At a June 19 water quality forum held in Town Hall, the only thing that was clear was that Harvard’s PFAS story is still being written. Massachusetts Department of Environmental Protection (MassDEP) officials revealed new test results on three public water supplies in Harvard that showed PFAS levels in the Ayer Road Properties water are significantly higher than those from previous tests, and two new PFAS compounds were detected (see table below).
“We've been drinking this water for 30 years, and we're all quietly freaking out.”
Old Mill Road
“We've been drinking this water for 30 years, and we're all quietly freaking out.”
Old Mill Road
PFAS stands for per- and polyfluoroalkyl substances, a family of chemical compounds used to manufacture stain-resistant, water-resistant, and nonstick products. Although scientists are just beginning to look at the substances’ effects on humans, studies show they may interfere with the development of fetuses and infants. Army contractors have identified several sources of PFAS contamination in the area of Devens bordering the northwest part of Harvard, and they are working to determine its migration path. As part of that work, the northwest part of Harvard was tested last August, and results showed PFAS in multiple private and small public water supplies. But without knowing the source and migration path, it’s difficult to determine who is responsible for the contamination and whose wells may be at risk.
About 40 residents attended the two-hour forum, organized by the Board of Health and held in Town Hall. Speakers included MassDEP Regional Director Mary Jude Pigsley, Assistant Commissioner of the Bureau of Waste Site Cleanup Paul Locke, and Jessica Berkhamer from the Department of Public Health. In Locke’s presentation, he identified a “sensitive group” (those that MassDEP is most concerned about) as pregnant women, nursing mothers, and infants who drink PFAS-contaminated water at home. Berkhamer said the only effect confirmed so far in humans is a slight reduction in birth weight, although other effects have been seen in animals, and research is still ongoing. But because little is known besides the developmental risks to fetuses and infants, Locke said there is less concern for drinking water consumed by those outside the sensitive group, as well as for water drunk in restaurants and workplaces or water used for bathing or washing food.
Locke also explained that MassDEP has proposed lowering the state’s PFAS advisory level from 70 parts per trillion (ppt) for the sum of five PFAS compounds to 20 ppt for the sum of six compounds. He said the proposal is currently under review, and it will likely be implemented in the fall. Locke added that the process to develop a maximum contaminant level (MCL) for PFAS has been initiated, and the level would match the proposed advisory level. The MCL would require all public water supplies in the state to test for PFAS on a regular basis; it is expected to be implemented sometime in early 2020.
Pigsley reported that the Army retested three small public water supplies in Harvard in May at MassDEP’s request, and those results had just come in. Using MassDEP guidelines, Appleworks and Harvard Green test results were in about the same range as last year, but Ayer Road Properties (Bowers Brook/Dunkin’Donuts complex) had more than doubled. Pigsley said the agency is working closely with the systems that exceed the proposed guideline of 20 ppt to prepare for the soon-to-be-lowered standard.
As residents asked questions, more difficult problems came to light. First, MassDEP made it clear that it is focusing only on public water supplies since it has no authorization over private wells, which serve 97% of Harvard residents. It has not asked the Army for any further private well testing beyond the 2018 sampling of six private wells in the northwest section of Harvard. When Depot Road resident Stephanie Opalka asked if she should test her water for PFAS, Pigsley said that would be “a personal decision.” Locke added that Opalka should look at the PFAS levels of the nearest well to her home that’s been tested—in this case, Shabokin well in Devens—to inform her choice. Locke said Shabokin well just tested at 32 ppt, but he did not say if that number would warrant testing for Opalka.
Pigsley also said that collecting water for testing is a difficult process because of all the products that could be on a person’s skin or clothing that might contain PFAS, such as sunscreen or fabric softener. Locke joked that Googling “How to sample water for PFAS” would likely result in an answer such as “Don’t shower for three days and sample naked.” He added that the MassDEP website has details about how to collect a sample, and some laboratories will send someone to collect one. Pigsley said samples must be sent to a laboratory certified to test for PFAS (a list is available on the MassDEP website), and the cost of the test is about $350.
Kim Manning of Park Lane asked what steps would be taken to make homeowners’ water safe if PFAS were found. Locke said MassDEP would resample to make sure the homeowner’s test results were correct, and it would then try to determine the cause of the contamination. He said that sometimes PFAS is found in “background levels” in septic systems. He added that MassDEP would also work with the homeowner to find a treatment solution. Manning then asked about financial support, and Locke said he was “hesitant to talk about that.”
The problem is that MassDEP has to recover remediation costs from the responsible party, and Locke said, “In the case of Harvard and Devens, it’s the Army.” But Pigsley said the Army has not yet accepted responsibility for the PFAS found in Harvard wells. And the Army has so far refused to reimburse MassDevelopment for PFAS treatment for its three municipal wells at Devens. Although those wells all exceed the proposed MassDEP levels, none of them exceeds the EPA’s advisory level, which the Army uses as a guide for its actions. But that may change. Locke said Devens is a Superfund site, and when the state defines a maximum contaminant level for PFAS, it will take precedence over the EPA advisory level for Superfund site cleanups. That will help MassDEP recover treatment costs for homeowners and public water supply owners. It will also help to expand the investigation, which is currently being guided by EPA levels.
Mapping the plumes
PFAS travels through groundwater in “plumes,” so in order to determine which private wells might be contaminated, and who is responsible for the contamination, the plumes have to be mapped from their source. Several sources have already been identified in Devens, and Army contractors are working to determine where the PFAS-contaminated water is flowing, but Pigsley said it’s difficult to follow in this area of Massachusetts because of bedrock fractures. “It’s easier on the Cape where the water is flowing through sand,” she added, referring to the Joint Base Cape Cod PFAS investigation that is currently underway.
Old Mill Road resident Helen Batchelder said, “We’ve been drinking this water for 30 years, and we’re all quietly freaking out.” She expressed frustration that she had not been notified that she lived near an area known to have PFAS in the groundwater and asked how long it will take the Army to map the locations of the plumes in Harvard. Locke said that will depend on the cooperation of the responsible party, in this case, the Army, which is working with the EPA. He said that, as a Superfund cleanup, the process is accelerated, although “from an outside perspective, it seems very slow.” He added that Superfund cleanups typically take five to 10 years. Select Board member Lucy Wallace asked if the technology existed to stop a PFAS plume, and Pigsley said it does, but the Army has not yet used it.
Wallace also asked the price of treatment for a small public water supply. Pigsley said the owner of one of the PFAS-contaminated public water supplies in Harvard is looking at an activated carbon system that costs about $20,000. As for treatment for private wells, Pigsley said that treatment systems must be certified by NSF International. She said she didn’t know of any tap-based systems that would bring PFAS levels down to 20 ppt, but some whole-house systems are bringing levels down to nondetectable.
Board of Health Chair Libby Levison told attendees that fellow board member Sharon McCarthy has asked Army contractors to test 40 private wells in Harvard. McCarthy, working with Sanitarian Ira Grossman from the Nashoba Associated Boards of Health, chose sample locations by selecting a checkerboard of properties in a 1-mile radius around areas that have tested higher than 20 ppt for PFAS. That includes the Appleworks well, the Ayer Road Properties’ wells on Lancaster County Road, and the Shabokin well in Devens, which is just across Route 2 from Depot Road. McCarthy told the Press she has not yet heard back from the contractors.
State Sen. Jamie Eldridge also attended the forum and told residents that state Reps. Jen Benson and Kate Hogan had filed legislation this spring to establish a PFAS task force that will review and investigate water and ground PFAS contamination. The bill, H.3851, includes a preamble that declares it to be an emergency law, “necessary for the immediate preservation of public health.” Eldridge said residents are welcome to use his office as a resource for PFAS issues.
More information is available on the MassDEP PFAS webpage and the Harvard Board of Health webpage on the town website.
Setting PFAS Limits
There are currently no enforceable federal or state limits for PFAS. In 2016 the EPA issued a lifetime health advisory limit for PFAS.
In 2018 MassDEP added an Office of Research and Standards Guideline for PFAS. MassDEP has proposed a new guideline and has also initiated the process to declare a maximum contaminant level for PFAS, which would be enforceable under the Drinking Water Program.
These are the limits for the advisories and guidelines
(ppt = parts per trillion):
- EPA advisory: Sum of PFOA and PFOS not to exceed 70 ppt
- Current MassDEP guideline: Sum of PFOA, PFOS, PFNA, PFHxS, and PFHpA not to exceed 70 ppt
- Proposed MassDEP guideline: Sum PFOA, PFOS, PFNA, PFHxS, PFHpA, and PFDA not to exceed 20 ppt