Letter - Climate Change, Water Reuse and Toxic Chemicals

from Dr. David Dow, East Falmouth

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I am a retired marine scientist and grassroots environmental activist living on Cape Cod. I  recently submitted comments on EPA’s Draft National Water Reuse Action Plan based on my experiences living in Slidell, La. and East Falmouth,  Ma.  EPA developed its National Water Reuse  Action Plan because forty states faced future water shortages as a result of climate change.  Both Slidell, La. and Cape Cod, Ma. use groundwater sources for drinking water with Cape Cod facing Summer water shortages in the present.  Both sites have Superfund sites (Bayou Bonfouca and Joint Base Cape Cod) and toxic chemical contamination of their public drinking water (7 chemicals above Environmental Working Group health guidelines in Slidell compared to 10 in Falmouth).

Local conditions make some waters unfit for human consumption without expensive treatment.

Since both Slidell and Falmouth are near the coast, Relative Sea Level Rise from climate change and extreme weather events (Hurricanes and Northeasters) can  lead to saltwater intrusion into coastal drinking water aquifers making the water unfit for human consumption without  expensive treatment.  In addition, these groundwater  sources are contaminated by toxic chemicals (heavy metals; organochlorine chemicals; PFAS; etc. from industrial activities; Superfund Sites, agricultural pesticides and herbicides; PAHs; etc.) from a variety of sources which can require closure of public and private drinking water wells.  In addition, during the Summer we have droughts on Cape Cod and more visitors added to our population which leads to water rationing for watering crops and grass/gardens adjacent to homes/businesses.  These constraints on water use is likely to get worse as we move into the future. 

Sources of water contamination need to be removed or cleaned up.

One action taken in Falmouth is tests using Ecotoilets as a way to reduce “nitrogen” input and water usage from septic systems.  This was part of the Clean Water Act Section 208 Wastewater Treatment process to reduce “N” input to our 14 coastal embayments which have created water quality problems and loss of essential fish habitat (eelgrass beds). In Slidell, La., the Bayou Bonfouca Superfund site was converted into a Heritage Park and municipal marina after treating sediments and groundwater contaminated by creosote.  On Upper Cape Cod, the Joint Base Cape Cod SDWA/CERCLA cleanup has been removing source areas for contaminants of concern and treating off-base plumes with extraction/treatment/reinjection (ETR) or Granular Activated Carbon (GAC) for public and private drinking waters wells contaminated with PFOS/PFOA (to the EPA Hazard Warning Level of 70 ppt).  Ma. DEP is developing a maximum contaminant level of 20 ppt for 6 PFAS chemicals. 

Wastewater – if adequately cleaned – can be new water sources.

Since oil/gas drilling occurs on land and in the Gulf of Mexico/Lake Pontchartrain in Louisiana and there are numerous refineries/chemical plants located along the Mississippi River between Baton Rouge and New Orleans, which has resulted in numerous waste disposal options (landfills; deepwell injection; incineration; salt dome storage; unit waste treatment operations; etc.).  Some of these generate potential water sources for reuse purposes (presuming that one removes the toxic contaminants).  On  Cape Cod, Barnstable; Bourne; Falmouth; Mashpee and Sandwich are considering sewering and taking over the wastewater treatment plant at JBCC and discharging the treated sewage effluent into the Cape Cod Canal. One could instead use this treated sewage effluent for drinking water if the PFAS chemicals; BTEX components; perchlorate and other SDWA (Safe Drinking Water Act)/CERCLA (i.e. Superfund) contaminants of concern were removed.  

Standards for clean water need to be national and more consistent.

Removing these toxic regulated and unregulated chemicals could be expensive and challenging technically. For example Ma. DEP has an mcl of 1 part per billion for perchlorate, while EPA is still working on its mcl of 15 ppt (?).  The same is true of PFAS chemical mcls: EPA- 70 ppt for PFOS/PFOA and Ma. DEP 20 ppt for the sum of 6 PPFAS chemicals.  Having different mcls and time lines for addressing toxic chemicals in drinking water could pose challenges in implementing a National Water Reuse Action Plan. Massachusetts and other New England states are likely to develop mcls for contaminants of emerging concern sooner and with stricter guidelines than EPA at the national level.  This is one of my major concerns with this proposed action plan.

EPA needs to more protectively address risks from new chemicals

On December 10 I participated in the U.S. EPA TSCA (Toxics Substances Control Act) New Chemicals Program Public meeting webinar which discussed the process for implementing the Frank R. Lautenberg Chemical Safety for the 21st Century Act under the Trump Administration.  My impression from the EPA presentations (including Administrator Wheeler) that the focus was on “creating a better world through chemistry” and loosening protections on public health and environmental effects.  These concerns were amplified in the public comments following the EPA presentations: unions expressed concerns about voluntary use of gloves and respirators when working with toxic chemicals (leaving work place safety up to OSHA); ENGO representatives expressed concern about EPA’s Risk Assessment Approach and the lack of Peer Review of the toxic chemical Prioritization  Process (a topic discussed in a recent piece in Truthout); complaints were made about industries abusing the Confidential Business Information process on toxic ingredients in their products (issue addressed in movie "Dark Waters” in regards to PFOA);  and scientists commented on the use of modeled data rather than measured data and unclear uses of exposure data from multiple sources (air, water, soil, food; dust in homes; consumer products; etc) being integrated into risk assessments and prioritization process.  

Since 2016 the TSCA PMN program has only identified 46 chemicals (30% of submission requests) as posing health threats if introduced into the market place. I gather that a number of ENGOs took EPA to court over the 2017 Federal Register notice on: “Procedures for Prioritization of Chemicals for Risk Evaluation under the Toxics Substances Control Act”. I presume that the December 10, 2019 public meeting was designed to address this litigation.  When President Trump ran for election, he criticized his predecessor for governing by Executive Order or Executive Branch actions without consulting Congress. I agree with this position and am  unhappy with EPA’s arbitrary changes to the intent of the Lautenberg TSCA legislation implementation.

Drinking water sources need to be located away from contaminated areas.

My other concern is removing of contaminants of emerging concern source areas that have caused the shut down of public and private drinking water wells on Cape Cod. The Ashumet Valley Plume from JBCC runs under the Yearling Meadows development where I live in East Falmouth, Ma.  The PFOA/PFOS source areas include: former Fire Training area; former wastewater treatment plant and water/sediments in Ashumet and Johns Ponds.  The Falmouth Ashumet Valley Public Drinking Water Well has been closed since the mid-1980’s and two Mashpee town public drinking water wells have been treated with Granular Activated Carbon to meet the EPA warning level of 70 ppt for PFOS and PFOA. It is unclear if the GAC treatment is effective to remove PFAS chemicals as a class at 1 ppt (Target of Conservation Law Foundation and Toxics Action Center which petitioned the Masa. Executive Office of Environmental Affairs). 

New sources of information on toxic hazards and health impacts should be considered.

I serve on the Community Advisory Committee for the University of Rhode Island’s STEEP (Sources, Transport, Exposure and Effects of PFAS) grant where the science; monitoring; epidemiological studies and treatment technology to remove PFAS chemicals from drinking water and source areas is changing rapidly.  Both the Army and Air National Guard staff and consultants at JBCC are carrying out research programs and considering action for the Bourne Rotary Plume and AVP. Between the US Geological Survey; Silent Spring Institute; and URI STEEP grant project, we have a lot of data on the contaminants of emerging concern in our public and private drinking water wells.  Many communities throughout the US lack such data which could hamper the 46 proposed actions in EPA’s Draft National Water Reuse Action Plan.

Dr. David Dow

East Falmouth, Ma.


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