You may have been reading in the media stories about “forever chemicals” in the environment. These stories refer to a category of chemicals known as per- and polyfluoroalkyl substances (PFAS), and there are thousands of different types. They have been in mass production in the country for over 60 years and are completely ubiquitous throughout the environment, meaning you will find them everywhere from water, grass, food, to clothing, carpeting, consumer care products, dust, and they are already in everyone’s bloodstream. Typically, the main source of ingestion of these chemicals is from consumer products and food, which have not been regulated to date. The only thing that is currently being regulated is drinking water. The Federal Environmental Protection Agency (EPA) develops drinking water standards for all contaminants and is currently working on nationwide standards for this category of chemicals. EPA currently has a Health Advisory of 70 parts per trillion for two PFAS chemicals (PFOA & PFOS). Some states went ahead and have already developed standards on their own (without EPA), which has lead to much confusion as there are different standards for different states. These standards were largely set in haste with limited stakeholder input and data. MA is one of the states that developed their own standard, without using the same standard development process that the EPA uses. As result, the standards set for drinking water in MA were set significantly lower than EPA’s standard, and the levels are down to the lowest level that technology can test to. The lowest reliable detection levels are around 2+ parts per trillion (as low as technology can go) and maximum allowable level developed by MADEP is 20 parts per trillion (PPT) for six different types of PFAS chemicals. These six PFAS compounds are: perfluorooctane sulfonic acid (PFOS); perflourooctanic acid (PFOA); perflourohexane sulfanic acid (PFHxS); perfluoroonanonic acid (PFNA); perflourodecanoic acid (PFHpA); and perflourodecanoic acid (PFDA). MassDEP abbreviates this set of six PFAS compounds as “PFAS6”. The maximum allowable level of 20 PPT is so low that it is approaching background levels found in the environment. State Regulations were published in late 2020 and larger water systems were required to start testing in January and April 2021. With the initial testing in early 2021, laboratories had a difficult time meeting quality control standards testing down to these low levels.
We have no reason to believe these chemicals will be found in our sources as they are well protected. But the uncertainty of such low standards has created many concerns about the reliability of results and the fact the limits are down close to background environment levels. Most contaminants tested in drinking water are in parts per million, some more recent contaminants have even been in parts per billion, but this new standard of parts per trillion is new territory for the industry (one part per trillion is equal to one second in 32,000 years). When sampling, our collector cannot wear certain types of clothing, or have used certain types of shampoo, or deodorant, or other personal care products in the past 48 hours or it may cause a false positive test. So we had to hire a professional firm to collect the first samples and train the staff for future sampling. From a common sense stand point, this seems irrational because you are likely consuming higher levels of these chemicals in your food from your local grocery store (in foods and packaging for foods), but this goes unregulated.
We did collect samples from both of our sources in October of 2021. We found PFAs levels of 2 parts per trillion at one wellfield and no detection at the other wellfield. 2 parts per trillion is the “RL” or reporting limit, meaning it is the lowest level that can be reliably reported by laboratories. Since we blend the wellfields roughly 50/50 during throughout the year, any sample collected within the system will likely be no detection. We collected a second set of samples in January 2022 from both wellfields and the results showed no detection in either wellfield. We then collected another set of samples in April 2022 from both wellfields and the results showed no detection in either wellfield. We will continue to monitor our wellfields throughout 2022 and if levels remain the same, we will be put on reduced monitoring by the State.
Another significant concern with this new standard is that the maximum allowable level of 20 parts per trillion is set ONLY for pregnant or nursing women, infants, and people diagnosed by their health care provider to have a compromised immune system. So this standard is NOT for the general public. This again is very unusual as generally regulated contaminants are based on the health of the general public and not just a small sub group of the general public. To date, there is no standard for the general public. As noted above, EPA has a Health Advisory of 70 parts per trillion. Some home treatment systems are certified to treat to this level. We are not aware of any home treatment units that are certified to treat down to the state standard of 20 parts per trillion.
And lastly, there is the issue of equity in that these chemicals are still being brought into the state and used for many different purposes. Massachusetts has not banned the import and use of these chemicals to date. Therefore the chemicals are still being introduced into the environment, consumer products, and the food industry through numerous sources. It seems inequitable that water utility rate payers should be bearing the cost to clean up and remove these chemicals from water sources as the chemicals were not put there by the water suppliers. Further, there are currently no standards for wastewater discharges into rivers. So when a water utility removes the chemical through filtration, the filtration process may create a waste water stream that contains PFAS that may get sent to the local wastewater (sewer) treatment facility which is not equipped to remove the chemical. So the chemical gets put right back into the river. This seems highly inefficient. There needs to be a comprehensive plan to address these chemicals from start to finish, instead of just regulating one facet of the entire cycle.
As you can see, this is a very complex and confusing issue that has unfortunately been rushed through due to media and political pressures, which has resulted in non-uniform standards that now must be met. While we are fortunate here in our town to not require treatment, we anticipate there will be many millions of dollars spent statewide to treat drinking water down to these standards. These costs will be mostly born by the rate payers of the effected communities as the state is not providing sufficient funding for the treatment required in all effected communities. All the while, these chemicals continue to be used in various industries in the state without restriction.
For more information regarding PFAS, please visit: https://www.safewatermass.org/
Other fact sheets, data, and studies:
Wisconsin Department of Health Services PFAS information
Study: PFAS Contamination Of Breast Milk Is ‘Universal’ (wateronline.com)
Study: PFAS Found in Rain at Levels up to 400 PPT
MADEP Study of PFAS Levels in Rivers where there are Sewer Discharges: https://www.mass.gov/doc/pfas-in-massachusetts-rivers-presentation/download
Note: This study did NOT sample the sewer effluent itself, only upstream and downstream of the discharge (doesn’t state how far downstream). It is reasonable to assume that if the effluent itself were sampled, levels would be substantially higher than what was found upstream and downstream. This again underscores the importance of a need for a comprehensive approach to addressing this issue instead of regulating one single component.