Vision on PFAS soil remediation around 3M

Fundamental right
Greenpeace Belgium 
Better Environment Association
Goorden Thomas

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This document identifies the most important conditions for dealing with PFAS pollution on and around the 3M site (including the Oosterweel site). The objective of minimizing additional exposure of local residents to PFAS is central to this; an objective that the Flemish government itself formulated¹. 

Limitation of further damage

1. As regards the Oosterweel works themselves, all possible measures must be taken to prevent further spreading of pollution by the works (dust, pumping, leaching, etc.) as much as possible. This applies to both the left and right banks and in the Scheldt itself (silt). Even when the works are temporarily suspended, all possible measures must be taken to prevent further spreading.
2. Any additional contamination with any PFAS in the broad area (20 km) of 3M is considered unacceptable. To this end, all permits in the area of both groundwater pumping, incineration, dumping, etc., must be clearly listed and indicated in what way the emission or spread of PFAS (any variant) via water, air or soil is reduced to the absolute minimum.

Standards framework

3. A new standard framework for earthmoving and remediation must be developed as soon as possible, based on an up-to-date and substantiated scientific basis. In this case, this means that both soil and groundwater standards must at least be derived from the most recent EFSA reference dose for PFAS, using the Dutch PFAS equivalence scale (PEQ) to fill any gaps. The most recent knowledge about the ecotoxicological effects must also be included in determining the standard framework.². 
4. The derivation of new soil and groundwater standards must meet the highest scientific standards. This means, among other things, that they must be subject to a scientific peer review, carried out by independent scientists, the results must be sufficiently reproducible, and so on. The Dutch approach can serve as an example, where all data, reports and models are made freely accessible.
5. If it is not possible to achieve standards that have been determined in this way, for example because the soil standards would fall below the Flemish background values, this must be clearly and openly indicated. If necessary, the lowest achievable standard must be proposed, including a clear justification as to why it is not possible to maintain a lower standard. All proposals that are put on the table at that time to still achieve the soil standards must be qualitatively and independently checked.

Soil remediation

6. A soil remediation plan must be drawn up for both the Oosterweel works and the wider environment. This soil remediation approach must be based on the framework of standards as discussed above.
7. This soil remediation plan must contain three parts:
   – The accelerated and priority remediation of the surrounding residential, natural and agricultural areas, in order to limit all further exposure to humans and nature to an absolute minimum.
   – A remediation of the Oosterweel sites, which is in accordance with the applicable legal framework but does not take priority over the remediation of residential, natural and agricultural areas.
   – An accelerated remediation of 3M's own sites in order to minimize long-term risks.
8. If soil is deemed non-remediable, it should be excavated and stored. The method of storage must be legal and demonstrated to be safe indefinitely. This follows the “best practices” also referred to by the EPA³.
9. This soil remediation plan must be designed as soon as possible, including an associated timeline. The plan must contain enforceable guarantees that it will be followed. These guarantees must also be there for soils that are stored.
10. This soil remediation plan must be drawn up by an independent research agency with demonstrable experience with this issue, preferably a foreign group. The selected agency may not have a previous (long-term) commercial relationship with BAM/Lantis or have been significantly involved in the approach to date. Sweco and Witteveen+Bos are absolutely excluded in this.
11. All communication with this research agency (assignment, interim communication, meetings) should be accessible to representatives of local action groups and interested environmental associations. There should be a point of contact within the research agency, where stakeholders (such as residents, farmers, etc.) can go. 
12. Each technical report must be accompanied by a simplified and brief summary prepared by the author(s) of the report itself.
13. If experimental techniques are proposed within this remediation plan, a test setup and period must be provided for this.
14. A clear plan must be formulated to recover the costs of both the remediation plans and the remediation itself from 3M.

Way of working

15. It goes without saying that affected residents must be involved in the process in which a soil remediation approach is developed. The way of working (together) in the future must be feasible for all stakeholders. This must be laid down in advance in mutual agreement.
16. In general, full transparency must be guaranteed throughout the entire process. Whether it concerns soil movements, measurements, interim reports, internal communication or whatever, everything must be made publicly available in the short term (maximum 1 week). Non-public forms of consultation at any level concerning soil remediation are unacceptable.

Future Covenant

17. Remediation of the area around the 3M site in Zwijndrecht is an important liveability project. Under no circumstances may other liveability projects, which have already been agreed upon within the Future Covenant or directly with the municipality of Zwijndrecht, come under pressure because of this soil remediation. To this end, solid guarantees must be given to all parties involved.
18. It is healthy for the Future Alliance that new insights and concerns are included. As a coalition, our focus is on tackling PFAS pollution in and around Zwijndrecht. 

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1 BevPFAS research Zwijndrecht
2 For example, using the USEtox model and associated “hazardous concentrations”.
3 Best practice EPA