On Saturday, March 16, at the East Madison Community Center, Madison Water Utility (WU) and Public Health Madison Dane County (PHMDC) staff gave presentations about the per- and polyfluoroalkyl substances (called PFAS) found in municipal drinking water Well 15 in Reindahl Park. Robert Thiboldeaux from the Wisconsin Department of Health Services was there to answer questions.
Watch the first part of the meeting here (presentations, some Q & A) and the rest here (all Q & A).[1]
The core messages officials shared at the meeting? PFAS levels in Well 15 are “low” and the water is perfectly safe—nothing to worry about. However, the well was recently shut down—according to officials, as a “precaution”—but will be turned on again this summer after DHS announces PFAS interim health standards they expect will deem the water safe.[2],[3]
On February 26, in response to citizens’ recommendations, the Water Utility Board approved ongoing testing at Well 15 for 30 PFAS compounds. But in a private meeting a few days later, Madison Mayor Paul Soglin and city staff decided to shut the well down, rendering the board’s decision moot.
Now, according to Water Utility staff, no further PFAS testing will be done before Well 15 is turned back on, since testing cannot be done while the well is off.
PFAS are from the Truax Air National Guard base about one mile to the northwest of the well, which uses fire-fighting foams with the compounds. Very high levels of PFAS were found in soils and groundwater at the base in limited preliminary testing done in November 2017.
Key omissions, convoluted answers
Officials’ presentations listed serious health problems associated with PFAS exposures, but they repeatedly assured the audience that the total levels of two PFAS compounds in Well 15 (PFOA and PFOS) are far below the EPA’s 70 parts per trillion (ppt) “health advisory” level, so there is no reason for concern.
Meeting attendees asked many good questions, but answers were often less than satisfactory. “How did the EPA come up with its 70 ppt health advisory level?” one person asked. After attempting a convoluted answer, PHMDC epidemiologist Jeff Lafferty explained that he “didn’t want to get into the weeds, it’s very complicated,” and finally advised the questioner, “you can look at the EPA report on that if you want to learn more about it.”
Alder David Ahrens asked about PFAS exposures to formula-fed infants. Lafferty told him there is nothing to be concerned about. “Because of the levels in the well…are well below [the EPA’s 70 ppt],” he said, “I wouldn’t have any cautionary advice to give…the water is fine.” However, he added, “ if a person wanted to take more precautions, that’s up to the parent, they could make the best decision they wanted to make…”
Rob Thiboldeaux stepped in at this point, emphasizing “safety factors” used in developing health advisory levels that add “layers of protection” for all vulnerable members of the population.
However, some other state agencies have concluded that EPA’s 70 ppt standard isn’t adequate to protect all vulnerable populations. Vermont’s current standard of 20 ppt for five PFAS compounds combined was developed with infants as the target sensitive population. In Well 15, the total for these five PFAS compounds combined was 34 ppt in recent tests, significantly exceeding Vermont’s standard.
After developing the 20 ppt standard, Vermont public health officials issued this advice:
“If your water has been tested and the total sum of the five PFAS is more than 20 ppt, we recommend not using your water for drinking, food preparation, cooking, brushing teeth, preparing baby formula, or any other manner of ingestion. Use bottled water instead or water from a known safe source. Do not use water containing the five PFAS over 20 ppt to water your garden. The PFAS could be taken up by the vegetables.”
According to PHMDC’s own documents, Vermont scientists used the same toxicity studies, safety factors, and assumptions as EPA in calculating this level, with only one key difference: they considered higher water ingestion rates for infants (also from EPA’s water ingestion tables). Infants, especially formula-fed infants, drink a lot more water per their body weight than other groups.
Several other state agencies, experts, and legislators have also proposed PFAS standards lower than EPA’s–see footnote [4]
Assessing one or two PFAS compounds at a time does not protect public health
Public officials also skimmed over the fact that EPA’s health advisory and DHS’s forthcoming interim health advisory are for only two of the 10 PFAS compounds found in Well 15. So these standards don’t really address whether or not Well 15 water is “safe,” especially for infants.
Many organizations and scientific experts have argued that assessing one or two PFAS at a time doesn’t adequately protect public health and causes delays of decades in developing standards. In her testimony before a Senate Committee and Subcommittee on Sept. 26, 2018, Dr. Linda Birnbaum (Director of the National Institute of Environmental Health Sciences and National Toxicology Program of the National Institutes of Health) stated that “Approaching PFAS as a class for assessing exposure and biological impact is the best way to protect public health.” Here in Wisconsin, in August 2018 Citizens for Safe Water Around Badger (CSWAB) petitioned the DHS to develop a summed-total PFAS standard. In November 2018, Wisconsin’s Senator Hansen wrote a letter to DNR and DHS to develop such a standard as well. [5]
Where’s DNR? Air National Guard? Dane County?
“Why isn’t the DNR making the Air National Guard clean up the site?” an audience member asked after the presentations. The Water Utility facilitator turned awkwardly to WU and PHMDC officials. “We don’t have anyone from the DNR here,” she said, “so it’s just speculation, right?” Government officials laughed nervously.
Doug Voegeli from PHMDC took the microphone. “I can say that the DNR is working with the Guard and cleaning up,” he said. He noted that the city, county and federal government all owned the lands at various points, so “it’s a matter of getting everybody moving in the same way. Of course, the bottom line will be, if there’s money available.”
In fact, as explained in a recent article in the Wisconsin State Journal, the Air National Guard is nowhere near initiating a PFAS cleanup at the site, and has barely begun investigating the PFAS contamination there and at adjacent burn pits, owned by Dane County. See a longer history of the burn pit contamination here.
Why is Air National Guard not engaging the community on PFAS, as required by federal laws? Why is DNR not asking them to do so, which they have the regulatory authority to do? Where is Dane County, owner of nearly all the land under the Truax ANG base and the two burn pits?
See Part 2 (coming soon): DNR and ANG’s long history of ignoring community engagement
[1] There is a short time gap between the two videos during the time DHS toxicologist Rob Thiboldeaux stepped in to answer a question. Another tape captured most of Thiboldeaux’s comments during the gap: “…calculation of the recommended groundwater standard…in terms of what we’re doing right now, DNR has provided us with a list of 27 chemicals. Some of these chemicals are pesticides, some are solvents…two of them are the chemicals we’re talking about today, PFOA and PFOS. This is a long process and we plan to have it done by the middle of the year.
[2] Meanwhile, people in the Well 15 area are getting water from other wells, primarily Well 11 and Well 29–and also at times Well 8 and other wells. Several of these wells have concerning levels of PCE, TCE, 1, 4-dioxane and/or metals—and unknown levels of PFAS.
[3] DHS standards will be for just two of the ten PFAS compounds found in Well 15.
[4] The Agency for Toxic Substances and Disease Registry (ATSDR) draft report released in June 2018 (and the agency’s November update) suggests limits of 14 ppt for PFOS and 21 ppt for PFOA to protect children. Several states have developed lower standards and more are in the process of doing so. The New Jersey Department of Environmental Protection recently proposed interim groundwater criteria of 10 ppt for PFOS and 10 ppt for PFOA.
Legislators in other states have proposed standards of as low as 5 ppt each for one or both compounds, and Boston University and Harvard scientists have proposed a 1 ppt PFOS limit based on their findings of immune system effects in children that affect their responses to vaccines—see here and here. A Natural Resources Defense Council (NRDC) analysis of the ATSDR recommendations proposed levels as low as 3 ppt and 1 ppt for PFOS to prevent immune system effects.
[5] In response to a comment about EPA’s standard only addressing two compounds, Thiboldeaux mentioned “a petition” to consider a summed-total of 26 PFAS compounds that DNR had accepted and that would be considered the next round of standards development by DNR and DHS (this was CSWAB’s petition, but he did not name the group). This is great–kudos to CSWAB for this victory! Unfortunately, if DNR and DHS approve a class-based approach, it will be a long time before these standards are promulgated.
