1. What is PFAS, and what is the concern?

PFAS stands for per and poly-fluoro alkyl substances, which are man-made chemicals developed by industry, and used as far back as the 1940’s & 1950’s. Most common PFAS compounds are PFOA and PFOS. PFAS compounds are present in non-stick cookware, food packaging, fabric coating, film coating, wire coating, fire fighting foam, first responder gear and anywhere grease, oil or water repellent qualities are desired. PFAS as a class includes 5,000 or more individual compounds, of which only four ( PFOA,PFOS, PFNA, PFHXS) have recently become regulated in New Hampshire. NHDES has published a Draft List of Health Effects, some of which include testicular, kidney, and other cancers; liver damage, increased cholesterol, increased risk of thyroid disease, immune deficiencies, ulcerative colitis, asthma, decreased fertility, small birth weight, and decreased response to vaccines. It is a well-known problem that is getting more attention nationwide.

2.  Aren’t these PFAS chemicals already regulated?

Not really as there has been industry driven resistance to add them to the hazardous substance registry for years. The EPA currently includes a strictly advisory limit for PFOA+PFOS combined at 70 ng/L (parts per trillion – ppt). In June 2018, the ATSDR (a branch of the CDC) released toxicological profiles (again not a treatment mandate) recommending drinking water exposure limits for PFOS and PFOA as 7 and 11 ppt. In the absence of EPA leadership in regulating this harmful chemical class, states have been left on their own to individually grapple with this emerging crisis. Examples of states in the northeast that have utilized toxicological data to guide regulations include Vermont with a limit of 20 ppt for the sum of 5 PFAS compounds, New Jersey with a limit of 13-14 ppt for each of 4 PFAS compounds, New York at 10 ppt for both PFOA and PFOS and Massachusetts who will shortly set a limit of 20 PPT for a total of 6 PFAS compounds. Each of these states require treatment at or above those levels and several other states across the nation are currently in the process of setting their own regulations.

3.  What about PFAS regulation in New Hampshire?

NH DES after a comprehensive review of health science and a significant public comment period, proposed Maximum Contaminant Levels (MCLs) for four PFAS compounds, which have been signed into regulatory law with an effective date of September 30, 2019. The new NH MCLs are as follows: PFOA 12 ppt, PFOS 15 ppt, PFHXS 18 ppt, PFNA 11 ppt. These regulations will apply to drinking water systems, ambient groundwater and surface water.

NH DES additionally has the authority to regulate air emissions of 4 PFAS compounds, PFOA, PFOS, PFHXS and PFNA. We have yet to see these regulations applied to Saint Gobain whose stack emissions have recently been analyzed by the EPA ORD and have been found to contain a significant total of 190 PFAS compounds. The air emissions are the source of soil and groundwater contamination. NH DES will be setting soil regulations for PFAS in 2020.

4. Doesn’t industry need to prove any chemical they release into the environment is safe before they release it?

No. Unlike the Food & Drug Administration (FDA), which tests chemicals before they are allowed to be used in food and drugs, there are no regulations to first prove a newly formulated chemical is safe before it is used. The chemical industry is even allowed to keep their chemical concoctions a secret and if a chemical is found to be a concern to the public health and the environment, the chemists practice what is called “reformulation”, where they alter the PFAS chemical of concern, and are allowed to use that “reformulated” version until the government catches up with the new chemicals years later. This is why regulating PFAS chemicals individually after the fact will never be effective and nonessential PFAS chemical use should be halted. Until a federal class approach is adopted, with a hazardous substance classification and addition to the Toxic Release Inventory, states and impacted communities such as ours, are on their own .

5. Where did Merrimack’s PFAS come from?

PFAS is in our air, water, soil, and our blood. Saint-Gobain Performance Plastics (SGPP) is the largest PFAS polluter in our state, they acquired Chemfab in around 2000 and utilize PFAS formulations in fabric coating and film coating processes. Other industrial sources of PFAS contamination have been attributed to past use from TCI in their Amherst, NH facility. PFAS has been released into the air as far back as 1985, and still continues to be released today, daily. PFAS deposits in air particles contaminate our soil and waterways in Merrimack, precipitation then washes the PFAS into our groundwater. The contamination area has been identified as at least 65 square miles and has forever altered our environment.

6. How has PFAS affected our drinking water in Merrimack?

All of these PFAS sources have caused PFAS to be found in all of MVD’s six active wells, and in many private wells in Merrimack. The highest Merrimack Village District (MVD) wells, 4 and 5, have PFOA and PFOS as high as 140 ppt. SGPP is the identified responsible party for the PFAS in wells 4 and 5, and they are paying for treatment of those wells, which will be back on line in 2020. MVD’s remaining four wells, wells 7 and 8 in Hollis, wells 2 and 3 in the central part of town, all have PFAS levels that exceed the recently enacted MCLS. Limited testing of private wells has shown the presence of PFAS levels in all areas of town with higher concentrations where air deposition, groundwater or waterways have hastened transport.     

7.  Why should we pay for PFAS treatment and not the polluters?

Past PFAS drinking water limits in New Hampshire followed the EPA advisory, and therefore, were inadequate. When the PFAS investigation began in 2016, only wells over 70 ppt were a focus. Public wells 4 and 5 in addition to 758 private wells in Merrimack, Bedford, Lichfield, Londonderry and Manchester were deemed by NH DES to be the responsibility of Saint Gobain and treated and/or connected to a public water source. Many residents who did not feel the federal advisory was protective to their health, installed home filtration systems and began to utilize bottled water upon learning of the presence of PFAS in drinking water. With the recent determination by NH DES that the federal health advisory is too high and adoption of lower standards, our community is awaiting a revisiting of Saint Gobain’s further responsibilities and also a determination of whether TCI will be held responsible for remediation of wells 7 and 8. In addition to the expectation that additional private wells will be connected to public water, restitution for the proactive citizen led petition warrant articles that passed earlier this year to engineer the design and treat all public wells for PFAS would additionally be expected.

8.  Is Merrimack public water safe?

Although the current MVD wells in use have tested below any applicable limits that were in place over the course of this investigation, and wells 4 and 5 remain off-line until treatment is finalized in 2020, the PFAS levels in the rest of Merrimack’s wells exceed what would be considered safe in several other states and all exceed the new NH limits. A 2017 exposure assessment by the NH Department of Health and Human Services consisting of 217 MVD users in 132 households, tested blood samples for 11 PFAS compounds and found that the average MVD customer’s PFOA blood levels alone was double the national average. Additionally, higher blood level averages were increased and statistically significant with increased water consumption.

9. When will treatment of all MVD public water be in place?

It will take up to 3 years. Design for PFAS treatment at Wells 4 and 5 did not begin until an agreement was reached with Saint Gobain in 2018 and will be completed in 2020. PFAS treatment design for the other wells begin in 2019 and will not be completed until 2022. It will be additionally necessary to treat wells 2 and 3 for iron and manganese prior to PFAS treatment, wells 7 and 8 already have iron and manganese treatment in place. Additional benefits of full filtration and maintenance of drinking water are that many unknown emerging contaminants are being detected at lower and lower concentrations as laboratory test methods and equipment is rapidly evolving. in addition to arsenic, lead and other presences in water, pharmaceuticals and personal care products are a growing concern. Naturally-occurring organics in our water are also present, can react with chlorine to form suspected carcinogenic compounds called Trihalomethanes and Haloacetic Acids. Many former industrial sites in town have been contaminated by industrial chemicals and Volatile Organic Compounds (VOCs), which still remain in the ground, thus also a threat to groundwater.

10. What should residents do now?

Residents in this area should protect themselves by reducing exposure to health disrupting PFAS chemicals where ever possible. According to NH DES and NH DHHS ingestion from drinking water is the greatest source of PFAS exposure. Additional pathways in impacted communities are from dermal absorption, air inhalation, biosolids, soil and local food sources in addition to exposure that most citizens have from other sources. PFAS chemicals are what’s called bio-accumulative, which means they build up both the environment and in the human body as they are very persistent, difficult to break down and difficult to excrete. In order to begin decreasing the body burden residents in PFAS impacted communities bear, exposure needs to cease. Prenatal exposure and exposure in infancy and childhood is of increased concern as endocrine disruptions at critical stages of development can create challenges. Residents should utilize appropriately filtered and/or bottled water.