Scientists, regulators, and the general public know very little about the locations of historic and ongoing PFAS production and use. There is also a critical lack of environmental monitoring. When data exists, it may not be available to the public or may obscure key details like specific location of the sample.
Sierra Club’s Grassroots PFAS team and supporters have strategically employed community-based monitoring to daylight the impacts of PFAS in a variety of locations and industries. Team members review available information about PFAS sources in a region to develop targeted testing plans. We use this information to boost place-based advocacy and reveal broad gaps in policies to protect people and the environment from harm.
Here are six cases where community monitoring identified major gaps in federal and state responses to the PFAS crisis.
· Merrimack, New Hampshire - Industrial point sources discharge PFAS to rivers
The community of Merrimack has been a national hotspot of PFAS contamination due to industrial activities of Saint Gobain Performance Plastics. Elevated measurements of PFAS have previously been reported in the Merrimack River,1 which is a water source for many downriver communities. Our sampling used low-cost Cyclopure2 monitoring kits and identified measurable concentrations of 7 PFAS chemicals in surface water downriver from Saint Gobain. We located wastewater pipes draining into the Merrimack River about one mile down from SGPP, with high levels of total PFAS in samples collected in two separate time periods (86 and 92 ppt). The pipe samples were predominantly PFOA (64.6 and 72.7 ppt. A sample of foam collecting on the river surface near the drain sites had high levels of PFOS (total PFAS 97 ppt, with PFOS 55.8 ppt).
National Implications - many industries continue to discharge PFAS-contaminated water into sewers and surface water. The origin of PFAS in these drainpipes must be identified and controlled to protect water quality.
· Steuben County, New York - Land application of sewage sludge threatens local water quality
Residents of Bath, Cameron, Thurston and Painted Post New York are concerned that the long-running practice of applying processed sewage sludge to local agricultural fields is posing a threat to community wells and waterways. They measured PFAS in 83 samples of well and surface water using both Cyclopure test kits and standard GC/MS/MS methods. PFAS are markedly higher in both wells and surface water samples near farms with land spreading. The average concentrations in wells near land spreading exceed >15 ppt PFAS compared to <2 ppt in wells collected in areas with no land spreading.3
Implications - More than half of all treated sewage waste is applied to agricultural fields for beneficial reuse. This practice could recycle PFAS from wastewater into food crops and contaminate local water sources.
· Northeastern Tennessee - PFAS enter surface water through disbursed sources
Sierra Club collected 18 water samples of surface water and 2 drinking water samples in the Northeastern corner of the state, using Cyclopure test kits.4 The tests document contamination of streams and reservoirs, with PFAS detected in 60 percent of surface water samples. While there were no detectable PFAS in the upper reaches of the watershed, tests indicate the sum of 8 identifiable PFAS chemicals in surface water sample ranged from 5.6 to 14.4 ppt throughout the inhabited regions. Higher levels below wastewater treatment outflows, near sewage biosolids application sites, and downstream from the Holston Army Ammunition Depot. PFOS levels in four surface water samples exceed EPA's proposed drinking water limit of 4 ppt. Similar levels of PFOS were measured in one sample of drinking water drawn from the river.
Implication - PFAS are ubiquitous in American surface water, which will pose a challenge for drinking water sources that will soon be required to meet stringent new legal limits for 6 PFAS chemicals. Source water protection is vital.
· Rockton, Illinois - The ongoing use of PFAS use in firefighting threatens surface water
In 2021, firefighters used 3,200 gallons of PFAS-based AFFF to extinguish a major industrial fire at Lubrizol’s Chemtool facility in Rockton IL. Sierra Club monitoring measured 78 to 87 ppt PFAS in the nearby Rock River, and another 75-100 ppt of unidentifiable PFAS "precursor" chemicals as quantified by the TOP Assay.5 Illinois EPA's samples of effluent from the Rockton sewage treatment plant contained nearly 6000 ppt PFAS, primarily 6:2FTSA, as wastewater was discharged into Rock River.
Implications - 15 states have banned sales of PFAS-based foams, and 16 states have initiated a Take Back programs. In most of the country, remaining stockpiles of PFAS-based AFFF pose a risk to water quality.
· National retail stores - Sewage-sludge based home fertilizers contain PFAS
In 2021 Sierra Club and Ecology Center analyzed 20 brand name home fertilizers made from processed sewage sludge.6 Concentrations of 25 PFAS chemicals ranged from 38 to 233 parts per billion (ppb) in samples. In 8 samples, levels of two specific PFAS, PFOS and PFOA, exceeded screening levels in the state of Maine for biosolids used on agricultural lands. The samples also contained 2- to 8-times more PFAS precursor chemicals as identified with the Total Organic Precursor Assay. Also, concentrations of Total Organic Fluorine were ~1000 times greater than identifiable PFAS (13,000-321,0000 ppb).
Implication - Sludge-based fertilizers pose a risk of contaminating food crops and nearby water supplies. They do not clearly identify the sewage residuals that make up the fertilizer, nor the likely presence of PFAS and other persistent contaminants in the product.
· Wigwam, Colorado, Military contamination extends beyond presently identified sites
In 2018 Liz Rosenbaum moved from Fountain Colorado to nearby Wigwam to get away from the PFAS contamination plume at Fort Peterson Air Force Base. However, water sampling by NRDC and Sierra Club in 2021 & 2022 confirmed PFAS was also in Wigwam drinking water. In Sierra Club tests concentrations of 12 PFAS ranged from 74 to 81 ppt, exceeding EPA’s new legal limit for PFOS and PFOA. While three nearby water systems have been removing PFAS since 2016, Wigwam managers were testing for PFAS but hadn't alerted the community.
Implications - PFAS could threaten other community water supplies outside of known military contamination zones. The state of Colorado is now using its "PFAS Fund" to pay for pitcher filters and a consultant to help Wigwam figure out how to meet EPA's legal limits for PFOS and PFOA. Many communities with military-related water contamination have not received transparency about contamination measured in wells and public drinking water supplies. Many water systems have not been fully compensated for costs associated with removing PFAS chemicals. New locations will be called into question once EPA’s drinking water limits come into effect.
Conclusion - Action needed to identify and control PFAS pollution
We encourage more community-based monitoring to bring visibility to local pollution hotspots and prompt more rigorous assessment of contamination. Monitoring studies should use modern methods with low detection limits. All data must be made available to the public.
The pollution “lessons” identified by Sierra Club’s community monitoring are not unique to the places we sampled. Rather they suggest that similar dynamics exist across the country. Stronger rules are needed to force industries to disclose its use and emissions of PFAS. Government agencies must control emissions from industrial sources and ensure secure disposal of PFAS wastes.
References:
1. Golder Associates Inc. 2019. Report on 2018 Stormwater and Surface Water Activities Volume I - Text, Tables, Figures. WSP USA Inc. 2023. 2022 Stormwater and Surface Water Monitoring Report.
2. Cyclopure. Water Test Kit PFAS. https://cyclopure.com/product/water-test-kit-pro/
3. Sierra Club Atlantic Chapter. 2023. Thurston Water Testing for PFAS. Full 2023 Results. https://waterfrontonline.blog/wp-content/uploads/2023/12/thurstontestresultsdec20.pdf
4. Sierra Club Tennessee. 2023. Toxic PFAS chemicals contaminate lakes and rivers of Northeastern Tennessee. https://www.sierraclub.org/tennessee/pfas-contamination
5. Sierra Club. 2021. It’s time to ban PFAS in Firefighting. https://www.sierraclub.org/articles/2021/08/its-time-end-use-pfas-firefighting
6. Sierra Club. 2021. Sludge in the Garden. https://sc.org/pfas-sludge
Authors: Sierra Club Grassroots PFAS team: Stephen Colby Brown, Doris Cellarius, Dan Firth, Tracy Frisch, Amy Kyle, Sonya Lunder, and Denise Trabbic-Pointer
Water Sampling contributors
Field samplers: Emily Gant, Sagarika Maitra, Summya Katoon, & Wendy Heiger-Bernays (NH), Liz Rosenbaum (CO), Dan Firth (TN), Steven Hall (IL), Elizabeth Donderewicz & Bill Mattingly (NY)
Collaborating organizations: Laurene Allen - Merrimack Citizens for Clean Water, Jeff Gearhart and Gillian Miller - Ecology Center Michigan, Liz Rosenbaum - Fountain Valley Clean Water Coalition