Military Bases Have High Concentrations of Per and Polyfluoroalkyl Substances (PFAS)
***Updated 8/29/18 to include video***
Analies Dyjak | Policy Nerd
Per and Polyfluoroalkyl Substances (PFAS) have been receiving a ton of media attention throughout this past year. PFAS are a category of toxic contaminants that have invaded public and private drinking water systems across the entire country. Military bases are extremely susceptible to this type of contamination because of necessary on-base activities. If you would like to learn more about what PFAS are, their health effects, and if they're regulated, please click here.
Why Do Military Bases Have High Concentrations of Per and Polyfluoroalkyl Substances (PFAS)?
Military bases have historically had issues with pollution, due to the nature of on-base activities. Municipal fire departments also travel to nearby military bases because they provide an open, secure area to train. So not only are military personnel being directly exposed to PFAS chemicals in water, but so are local fire departments. The Department of Defence isn’t necessarily to blame for the high rates of contamination of PFAS on military bases. The Manufacturers of PFAS-containing fire fighting foam who actively sell to the DOD are greatly at fault. Because there is no effective alternative on the market, the military has no choice but to continue purchasing and using these products. Unlike many other countries, the United States doesn’t use the precautionary principle in chemical manufacturing. This means that chemicals are introduced to the market before toxicological due diligence is completed. Most of the time it takes someone getting extremely sick for manufacturers to even begin to pay attention.
More often than not, military bases have their own underground private wells that provide drinking water to families living on base, rather than being apart of a public drinking water system. Fire fighting foam can either directly percolate into soil, or run off into surrounding surface water sources. Water from contaminated soil naturally recharges on-base drinking water wells, which families consume on a daily basis.
What Is The Department of Defense Doing About Per and Polyfluoroalkyl Substances (PFAS) on Military Bases?
The most recent data provided by the DOD stated that 99% people receiving non-DOD-treated water were served by systems with no violations, whereas only 89% of people receiving DOD-treated water were served by systems with no violations. It’s important to note that these data are from bases that voluntarily tested for PFAS chemicals in water, but they do however reiterate that military bases have higher concentrations of this contaminant than other areas in the country. In October of 2017, the US Government Accountability Office reported that the Department of Defense has taken action on PFAS. DOD has directly shut down wells or provided filtration to 11 military installations. This is definitely a step in the right direction, but there are over 400 military bases in the United States that are still contaminated. Approximately 3 million people in the US drink water provided by the DOD. Not only are active military personnel at risk, husbands, wives and children are being adversely impacted by PFAS chemicals in water. Again, manufacturers of these dangerous chemicals are mostly to blame for such high concentrations of PFAS contamination on military bases.
What Are Public Officials Doing About Per and Polyfluoroalkyl Substances (PFAS)?
EPA set a Lifetime Health Advisory Level of 70 parts per trillion for both PFOA and PFOS. The rule of thumb for PFAS is that the sum of the category of contaminants should be no higher than 70 parts per trillion. ATSDR believes this level should be reduced to 20 parts per trillion for drinking water. Again, Lifetime Health Advisory Levels and Minimum Risk Levels are non-enforceable limits that municipalities are not required to follow. DOD has not developed their own standard for PFAS in drinking water and therefore follow the non-enforceable national level of 70 parts per trillion. DOD is not at all incentivized to create a standard or even test for PFAS, because of the outrageous mitigation expenses.Other Articles We Think You Might Enjoy:
PFAS: What You Need To Know
Recap of EPA's 2018 PFAS National Leadership Summit
PFAS: Toxicological Profile
EPA Proposes New Definition of "Waters of the United States"
Analies Dyjak & Matthew Krug
February 14th 2019: The Department of the Army and the Environmental Protection Agency posted the newly proposed “Waters of the United States” rule to the Federal Register. At its core, the proposed EPA WOTUS rule limits the water that EPA can regulate and monitor. By narrowing the scope of WOTUS definitions, this basically gives industries a roadmap of where it’s okay to pollute without the need for permitting. This is a big deal for the 45 million Americans who rely on well water for drinking and bathing. So, why should you care about the definition of waters of the United States?
"Waters of the United States"
This definition, also known as “WOTUS” has been up for debate for decades, and it’s interpretation has seen several Supreme Court cases. This proposed rule determines what waters the federal government is able to regulate and monitor. Generally, “waters” have traditionally been navigable waters such as oceans, rivers, ponds, and streams. As our scientific understanding of hydrology has improved, the scope of what are considered “waters” has expanded.
What Is Not Protected Under The Proposed Rule?
WOTUS definitions name certain waters as “excluded,” which, in this case, means they do not have a surface water connection. This means that groundwater, ephemeral streams, ditches, prior converted cropland and some wetlands and ponds are not included. This is a continued rollback of environmental regulations - and the 2019 EPA WOTUS rule proposal may have the farthest-reaching implications of all.
How Does This Proposed Rule Affect Drinking Water?
This rule puts the 45 million Americans that use private wells as a primary source of drinking water at risk. Private wells are not regulated by federal, state, or local governments, and agencies are not required to test for contaminants or ensure “compliance.” A 2006 study by the USGS concluded that private wells are already contaminated with various types of agricultural runoff, solvents, fumigants and inorganic compounds, the most common being arsenic and nitrates. Arsenic is a naturally occurring organic compound, that enters groundwater as bedrock weathers overtime. However, nitrates are used in fertilizers and enter both surface and groundwater from agricultural runoff. 8.4% of the wells tested in this study were in exceeded the federal standard for nitrates (we have an article dedicated specifically to nitrates in groundwater). Further, EPA does not provide recommended criteria or standards for private well users. By rolling back protections, private well users are being further kept in the dark.
How Did They Arrive At this Rule?
The proposed EPA WOTUS rule is primarily based off a majority opinion by Justice Scalia in the Supreme Court case Rapanos v. United States. Scalia’s interpretation favored “traditional waters,” and steered away from Justice Kennedy’s “significant nexus theory.” In his majority opinion, Scalia wrote that federal protections should cover:
“...only those wetland with a continuous surface connection to bodies that are waters of the United States.”
The American Farm Bureau dominated the conversation at the press conference for the proposed EPA WOTUS rule in early December of 2018. Industries lobbied hard to limit the scope of jurisdictional waters. In a political landscape where there is an abundance of legislation grandfathered in to protect the chemical, fossil fuel, and agricultural industries, it should come as no surprise that the current administration did not break from tradition. The agricultural industry is not the only institution who will benefit from this proposed rule. Chemical manufacturing companies have to go through a rigorous permitting process determined by state or federal governments (NPDES) which regulate pollution. But now, with a clearly defined and reduced scope of what constitutes a water of the United States, these companies are able to map out how to circumvent regulation.
The federal government has designated this as “economically significant”
This means that the proposed rule with have an annual effect on the economy of $100 million or more.
This proposed WOTUS definitions puts the 15% of the country at further risk of groundwater contamination. This population of people are now on their own in terms of monitoring their drinking water and keeping up with land use changes. Our science team will be submitting public comments on this proposed rule, which will be available on our website in the upcoming weeks. We encourage our readers to do the same thing! CLICK HERE for the link to the WOTUS public comment page.Other Articles We Think You Might Enjoy:
5 Reasons Why Bottled Water Isn't The Solution To Drinking Water Contamination
Nitrates In Drinking Water
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Orthophosphate and Lead Contamination in Drinking Water
Analies Dyjak | Policy Nerd
Lead contamination in drinking water is a huge problem for municipalities with an older infrastructure. Lead contamination occurs when water comes in contact with lead pipes. This article discusses a common additive used to combat lead pipe corrosion.
What is Orthophosphate?
Orthophosphate is a common corrosion inhibitor used by water suppliers to prevent lead pipes from leaching. When orthophosphate water treatment is added to a water source, it reacts with lead to create a mineral-like crust inside of the lead pipe. This crust acts as a coating which prevents further lead corrosion. The use of orthophosphate treatment in drinking water became popularized in 2001, during the lead crisis in Washington, D.C. Lead contamination in many cities including D.C. and Flint, occurs when a city’s water becomes more corrosive, which can allow for lead from pipes to leach into the drinking water supply. When the lead problem initially occurred, cities such as Flint, Michigan, Durham and Greenville, North Carolina, and Jackson, Mississippi didn’t learn from D.C’s mistakes and all had lead outbreaks.
Does Orthophosphate Fix Lead Contamination?
It certainly can. Once the protective layer is formed, cities can find that lead concentrations in the water drop by 90%. However, Orthophosphate is somewhat of a bandaid to temporarily fix the presence of lead in drinking water. For example, if the protective layer is corroded away or otherwise disturbed (e.g. in the case of a partial service line replacement or the water’s corrosivity changes), lead can leach back into the water. Finally, not all municipalities are adding orthophosphate to drinking water because of its cost. If you have any questions regarding lead prevention in drinking water, send us an email at firstname.lastname@example.org.Other Articles We Think You Might Enjoy:
Lead In Drinking Water: What You Need To Know
Lead and Copper Rule
Things To Know Before Replacing Your Home's Lead Service Pipes
5 Reasons Why Bottled Water Isn't The Solution To Drinking Water Contamination
Analies Dyjak | Policy Nerd
Whenever severe water contamination impacts a community, people (and media outlets) tend to jump to bottled water as the only water contamination solution.
The bottled water industry has managed to convince vulnerable consumers that their product is inherently safer than what’s coming out of their taps. Oftentimes, this isn’t the case. So why is bottled water bad? The reality is that bottled water is associated with a host of ethical, environmental and regulatory problems. Drinking bottled water is not a long-term solution to water contamination, and we should critically examine its role as water quality crises continue to pop up across the country. Here are our main problems with the bottled water industry to give you a better idea of why bottled water is bad.
1) Bottled Water Companies Use The Same Source As Tap Water
According to the FDA, bottled water companies are permitted to package and sell water from municipal taps, artesian wells, mineral water, natural springs, and drilled wells. Surprisingly enough, they aren’t required to disclose the source water itself. If you’re looking for transparency, municipal systems are required to publish an annual Consumer Confidence Report (CCR) that discloses characteristics about the source water, treatment techniques, and other distribution information. The bottled water industry also frequently packages and distributes groundwater from dug wells. Groundwater can often be more susceptible to pollution than surface water because it’s not regulated by the federal government. Groundwater acts as a catchment for surface water runoff and agricultural pollution, not to mention its increased risk of arsenic contamination.
2) Bottled Water and Tap Water Have Almost Identical Standards
People are often surprised to learn that there’s virtually no difference between the regulations for bottled water and tap water. The Environmental Protection Agency regulates tap water and the Food and Drug Administration regulates bottled water. The allowable concentrations of contaminants are identical for both, with the exception of lead. The standard for lead in bottled water is 5 parts per billion, as opposed to 15 parts per billion in tap water. This is because during bottling production, water should never come in contact with older lead service pipes the same way municipal water does. Arsenic can be present in groundwater as a result of natural weathering of bedrock. Exposure to arsenic in drinking water can result in cancers in various organs, including skin, bladder, lung, kidney, liver, and prostate. Non-cancerous health effects include neurological damage, such as peripheral neuropathy.
3) Impacts On The Environment
It’s well-documented that single-use plastic water bottles wreak havoc on the environment. Plastics are made from petroleum, which is a fossil fuel and a non-renewable resource. Companies often tout their commitment to reducing plastic consumption by weight, but this has no bearing on the volume at which it’s produced. You may be familiar with “Trash Island,” in the Northern Pacific Ocean. This phenomenon is the result of decades of poor waste management and excessive production of various types of plastic. According to a 2016 study by the Ellen Macarthur Foundation, the ocean will contain more plastic by weight than fish by the year 2050. Polyethylene Terephthalate (PET) is the main ingredient in plastic water bottles. PET takes over 400 years to decompose in the environment and its constituents can often take longer to degrade. Chemicals like Bisphenol A (BPA) have since been phased out of plastic production, but are still very much present in the environment and will continue to be released as older plastics degrade.
4) False Advertising
Marketing schemes deceive consumers into believing that companies use pristine source water. The packaging uses carefully curated images of mountain-top creeks and streams to suggest pure, untainted products. The reality is bottled water hardly ever comes from the sources depicted on the label.
5) Ethical Dilemma
Nestle, a company with a long track record of unscrupulous business practices, owns deep aquifers throughout California, a state which has been experiencing drought-like conditions for several decades. The expensive equipment purchased by Nestle allows the company to extract water in a way that tribes and municipalities cannot afford to do. Similar companies have been known to use their purchasing power to acquire land, pushing tribes and municipalities out of the conversation. Problems arise when drought-stricken or contaminated communities are unable to afford the same resources as bottled water companies.
While bottled water offers some measure of immediate relief to a severe drinking water crisis, it is in no way a long-term water contamination solution. Companies often sell the same water that’s feeding municipal systems. Not to mention, EPA and FDA have almost identical regulations for both tap and bottled water. There’s also an inherent cost associated with bottled water, which varies depending on the brand. Finally, a huge part of why bottled water is bad is that scientific data confirms the importance of reducing plastic pollution on a global scale. Municipal providers offer greater transparency and are required to disclose information about the source water.Other Articles We Think You Might Enjoy:
Microplastics In Water: What You Need To Know
Endocrine Disruptors In Drinking Water
Water Conservation and Water Quality In The Sports Industry
Chemours To Pay $13 Million To The North Carolina Department of Environmental Quality For Years Of PFAS Pollution
Analies Dyjak | Policy Nerd
Our Water Nerds have been closely following the environmental and public health disaster in North Carolina for a while now. This article provides an overview of the recent consent order, and some background information on what's going on in North Carolina.
The Chemours Plant in Fayetteville, North Carolina has been discharging various per and polyfluoroalkyl substances (also known as PFAS) for decades. PFAS are a category of emerging contaminants that are found in some of the most popular consumer products such as Scotchgard, Gore-Tex, Teflon, and other stain/water resistant products. PFAS is also an important ingredient in firefighting foam, which has been a major source of water contamination throughout the country. In recent years, a replacement chemical for PFOA called GenX has dominated the conversation, particularly in North Carolina. In November 2018, EPA admitted that GenX is “suggestive” of cancer, which is significant for residents who have been unknowingly exposed.
$13 Million Awarded to NCDEQ
Chemours is awarding $13 million to the North Carolina Department of Environmental Quality in the form of civil penalties and investigative costs. In comparison to other PFAS-related settlements, this is by far one of the smallest. In early 2018, 3M paid the state of Minnesota $850 Million in environmental degradation. In 2017, DuPont was involved in a $670.7 million settlement in the Mid-Ohio Valley region for PFAS water contamination.
Overview Of The Consent Order
The Consent Order clearly lays out a timeline of air emission goals and wastewater discharge stipulations. Chemours’ National Pollution Discharge Elimination System (NPDES) permit was revoked in early 2017 and the new Consent Order prohibits any sort of wastewater discharge until a NPDES permit is reallocated. Chemours must also create laboratory methods and test standards for all PFAS compounds released by the Fayetteville plant. Basic remediation plans must be agreed upon by the North Carolina Department of Environmental Quality, North Carolina River Keepers, and Chemours. Chemours will also pay for water filtration for water filtration for residents on private wells. Concentrations of GenX must be above 140 parts per trillion or any updated health advisory, in order to be eligible for a filter. GenX is not the only PFAS compound detected in the Cape Fear area, and the consent order addresses that. the Residents can also be eligible for filtration if other PFAS compounds are detected in well water over 10 parts per trillion individually, and 70 parts per trillion combined. NCDEQ is currently seeking public comment regarding the recent settlement.
How Are Cape Fear Residents Responding?
Cape Fear Public Utility Authority (CFPUA) created a comprehensive breakdown of the Chemours consent order. The utility provider acknowledged that the settlement did not go far enough to cover the scope of GenX and PFAS water contamination in the Cape Fear area. In a press release, CFPUA talked about how the consent order did not acknowledge the PFAS sediment pollution at the bottom of the Cape Fear River. Any sort of dredge or fill could disturb the sediment and create GenX concentrations to sky rocket in drinking water. Local non-profit groups are also not in agreement with the Chemours settlement because they believe it does not go far enough to mitigate the scope of PFAS water contamination. The current consent order places most of the mitigative costs water utility providers which would of course be paid for by taxpayers.
In early November of 2018, EPA released a draft toxicity report for GenX, proposing a threshold of 80 parts per trillion for drinking water. The concentration deemed “safe” by North Carolina and Chemours is almost two times higher than what the EPA is proposing as safe. Health and regulatory agencies know very little about the adverse health effects of GenX and other PFAS compounds. It’s up to consumers to decide the best course of action to protect themselves and their families.Other Articles We Think You Might Enjoy:
EPA Admits That GenX Is Linked To Cancer
Military Bases and PFAS
Toxicological Profile For PFAS
Surface Water: What You Need To Know
Analies Dyjak | Policy Nerd
Surface water is an extremely important natural resource. From the water we drink, give to our pets, and use for recreation, we are dependent on its various uses. Surface water is continuously being threatened by anthropogenic activities. It’s extremely difficult and costly for municipal treatment facilities to keep up with new contaminants that are polluting waterways every single day. Additionally, federal regulations don’t reflect the large scope of surface water pollution. This blog post discusses the various threats to surface water and why humans should care.
What Is Surface Water?
Lakes, oceans, streams, rivers, ponds, reservoirs, and wetlands are the various types of surface water. Freshwater sources are responsible for providing potable drinking water to 84% of the nations population. Surface water is different from groundwater because it has the ability to disperse and become diluted as it travels throughout a body of water. Groundwater aquifers are essentially holding tanks for highly concentrated contamination. There’s less room for contaminants to move around, and less volume for the contamination to become less concentrated.
How Does Surface Water Become Polluted?
Surface water is extremely susceptible to pollution because it occupies such a large portion of the earth’s surface. Surface water pollution is almost entirely the result of human activities. Agriculture, mining, factory effluent, landfills, human/animal waste and localized pollution are just some of the most common sources of surface water pollution. Topography and geological formations create natural surface water runoff, but human manipulation of the land increases flow rates and overall contamination.
Point source pollution comes from an easily identifiable source, like a factory or sewage treatment plant. Point source pollution is discharged through a pipeline, ditch, or any “discrete conveyance” that directly or indirectly enters a body of water. Point sources are typically regulated by National Pollutant Discharge Elimination System (NPDES) permits.
Non-point source pollution is much harder to regulate because the source is not easily identifiable. Agricultural and stormwater runoff are the two most common types of nonpoint source pollution. Heavy rain events cause contaminants to runoff from roads and fields, collecting debris and pollution as it travels into a body of water.
How Do You Mitigate Surface Water Pollution?
It’s expensive and nearly impossible to mitigate a contaminant once it has entered surface water. For some contaminants, the solution is typically self-mitigating. A contaminant will become diluted to extremely small concentrations after it has traveled and dispersed throughout a body of water. Additionally, some contaminants are still extremely toxic at very small concentrations. There are also several persistent contaminants that never fully decompose in nature (PCBs, DDT and Dioxin), or take hundreds of years to degrade. As we’ve seen in Wilmington, North Carolina, and Maplewood, Minnesota, municipal water treatment facilities are only equipped to remove certain types and quantities of surface water contamination.
What Is Currently The Biggest Threat To Surface Water?
Man-made compounds are one of the largests threats to drinking water sources. Per and Polyfluoroalkyl Substances (PFAS) are a category of man-made “emerging contaminants,” which means they have been detected in the environment but the risk to human health is not well-understood. Chemicals such as GenX, PFOA, and PFOS are all common contaminants that fall under the category of PFAS. DuPont, Chemours, and 3M have been using variations of these chemicals in industrial and consumer products since the early 1950’s. Scotchgard, Teflon, firefighting foam, metal plating, heat/water repellent chemicals, and stain resistant fabrics are common uses of PFAS. They are extremely persistent in the environment, which means they do not readily degrade. PFAS effluent is either directly dumped from a factory into surface water or a dug ditch, which will then percolate into groundwater. This is allowed because PFAS are unregulated by the federal government.
North Carolina’s Cape Fear River has been unknowingly experiencing surface water contamination for years. A Chemours plant located in Fayetteville, North Carolina, had been discharging various types of PFAS into the Cape Fear River since the 1980's. The Cape Fear is the primary drinking water source for residents of Brunswick and New Hanover County. Their water resource is now tainted with a dangerous contaminant that's unregulated by the federal government.
Algal Blooms and Surface Water
Algal blooms are another major threat to surface water. An influx of nutrients or heat can increase the quantity of algae. Often, this overload of nutrients is the result of agricultural fertilizer runoff. Harmful Algal Blooms or HABs occur after an influx of nutrients or a sudden increase in water temperature. HABs can then produce cyanotoxins, which are harmful to humans and the environment.
How Can I Protect Surface Water?Protecting surface water from contamination will not only improve drinking water quality, but also valuable habitats. Here are some tips for local level surface water management:
- Watershed Management: Municipalities should look at watersheds as an entire system, rather than exclusively a water resource. Watershed management surveys the land surrounding a body of water to determine the natural flows and influxes.
- Eliminating Pesticides, Herbicides, and Fertilizers: What’s bad for plants and animals, is also bad for humans. This category of surface water pollution runs-off directly into surrounding bodies of water and effects fragile surface water ecosystems. Reducing or eliminating the use of pesticides, herbicides, and fertilizers will reduce the amount of necessary additives by municipal water treatment facilities to eliminate contaminants.
- Reduce Impervious Surfaces: Impervious surface is any type of ground cover that prevents water from infiltrating into the ground. Pavement or asphalt is the best example. Impervious surface increases runoff flow rates into surface water, and prevents groundwater from naturally filtering contaminants. Next time you’re thinking about paving your driveway, consider a pervious alternative such as porous asphalt or pervious concrete.
- Hold Municipalities Accountable: Stay current with commercial and industrial development within your community. Public comment periods are required prior to development and prior to obtaining a NPDES permit. Companies are required to address each question and concern individually, so if development plans raise personal concern, don’t be afraid to utilize the public comment period.
Groundwater: What You Need To Know
Timeline Of GenX Contamination In The Cape Fear River
Unregulated Contaminant Monitoring Rule