Letter - Input on Ma. DEP PFAS Regulations for Drinking Water

from Dr. David Dow, East Falmouth

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I recently submitted written comments to the Massachusetts Department of Environmental Protection (Ma. DEP) on establishing a maximum contaminant level of 20 parts per trillion for the sum of 6 PFAS chemicals (PFOS; PFOA; PFHxS; PFNA; PFHpA and PFDA). The mcl would provide the safety standard for public drinking water wells and be much lower than EPA’s proposed mcl of 70 ppt for PFOS and PFOA. 

A public hearing on this proposal will be held at 10 AM at the Ma. DEP Regional Office in Lakeville at 20 Riverside Drive (call 508-946-2700 for directions).  Writen comments may be submitted via email to: [email protected]  The deadline for comments is 5 PM on February 28, 2020.

I live in the Yearling Meadow Development in East Falmouth and the Ashumet Vally Plume (AVP) from Joint Base Cape Cod  (JBCC) has contaminated public and private drinking water wells upgradient from my house with PFAS chemicals (PFOA and PFOS at greater than 70 ppt).  The source of this PFAS contamination is the former JBCC fire training area and wastewater treatment plant and the water/sediments (?) in Ashumet and Johns Ponds.  Thus the plume is not a simple linear feature, but a big blob which has contaminated water supplies in Falmouth and Mashpee.  This poses challenges for waste site cleanup standards for the source areas and the drinking water itself (Granular Activated Carbon; Reverse Osmosis are common  approaches). The effectiveness of incineration for AFFF foams and soils/sediments  has been questioned in a recent ENGO letter to Secretary of Defense Mark T. Esper. A recent article in volume 97, issue 12 of Chemical & Engineering News discusses some treatment and removal options for both liquid and solid waste streams  containing PFAS chemicals.  

I feel that PFAS chemicals should be addressed as a class (4700-5300 different forms exist with 600 being utilized in a variety of industrial products).  The carbon-fluorine bonds are man made products and called “forever toxic chemicals” because they break down slowly in human bodies and the wider environment. They attach to proteins in the body and are not stored in fat tissues like polychlorinated biphenyls (PCBs). Thus they are PBT (Persistent/Bioaccumulative/Toxic) chemicals which can be found in food from agricultural sources that utilize sludge from industrial sources as soil amendments and can bioaccumulate in aquatic food chains (similar to methyl mercury) which poses consumption threats to sensitive populations (women of child bearing age and kids).

PFAS chemicals have a wide variety of biological, chemical and physical characteristics which influences their fate and transport in the environment/leading to multiple exposure pathways for humans and wildlife.  Their toxicity is based upon acute and chronic effects and their environmental consequences.  There is a wide variety of mcl standards being proposed from 70 ppt for PFOS/PFOA (EPA) to 20 ppt for 6 PFAS chemicals (Ma. DEP) to 1 ppt for PFAS chemicals as a class (Conservation Law Foundation and Toxics Action Center) to 0.1 ppt by Linda Birnbaum (National Institute of Health Sciences retiree). I certainly don’t know the answer to “safe level” 

in drinking water, but am pushing for an mcl between 1-10 ppt for PFAS chemicals as a class.  The mcl depends on exposure pathways in humans from other sources  (food; consumer products; stain resistant and water proof household products; cosmetics, etc.).

Given the research and monitoring conducted on Cape Cod of PFAS chemicals in the JBCC plumes by the US Army and Air Force National Guard staff/contractors; University of Rhode Island STEEP (Sources, Transport; Exposure and Effects or PFAS) and Silent Spring Institute monitoring studies of public/private drinking water wells/research on effects of PFAS levels in drinking water on the immune system of children 4-6 years of age, I was surprised that Ma. DEP didn’t hold a public hearing on their proposed mcl and waste site cleanup standards -here on Cape Cod.  There have been GAC cleanup efforts in Falmouth; Hyannis and Mashpee to remove PFOA and PFOS from the drinking water and delineation of the source areas for this toxic pollution.  A big issue is who is going to fund these cleanup efforts, since EPA has not listed these chemicals as toxic or hazardous and placed the cleanup cost on the industrial sources (see recent movie “Dark Waters”). The Air Force Civil Engineer Center has funded GAC treatment for PFAS contaminated wells in Falmouth and Mashpee from the AVP.

One consequence of lowering the mcl for 6 PFAS chemicals to 20 ppt here in Massachusetts is that we will have more of our public drinking water listed as contaminated and will have to treat this water/remove the source areas for the PFAS pollution.  The Environmental Working Group (EWG) has good online information sources to reduce ones in home exposure to PFAS chemicals.  There is state legislation to establish a PFAS Commission to explore solutions to this challenges (Sen. Julian Cyr is a co-sponsor).

Dr. David Dow

East Falmouth, Ma.

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