August 20, 2024      via electronic delivery (email)

Boeing of Portland

Cascade

Subject: Request for Assessment of Per- and Polyfluoroalkyl Substances (PFAS)

FYI:

Information available to the Oregon Department of Environmental Quality (DEQ) indicates that historical or current activities at the Boeing and Cascade sites (ECSI# 0167) may have involved the storage or use of per- and polyfluoroalkyl substances (PFAS) including perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS). Of specific concern is Tektronix’s long-term manufacturing and assembly of electronic measurement equipment, and associated waste management and treatment operations. Since you are currently investigating historical releases of other hazardous substances from this site, DEQ recommends that you include PFAS as contaminants of potential concern.

As you are aware, the US Environmental Protection Agency (EPA) designated PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) in April 2024¹, and in the same month issued legally enforceable drinking water standards, or Maximum Contaminant Levels, for PFOA, PFOS, and four additional PFAS: perfluorohexane sulfonic acid (PFHxS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide-dimer acid (HFPO-DA, also called Gen-X), and perfluorobutane sulfonic acid (PFBS)². EPA has also issued Region Screening Levels³ for multiple media. DEQ has begun rulemaking to include PFOA and PFOS as hazardous substances in Oregon Administrative Rule (OAR) 340-122-0115(30), with expected completion in 2025.

As part of ongoing site investigation work, DEQ recommends that you: a) compile information on historical and current use of PFAS at your facility; and b) perform reconnaissance-level sampling where releases may have occurred. Information collection and sampling would be on a voluntary basis prior completion of DEQ rulemaking.

Please let us know how you plan to proceed.

Respectfully,

Erin McDonnell, Project Manager

Northwest Region Cleanup

Ec:  Dan Hafley, DEQ

 Amber Lutey, DEQ

 Joe Kalmar, Landau

 Erin Waibel, Landau