MVD PFAS Filtration FAQs 

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. Initially PFAS compounds were used on non-stick cookware, and then expanded to rain and water-proof clothing, etc. PFAS includes about 30,000 individual compounds, of which only four are proposed to become regulated in New Hampshire. DES 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! EPA currently includes an advisory limit (not a treatment mandate) 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) for those two compound as low as 7 and 11 ppt. Vermont has imposed a limit of 20 ppt for the sum of 5 PFAS compounds; New Jersey between 13-14 ppt for each of 3 PFAS compounds; New York 10 ppt for each of PFOA & PFOS. All those states require treatment at or above those levels.

3.  What about regulation in New Hampshire?

Our NH DES has proposed draft Maximum Contaminant Levels (MCLs) for only four PFAS compounds, two of which include PFOA at 38 ppt, PFOS at 70 ppt. DES used less conservative risk factors in setting the proposed MCLs than many other states, than the ATSDR/CDC, and than many other published academic studies who have concluded much lower safe levels of PFOA & PFOS than the current EPA and proposed DES standards. The chemical industry has a tremendous and well-paid lobby effort right here in New Hampshire. 

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 simply pluck an atom or two off of a PFAS chemical of concern, and are allowed to use that “reformulated” chemical until the government catches up with the new chemicals years later. This is called the “whack-a-mole” conundrum!

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, and acquired Chemfab in around 2000. Other industrial sources of PFAS contamination exist in Amherst. PFAS has been released into the air as far back as 1985, and still continues to be released today, daily. PFAS rained down on the ground contaminating our soil in Merrimack, and precipitation has washed the PFAS into our groundwater.

6. How has PFAS affected us 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 MVD wells 4 & 5 have PFOA+PFOS as high as 140 ppt. SGPP is the cause for the PFAS in wells 4&5, and they are paying for future treatment of those wells, which is anticipated to be on line in 2020. MVD’s remaining four wells (wells 7&8 in Hollis, and wells 2&3 in the central part of town), have PFAS levels that would render those wells undrinkable if they were in many other states.     

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

Currently, the PFAS drinking water limits are too high in New Hampshire, and therefore, there is technically no violation. So, we need to stand up and take care of ourselves and stop the bleeding now! We can always go back and seek legal restitution in the future for repayment for PFAS treatment if the PFAS limits are eventually lowered. 

8.  Isn’t MVD water safe?

Although MVD water has always tested below any applicable limits that were in place at any time, including wells 4 & 5 which are currently off-line until treatment for those two wells comes on line in 2020, the PFAS levels in the rest of Merrimack’s wells exceed limits identified in other reports and in other states. Consider a study done in 2017 by our NH Department of Health and Human Services (DHHS), where 219 MVD users’ blood was tested for some PFAS compounds found that the average MVD customer’s PFOA blood level was double the national average. There is no coincidence. I would say drinking water that doubles your blood’s PFOA level, although considered below current regulatory limits, clearly means MVD water is not safe. Legally yes, but practically, NO! 

9.  What are the proposed PFAS treatment warrant articles about?

There are two separate warrant articles. One is to provide PFAS treatment at Wells 7&8, which costs $3.6 Million. This necessitates an expansion of an existing Iron & Manganese treatment plant to provide granular activated carbon (GAC) filters. The second warrant is to provide PFAS treatment at Wells 2&3, which requires connecting them together, and building a new treatment plant to treat Iron, Manganese, and PFAS. We need to treat Iron & Manganese first, so that it doesn’t conflict with PFAS treatment. That’s the reason for the higher cost for Wells 2&3. The passage of both warrant articles would result in all of MVD water being treated for PFAS! 

10.  How much is this going to cost the average water user?

When compared to the present-day average residential water bill, the increase would be $49 (16%) from $315 to $364 for the $3.6 Million PFAS treatment at wells 7&8; and $112 (36%) from $315 to $427 for the $10.9 Million Iron, Manganese, and PFAS treatment at wells 2&3. Recognize that for Wells 2& 3, $76 of the $112 is PFAS treatment related, and $36 of the $112 is Iron & Manganese treatment related.

11.  When would treatment be in place?

It would take about 3 years. Given that the design for PFAS treatment began in 2018 for Wells 4&5, and is targeted to be on line in 2020, PFAS treatment design could begin this summer 2019, and be on line by the end of 2021.

12.  Besides removing PFAS chemicals from our drinking water, what other benefits will PFAS treatment provide?

There are many unknown emerging contaminants in all groundwater that are being detected at lower and lower concentrations as laboratory test methods and equipment is improved. Pharmaceuticals and Personal Care Products (PPCP) are a growing concern. Naturally-occurring organics in our water react with chlorine and can form suspected carcinogenic compounds called Trihalomethanes (THM), and Haloacetic Acids (HAA). Many former industrial sites in town have been contaminated by Volatile Organic Compounds (VOCs), which still remain in the ground today. In fact, in the 1980’s, MVD Well-6 was abandoned due to VOC contamination and remains off-line today. The good news is that PPCP, THM, HAA, and VOCs are effectively removed by Granular Activated Carbon (GAC), which is the treatment being proposed.

There are other benefits as well:

A.   Property values in town will be better maintained without the stigma of contaminated drinking water, which may otherwise threaten Merrimack property values if buyers pass over Merrimack because of the untreated water situation.

  1. Even people who have installed in-home whole house filters will save money by not paying to replace their filter media as often. Consider that it will cost at least $1,000 and more to replace media every 5 years, which is $200/yr. If MVD treats our water, it will extend the life of in-home filters.

  2. It will be far less expensive than continuing to buy bottled water which can cost $250-500 per year.

  3. We will have peace of mind drinking water at local businesses and restaurants in town, and local businesses and restaurants will not have to worry about possible loss in business due to concerns about the water they serve to their employees, their customers, or use in their food preparation, etc.

  4. MVD will still be able to apply for and may receive grant money to offset the cost of filtration, and could go after the polluters for restitution in the future even after treatment is installed.    

13.  If PFAS treatment is so important, why hasn’t it been done yet?

MVD is currently in a holding pattern due to litigation. MVD is a co-defendant with Saint-Gobain in a lawsuit filed by residents of Merrimack and Bedford, which alleges that MVD should have known about PFAS risks, and should have taken steps to reduce the PFAS in its water. MVD is being advised that anything they do to advocate proactively for PFAS treatment would be counter-productive to the litigation, so it is left to the residents to make this happen while MVD’s hands are tied. If these articles pass, MVD would be required to implement treatment, and they will not be harmed legally, as the customers will have mandated it, not them.