Document dYmBmEDRajMwJqbvpzKbVRLMb

Developing a societal acceptable remedial action plan for an important PFAS hotspot in Flanders : challenges and lessons learned? Presented by: Senior Partner ERM October 21st, 2022 Copyright 2022 by The ERM International Group Limited and/or its affiliates (`ERM'). All Rights Reserved. No part of this work may be reproduced or transmitted in any form or by any means, without prior written permission of ERM. The business of sustainability Content 1. The `Project' 2. Developing a societal acceptable remedial action plan 3. Lessons learned to date 4. Q&A www.erm.com ENSOr Presentation 25/10/2022 2 The `Project' The `Project' PFAS manufacturing plant situated in the Antwerp harbour cluster, a major mobility infrastructure project called `Oosterweel' underway in its direct vicinity; Historical C8-PFAS production (mainly PFOS) thru Electrofluorination (ECF) process, stopped in 2002; Onsite remediation ongoing since 2010 thru pump & treat, after the completion of the regulatory site investigation studies and remedial action plan, approved by the environmental agencies; Recent new scientific insights and stakeholder observations made generated a catalyst effect pushing for new offsite sampling and risk assessment with a initial focus on human health; The `project' went thru a media and political storm in the last 18 months; and Within this complex and rapidly evolving context a 1st offsite remedial action plan (RAP) upon completion of a descriptive site investigation (DSI, done within 6 months), addressing the (potential) human risk via soil, has been developed for the area of concern with the highest priority. www.erm.com ENSOr Presentation 25/10/2022 4 Key findings of the initial offsite DSI - soil (including human health risk assessment or HHRA) 7 km impacted area Around 200kg PFAS Residential & Agricultural land use Risk driven by free-range chicken egg consumption `No regret' measures In place DSI HHRA Phased remediation to be considered Further study required Over 4500 cadastral parcels www.erm.com ENSOr Presentation Main impact observed <1,5 km from manufacturing plant Biomonitoring elevated PFOS blood levels Commingling with other external PFAS sources 25/10/2022 5 PFOS distribution topsoil www.erm.com Source ERM DSI, Jan 2022 ENSOr Presentation 25/10/2022 6 Need for an integrated holistic PFAS approach needed Basis for pragmatic PFAS management in Flanders Creating a more eco-friendly neighbourhood Reduce exposure Sustainable and reasonable remedial actions www.erm.com ENSOr Presentation 25/10/2022 7 RAP zoning (zones 1A & B, and 2) www.erm.com ENSOr Presentation 25/10/2022 8 Developing a societal acceptable remedial action plan Challenges to overcome 1. Evolving policy & regulatory framework 2. Biomonitoring results (blood serum) had to be integrated 3. EFSA opinion 2020 4. Human risk mainly driven by consumption of free-range chicken eggs 5. Extremely short RAP development time imposed <6 months 6. Remedial works will be intrusive for the involved people 7. Many stakeholders involved with different interests www.erm.com ENSOr Presentation 25/10/2022 10 Seeking societal approval : What the stakeholders were saying when starting the RAP development We want a more sustainable environment for our children PFAS exposure should be minimized as much as possible Integrated plan needed covering manufacturing plant and its surroundings within regulations Synergies should be developed with Oosterweel,project The reference frameworks need to be revisited based on the actual knowledge Compensation for property value loss and business impacts www.erm.com ENSOr Presentation 25/10/2022 11 Final Proposed Remedial Plan - main actions (currently subject to approval process) 1. 70 cm soil exchange residential/agricultural area; 2. Treatment/disposal of the excavated PFAS containing soils; 3. Backfill with good quality soils, fertile top layer; 4. Restoration of the residential gardens; and 5. Anticipated duration of the works 3 to 4 yrs, subject to backfill material/treatment capacity and agreements with the property owners. www.erm.com ENSOr Presentation 25/10/2022 12 Lessons learned to date Co-creation is the only way to go Responding to and managing societal expectations Collaboration will be the key success factor Integrated and multifacetted solution needed Pragmatic Framework & implemenation Proportional, fair and prioritized solution Building remedial capacity www.erm.com ENSOr Presentation 25/10/2022 14 The PFAS problem is far more complex! Widespread use of AFFF and other PFAS containing products & applications Comingling of PFAS sources Background elevation www.erm.com ENSOr Presentation 25/10/2022 Source website PFAS verkenner 15 Questions & Answers The business of sustainability Antwerp/Brussels, Belgium Thank you