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Private Well Testing and Results
Q: What is the process to get started with testing my well water, and what are the next steps?
A: If your home is in the identified study area, you should contact Jonathan Costello. at jcostello@lawson-weitzen.com, who will arrange for an access agreement to be sent to you. This will allow your water to be tested. If the water testing shows PFAS6 (the sum of the six regulated PFAS compounds) levels higher than 20 parts per trillion (“ppt”), the standard set by the Department of Environmental Protection in Massachusetts for six specific PFAS chemicals, a water treatment system will be installed at your house with no cost to you. Quarterly sampling will be performed for the first year, at a minimum, at which time the monitoring schedule will be evaluated by the Licensed Site Professional of Record for the site. If your sampling results have detectable levels of a PFAS but are less than 20 ppt PFAS6, then bottled water will be provided until it is demonstrated that PFAS6 concentrations are consistently below the drinking water standard of 20 ppt.
Q: What are the PFAS6 compounds?
A: Perfluorooctane Sulfonic Acid (PFOS)
Perfluorooctanoic Acid (PFOA)
Perfluorohexane Sulfonic Acid (PFHxS)
Perfluorononanoic Acid (PFNA)
Perfluoroheptanoic Acid (PFHpA)
Perfluorodecanoic Acid (PFDA)
Q: What can I expect before my well is tested?
A: We will contact you to schedule the work through Lessard Environmental. In order to conduct the sampling an agreement allowing Lessard Environmental to sample will be provided to you. The sampling should be in the house at the well pressure tank. We want to collect samples before the house piping and before any water treatment you might have, such as a water softener. We will need access to the area around the well pressure tank. We prefer to not move your belongings. If you are unable to clear the space, please let us know in advance so we can discuss options with you.
Q: What can I expect during testing?
A: We will schedule a window of time during which we expect to arrive. Arrival time is approximate and may be impacted by completion of prior sampling. Our field sampling staff are generally not intended to answer your questions. If you have questions, please contact Lessard Environmental at westminster@lessard-environmental.com. Sampling typically takes less than 20 minutes to complete
Q: What can I expect after testing?
A: The samples will be analyzed by an independent laboratory certified by the Commonwealth to conduct PFAS6 analysis. Laboratory turnaround time is typically 10 to 15 business days after the laboratory receives the samples (usually the day after sampling). Weekends and holidays are not business days. When we receive the results, we will contact you by telephone and/or email; you will also receive a mailed copy of the laboratory results. Depending on the results, we may recommend next steps. In order to get results to you in a timely fashion, please confirm your telephone number by emailing westminster@lessard-environmental.com with a copy to jcostello@lawson-weitzen.com. This is very important for us to be able to contact you with the results.
Q: I received the results of my water test. What level of PFAS6 does MassDEP consider to be acceptable?
A: MassDEP has established a drinking water standard of the sum of 20 ppt (parts per trillion) of each of the six specific PFAS chemicals (PFOS, PFOA, PFHxS, PFNA, PFHpA, and PFDA) individually and combined
Q: I heard that the acceptable level is 70 ppt, is that true?
A: Environmental Protection Agency (EPA) formerly set 70 ppt as a Health Advisory Level (HAL) for two specific PFAS – perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). An HAL is a concentration of a drinking water contaminant at which adverse health effects are not anticipated to occur over a specific exposure duration. EPA has recently changed these HALs, however, and 70 ppt is no longer applicable and has set a much lower level. The EPA’s HALs are not enforceable drinking water standards. Therefore, Massachusetts has established its own drinking water standard. MassDEP has determined that 20 ppt is an acceptable level of a combination of PFAS6 in drinking water Drinking water health advisories provide information on contaminants that can cause human health effects and are known or anticipated to occur in drinking water. EPA’s health advisories are non-enforceable and non-regulatory and provide technical information to states agencies and other public health officials on health effects, analytical methods, and treatment technologies associated with drinking water contamination. EPA’s lifetime health advisories identify levels to protect all people, including sensitive populations and life stages, from adverse health effects resulting from exposure throughout their lives to these PFAS in drinking water. At this time, MassDEP is working to review the new EPA Interim Health Advisories and will determine next steps based upon that review. For more information about EPA Health Advisories for PFAS see Drinking Water Health Advisories for PFAS Fact Sheet for Communities and Questions and Answers: Drinking Water Health Advisories for PFOA, PFOS, GenX, PFBS FAQs.
Q: Is there any amount of water which is acceptable to drink if I know that water contains PFAS6 and its level is below 20 ppt?
A: MassDEP has determined that drinking water below the standard of 20 ppt does not present an unacceptable risk even to sensitive populations such as pregnant women, nursing mothers, infants, or immune-compromised people.
Q: Some standards talk about ppt (parts per trillion) and some use ng/l. What is the difference between ppt and ng/l? What is the right standard? How can I convert ng/l into ppt?
A: These are the same for drinking water samples. Ng/l stands for nanograms per liter, which is equivalent to parts per trillion.
Q: Why do different water tests show different results? What is the reason for a discrepancy? For instance, testing conducted by Lessard Environmental showed lower levels of PFAS6 than the testing I did on my own.
A: Variation between samples is expected and even duplicate samples collected at the same time and place can be different because of limitations of the laboratory testing of these very low concentrations. Also, groundwater concentrations vary over time based on a number of factors (groundwater flow velocity, well depth, etc.). Further, Lessard Environmental and Tighe & Bond sample at very specific locations within the home’s water distribution system with strict protocols, acceptable to MassDEP, which may not be duplicated by other companies. Sample location matters because pipe sealants and other sources in your house piping can add PFAS6 to the water beyond any present in the groundwater. General plumbing work makes ample use of Teflon tape and pipe sealants which can impact PFAS6 concentrations. POET installations minimize use of these materials to applications where there are not readily available alternatives.
Q: What is the timeline for completing the drinking water evaluation of the Study Area?
A: The actual timeline depends on Westminster residents signing Access Agreements and granting access to Lessard Environmental (and Tighe & Bond) to perform the water tests. This is an ongoing, dynamic process. As more data become available the extent of the study area continues to change. This is done according to the Immediate Response Action Plan approved by MassDEP. If PFAS6 are detected in drinking water wells the sampling area will be expanded according to the IRA Plan. Weekly updates containing all the sampling data are submitted to MassDEP. The updates and IRA Plan are available online at https://eeaonline.eea.state.ma.us/EEA/fileviewer/Rtn.aspx?rtn=2-0021866; from the online document repository prepared by Lessard Environment, Inc. at: https://www.dropbox.com/sh/3evye9ec9gjaghv/AAAc8OMg4L3-CnfNJq317Wjsa?dl=0; and are available at the Forbush Memorial Library in Westminster. The updates provide information about which homes have been sampled, when sampling results are expected, and maps and tables showing the concentrations and distribution of PFAS in the area.
Q: Are expedited results accurate?
A: Yes. The laboratory has to follow the same quality control procedures for each and every sample and the process by which the test is done is the same whether the samples are expedited or not.
Q: Is the stream or pond being mitigated?
A: The Site is currently being managed under the Immediate Response Action provisions of the state cleanup regulations. At this time, the Licensed Site Professional is focused on identifying PFAS exposures through drinking water. When the extent of those exposures has been identified and mitigated through installation of water treatment systems, MassDEP has requested a plan for sampling and mitigation of the portion of surface water impacts potentially attributable to MNF be submitted for their review in the Fall of 2022
Swimming and Bathing
Q: My water was tested and the test came back with a result that is higher than 20 ppt, is it safe to take a shower? Is it safe for kids to bathe?
A: According to MassDPH PFAS concentrations of concern for bathing or showering are age dependent:
- Young children (0-6 years): > 500 ng/L
- Older children (7-20 years): > 1,300 ng/L
- Adults (21+): > 3,500 ng/L
Q: Does swimming in a surface water body (like a lake or pond) present a health concern if that water contains PFAS?
A: According to MassDPH, although typical contact with the water while occasionally swimming should not be a health concern, it is important, to avoid, as much as possible, accidentally swallowing water. If you have young children, you should monitor them while they’re in the water to limit the amount of water they swallow. If your skin has cuts, abrasions, or open wounds, you should limit time in the water and wear rubber gloves when washing dishes. See DPH PFAS and Swimming FAQ, here. Further, MassDPH addressed this issue at the June 8, 2022 hearing, linked here.
Q: Does use of our swimming pools present a health concern
A: According to MassDPH, although typical contact with the water while occasionally swimming should not be a health concern, it is important, to avoid, as much as possible, accidentally swallowing water. If you have young children, you should monitor them while they’re in the water to limit the amount of water they swallow. If your skin has cuts, abrasions, or open wounds, you should limit time in the water and wear rubber gloves when washing dishes.
See DPH PFAS and Swimming FAQ, here
Q: If PFAS 6 concentrations in our pool is high, can we pump out the pool and re-fill it with clean water?
A: Under MassDEP’s cleanup regulations, the Potentially Responsible Parties must eliminate, prevent or mitigate private drinking water well contamination. MassDEP has emphasized to the LSP for the site that identifying and mitigating drinking water exposures is the top priority to address. However, although not an exposure priority, MassDEP has discussed alternatives to address pool water contamination. Uncontrolled draining of thousands of gallons of water could spread contamination to create a larger disposal site. Removal and disposal of pool water may be an alternative, but could be very expensive. The LSP and MassDEP have briefly discussed constructing a portable treatment system that moves from pool to pool, but currently are focused on providing clean drinking water to all residents. Residents are not under supervision by Lessard Environmental or Tighe & Bond and should make their own choices. That said, discharge of potentially thousands of gallons of contaminated water to the ground or to a drain is not desirable as it could impact local groundwater conditions and could exacerbate contamination issues. Discharge of contaminated water could meet MassDEP’s definition of a new release condition and expose one to scrutiny and even responsibility for any resultant impacts
Q: What can be done to reduce PFAS 6 concentrations in pools?
A: Little currently because of MassDEP’s requirement that efforts not stray from private well sampling and, if necessary, treatment. From a technical perspective, we would expect that treatment with granular activated carbon could be used to reduce, but likely not eliminate, PFAS 6 in swimming pools. Assessment and, potentially, treatment of swimming pools is a topic for the future.
Bottled Water
Q: What are the criteria for receiving bottled water?
A: According to the MassDEP, we are required to provide bottled water only after we have conducted testing and shown detectable concentrations of any PFAS. As a proactive measure, however, given the time required to sample and receive results and the lead time for water deliveries to start, we are voluntarily initiating bottled water deliveries at locations we will be sampling. If you have questions about receiving bottled water, please contact Louise at Lessard Environmental by email at westminster@lessard-environmental.com
Q: What are the criteria for ending supply of bottled water?
A: If your sampling results have detectable levels of a PFAS, but are less than 20 ppt PFAS6, then bottled water will be provided until it is demonstrated that PFAS6 concentrations are consistently below the drinking water standard of 20 ppt with a future evaluation by the LSP and in consultation with MassDEP.
Q: How do we re-order water?
A: Deliveries are automatic, and are scheduled to occur every two weeks. There is no need to re-order. If you run out of water prior to the next delivery, there is a limited amount of additional water available at the offices of Massachusetts Natural Fertilizer.
Point of Entry Treatment Systems (“POETs”) Generic POET diagram is provided here
Q: What does the POET system do?
A: The POET system is designed to remove PFAS from your water by granulated activated carbon filtration.
Q: What can I expect before installation?
A: Lessard Environmental will contact you to schedule the work. This may include a pre-installation inspection and the installation date itself. If a pre-installation inspection is conducted it will usually be completed in about 20 minutes. Lessard Environmental, or its contractor, will need access to the area around the well pressure tank. If you are unable to clear the space, please let Lessard Environmental know in advance so we can discuss options with you.
Q: What can I expect during installation?
A: We will schedule a window of time during which we expect our Subcontractor to arrive. Arrival time is approximate and may be impacted by completion of prior work or availability of materials.
- Installations typically take 2-4 hours if there are no complications.
- The installation will include: a pre-filter, two carbon filters, a post-system sediment filter, an ultraviolet disinfection unit, and various connecting parts and sample ports.
- The carbon vessels are delivered to us either in a ‘natural’ color that is tan to yellow and shows the fiberglass reinforcement on the outside of the tank or in a painted configuration (usually blue or black). The carbon vessels are the same internally but may be different colors on the exterior.
- During installation, there will be periods of time when the water supply to the house is off. We will try to minimize these periods.
- Equipment will be installed immediately after the well pressure tank. Normally, installation is before any treatment you might have, such as a water softener.
- The POET system includes an ultraviolet disinfection device that requires power through a normal electrical outlet. If you do not have an outlet near the POET system, an extension cord will be used temporarily to supply power. Our Subcontractor would return on another day to install an appropriate outlet for the system and the extension cord would be removed. If needed, this work is at our cost.
- The granular activated carbon is dry at the time of system installation. Our Subcontractor will purge water through the system. Initially, there will be some carbon dust in the water. This will abate after sufficient water has passed the system.
Q: What can I expect after installation?
A: You should continue use of bottled water until we have sampling data that shows the POET is working as intended. Continue use of bottled water until we indicate you can use the treated water.
- For a short period after installation, carbon dust may discolor the water. Passing water through the system abates this.
- We will sample the system for the first time two to three weeks after installation, then monthly for three months and quarterly thereafter. We will schedule this sampling with you.
- Over time, the filters will eventually need to be replaced. The sediment filter will likely be replaced much more frequently than the carbon vessels. Our sampling and field observations will determine when filters should be changed. The ultraviolet unit also requires occasional cleaning and bulb replacement.
- You are not responsible for any of the system maintenance.
Q: Any other things I should be aware of with respect to POET systems?
A: Please notify Lessard Environmental of any of the following:
- Subcontractor not arriving during the scheduled arrival window.
- Any drips or leaks.
- A substantial drop in water pressure. This may indicate need to change the sediment filter or one of the other filters.
- Discoloration of the water other than the black/grey carbon dust that may be present immediately after installation.
- Any concerns you have regarding the POET system.
Q: Is there any priority for water testing and/or installation of the Point of Entry Water Treatment (POET) Systems?
A: Massachusetts Department of Environmental Protection (MassDEP) has stated that priority should be given to residents whose wells have higher levels of PFAS relative to other houses, and to residents with active pregnancy, infants and young children.
Cost Reimbursement
Q: Will people at impacted properties be reimbursed for the cost of blood work?
A: at this time, there will be no reimbursement for this cost. Please see the Massachusetts Department of Public Health’s website
Q: Will there be reimbursement for private well sampling done by residents?
A: No; at this time, there will be no reimbursement for private well testing. There are legal issues related to chain of custody of samples, and most importantly, methodology (how the samples were taken) for the sampling. Lessard Environmental (or Tighe & Bond) will handle all well testing.
Public Water Supply
Q: Where do we stand in the process of extending the town water line to the study area?
A: The PRPs will be responsible for funding the permanent remedial measure, which we assume will be an extension of the waterline from Fitchburg. For that to happen, the Town needs to work with the City of Fitchburg to determine whether the Intermunicipal agreement they already have will need to be revised. When the extent of the contamination has been defined, MassDEP, Westminster DPW, and Fitchburg DPW will work with a contractor paid by the PRPs who will design and construct the waterline extension. Until the waterline is completed, all homes with detections of PFAS exceeding the drinking water standard of 20 parts per trillion (ppt) will have POET systems installed and maintained by the PRPs so no one will be drinking untreated water. The Potentially Responsible Parties (PRPs) will need to evaluate the feasibility of installing a POET system or connecting to public water for home wells with detections below the drinking water standard of 20 ppt before reaching a Permanent Solution.
Q: How will the cost of connecting to a public water supply be paid?
A: Specific questions concerning connecting to public water supplies are premature, in that this is one preliminary option being examined with respect to a long term solution. You will be provided with more information as soon as it becomes available.
Massachusetts Natural Fertilizer
Q: What environmental permits does Massachusetts Natural Fertilizer (“MNF”) hold with the State and Town?
A: On October 5, 2020, MassDEP issued a “Final Approval Recycling, Composting, or Conversion (RCC) Operation BWP SW46,” Authorization Number 0000053 to Massachusetts Natural Fertilizer Company, Inc., with an effective date of October 27, 2020. The permit remains in effect until October 27. 2025; however, on July 20, 2022, MassDEP suspended the permit effective immediately. MassDEP also directed MNF to cease composting operations at the facility.
Q: Was MNF ever operating under an expired permit, without a permit or under the general regulation 310 CMR. 16.00 and 310 CMR 19.000?
A: In 1987, the Westminster Board of Health issued a Site Assignment authorizing composting of agricultural by-products and paper fiber waste at the facility. MassDEP issued a permit authorizing the composting operation at the same time. In 2020, MassDEP issued the Recycling, Composting or Conversion (RCC) permit, which expires on October 27, 2025. There was no time during which the facility operated without a permit from MassDEP since 1987.
Gardening
Q: Do PFAS affect my home-grown produce? Can I predict PFAS levels in produce based on concentrations in water or soil?
A: According to MassDPH, although PFAS do not stick to soil very well, gardens watered with PFAS-contaminated water may have somewhat higher levels of PFAS in the soil. If possible, use an alternative source of water and add clean compost to your garden to lower the amount of PFAS in your garden. According to MassDPH and statements made by MassDPH at a public hearing on June 8, 2022, while the available data indicates that most plants are not expected to have detectable levels of PFAS in the parts of the plant that people eat, it is possible for plants to take up some PFAS from soil and water. The amount of PFAS in the plant and where the PFAS would be distributed (e.g. stem, leaves, flower, fruit) is hard to predict. In addition to PFAS levels in water and soil, the amount of PFAS in home-grown plants depends on other factors, such as the type of plant and nutrient levels in soil
Q: What are the best practices for growing produce if my water may contain PFAS?
A: According to MassDPH, to reduce any potential exposure to PFAS in home-grown produce, you can:
- Water seedlings and gardens with an alternative source of water, such as water collected in a rain barrel, if possible.
- Add clean compost to the soil. This will reduce levels of PFAS in the soil, and thus reduce the chance of plants absorbing PFAS.
- Wash all fruits, vegetables, and herbs in clean water before eating. You may also choose to peel root vegetables before eating.
- Use a raised bed filled with clean soil.
Blood Tests
Q: Should I test my blood if I was exposed to PFAS? What is considered a high level in blood tests and when should people worry? How long does it take to lower levels of PFAS in blood, once exposed?
A: According to MassDPH, Blood tests for PFS are not recommended. The Agency for Toxic Substances and Disease Registry (ATSDR) states that blood tests will most likely show that you have PFAS in your blood. This is because nearly all Americans have PFAS in their blood due to the widespread use of these compounds for commercial and industrial purposes. If you do test your blood for PFAS, the results would be difficult to interpret with respect to whether you would experience health effects. If PFAS levels in blood are higher than in the general population, PFAS levels will start to decrease as soon as a person eliminates major sources of exposure to PFAS. Depending on the specific PFAS, and how high PFAS levels are, it can take many years for PFAS levels in blood to decrease to levels observed in the general population.
Q: Are there steps I can take to lower the PFAS level in my blood?
A: You should consult with MassDPH and/or your personal health care proessional regarding this question.