NH DES STATEMENT ON INTERIM EPA HEALTH ADVISORY ON FOUR PFAS SUBSTANCES
On June 15, 2022, the US Environmental Protection Agency issued an interim Drinking Water Health Advisory for Four Perfluoroalkyl Substances (PFAS).
The NH Department of Environmental Services which is responsible for the NH regulatory standards with which all municipalities must comply issued this statement on what the NHDES described as "several non-enforceable health advisories for certain Per- and Polyfluoroalkyl Substances (PFAS).
CITY OF PORTSMOUTH COMPLIANCE WITH NEW HAMPSHIRE REGULATORY REQUIREMENTS FOR PFAS
The City of Portsmouth is currently in compliance with the New Hampshire Drinking Water standards for per- and polyfluoroalkyl substances (PFAS) in both the Portsmouth Regional and Pease International Tradeport Drinking Water Systems serving the following areas:
Portsmouth Regional Drinking Water System:
- New Castle (and wholesale water to the New Castle Water District)
- Some of Rye (and wholesale water to the Rye Water District), Durham, Madbury and Dover
Pease International Tradeport Drinking Water System:
- Pease International Tradeport
- The village area of Newington
Annual Water Quality Reports for all these systems are sent to all water customers and posted here.
The City of Portsmouth’s water system tests for Poly- and Per- Fluoro Alkyl Substances (PFAS) in all of our sources of supply quarterly. Four PFAS chemicals are regulated by the NH Code of Administrative Rules, Chapter Env-Dw 700. These rules establish Maximum Contaminant Levels (MCLs), and compliance requirements for: PFOA, PFOS, PFHxS and PFNA. Currently all of the City of Portsmouth Water System sources are in compliance with the New Hampshire MCLs.
The following table provides a summary of the four-quarter rolling average results for Portsmouth water system testing results through March 2022. Go to additional results from collected samples.
The State of New Hampshire has adopted enforceable drinking water Maximum Contaminant Level (MCL) standards for four per- and polyfluoroalkyl substances (PFAS); Perfluorohexane sulfonic acid (PFHxS), Perfluorononanoic acid (PFNA), Perfluorooctane sulfonic acid (PFOS), and Perfluorooctanoic acid (PFOA). Prior to the adoption of these standards, the State had been following the EPA’s Health Advisory standard of 70 parts-per-trillion (ppt) for two compounds, PFOS and PFOA.
The New Hampshire standards for drinking water maximum contaminant levels (MCL) are:
MCL parts per trillion (ppt)
The regulatory requirements and health advisories for PFAS compounds have evolved considerably since May 2014. When the Pease Haven Well test results were reported to us back then, the only guidance for PFAS compounds were the EPA’s Preliminary Health Advisories for PFOA at 0.400 parts-per-billion (400 ppt) and for PFOS at 0.200 parts-per-billion (200 ppt). According to the EPA’s information at the time these, “health advisories describe non-regulatory concentrations of drinking water contaminants at or below which adverse health effects are not anticipated to occur over specific exposure durations. They serve as informal technical guidance to assist federal, state and local officials, and water system managers by providing information on the health effects of and methods to sample and treat PFOA and PFOS in drinking water.”
In May 2016, the EPA issued Lifetime Health Advisories for PFOA and PFOS and set them at 70 ppt, stating, “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. This health advisory level offers a margin of protection for all Americans throughout their life from adverse health effects resulting from exposure to PFOA and PFOS in drinking water.” Subsequently, New Hampshire adopted EPA's health advisory for PFOA and PFOS as an Ambient Groundwater Quality Standard at 70 parts per trillion (ppt) individually or combined.
On June 15, 2022 the EPA issued updated Lifetime Drinking Water Health Advisories for Four Perfluoroalkyl Substances (PFAS) from the US Environmental Protection Agency (EPA). According to their release, “EPA’s health advisories, which identify the concentration of chemicals in drinking water at or below which adverse health effects are not anticipated to occur, are: 0.004 parts per trillion (ppt) for PFOA, 0.02 ppt for PFOS, 10 ppt for GenX chemicals, and 2,000 ppt for PFBS. Health advisories are non-regulatory and reflect EPA’s assessment of the best available peer-reviewed science.”
The development of New Hampshire’s 2019 MCLs were described by the NHDES on their website with the following information:
To establish MCLs for PFOA, PFOS, PFHxS and PFNA, NHDES had to consider the extent to which the contaminants are found in New Hampshire, the ability to detect them in public water systems, the ability to remove the contaminant from drinking water, and the costs and benefits to affected parties that will result from establishing the standard, and then develop a MCL for each compound that is protective of the most sensitive population at all life stages.
Included with the final proposal, NHDES provided a summary technical report on the development of the drinking water standards (MCLs) including an explanation of the health risk assessment for each compound and information on cost, benefit, occurrence, and ability to detect and treat these chemicals.
The following table summarizes the EAP advisories and timeline of MCLs for the four New Hampshire regulated compounds, together with PFBS:
• All levels are in Parts-per-Trillion (ppt)
• * EPA’s 2016 Advisory was for 70 ppt combined for PFOA and PFOS
• No advisories or MCLs were previously set for PFHxS or PFNA
What is the difference between a Maximum Contaminant Level (MCL) Regulatory Requirement and a Health Advisory?
According to the EPA’s website regarding how health advisories and regulatory standards are set for drinking water contaminants:
- Under the SDWA, EPA has the authority to set enforceable National Primary Drinking Water Regulations (NPDWRs) for drinking water contaminants and require monitoring of public water supplies. To date, EPA has regulated more than 90 drinking water contaminants but has not established national drinking water regulations for any PFAS. The proposed timeline for water regulation of PFOA and PFOS is expected in the Fall of 2022, with the final rule expected in the Fall of 2023.
Health advisories offer a margin of protection by defining a level of drinking water concentration at or below which lifetime exposure is not anticipated to lead to adverse health effects.
- After reviewing health effects data, EPA sets a maximum contaminant level goal (MCLG). The MCLG is the maximum level of a contaminant in drinking water at which no known or anticipated adverse effect on the health of persons would occur, allowing an adequate margin of safety.
MCLGs are non-enforceable public health goals. MCLGs consider only public health and not the limits of detection and treatment technology effectiveness. Therefore, they sometimes are set at levels which water systems cannot meet because of technological limitations.
Once the MCLG is determined, EPA sets an enforceable standard. In most cases, the standard is a maximum contaminant level (MCL). The MCL is the maximum level allowed of a contaminant in water which is delivered to any user of a public water system.
Currently there are a number of contaminants that have been regulated by the EPA that have MCLs that are higher than the MCGLs. These include Arsenic, Uranium, Benzene, Carbon Tetrachloride and others.
CITY OF PORTSMOUTH REGIONAL WATER SYSTEM RESPONSE
The City of Portsmouth has proactively been sampling for PFAS compounds ever since the discovery of PFOS above the EPA’s provisional health advisory in the Pease Tradeport Water System’s Haven Well in May 2014. The well was contaminated by the use of fire-fighting foam at the former Pease Air Force Base. That well was shut down and a comprehensive investigation into the source and extent of the contamination was undertaken. A monthly monitoring program of the Pease supply wells was also implemented. This program included monitoring of the City of Portsmouth’s Collins and Portsmouth wells. Sampling at that time included not only the six compounds that the EPA was soon to require large systems to sample, but a total of 23 compounds to provide a better understanding of the extent of the contamination.
Similar to regulatory standards, laboratory methods and detection levels have evolved over time to enable ever lower detection capability. This is why some sources of supply that previously were “non detect” for some PFAS compounds early in the sample process now have low levels of PFAS detections.
Due to the levels of PFAS in the Portsmouth, Collins and Greenland Wells, the City has engaged the services of our consulting engineer to prepare preliminary design of treatment systems for those sources of supply.
PEASE INTERNATIONAL TRADEPORT PFAS RESPONSE
Construction of a new Pease Drinking Water Treatment Facility was substantially complete in April 2021. The treatment process at this facility includes both ion-exchange resin and activated carbon filtration systems for the removal of PFAS. Water from the Harrison and Smith wells have been continuously treated through granular activated carbon (GAC) since 2016. The ion-exchange resin filters were added to the treatment system on April 20, 2021, and have since been removing PFAS from the Harrison and Smith well water.
The Haven Well, which had been out of service since the discovery of PFAS contamination in 2014, was reactivated and approved as a source of water for the Pease Water Treatment Facility in July 2021. Since August 3, 2021, water from Haven Well has been treated along with Smith Well and Harrison Well water through the Pease Water Treatment Facility. Over a four week startup testing period, samples were collected weekly and analyzed for PFAS from each ion-exchange resin filter and from the granular activated carbon filters. Samples are now being collected monthly throughout the treatment process and analyzed for PFAS. Samples are analyzed with EPA Method 533 which provides results for 25 PFAS compounds, of which four are regulated by the NHDES for drinking water. There have been no detections of these compounds in the water entering the distribution system from the treatment plant since it has been in operation.
SAFE WATER ADVISORY GROUP
The Safe Water Advisory Group (SWAG) was founded by Council action on October 5, 2020, the group's stated mission is to:
- To review and communicate the latest science on the health and environmental effects of PFAS, to monitor federal and state level legislative changes, and to anticipate policy changes that could impact the city of Portsmouth.
For the latest information on SWAG please click here.
PFAS IN DAILY LIFE
The attention to PFAS in drinking water, and other products, has grown considerably since it was first discovered at the Haven Well in May 2014. Pease was one of the first sites in the nation to have to respond to PFAS contamination caused by fire-fighting foam. Since then, many other prominent sites in New Hampshire and across the nation have discovered the presence of these compounds in their groundwater and drinking water. However, other research has revealed PFAS to be present in:
- Certain products utilizing PFAS produced by 3M, Chemours, Dupont, Tyco and others.
- Products from foreign manufacturers that do not have PFAS regulations.
- Food, including milk, meat and fish;
- Products, including non-stick cookware, pans and utensils, dental floss, floor and car polishes/waxes, cleaning, rinse and waterproofing agents:
- Stain resistant coatings used on carpets, upholstery, and other fabrics.
- Water resistant clothing, sporting goods and camping gear.
- Certain cosmetics, such as lotions, cleansers, nail polish, shaving cream, and some types of makeup, such as lipstick, eyeliner, eyeshadow, and mascara. According to greenmatters.com “a study found PFAS in more than half of cosmetics tested.”
- Children’s car seats
- Certain ski waxes
- Byproducts such as air dust and biosolids;
- Forested areas of Vermont where 68 soil samples, collected from 66 locations, revealed PFOS in all soil samples, some with high frequency;
- Some bottled water, NHDES sampling has found detectable levels in three brands, one which exceeded the EPA’s current health advisory limits. A study published in the journal Water Research by Johns Hopkins University researchers detected PFAS in 39 out of more than 100 bottled waters tested.
- Private wells on Cape Cod with no known sources of contamination other than septic systems according to a study by the Silent Spring Institute; and
- Other New Hampshire municipal landfills, fire training centers and fire department facilities.
- Mount Everest snow and meltwater: The journal Science of The Total Environment published a study that found perfluorooctanesulfonic acid (PFOS), perfluorooctanoic acid (PFOA), and perfluorohexanoic acid (PFHxA) in Mt. Everest snow and meltwater. The highest concentrations found were 26.14 and 10.34 ppt of PFOS at Base Camp and Camp 2, respectively
With regard to drinking water in particular:
- An analysis of one-third of the nationwide water systems found that 28 percent of them contained PFAS chemicals at concentrations at or above 5 ppt (Environmental Working Group Article, May 2018, reporting on work of Eurofins Eaton Analytical); and
- Many water systems that originally had samples with “non detections” are now detecting low levels of these compounds with improved/lowered laboratory detection capabilities. Seacoast communities with detections include Hampton and North Hampton (served by Aquarion), Dover, Rochester, Rye, Seabrook and Stratham.
The City of Portsmouth’s water operations staff continues to monitor and address this evolving issue through ongoing research, monitoring and system upgrades as necessary. Because Portsmouth was one of the first to address this issue, the City has had the opportunity to explore, pilot and implement treatment technologies to ensure that the drinking water delivered to City water customers meets regulatory requirements. The City of Portsmouth is also fortunate that local and Congressional delegations are supportive and that the Air Force is a willing partner in responding to the contamination discovered at Pease.
Technologies and regulatory requirements are likely to continue to evolve. The City continues to implement necessary and feasible actions to respond to and comply with regulatory standards. Links to the regular reports to the City Council, Safe Water Advisory Group and Pease Restoration Advisory Board meetings and at various water conferences are compiled on this webpage.
In summary, the City of Portsmouth Water Division's continued PFAS response includes:
- Sampling of all Portsmouth drinking water sources quarterly for PFAS compounds to assess the 12-month rolling averages for the four New Hampshire regulated compounds.
- Evaluating the need for and type of treatment that may be necessary at any other drinking water sources of supply serving the City’s drinking water system.
- Working with the Air Force to monitor PFAS compounds in the water sources in the Pease southern wellfield aquifer.
- Working with regulators and other waterworks professionals to track and respond to the evolving water quality information, regulations and treatment technologies related to PFAS compounds.
- Providing public information on this and all other water quality parameters in the City's water systems. For information for both the City of Portsmouth and Pease water systems, click here.
- Portsmouth Water System PFAS Update: June 15, 2022
- Portsmouth Water System PFAS Sampling through March 2022
- Portsmouth Water System PFAS Update: September 23, 2021
- Portsmouth Water System PFAS Sampling through January 2021
- Portsmouth Water System PFAS Update: March 30, 2021
- Portsmouth Water System PFAS Update: November 30, 2020
- Portsmouth Water System PFAS Update: August 7, 2020
- Portsmouth Water System PFAS Update: March 13, 2020
- Portsmouth Water System PFAS Update: December 12, 2019
- Portsmouth Water Supply Status Report: September 3, 2019
- Report Back to City Council regarding PFAS: August 27, 2019
- Portsmouth Water System PFC Sampling Update: July 2, 2019
- Portsmouth Water System PFC Sampling Update: May 28, 2019
- ATSDR releases health consultation report on PFAS in the Pease Public Water System: April 2, 2019
- Portsmouth Water Division offers update on PFAS regulations: January 3, 2019
- Portsmouth Water System PFC Sampling Update: December 21, 2018
- PFAS Sampling Summary: Most Recent Samples
- Pease Tradeport Water System Update to City Council October 2, 2018
- PFAs Roundtable with City Council: March 19, 2018
- Report Back to City Council regarding PFAS: March 5, 2018
- Portsmouth Water System PFC Sampling Update: November 7, 2017
- Portsmouth Water System PFC Sampling Update: September 25, 2017
- Portsmouth Water System PFC Sampling 2016 Summary February 6 2017
- Portsmouth Water System PFC Sampling as of June 1 2016
- Madbury Well 5 PFC Testing April 2016
- Portsmouth UCMR Sample Results for PFCs April 2015
- NHDESPFC Sampling of Portsmouth Water - Batch 1
- NHDESPFC Sampling of Portsmouth Water - Batch 2
ADDITIONAL PFAS INFORMATION AND RESOURCES