Letter: Perflourinated Chemicals in Our Drinking Water

from Dr. David Dow of East Falmouth

On January 16 Ma. DEP held a Petition Meeting to consider input from the Conservation Law Foundation/Toxics Action Center on a Treatment-based approach to address perfluorinated chemicals (PFAS) in our drinking water on Cape Cod.  On January 28 Ma. DEP released its response which focused on developing a maximum contaminant level for 5 PFAS chemicals at a concentration of 20 parts per trillion and develop a remediation plan for source areas under the waste site cleanup program.  Since EPA has not developed an mcl under the Safe Drinking Water Act for two PFAS chemicals (PFOS and PFOA), but has only proposed a hazard level at 70 ppt, grassroots entities from Barnstable to Mashpee have had to address contamination of Public Water Supplies (PWS).  In Falmouth contamination of 22 private drinking water wells is being mitigated by Joint Base Cape Cod’s AFCEC (Air Force Civil Engineer Center).

There has been a lot of media coverage of the situation in Barnstable where the town PWS has been contaminated by the Barnstable Fire Training Academy and granular activated carbon treatment (GAC) has been implemented to meet the state/EPA 70 ppt warning level.  As a resident of Falmouth I have been concerned about the Ashumet Valley Plume from Joint Base Cape Cod which underlies the Yearling Meadows development where I live.  The town’s Ashumet Valley PWS well was closed in the mid-1980’s by this plume and cleanup was undertaken under a combination of the Safe Drinking Water Act/Superfund (CERCLA) mandates.  EPA Region 1 and Ma. DEP have overseen this cleanup. Recently PFOS and PFOA were added to the contaminants of concern and AFCEC responded by mitigating the private drinking water wells in Falmouth and Mashpee Village PWS.  The source areas for the AVP are the former fire training area and old wastewater treatment plant with pollution of the water in Johns and Ashumet Ponds (as well as the downgradient  AVP).

My concern is that as formal drinking water standards are developed by Ma. DEP and waste cleanup standards are implemented for source areas of contamination, the regulations and cleanup policies may not keep up with emerging science on cleanup technologies to meet these new public health & safety standards.  The would be especially true if the petitioners long term goal of treating PFAS chemicals as a class (> 4000 individuals components with a variety of biological/chemical/physical properties) and health safety target of 1 part per trillion is implemented.  EPA may classify PFOS and PFOA as hazardous chemicals  under CERCLA (Superfund), while Ma. DEP is reducing the mcl under its SDWA authority. As a retired marine scientist, I don’t know the combination of technologies required to remove PFAS chemicals as a class from drinking and remediate the source areas, but it is likely to be expensive for Cape Cod Towns/Drinking Water Districts.  It is unclear whether the “polluter pays” concept will be implemented by the industries that produced these “forever chemicals" or the entities that utilized fire fighting foams which are a common source.  What to do with stored AFFF fire fighting foams is a major challenge.

Cape Cod is fortunate that the University of Rhode Island STEEP (Sources,Transport, Exposure and Effects of PFAS) and Silent Spring Institute’s REACH (Research, Education and Action for Community Health) grants are studying the  effects of PFAS chemicals on the immune system of children 4-6 years of age.  These grants include sampling of private drinking water wells for over 20 PPFAS chemicals.  Both of these grants include public outreach programs to translate this science into information to support elected officials & town health officials; medical professionals and wider public.  The challenge is moving from this scientific understanding of potential health threats into concrete action which is both effective in remediating drinking water/source areas and is cost effective.

This will require some type of coordinated effort like the Comprehensive Wastewater Management Plans that are being developed to reduce “nitrogen loading” from septic systems that have diminished water quality and lead to loss of essential fish habitat in our coastal  embayments.  In the latter case, it was assumed that 50% of the infrastructure investments would be covered by state/federal grants. A significant number of seniors and those in service industries have fixed incomes and live month to month on this income which raises Environmental Justice concerns.  These issues need to be addressed in developing the solutions required to address our PFAS challenges.  During the Ma. DEP Petition hearing and formal reply cost and implementation strategy was addressed as  concerns.

Dr. David Dow

East Falmouth, Ma.

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