November 1, 2017
Emerging Water Quality Issues
Over the past several years, Indeglia Environmental Science and Engineering, PLLC has been working with Federal, State, and local governments as well as water utilities and community groups on a number of emerging water quality issues. Perhaps the most visible is the contamination of ground water with substances called perfluorochemicals (PFCs), with the two most common being perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS).
Never heard of PFCs? This is not surprising as many of the household items that we have used throughout our lifetimes contain or are synthesized using some obscure chemicals. PFOA is used in the production of another chemical, polytetrafluoroethylene (PTFE), better known by its brand name, Teflon®. PTFE does not contain notable amounts of PFOA; however, PFOA is released in air emissions during the synthesis of PTFE. PFOS is used in numerous applications including fire-fighting foams and as a fabric protector…think ScotchgardTM. Upwards of 8,000 tons of PFOA and other PFCs, or perfluorochemicals, have been produced since their invention after World War II.
Why is this an issue? PFCs are just about everywhere. Don’t believe me? Pinch yourself. Go ahead. You have just touched tissue containing PFCs. The average blood serum level of humans in the United States are about 4 ng/mL (nanograms per milliliter) for PFOA and 21 ng/mL for PFOS (2010 data). Residents of a community near an industrial facility that used PFOA had an average blood serum level of 82 ng/mL (2005 data) with workers at a PFOA production facility displaying an average blood serum level of 240 ng/mL (2004 data).
Is that a lot, you might ask? It depends on how you want to define “a lot”? 1 ng/mL, or part per trillion (ppt) is about a drop in a swimming pool, so it could be considered “not a lot” at all until you consider that your body does not metabolize (break-down) PFCs and that rats delivered doses of PFOA as low as 1 ng/mL in their drinking water have developed tumors in their pancreas, liver, and reproductive organs. (We do not test on human subjects so we use rodents, which have shown to demonstrate the greatest similarity of all non-primate mammals in terms of toxicological response.) Other documented toxicological responses from PFCs include reduced birth weight and still-births in mice, decreased immune responses (B-cells and T-cells), adverse impacts to the thymus, hypothalamus, pituitary, and thyroid glands, which produce hormones.
It is easier to list the states in the continental US that do not have issues with groundwater contaminated with PFOA (there are only ten of them) and those exclusions may result from a lack of data. New Hampshire recently discovered numerous communities contaminated with PFCs; private and community water systems were found to contain PFOA emitted from a nearby manufacturing facility that produced roofing material for AT&T Stadium (home of the Dallas Cowboys), Denver International Airport, and The Louvre in Paris. A public water supply in a coastal community was impacted by PFOS from a recently closed military facility where training used extensive amounts of fire-retardant foam. PFCs also have been found in some of the remotest places on Earth including polar bears in Greenland and school children in the Faroe Islands.
While numerous peer-review toxicological studies have indicated that there are links between these chemicals and biological impacts such as cancer, the EPA has not taken the steps to indicate that PFCs are cancer-causing agents, thus enabling them to be largely unregulated by the Federal government. It is not all bad news, though. The United States Environmental Protection Agency (EPA) required the monitoring of PFCs in public drinking water supplies (PWS) since 2012, although evidence indicates that not all PWS were adhering to this requirement or were even aware of it and that the EPA was not enforcing it. In 2016, the EPA issued a drinking water advisory indicating a level of concern of 70 ppt. Several states have taken action to bring attention to the issue of the potential health problems association with PFCs. For example, California recently provided public notices listing PFOA and PFOS as a known cause of reproductive toxicity and New Jersey has set a maximum allowable level of 14 ppt for PFOA.
PFCs are just one class of chemicals in industrial use worldwide, although some manufacturers in the United States have ceased its domestic production. There are more than seven million chemicals known to exist with about 80,000 commonly employed (1994 data – so both of these numbers are likely much larger); the EPA receives between 2,000 and 2,500 new chemical requests (or pre-manufacturing notices, PMNs) annually (2016 data), but the legislative requirement is that the EPA must review 20 high-priority substances at a time, according to the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Public Law No: 114-182) and each of those reviews have seven years in which to be completed. The first peer-review publication on the toxicity of PFCs that I found was in 2002; I was personally told by contacts at National Risk Management Laboratory at the EPA to get rid of all my Teflon® products in 2007. It has been 15 and 10 years respectively since both of those events and PFOA has yet to be regulated…so maybe it is all bad news.