Laura Olah / Cease Fire Campaign & Citizens for Safe Water Around Badger (CSWA – 2017-09-29 21:28:07

Special to Environmentalists Against War

Toxic Compound Highest in Groundwater at Fort McCoy
Laura Olah / Cease Fire Campaign &

(September 28, 2017) — CSWAB petitioned the Wisconsin DNR today to develop drinking water Health Advisory Levels for toxic compounds that have been detected in groundwater at US Army Reserve Fort McCoy and other Wisconsin sites that used industrial fire-fighting foams. The petition is the first step in securing enforceable standards and cleanup.

Concentrations of PFOS (Perfluorooctane Sulfonic Acid) in groundwater at Fort McCoy are the highest reported in the state, DNR officials said. Reported levels are as high as 120 ug/l, which is 1700 times higher than the EPA’s drinking water health advisory of only 0.07 ug/l.

PFOS and PFOA (Perfluorooctonoic Acid) are man-made compounds that are used in a number of products, most notably firefighting foams such as Aqueous Film Forming Foam and in the production of nonstick cookware and stain- or water-resistant fabric.

Animal studies show that exposure to these chemicals can cause adverse effects on the animal’s liver, kidney, and immune system along with developmental effects and cancer.

Studies conducted on people who have been exposed to these chemicals suggest that exposure at certain levels may adversely affect the developing fetus and child, the thyroid gland and immune systems, and result in decreased fertility and increased cholesterol levels.

Drinking water is not the only concern as groundwater at Fort McCoy feeds at least seven trout streams that run throughout the property. Many states, including Wisconsin, have issued fish consumption advisories for PFOS in certain water bodies as eating fish is a major pathway for human exposure to these compounds.

The establishment of state Health Advisory Levels is the first step in developing enforceable state standards that will help compel cleanup and restoration of the state’s groundwater resources. Approximately two thirds of the people living in Wisconsin rely on groundwater for their drinking water.

Laura Olah is the Executive Director of Citizens for Safe Water Around Badger (CSWAB) and National Coordinator of the Cease Fire Campaign. CSWAB, E12629 Weigand’s Bay South, Merrimac, WI 53561.

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RE: Citizens Petition for Wisconsin Health Advisory Levels for PFOA, PFOS and combined

Perfluorooctane Sulfonic Acid (PFOS) and Perfluorooctonoic Acid (PFOA) are manmade compounds that are used in a number of products, most notably firefighting foams such as Aqueous Film Forming Foam (AFFF) and stain resistant sprays as well as in the production of nonstick cookware and stain‐ or water‐resistant fabric. (1) (2)

PFOS and PFOA are extremely persistent in the environment and are resistant to typical environmental degradation processes. (3) The toxicity, mobility and bioaccumulation potential of PFOS and PFOA pose potential adverse effects for the environment and human health.

Animal studies show that exposure to these chemicals can cause adverse effects on the animal’s liver, kidney, and immune system along with developmental effects and cancer.

Studies conducted on people who have been exposed to these chemicals suggest that exposure at certain levels may adversely affect the developing fetus and child, the thyroid gland and immune systems, and result in decreased fertility and increased cholesterol levels (4).

In 2016, EPA established health advisory levels for drinking water at 70 parts per trillion (0.07 ug/l) in May 2016. When both PFOA and PFOS are found in drinking water, the combined concentrations of PFOA and PFOS should be compared with the 70 parts-per-trillion health advisory level for drinking water. (5)

However, the EPA’s drinking water advisories are not enforceable and the Agency emphasizes that it is “committed to supporting states and public water systems as they determine the appropriate steps to reduce exposure to PFOA and PFOS in drinking water.” (6)

As a result, several states have adopted more stringent enforceable standards.

* Last week, the State of New York announced plans to set maximum contaminant levels for PFOA and PFOS. (7)

* Minnesota has adopted a Chronic Health Risk Limit of 30 part per trillion (0.03 ug/l) for PFOA and PFOS in drinking water.

* Last year, Vermont proposed amendments to the stateʹs groundwater protection and hazardous waste management rules that would set a limit of 20 parts per trillion (0.02 ug/l) for PFOA and related chemical PFOS in drinking water.

* New Jersey set a 40 part per trillion (0.04 ug/l) limit in 2007.

On June 28, 2017 the Wisconsin DNR Remediation & Redevelopment program reported that it has received information on the detections of PFOA and PFOS in wells at the five Wisconsin sites listed below. The number of wells with detections, and the maximum concentration of PFOA and PFOS detected in groundwater at each site are included in the following summary prepared by the WDNR. (8)

Pursuant to the Safe Drinking Water Act, once every five years EPA issues a new list of no more than 30 unregulated contaminants to be monitored by public water systems. From 2013 – 2015, all large public water systems and a subset of small systems were required to monitor for approximately 30 unregulated contaminants (including 6 perfluorinated chemicals) under the third cycle of the Unregulated Contaminant Monitoring Rule (UCMR3).

During UCMR3, EPA reports that three samples from Wisconsin’s West Bend Water Works (PWS ID#:WI2670120) had PFOA detections above the minimum reporting level (MRL) – concentrations ranged from 0.02155 to 0.04317 ug/l. Two samples from the La Crosse Water Works (PWS ID# WI6320309) had PFOS above the MRL during this cycle – detected levels were 0.053 ug/l and 0.140 ug/l. (9)

CITIZENS PETITION
Lifetime Health Advisory Levels (HALs) are established by the Wisconsin Department of Health Services for contaminants in groundwater and drinking water. HALs serve as technical guidance to assist regulators with water consumption advisories and groundwater remediation decisions. (10)

By this letter, we petition the Wisconsin Department of Natural Resources to add the following groundwater contaminants to its list of substances that have been detected and/or have a reasonable probability of entering the groundwater resources of the state, and that the WDNR request that the Wisconsin Department of Health Services review the health effects and consider establishing health advisory levels or interim groundwater standards for the following:

(1) PFOA (CAS #335‐67‐1)
(2) PFOS (CAS #1763‐23‐1)
(3) PFOA/PFOS combined

The requested values may be used by the Department in making recommendations to well owners and/or water users on continued use of their water supply and as remediation goals for the protection of groundwater resources of the state. They also provide the public with essential information about the potential health risks associated with exposure to contaminants in drinking water and well water.

Thank you in advance for your consideration and attention to our request. Sincerely,
Laura Olah, Executive Director

Notation:
On June 10, 2016, the US Department of Defense issued a Memorandum requiring all DoD drinking water systems to test the finished drinking water for PFOS and PFOA at all installations where DoD is the water purveyor, including overseas.

To the best of our knowledge, groundwater and drinking water testing for PFOA/PFOS has never been conducted at the former Badger Army Ammunition Plant including at the facility’s former fire training area. WDNR recently ran a query on the PFOA/PFOS parameters in the GEMS database and reports that no records were located. (11)

Footnotes
(1) US Environmental Protection Agency (EPA), Fact Sheet: PFOA & PFOS Drinking Water Health Advisories, May 2016, EPA 800‐F‐ 16‐003. https://www.epa.gov/sites/production/files/2016‐06/documents/drinkingwaterhealthadvisories_pfoa_pfos_updated_5.31.16.pdf

(2) Grandjean, P. and Clapp, R. Changing Interpretation of Human Health Risks from Perfluorinated Compounds, Public Health Reports, Vol 129: 48‐85, Nov‐Dec 2014, http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4187289/

(3) US EPA, Emerging Contaminants Fact Sheet – PFOS and PFOA, March 2017.

(4) US EPA, Groundwater and Drinking Water, Drinking Water Health Advisories for PFOA and PFOS, undated. Online at https://www.epa.gov/ground‐water‐and‐drinking‐water/drinking‐water‐health‐advisories‐pfoa‐and‐pfos.

(5) US Environmental Protection Agency, FACT SHEET: PFOA & PFOS Drinking Water Health Advisories, May, 2016. Online at https://www.epa.gov/ground‐water‐and‐drinking‐water/drinking‐water‐health‐advisories‐pfoa‐and‐pfos.

(6) US Environmental Protection Agency, Groundwater and Drinking Water, Drinking Water Health Advisories for PFOA and PFOS, undated. Online at https://www.epa.gov/ground‐water‐and‐drinking‐water/drinking‐water‐health‐advisories‐pfoa‐and‐pfos.

(7) Times Union Newspaper, State Water Quality Council to address PFOA, other contaminants: 12‐member group will recommend maximum contaminant levels for PFOA, PFOS, September 22, 2017.

(8) P. Derge, Bureau of Legal Services, WDNR, RE: DNR Records Response, Email message to L. Olah, Citizens for Safe Water Around Badger, 28 June 2017.

(9) US EPA Region 5 — Chicago, Water Quality Branch, K. Harris, RE: USEPA response to UCMR3 PFAS data request (WI), Email message to L. Olah, Citizens for Safe Water Around Badger, September 29, 2017.

(10) WI DNR — Drinking Water and Groundwater Quality Standards/Advisory Levels, Narrative for table, accessed online September 25, 2017 at http://dnr.wi.gov/topic/drinkingwater/documents/haltable.pdf.

(11) P. Derge, Bureau of Legal Services, WDNR, RE: DNR Records Response, Email message to L. Olah, Citizens for Safe Water Around Badger, 28 June 2017.