Officials in Ayer and Devens and two small public water supply owners in Harvard are scrambling to provide safe drinking water to consumers after the Massachusetts Department of Environmental Protection (MassDEP) recently notified them it will likely lower acceptable PFAS levels from 70 parts per trillion (ppt) to 20 ppt.
Every well that provides municipal water to Ayer and Devens has PFAS levels over 20 ppt, as do two small public water supplies in Harvard: one that serves the Appleworks building on Ayer Road and one that serves the complex of four buildings at 188, 196, 198, and 200 Ayer Road, which includes Bowers Brook Apartments and Dunkin’ Donuts. Harvard’s municipal water supply tested negative for PFAS in early April.
While MassDEP’s letter does not require recipients to take action, it “encourages” them to notify local officials and consumers about PFAS test results as well as any actions they plan to take to lower the levels of these toxic compounds in their water. In addition, they are being asked to begin monitoring for PFAS compounds quarterly. The new guidelines will likely be in place by early 2020 according to MassDEP officials.
PFAS stands for per- and polyfluoroalkyl substances, fluorinated organic chemicals that can enter groundwater from industrial facilities or from areas where firefighting foam was used. Extensive firefighting training was done at Ft. Devens during its years as a military base, so in 2016, MassDEP ordered testing of Ayer’s Grove Pond wells, which are near Barnum Road. PFAS was found in all of them; one of them, Well 8, was over the 70 ppt Environmental Protection Agency (EPA) guideline set earlier that year.
Trouble for Ayer …
Ayer first attempted to lower PFAS levels by blending water from the Grove Pond wells, but last February, it took Well 8 offline. In the spring of 2018, Ayer’s Town Meeting voted to approve $4.2 million for a PFAS removal treatment system at the site of the Grove Pond wells. The Army has since agreed to cover the cost of that system, but the project is just going out to bid and will take months to complete.
In the meantime, MassDEP’s plans have escalated the problem. All of Ayer’s wells, four at Grove Pond and two at Spectacle Pond, have PFAS levels over 20 ppt. Mark Wetzel, Ayer’s superintendent of public works, said that Ayer has notified all its water consumers of the latest PFAS updates from MassDEP, and it is recommending that the sensitive population (pregnant women, nursing mothers, and families with infants) not drink or cook with Ayer’s water until levels can be brought below 20 ppt. It is also evaluating “point of use” filters, and if they prove to be effective in lowering PFAS, Ayer will provide them to the sensitive population. In the meantime, Ayer is working with the Army to install a temporary treatment system consisting of two large activated carbon vessels at one of the Grove Pond wells. The temporary system is expected to be installed in May, and Wetzel said the treatment will keep water from those four wells below 20 ppt. The town is looking into treatment options for Ayer’s other two wells at Spectacle Pond.
… and trouble for Devens
Devens faces a similar dilemma. It has three wells at different locations: Macpherson, Shabokin, and Patton. In 2018 the Macpherson well was taken offline when it tested over 70 ppt (using MassDEP guidelines—see Guidelines and MCLs). The Shabokin and Patton wells tested at 32 ppt and 29 ppt, respectively.
MassDevelopment, the owner of the Devens water system, has notified its customers of the test results and of MassDEP’s proposed actions, and is taking the extra step of making free bottled water available to some consumers. The list of those eligible includes all Devens residents, Parker Charter School, Applewild School, Evergreen Garden Playschool, Oxbow Schoolhouse, and various residential programs such as Transitions. Consumers working at businesses in Devens who are in the sensitive population are also eligible. MassDevelopment said it hopes to have treatment systems that will bring PFAS levels below 20 installed for all its wells by the end of the year.
The Press spoke to Parker Charter School Principal Todd Sumner about the school’s response, and Sumner said the water bubblers throughout the school have been turned off, and bottles of water continue to be distributed at the bubbler locations. In addition, bottled water is being used for all food preparation, including washing vegetables and fruits and cooking pasta. He added that cafeteria workers will make do with bottled water until the end of the school year, but if the school has to continue preparing food that way into the fall, it will have to reconsider food preparation until public water is restored.
Harvard’s trouble is different
Unlike Ayer and Devens, the number of Harvard’s water supplies that have been tested for PFAS is just a small sampling of those that exist near Devens. Because the area of Harvard north of Route 2 was within a mile of an old firefighting training area off Barnum Road, Army contractors tested 12 public and private wells in Harvard for PFAS in 2018; six tested positive for PFAS, but none were over the 70 ppt limit. The highest levels were found at Appleworks, 42 ppt, and the Bowers Brook/Dunkin Donuts complex, 27 ppt. One private well tested just over 20 ppt.
The Army did not test the public water supply at Harvard Plaza, even though it was within the one-mile testing radius of the Barnum Road PFAS contamination site. Harvard Plaza’s water supply is considered a “transient” supply, serving fewer than 25 of the same people every day, and water testing regulations for those types of water supplies are less strict. Likewise, most of the private wells along Ayer Road were not tested. Many of the smaller office buildings in the commercial zone have private wells, and MassDEP requires testing of private wells only when they are first installed. Employees, including pregnant women, may not realize the water they are drinking is not required to be tested regularly for any substance, let alone PFAS.
It’s up to local health boards to regulate the testing of private wells. Harvard’s Board of Health Chair, Libby Levison told the Press she will ask the Army to do further PFAS testing in Harvard. She said she has also spoken to the Select Board about inviting MassDEP to come to Harvard for a public forum.
Who’ll pay?
Paul Locke, MassDEP assistant commissioner of the Bureau of Waste Site Cleanup, told attendees at a Restoration Advisory Board meeting in Ayer on April 25 (see Drilling for PFAS) that MassDEP is considering mandating testing of all public water supplies in contaminated areas, and the state may pay for that testing.
Cleanup is another matter. The Army is paying for Ayer’s PFAS treatment plant at Grove Pond because one of the four wells there tested over EPA guidelines. But Ayer’s two Spectacle Pond wells, all three of Devens’ municipal wells, and Harvard’s two smaller public water supplies have levels of PFAS that exceed the proposed MassDEP guidelines, but do not exceed EPA guidelines. Kelsey Schiller, director of communications at MassDevelopment (which owns the Devens public water supply), told the Press the Army has not agreed to provide any funding for the PFAS treatment systems needed for Devens wells. She added that MassDevelopment will “continue to encourage the U.S. Army to consider contributing to this effort as part of our work redeveloping the former Fort Devens.”
When the Press asked Locke what might happen in Harvard, Locke said MassDEP would first try to determine who was responsible for the contamination. And if the responsible party is an agency that adheres to EPA guidelines instead of MassDEP’s? “It’s complicated,” Locke said.
Guidelines and MCLs
The Safe Drinking Water Act requires water quality tests for a variety of substances, and the EPA establishes a maximum contaminant level (MCL) for each of those substances. MassDEP adopts most of those MCLs, but it sometimes adopts stricter standards. When a maximum contaminant level is specified for a substance, MassDEP informs public water supplies how often they must test for the substance, and if tests show the level has been exceeded, water must be treated to bring the level below the maximum.
When a contaminant has no MCL, the EPA may issue a health advisory for that contaminant, and, similarly, MassDEP may issue a guideline from the Office of Research and Standards (ORSG). While, in general, Massachusetts public water supplies are not required to test for contaminants that only have guidelines, the state may ask specific water supplies to test for those contaminants, and if levels exceed that of the ORSG, it may require that actions be taken. Currently, PFAS has no maximum contaminant level, only state and federal guidelines. Here’s the history:
2016: EPA issued a lifetime health advisory for PFAS in drinking water. It recommended that over a person’s lifetime, daily consumption should not exceed 70 ppt daily of the sum of two PFAS chemicals, PFOA and PFOS.
June 2018: MassDEP added a PFAS guideline to its ORSG. It set the limit to 70 ppt for the sum of five PFAS chemicals: PFOA, PFOS, PFNA, PFHxS, and PFHpA. That is the level MassDEP considered safe for daily consumption by the most sensitive population, which includes pregnant women, nursing mothers, and infants.
January 2019: MassDep announced it was starting the process to develop a maximum contaminant level for PFAS in drinking water, but it did not state what that level might be.
April 2019: MassDEP announced it was drafting an amendment to the state’s hazardous waste cleanup regulations that would lower the PFAS standard for groundwater that is protected for current or future use as drinking water to 20 ppt for the sum of six specific PFAS compounds. Those include the five already in the ORSG, as well as PFDA.
April 2019: MassDEP announced it is convening its Health Effects Advisory Committee to consider revising the guideline for drinking water to 20 ppt for the same six compounds specified above.
April 2019: MassDEP announced it is aligning the recently proposed maximum contaminant level to the proposed groundwater and drinking water guidelines above; 20 ppt for the sum of PFOA, PFOS, PFNA, PFHxS, PFHpA, and PFDA.
Drilling for PFAS
At an April 25 meeting of the Restoration Advisory Board, responsible for keeping the public informed about the cleanup efforts at Fort Devens, representatives from the Army, MassDEP, and private contractors presented their latest PFAS testing status and results. Army contractors began testing the groundwater at Devens for PFAS in October 2018. Tests are being conducted in three sections of Devens: Section 1 is to the east, around Barnum Road; section 2 is a larger area that runs through the middle of Devens, lengthwise from Route 2A to about Patton Road; and section 3 is in northern Devens, across Route 2A.
Contractor Katy Thomas of Koman Government Solutions explained that drill rigs are being used to test groundwater vertically every 10 feet. In the Barnum Road area, where testing is nearly complete, three areas of contamination were found. Thomas said the section “had so much contamination, it was hard to find the edges.” But, the contractors now “have a good feel for the nature of PFAS in the ground and surface water” in section 1, and they are moving on to assessing groundwater flow from that section. So far, groundwater from all three contamination areas in section 1 is thought to flow into Cold Spring Brook, which flows along the boundary between Devens and northwest Harvard. Cold Spring empties into Bowers Brook, which flows north and empties into Grove Pond in Ayer.
In section 2, five contamination areas have been identified, including one at the Devens Fire Station, which was also a fire station when Fort Devens was operational. The highest PFAS level found at Devens so far, 4,000 ppt, was in this area. Thomas said the contamination likely came from firefighting foam stored at the station and used for training exercises there. Fire trucks were cleaned behind the station as well, she said, and any foam on the trucks would have run off toward Jackson Road. She added, “The contamination in this area is broader and deeper than originally anticipated.” Testing in section 3 has just begun, and no data is available yet.
As contractors continue to drill to try to find the disbursement patterns of PFAS at Devens, they use the guidelines recognized by the Environmental Protection Agency (EPA), not MassDEP, to determine where to continue testing or move on. The EPA continues to recognize 70 ppt as a safe level, and it includes only the sum of the two most commonly found PFAS compounds, PFOS and PFOA. Thomas said her company is working with MassDEP and the EPA to understand which levels to use, and it is considering using the state’s proposed groundwater standard of 20 ppt for the sum of six compounds if it is adopted. If that happens, Thomas said, further testing may need to be done in contamination areas already considered complete.
