all of them as one should. This tool that we have automates the scanning of our project documents to search for over fourteen thousand PFAS related search terms, which a subject matter expert can then triage to confirm the hits and identify areas for further review. I wanna show a couple of use cases where this approach has really helped us out. When doing a manual screening of project documents for PFAS, things can be easy to miss either because we're searching through hundreds of pages of chemical inventories or we're not recognizing things listed as PFAS within the document. I have two examples of safety data sheets here on the right. The top example is a floor polish. And if you were to look at section three, composition and information on ingredients, you would see two chemicals listed, neither of which are fluorinated, and therefore, they're not PFAS. You might put eyes on section three quickly, realize there's no PFAS here, and move on. But if you were to scroll all the way down to section fifteen of the safety data sheet, you'd see here that it states PFOA is in fact present in the floor polish, and that should trigger you to conduct some follow-up assessment on product usage and disposal. The second example down in the bottom right is the safety data sheet for an architectural paint. Here, the SDS composition lists it identifies one component as an acrylate polymer present at five to ten percent concentration. It looks relatively benign. However, the cast number here for this, quote, acrylate polymer is actually the CAS number for the ammonium salt of PFOA. So unless you knew off the top of your head that this CAS number represents PFOA, like me, you would gloss right over this composition list. But with some clever strategies and document screening, we're able to pick up on it. So let's say you go through this operational assessment approach and you find PFAS in your facility processes, it's prudent to consider how those PFAS may be leaving the facility. Often when considering more traditional chemicals, if you will, the pathways for release can be more static and easier to define. But with PFAS, those release mechanisms and pathways are generally more complex as PFAS that might affect your enterprise risk could be leaving the facility with your product as air emissions and wastewater, a solid waste. And then once in the environment, there's the potential for them to cycle through different environmental compartments. This then leads to the conversation about sampling. If you do want to do an intrusive assessment, where do you start, and what are the important considerations? Some of those key high level questions include whether sampling is even necessary in the first place. Can we get our hands wrapped around the risk without it? Who does the sampling is also important. There are special considerations for sample collection for PFAS to limit cross contamination, so qualified personnel should be present. The PFAS analyte list is also just as important. If an agency is inquiring about PFOA and PFOS, it might make sense to limit the laboratory to only analyzing for those two chemicals rather than a larger suite of PFAS. And if these are environmental samples, the potential for PFAS to be present as background concentrations could also be relevant. We've had instances where we found PFAS in facility wastewater effluent, but those same PFAS are present at the same level in the incoming municipal water. So we can make the case that the facility is not a material discharger of additional PFAS above those background levels. And, of course, staying on top of the relevant regulatory jurisdiction, bearing in mind the potential reporting obligations that might affect your facility is important for risk management. And, again, doing this under attorney client privilege is often advised. So if we've defined our PFAS enterprise risk, what can we do next? One thing is building a risk mitigation plan specific to your project objectives. A risk mitigation plan could include preventative measures like material substitution or process modification if we've identified PFAS in the manufacturing operations. If sampling's advised, we can develop sampling protocols and guidance for those that are collecting routine samples and maybe even implement continuous monitoring as needed. And, of course, as we've discussed, staying informed of the changing regulatory landscape is key to being in compliance. And then we can also think about stakeholder communications with customers, suppliers, and even employees about program objectives, getting in front of that brand reputational risk that is sometimes associated with PFAS. These are all components that could go into a tailored risk mitigation plan to keep you and your facility prepared. So with that, I wanna thank you for your time, and now I'll pass it back to Yana to discuss some case studies. Thank you very much, Brian. I will then discuss couple case case studies that illustrate the different scenarios where operational assessments were conducted and were helpful and also discusses the triggers behind those assessments. So I'll start with the first case study that evolves around a former industrial facility. And here, the main trigger was or a scenario was when the a agency was requesting for PFAS sampling at this facility. So this specific facility manufactured small metal items such as jewelry and coins. This is located near a very small upgrading man made lake where the waste from this facility were initially discharged to. Currently, that facility is decommissioned and undergoing remediation for chlorinated solvents. So as I mentioned, the main trigger for operational assessment was an agency request to sample for PFAS. PFAS was found in a drinking water supply sourced from a down gradient lake, so not the same one that Because the facility was engaged in metal finishing and manufacturing and also located within drinking water source protection area, the agency scrutinized this facility and asked them to sample for PFAS from groundwater monitoring wells on the property. So in terms of our approach for this assessment, it was completely a desktop assessment. However, we had the benefit of having worked at this site already for several years to support the response actions. So we had a lot of institutional knowledge on the facility to begin with. And we supplemented that institutional knowledge by doing a deeper dive into the potential for PFAS use in those historical operations. And that deeper dive included document interviews with current and past environmental professionals and then, of course, a document review that included a wealth of historical documents related to operations such as regular facility information documents from the early eighties and also early nineteen seventies wastewater treatment plan, design plans, and discussions on which include discussions discussions on the types of processes and types of chemicals that were used. We, of course, looked at public records in order to determine whether fire fires were had occurred at the site. We also had a lot of data to look at in addition to the typical hydrogeology and hydrology data. We actually had PFAS data from the nearby man made lake, tributaries to it, and from private affected private and public water supply wells as well as that down down gradient lake that had been affected by by PFAS. In terms of our operational assessment findings, we did not find any evidence for plating operations at the site requiring the use of a fume suppressants. For example, chrome plating or chrome anodizing, which at the time that when the facility was operating would have likely used PFOS based fume suppressants. Some operations based on the documents did were consistent with potential PFAS use, like metal cleaning and etching. However, the available documents, including the chemical list, did not suggest that this would have contained PFAS. We did not find evidence for fire suppression systems or fire training occurring at this with PFAS foam at the site. The PFAS data from the vicinity of the facility or the nearby public water supply wells or the down gradient lake did not suggest that the facility was a source of PFAS. So PFAS fingerprints were inconsistent what we were anticipating for the p PFAS containing fumes suppressants. That is we did not see PFOS dominant fingerprints in these samples. Also, concentration gradients did not support the facility of being a potential source. And as part of our document review, we did find other regional sources of PFAS that were present, upgrading of the affected affected drinking water supplies, namely inactive land landfills that were up up gradient and also at least in one of them, PFAS had been detected. So in terms of the outcome and the benefits for the client, we summarized the information that suggested that historical operations did not involve the use of PFAS in a document that the client then has for potential future requests for or scrutiny on PFAS around that facility. And eventually, the agency request for sample for PFAS was rescinded. Our second case study is somewhat similar as it does involve a facility. But this is in the context of due diligence of a plating facility portfolio. This portfolio consisted of eleven operational or closed facilities that conduct or conducted chrome plating. PFAS containing fume suppressants were used in operations along with air pollution control equipment. Wastewaters in general, including those from planning operations, were sent to the local publicly owned treatment wastewater treatment plants. So the main trigger for the operational assessment here was as part of the due diligence, the prospective buyer was very concerned about PFAS risks associated with these facilities. They were interested in the assessing the likelihood of expanding cleanup obligations. Many of these facilities were already being addressed for metals and solvents, and the question was whether there's a potential for those cleanup obligations to involve PFAS down the line as well. Another interest question that they were interested in was the potential for community exposures and then potential for associated litigation sometimes down the line. And also of interest for the buyers were the estimates of costs to reserve in case there would be potential liabilities arising from cleanup for PFAS. So, again, this was really a desktop assessment, including interviews and document reviews publicly available or documents that were provided by the target target portfolio. We focused on four main areas of inquiry. One of them was the period of plating operations. So, for example, the timelines, we wanted to understand what the timeline for air pollution control systems systems implementation was versus the starting of plating operations and the use of PFAS containing fumes suppressants. We were also interested in how wastewaters were managed. So whether they were held in on-site ponds, how they were treated before discharging into POTW. The site setting was also another factor. We were interested in the groundwater flow directions and if surface water features were present, whether there was any discharges or runoff potentially to those features and where those features ended up. We were also interested in the prevailing wind directions as a proxy to assess potential for air emissions fall from the plating operations, and, of course, locations of the municipal drinking water wells or other sensitive receptor locations. We assess the regulatory actions, status with the state agencies and programs. For example, if there had been already inquiries of PFAS at the facility or in the in the in the in the within the purview of the agency or if PFAS were already being added, considered as a chemical of concern of the at these facilities. And then lastly, the municipality and local involvement. We were interested in the land application of biosolids from those publicly owned treatment works where the wastewaters were being sent to. And then, of course, community awareness and general concerns about PFAS at these facilities at these communities. In terms of the key select key findings, I wanted to show three representative facilities sort of spanning the range from low impact into a much higher impact facility. So one of these facilities was very, what we consider, rural and remote. This had groundwater impacts that were very well delineated in terms of metals. Municipal water supplies and irrigation wells were well upgrading of the facility. So with the with the facility migration potentials potential low affecting these municipal water supplies. There was no potential for biosolid applications from the POTW