PFNA in Seacoast Waterway Tied Third Highest Ever Detected
Update: On June 19, 2019, two years after the NHDES said the contamination of Berry’s Brook is unacceptable, the legislative Committee of Conference voted unanimously to re-strengthen House Bill 494. The amended version will requires the NHDES to take steps to stop the toxins flowing from the Portsmouth Dump (aka Coakley Superfund Dump). There are two milestones at which the NH Attorney General will take steps if progress is not made. After decades of toxins flowing from this dump into our beautiful seacoast towns the polluters will have a deadline of September 1, 2020 to start construction on remediation.
If you want to watch the Committee of Conference meeting it is posted on Facebook here.
Post August 20, 2017: Once again, I have been pushed into making a public criticism of the New Hampshire Department of Environmental Services (DES) and U.S. Environmental Protection Agency (EPA) over something that they have had fair warning about. For several months now, I have been speaking in emails to the regulators and in public meetings about my concerns relating to the unmitigated contamination of waterways which originate near Coakley Landfill located in Greenland, New Hampshire. I have publicly discussed the fact that the concentration of one perfluorinated chemical (PFAS), perfluorononanoic acid (PFNA), was detected in Berry’s Brook on now three occasions at very high concentrations, some of the highest in the world.
In fact, the concentration detected in our Berry’s Brook that runs through Greenland, Rye and Portsmouth, eventually discharging at Odiorne’s Point, is tied for second highest known concentration in the world — a fact which I have communicated directly to the Agencies on numerous occasions even citing where I got the information from. Instead of proactively investigating this fact, the Agencies have once again taken to making public statements in the local papers and in public meetings which try to undermine my credibility rather than be proactive in protecting the public from undue exposure to high levels of toxins flowing through three of our seacoast towns.
For the record, as a New Hampshire House Representative I make $100 per year, get an EZPass for tolls and get mileage reimbursement (only for days I am in Concord at committee meetings or sessions). EPA, DES and New Hampshire Department of Health and Human Services (DHHS) representatives get paid a salary to do their job. Nonetheless I will do a part of their job once again.
There are four waterways that originate there including; Norton Brook, Little River, Bailey’s Brook and Berry’s Brook. The only reason we know about the surface water contamination in the first place is because Conservation Law Foundation (CLF) sampled Berry’s Brook and Little River for free and with private donations to cover the lab costs. The DES confirmed the CLF results with their own sampling event which showed even higher concentrations in Berry’s Brook about a month later. After many requests, the Agencies still have not compelled the responsible parties (Coakley Landfill Group [CLG]) to fully evaluate the concentrations of PFAS in any of the brooks that originate from the area west of Coakley dump.
As discussed above, the Agencies have also not investigated the information that I have provided them relating to the concentrations detected of PFNA in Berry’s Brook. The ratios of the suite of PFAS detected in the surface water closely matches that detected in monitoring wells located around the dump, therefore, regulators have in recent weeks admitted that the source of impacts is the dump.
I have recently communicated the following in an email to the DES, EPA and DHHS:
“As I have publicly stated many times, the concentrations of PFNA detected in surface water around Coakley are of concern. The concentrations detected have ranged from 170 parts per trillion (ppt) to 308 ppt (most recently) in the samples collected by CLG. As publicly stated this concentration is one of the highest detected anywhere so far. Even at Pease, the highest concentration of PFNA in groundwater and drinking water is in the tens of ppt not the hundreds.
In response to concerns about the toxicity of PFNA, the state of New Jersey Department of Environmental Protection (NJDEP) recently proposed a separate maximum contaminant limit (MCL) of 13 ppt for PFNA. During the process of determining the need for this proposal, the state of New Jersey conducted sampling, evaluated levels of PFNA in New Jersey surface waters and conducted a literature review of available data for PFNA internationally. The following is a quote from a comprehensive review of scientific data published in 2012 by the Delaware River Basin Commission (DRBC): ‘Perfluorononanoate (PFNA) at a maximum of 976 ng/L was the PFAS with the highest concentrations in the DRBC surveys (Table 9). Figure 6 shows the distribution of PFNA in the tidal river. The highest concentrations occur between RM 68.1 and 80.
The concentrations found are higher than the 0 to 6 ng/L concentrations of PFNA found in streams of an industrial area in Korea (Rostkowski et al., 2006) and levels measured in the Conasauga River (maximum level at 32.8 to 369 ng/L) near carpet manufacturing facilities in Georgia, USA (Konwick et al., 2008).’
The recent detection of 308 ppt detected in Berry’s Brook is approximately tied for 2nd highest ever detected (369 ppt) in the Conasauga River near a carpet manufacturing facility where they dumped adhesives directly in the river.
Another useful reference to this issue is data presented by the DRBC in 2009 showed that PFNA concentrations were detected at elevated concentrations in fish tissue indicating that PFNA bioaccumulates in fish.
In a report issued by the New Jersey Drinking Water Quality Institute (NJDWQI) in 2015 surface water, there is the following quote ‘In 2007−09, PFNA was found in the Delaware River water at up to 976 ng/L starting near and downstream of the discharge location of the above-mentioned industrial facility [Solvay, West Deptford, New Jersey]; this is higher than the surface water concentrations elsewhere in the U.S. and worldwide in studies located in the literature. Elevated levels of PFUnDA (C11), a component of the Surflon S-111 mixture used at the facility, were also found in the Delaware River at these same locations (DRBC, 2012).’ A similar quote is also found in a peer-reviewed paper published in Environmental Science & Technology (ES&T) in 2013 entitled ‘Occurrence of Perfluorinated Compounds in Raw Water from New Jersey Public Drinking Water Systems’ by Gloria B. Post,* Judith B. Louis, R. Lee Lippincott, and Nicholas A. Procopio.”
While recently Clark Freise (DES) responded to me in meetings that DES does not need any legislative involvement to determine drinking water and groundwater standards or MCLs for PFAS in New Hampshire, has opposed my legislative attempts, told me they would oppose our Rulemaking Petition when submitted and responded to me in an email with the following “As you are aware, we completed our study and developed an enforceable standard over a year ago. We will watch what Pennsylvania does and see what science they use as we do with all states that are similarly now reviewing these chemicals.” However, it appears that they need some help keeping apprised of what other states are doing. How many other states will have to act proactively before DES does?
As a state legislator, with my professional and academic background, who represents my constituents who are faced with children who are dying of cancer at alarming rates, I feel it is my duty to protect the health and well-being of my constituents in whatever way I can. Regulators must act to compel the parties responsible to stop the unmitigated contamination of our beautiful Seacoast surface waters now.
