State DEP: PFAS chemical contamination at Hyannis airport not investigated enough

Jeannette Hinkle Cape Cod Times 

Published Sep 14, 2021

HYANNIS — Cape Cod Gateway Airport officials have failed to adequately investigate the use and spread of PFAS and other chemicals there, according to findings from a Massachusetts Department of Environmental Protection audit of the airport's assessment of hazardous contaminants on site.

The state DEP on Aug. 24 issued a notice of noncompliance to airport manager Katie Servis.

The notice states the airport’s Phase II Comprehensive Site Assessment, which airport staff submitted to DEP on March 12, violated the Massachusetts Contingency Plan. That body of regulations is designed to streamline and accelerate the assessment and cleanup of oil and hazardous materials released into the environment.

Airport staff are now charged with submitting a revised Phase II Report to DEP by Nov. 10. The revised report must incorporate DEP’s comments in the notice of noncompliance.

If the airport doesn’t complete the required actions by Nov. 10, DEP could levy daily administrative penalties.

To obtain full compliance, the notice warned, DEP could also pursue criminal prosecution; civil action including court-imposed civil penalties; or other forms of administrative action.

Airport staff consulted with the DEP after receiving the notice of noncompliance, assistant airport manager Matt Elia said last week, and are in the process of scheduling another meeting to go over the steps the airport needs to take to correct the deficiencies in its site assessment.

“Our goal is to achieve buy-in from DEP to make sure that they are fully on board with how we're going to move forward and that they are comfortable with that,” Elia said. 

“We care very much about environmental stewardship,” he added. "In the big picture, the airport cares about that role we play in the community and we've made great strides to ensure the protection of natural resources.”

What did DEP’s audit find?

In the audit, the DEP took particular issue with the airport’s assertion that on-site releases of 1,4-dioxane and PFAS — two hazardous substances linked to health problems, including cancer — did not contribute to contamination of the nearby Maher wellfield. The wellfield is a source of public drinking water for the area.

Related:As Barnstable hunts for new sources of public drinking water, PFAS contamination rears its ugly head

DEP staff identified several gaps in the data provided in the site assessment, as well as problems with calculations that airport consultants used to back the finding that off-site contamination is to blame for the well contamination.

The airport reports “conclusions that the 1,4-dioxane and PFAS compounds in the Maher Wells has not originated from the Airport are not adequately supported at this time,” the notice read. 

Among other gaps, the site assessment didn’t fully catalogue the location of past fire training exercises at the airport, during which firefighting foam loaded with PFAS was used. The airport’s assessment also failed to document where the firefighting foam was stored and where hoses and equipment were cleaned before 1996, the audit found.

In addition, the site assessment did not address the full scope of PFAS compounds used at the airport, according to the DEP. PFAS, or per- and polyfluoroalkyl substances, are a group of thousands of human-made chemicals, six of which are currently regulated by the state.

An unexplained lack of testing for 1,4-dioxane both on and near airport grounds was also flagged by DEP staff.

What’s next?

The airport is currently gathering the additional information the DEP requested in the notice of non-compliance, Elia said.

“We jumped right on this to make sure that we can document and gather the necessary data to show why we believe in the science we put in there and to add information and further document their areas of concern,” he said.

As part of that effort, Elia said, airport consultants and staff will pull together information left out of the site assessment to better explain why the airport stands by its claim that contamination from the airport hasn’t reached the Maher wellfield.

“This is a very complex site,” Elia said. “There are other locations and other sources that are impacting the area here.”

Who pays rising costs 

The town-owned airport is less than a mile away from the county-owned Barnstable County Fire Rescue and Training Academy, where decades of use of PFAS-laden firefighting foam resulted in severe groundwater contamination that is still being studied.

Town officials recently criticized the county’s draft plan for assessing the scope of PFAS contamination at the fire-training academy as inadequate, and urged the county to extend its sampling effort to the Maher wells.

'A hodgepodge': Draft PFAS assessment plan for Barnstable fire academy plume is inadequate

Costs associated with PFAS contamination are rising fast for local governments.

The town of Barnstable has spent upwards of $22 million to address PFAS contamination. The airport, which uses a separate operating budget, has spent $1.29 million on the problem. And the county is now compiling its own PFAS-related expenses.

Public and private entities are within their rights to search for other parties that could share the liability for contamination costs, said Andrew Gottlieb, executive director of the Association to Preserve Cape Cod.

But the search for other potentially responsible parties shouldn’t delay comprehensive efforts to identify and clean up contamination, he said.

“Ultimately, the longer you wait to do something, the more it costs,” Gottlieb said. “In this instance, we've got a couple of public entities squabbling over assigning responsibility to one another. At the end of the day, it will be the same people who have to reach into their pockets to finance the solution.”

Betsy Young, president of the Greater Hyannis Civic Association, said residents will be closely monitoring both the town’s and the county’s PFAS assessment and cleanup efforts in the village.

“If the town and the county can’t work through a reasonable plan for us, it is the citizens of Hyannis, really, that are going to suffer here,” Young said. “There is going to have to be a giant amount of money thrown at this problem.”

Attorney Robert Bilott — who played a pivotal role in proving the companies that manufactured and sold products containing PFAS, including firefighting foam, hid the chemicals’ dangers for decades — recently told Massachusetts lawmakers that taxpayers shouldn’t shoulder the burden of cleaning up PFAS contamination at all.

“These fire departments, these airports, the state of Massachusetts — none of the taxpayers here should have to pay this,” he said. “We know who the responsible parties are. They should be paying for it.”

Attempts to reach officials from the Airport Commission, which oversees the airport, were unsuccessful.

 

PFAS contamination: Of 21 Barnstable ponds tested, 21 had contaminants, town report finds

Jeannette Hinkle Cape Cod Times 

Published Oct 4, 2021 

In July 2020, Tom Cambareri dragged his kayak to the shore of Aunt Bettys Pond in Barnstable. He paddled out to the middle and dropped his sampling equipment into the water.  

Cambareri, a hydrologist and the founder of Sole Source Consulting, was on a mission for the town of Barnstable. His goal was to better map the landscape of PFAS contamination in the town’s surface water bodies as the search for new sources of drinking water to meet rising demand intensifies.

The issue:As Barnstable hunts for new sources of public drinking water, PFAS contamination rears its ugly head

Cambareri ultimately collected water samples from 21 water bodies in town, according to a report he produced in December 2020. 

The results from lab tests of those samples showed PFAS compounds were present in every water body tested, with some registering PFAS levels far above the state standard for drinking water. There is no standard for PFAS contamination insurface water bodies, such as ponds and creeks.

PFAS, or per- and polyfluoroalkyl substances, are a group of thousands of manmade chemicals linked to health problems ranging from immune system issues to cancer. The chemicals remain essentially unregulated at the federal level, but some states, including Massachusetts, have begun to put safe drinking water limits on a few of the more well-researched compounds.

State DEP:PFAS chemical contamination at Hyannis airport not investigated enough

In 2020, Massachusetts instituted a drinking water standard of 20 nanograms per liter for a group of six PFAS compounds, which are now known as the PFAS6.

Of the 21 samples Cambareri collected, seven had PFAS6 levels that exceeded the state drinking water standard. The sample taken at Aunt Bettys Pond had one of the highest readings: 141.4 nanograms per liter, roughly seven times the state drinking water standard.

Cambareri tested for 18 other PFAS compounds that haven’t yet been regulated by the state or federal government.

Keating:Air Force agrees to pay for PFAS cleanups in Mashpee and Falmouth wells

Three water bodies had total PFAS levels exceeding 200 nanograms per liter, three had levels exceeding 100 nanograms per liter, and five had levels exceeding 20 nanograms per liter.

At Aunt Bettys Pond, total PFAS levels registered at 237.9 nanograms per liter, the second-highest reading after its feeder system, Hyannis Creek, where levels topped 252 nanograms per liter

When Cambareri compared PFAS levels in the surface water bodies he sampled to PFAS levels in Hyannis’s public drinking wells before treatment, he confirmed that contamination in ponds, lakes and creeks was correlated with contamination in village wells.

“… Areas with high concentrations of PFAS contamination in surface water bodies also have similarly high concentrations of contamination in wells,” Cambareri wrote. 

“Because of this relationship we can assume that development of wells in an area with high concentrations of PFAS in surface water would result in high concentrations of PFAS in wells, thus resulting in higher treatment costs,” he added.

Laurel Schaider, a senior scientist at Silent Spring Institute, where she leads the institute’s water quality research on PFAS, reviewed Cambareri’s report at the Times’ request.

“I think this is a really important report,” Schaider said Friday. “It’s a reminder of the interconnectedness of groundwater and surface water on the Cape. Given what we know about the high levels of PFAS reaching the drinking water wells in Hyannis, it’s not surprising that the ponds in those same areas have similar levels of PFAS.”

Cambareri said in his report that, as the town considers new sources of drinking water, it should rule out places where PFAS contamination is known to be present in nearby surface water bodies.

Help needed: Cape towns look to Congress to help pay PFAS cleanup costs

“By taking account of the behavior of contamination plumes from multiple sources, several future well sites can be ruled out,” Cambareri wrote in his report. “For example, two of the most convenient potential future well sites located within Hyannis, thus requiring the shortest transmission mains, have a high degree of risk because of the presence of multiple PFAS sources.”

Where is the contamination coming from?

The Barnstable County Fire Rescue and Training Academy and the Cape Cod Gateway Airport — two locations where PFAS-laden firefighting foam was applied for decades — are two known sources of significant PFAS contamination in Hyannis. 

The levels of PFAS detected at those sites are staggering. At the fire training academy, tests done after some cleanup efforts showed total PFAS concentrations in groundwater there reached 167,510 nanograms per liter. At the airport, total PFAS concentrations in groundwater have reached 15,583 nanograms per liter, according to Cambareri’s report.

The Hyannis Water District began removing PFAS from public drinking water wells contaminated by those sites in 2015 and has since brought the level of PFAS contamination in the public drinking water supply down to non-detect levels. 

Elsewhere: 'Forever chemicals' detected in Chatham drinking water wells

But Cambareri’s report found that PFAS emanating from the fire training academy and airport was redistributed across the village through contaminated well water before that treatment began. 

PFAS, which were designed to be water, stain and fire-resistant, are often called “forever chemicals” because they do not break down naturally in the environment. Rather, they accumulate, in soil, in water, in animals, and in people. Beyond firefighting foam, PFAS can be found in packaging, cooking pans, cosmetics and other consumer products.

Highly persistent PFAS from the fire training academy and airport distributed through Hyannis before drinking water treatment began are combining with highly persistent PFAS from consumer products that end up in wastewater from homes and businesses, Cambareri found.

PFAS from wastewater ends up in the groundwater in two ways. 

If a property is connected to a sewer , its wastewater is sent to the Barnstable Water Pollution Control facility, where it is treated — though not for PFAS — before being discharged into local groundwater.

If a property is not connected to the town's sewage treatment plant and relies on a septic system, its wastewater is leached into the groundwater on-site without being treated for PFAS. When the septic tank is pumped, the wastewater goes to the Barnstable Water Pollution Control Facility, where it is discharged into groundwater without being treated for PFAS.

All of this PFAS, from the fire training academy, the airport, the treatment plant or individual septic tanks, ends up in Hyannis’s groundwater, where it circulates throughout the village.

“The redistribution of primary PFAS sources in Hyannis resulted in widespread secondary groundwater contamination in the Hyannis area aquifer,” Cambareri wrote.

Schaider said Cambareri’s report is a reminder that local governments need to follow through on ongoing efforts to clean up sites that are highly contaminated with PFAS, including the fire training academy and airport.

“The Hyannis water system has gone to great lengths to treat the drinking water supply for the town, but as these results show, there are still elevated levels of PFAS in the groundwater and in the surface water in this whole area,” she said. “So it's important to, as much as we can, remediate the sources so that no new PFAS are getting out into the environment and for us to continue to monitor the levels in water and in fish over time.”

'A hodepodge':'A hodgepodge': Draft PFAS assessment plan for Barnstable fire academy plume is inadequate

What is the town doing in response to the report?

Barnstable Director of Public Works Daniel Santos denied the Times’ request to speak with Cambareri, the former water resources program manager for the Cape Cod Commission, about the report’s findings. 

The Barnstable Health Department referred questions to Santos, and Town Manager Mark Ells did not return a call to his office requesting an interview about the report. 

Santos said the biggest takeaway from Cambareri’s report is “that there is PFAS in surface waters and groundwaters throughout the town of Barnstable.”

That information will guide the town’s search for new sources of drinking water, as Cambareri’s report found surface water contamination correlates with groundwater contamination.

PFAS removed from town drinking water

“There is a drinking water standard that as we search for new sources of drinking water, it makes sense to find out whether we can put wells anywhere in town that aren't going to be affected with PFAS, or if we do, we want to understand what level of treatment we're going to need to put on them,” he said.

But Santos said there isn’t much more the town can do with the knowledge that many ponds are contaminated with PFAS because there is no state or federal standard for human exposure to PFAS in surface water bodies, only for drinking water. 

With no state or federal standard for surface waters, Santos said, the town is not required to take any action in response to the report’s findings.

In a joint response from the state Department of Environmental Protection and the Department of Public Health sent in response to questions from the Times, DEP spokesperson Edmund Coletta said the state is not currently working on developing a standard for PFAS in surface water bodies.

"It would take considerable work to develop such a standard or advisory," Coletta wrote on behalf of the departments.

Santos said Barnstable is ahead of other communities that haven’t yet begun testing their surface waters for PFAS. 

“This is all new,” Santos said. “We get more information every week on it and we’re trying to get a sense of what the situation is in town, in groundwater, in drinking water, in ponds. We’re collecting data so that when we do get information from regulatory agencies, at least we’re out ahead of this and we understand where it is so that if they do put standards in place we can move and deal with it if that’s required.”

Cambareri’s report recommends implementing limits on PFAS in surface water bodies.

“Because 40% of the groundwater in the aquifer passes through ponds, a more stringent PFAS cleanup standard for surface water should be applicable on Cape Cod,” he wrote.

What does this mean for people who use the ponds?

Researchers are still working to determine the implications of PFAS contamination in surface water bodies.

Around the same time that Cambareri was paddling through Barnstable’s ponds to collect water samples for his study, staff with DEP and the U.S. Geological Survey were collecting water samples for PFAS analysis from 27 rivers in Massachusetts.

PFAS were detected in all 27 rivers sampled. Total PFAS levels ranged between 0.3 and 399 parts per trillion. The highest concentrations were observed downstream of wastewater effluent discharges, but PFAS were also found in rivers upstream of those discharges, according to DEP’s website. The lowest concentrations were found in rivers located in less populated areas.

“MassDEP will continue to identify future monitoring objectives, potential studies, and other actions to better understand and address the distribution of PFAS in surface waters, relative contributions of different sources, and implications for public health and aquatic life,” the DEP website states.

A fact sheet about use of ponds contaminated by chemicals applied at Joint Base Cape Cod produced by the DPH in 2021 says that potential exposure to PFAS associated with swimming, wading, boating or catch-and-release fishing would be much less than potential exposure from drinking water containing PFAS.

“This is because the amount of water ingested during recreational activities is much less than the amount ingested as drinking water, and because very little PFAS are absorbed through the skin,” the fact sheet states.

Coletta wrote that exposure from swimming in water bodies that test above the state drinking water standard for PFAS "would not automatically be expected to result in adverse health effects."

"The risk associated with recreational activities such as swimming would be dependent on the concentrations of PFAS and relative levels of ingestion, whether over a prolonged period or during a single event," Coletta wrote.

Two of the ponds the DPH fact sheet referenced, Ashumet Pond and Johns Pond in Mashpee, had concentrations of one PFAS compound called PFOS that reached 200 nanograms per liter, according to Joint Base Cape Cod Remediation Program Manager Rose Forbes.

DPH is in the midst of testing 16 water bodies approved for swimming in Barnstable, Bourne, Sandwich, Mashpee and Falmouth for PFAS, according to information provided by Forbes. 

The agency is collecting water samples from each water body, and fish samples from selected water bodies.

Schaider, who is leading Hyannis-based human health studies about PFAS exposure through drinking water, said exposure to PFAS through swimming in PFAS-contaminated ponds is unlikely to be significant.

“It's important for people to have this knowledge for people to know it would make sense to minimize how much water people are swallowing when they're out swimming, but it's unlikely to be a major source of exposure for most people,” she said.

But she did recommend that Cambareri’s report be followed up with testing of fish in the studied ponds, as some are popular spots for fishing and ice fishing.

“It can be difficult to predict in every case how much accumulation will happen among different types of fish, so I think the next step should be to conduct testing of fish to learn more about the levels of accumulation, particularly in ponds where people are consuming fish,” Schaider said.

Coletta wrote that the risk associated with consuming fish from PFAS-tainted water depends on the level in the fish's tissue, rather than the water.

DPH has not issued any advisories warning people not to enter a surface water body because of PFAS, according to Coletta. Neither the DPH or DEP have an estimate of how many surface water bodies are contaminated with PFAS in the state.

"The commonwealth continues to monitor surface water bodies for PFAS and will continue to do so, sharing data as they become available and developing a better understanding of the scope of the issue with data collection," Coletta wrote.

 

'A hodgepodge': Draft PFAS assessment plan for Barnstable fire academy plume is inadequate

Jeannette Hinkle Cape Cod Times 

Published Aug 30, 2021

The now-shuttered Barnstable County Fire and Rescue Training Academy is one of the most PFAS-polluted sites in the state, if not the country, according to hydrogeologist Tom Cambareri.

In 2016, Cambareri says, the maximum, average and median concentrations of one PFAS compound in groundwater there were 320,000, 10,126 and 930 nanograms per liter, respectively. The state standard is 20.

Cleanup,  including removing tons of contaminated soil, has helped, but recent samples revealed the contaminants remain sky-high, up to roughly 10,000 nanograms per liter in some cases, Cambareri said.

More: Barnstable County OKs nearly $1M to cap PFAS-polluted site, demolish buildings

Cambareri, a water resources specialist, began managing assessment and cleanup of contamination on the property in the 1980s, first as a consultant and then with the Cape Cod Commission.

'Just about every new contamination that's been found has been found on this site.'

Over the years, he assessed the damage done to the area — a stone’s throw from Hyannis’ public drinking water supply — by petroleum hydrocarbons, then MTBE, then perchlorate.

“This has been an incredible site,” Cambareri said. “Just about every new contamination that's been found has been found on this site. Each time, the only way we could deal with it was to hit it hard, do the assessment and do the remediation.”

Today, the problem at the fire training academy is per- and polyfluoroalkyl substances, or PFAS, a group of man-made chemicals used in firefighting foams sprayed on the county-owned property during training sessions. The chemicals are linked to health problems including cancer, thyroid hormone disruption and immune system issues.

Cape watersheds: Study uncovers previously unknown PFAS contaminants

And Cambareri, who is now working as a hydrogeologic consultant for the town of Barnstable, says the county isn’t hitting the problem there hard enough.

In a letter to Barnstable Department of Public Works Director Dan Santos, forwarded to county officials, Cambareri laid out what he sees as deficiencies in the county consultant’s draft scope of work for a comprehensive site assessment of PFAS contamination at the fire training academy.

The deficiencies are so great, Cambareri argues, that he recommends scrapping the entire document and beginning anew, with an independent consultant.

He calls the current plan, prepared by engineering consultant BETA Group, “a hodgepodge of incremental tasks that diverts resources from assessing the full extent of contamination.”

“The County should withdraw the (BETA comprehensive site assessment draft) scope and revise it with clear objectives developed by an independent team,” Cambareri wrote. “The (comprehensive site assessment) scope should be recast as a full assessment of the PFAS impacts on downgradient groundwater and resources.”

“Nowhere else have 11 public water supply wells been impacted by PFAS in the Commonwealth, not even Joint Base Cape Cod,” he added. “It is time for the County and (the Massachusetts Department of Environmental Protection) to engage experts to broaden the knowledge base to solve this community problem in a pragmatic manner.”

County Administrator Beth Albert, who was hired in the spring, said the county will review Cambareri’s comments.

“We are asking for just this kind of feedback,” she said Thursday. “That's why we did this. It's a very open process and I really appreciate Tom's comments, because he's very knowledgeable about this site. I think we can all agree that we need to get more information, which is exactly what we're trying to do.”

What are Barnstable’s problems with the county’s PFAS plan?

Cambareri laid out a litany of problems with the county’s draft scope of work for the fire academy site assessment, but his biggest concern is that the proposed plan won’t add much to the public’s understanding about the spread of the PFAS plume from the fire training academy over the course of the past few decades.

The proposed monitoring wells are mostly located within the known area of impact, Cambareri says.

“When you're trying to expand the area of understanding, you need to start placing wells more on the perimeters of where you already know the contamination is and then use groundwater flow to project where the contaminants will go,” he said.

It’s a criticism Santos agrees with.

“We concur that the proposed plan is inadequate, given the serious nature of the contamination,” Santos said. “Primarily, the county plan does not go far enough in helping the town of Barnstable, the town of Yarmouth and the Mid-Cape region as a whole to understand the extent of the contamination there. We've been asking for this for the last three or four years.”

An adequate response to Barnstable’s concerns, Santos said, would be going back to square one to design a comprehensive investigative program that thoroughly maps the plume’s progress from the fire training academy.

Cambareri thinks monitoring should extend further downgradient, from Mary Dunn Pond through the airport — which has contributed its own PFAS to the area’s contamination problem — and then through the Maher wellfield to Mill Creek in Yarmouth, where current data on PFAS contamination is lacking.

Cambareri questions why the county, through BETA, would recommend spending time and money placing new monitoring wells upgradient of the fire training academy.

“It’s like putting a marble on a ramp and expecting the marble to roll uphill,” Cambareri said. “I'm not downplaying the contamination of the fire district wells that are to the west. But I think there are other sources of that.”

Santos said some upgradient monitoring is a normal part of any contamination investigation, but he stressed any upgradient monitoring should be paired with more comprehensive downgradient monitoring that he thinks is lacking in the county’s draft plan.

“The only reason you would look upgradient is if you believed you weren't the source of the contamination, and that's just not plausible here given what we know about the site,” Santos said. “As a responsible party under the Massachusetts DEP contingency plan, if there are other responsible parties, they want to identify them, of course, and share liability if they can.”

Roger Thibault, the licensed site professional in charge of the site assessment for BETA Group, said at a recent public hearing about the site assessment’s draft scope of work that inclusion of upgradient monitoring in the Barnstable Fire District stemmed from a request that BETA investigate contamination there.

“The reason there are wells on the west side of the pond is because we have assertions from the Barnstable Fire District that there is migration upgradient,” Thibault said. “I just want to note that that's just not out of the blue.”

Cambareri said that if the county amended its monitoring plan on behalf of the fire district, it should also amend its monitoring plan on behalf of the town of Barnstable, and members of the public.

County not 'doing the job it needs to do'

At the public hearing of the draft scope of work for the site assessment, Greater Hyannis Civic Association President Betsy Young said her group is worried the county is not “doing the job it needs to do.”

“The community is very concerned about this contamination, which affects all of our wells,” Young said. “We believe the scope needs to be widened to include the entire area so we can understand the extent of the exposure and not be limited to the area around the site.”

In addition to requesting the DEP create a team focused on PFAS contamination in Hyannis that would include town and county representatives as well as members of the public, Young called for the agency to expand the public involvement process governing the fire academy project, and access to records showing project costs.

The town of Barnstable has already spent upwards of $20 million to deal with the effects of PFAS pollution from the fire academy, and because of ongoing treatment of wells near the property, the water in Hyannis is safe to drink. 

Albert said the county is currently working to compile a list of its appropriations and expenditures for the fire training academy PFAS assessment and cleanup. 

PFAS cleanup costs: Cape towns look to Congress to help pay

“We want to make sure that that information is transparent and available to the public,” Albert said. “As the new county administrator, I feel really very supportive of that and we are working internally to get that information together and get it out to the public.”

Young, Cambareri and others have argued the county should use some of the roughly $40 million in COVID-19 relief money it received from the federal government through the American Rescue Plan Act, as well as other revenue, to expand its investigation into the PFAS plume emanating from the fire training academy.

“There are substantial sums available and I believe that they should be designated for expansion of the types of testing that's being done,” said Sue Phelan, one of the residents who petitioned for the project to include public involvement.

As written, Cambareri doesn’t think the draft scope of work complies with Massachusetts regulations requiring the county to evaluate the full vertical and horizontal effect of PFAS contamination coming from the fire academy. And he thinks a different group, an inclusive one independent of county control, should be tasked with the job.

“We know how to do this. It just takes resources and the right people to do it,” he said.

DEP Public Affairs Director Edmund Coletta said that, under the public involvement process, the county is now charged with responding to comments about the draft scope of work proposed by BETA Group, and making changes based on those comments.

"It's really up to them to take the public input and make changes as they see necessary and issue a final scope of work," Coletta said, adding DEP would give its input informally along the way. "Should we determine once the final scope comes out that it is inadequate in any way, there is a possibility of a comprehensive audit that we could conduct that could require them to make changes, but we're not at that point."