The Wisconsin Department of Natural Resources has taken the first step in establishing standards for currently unregulated contaminants that threaten the state’s groundwater – the source of drinking water for two-thirds of people living in Wisconsin.
The Department’s March 2 letter asks the Wisconsin Division of Public Health to recommend state health-based groundwater quality standards for 16 substances including PFOA and PFOS – compounds that are used in a number of products, most notably firefighting foams.
To date, the highest levels of PFOA and PFOS in groundwater in Wisconsin have been detected at the Tyco-Ansul Fire Technology Center in Marinette. Reported total concentrations are as high as 202 µg/l (micrograms per liter) – 2,800 times higher than the EPA’s Health Advisory Level of only 0.07 µg/l for the compounds combined. The drinking water wells of dozens of nearby families have also tested positive for contamination.
According to the EPA, exposure to these compounds may result in adverse health effects, including developmental effects to fetuses during pregnancy or to breastfed infants, cancer, liver effects, immune effects, thyroid effects and more.
At U.S. Army Garrison Fort McCoy near Sparta, three fire training burn pits are the source of high concentrations of PFOS in groundwater. Reported contaminant concentrations are as high as 120 µg/l – more than 1,700 times the EPA advisory level of 0.07 µg/l.
The exceedances at Fort McCoy are of particular concern as groundwater feeds at least seven trout streams that run throughout the property, including areas open to public fishing. Many states, including Wisconsin, have issued fish consumption advisories for PFOS in certain water bodies as eating fish is a major pathway for human exposure to these compounds.
However, DNR project staff said that to the best of their knowledge, site investigations at Fort McCoy have not included surface water and sediment sampling.
Like Fort McCoy, the former Badger Army Ammunition Plant has fire training areas but so far the Army at Badger has not been required to conduct environmental testing for PFOA and PFOS. Both compounds are bioaccumulative toxins that are water soluble and readily migrate to groundwater where they do not degrade, persisting many decades after disposal and use.
While the EPA has issued drinking water advisories for these compounds, it has not established enforceable standards. So it falls to states like Wisconsin to set enforceable health-based groundwater standards and corresponding drinking water standards.
CSWAB formally petitioned the state to begin the rulemaking process for PFOA and PFOS in September 2017. The DNR’s formal request to state health officials is the first step in this process.
Wisconsin will not be the first state to set groundwater standards. New Jersey has a groundwater standard for PFOA and PFOS combined of 0.04 µg/l, and Vermont has adopted a standard of 0.02 µg/l. In recent weeks, Wisconsin legislators have offered formal support for regulation of PFOA and PFOS including State Senator Dave Hansen, State Senator Jon Erpenbach and Representative Dave Considine.
Documents:
CSWAB Petition for Wisconsin PFOA PFOS Health Advisory Levels 2017
Map – Badger Ammo Fire Training Area
State Senator Dave Hansen letter to DNR Tyco Water Issues 26 Jan 2018
WDNR Request for Health-based ES Standards 02 March 2018