From: David Dow <@comcast.net> Sent: Tuesday, May 7, 2019 11:10 AM To: Information, BWSC (DEP) Cc: David Dow Subject: Comments on 2019 Massachusetts Contingency Plan Changes for PFAS Chemical Regulation I am a retired marine scientist and grassroots environmental activist living on Cape Cod. The Yearling Meadows development where I live in East Falmouth is underlain by the Ashumet Valley Plume (AVP) from Joint Base Cape Cod (JBCC). I spent over 20 years as an environmental activist at the Safe Drinking Water Act/Superfund cleanup at JBCC. In recent times the U.S. Geological Survey and Installation Restoration Program (IRP) discovered PFAS as an additional contaminant in the AVP (source area is the former fire training site where AFFF fire fighting foams were utilized). Activated carbon mitigation has been utilized on 22 private drinking water wells in Falmouth and the Mashpee Village Public drinking water well to reduce the PFOS and PFOA levels to 70 ppt (EPA Hazard Level). I recently submitted comments to EPA on their proposal to develop a maximum contaminant level (mcl) of 70 ppt for PFOS and PFOA. I told them that this was inadequate and that I supported the Massachusetts Contingency Plan (MCP) for an an mcl of 20 ppt for 6 PFAS chemicals and the associated waste sit cleanup standards. I also urged EPA to designate PFAS chemicals as class under CERCLA, so that JBCC could add PFAS chemicals as a class to their contaminants of concern (cocs). Perchlorate is on the JBCC coc list and one of the Falmouth Public Drinking water wells near where I live has been closed due to perchlorate levels > 2 ppb. I was was involved the JBCC cleanup when Ma. DEP developed an mcl for perchlorate as the cleanup target for a plume from the Central Impact Area. EPA was discussing an mcl of 15 ppb as the cleanup target, but I don’t know if this was ever implemented. Thus there is a precedent for a MCP mcl being much lower than the EPA mcl for the same contaminant. Since the AVP from JBCC has contaminated both the water and likely the sediments in Ashumet Pond, this should be considered as a waste site source area and appropriate cleanup processes need to be developed It is also likely that the fish targeted by recreational anglers are contaminated, so that fish consumption standards need to be developed for sensitive populations (women of child bearing age and children). I used to be the Recreational Fisheries Coordinator in the Northeast at the Fisheries Lab and polychlorinated biphenyls (PCBs) posed fish consumption challenges for Apex Predators. The University of Rhode Island’s STEEP (Sources, Transport, Exposure and Effects of PFAS) and Silent Spring Institute’s REACH (Research, Education and Action for Community Health) grants are studying the effects of 26 PFAS chemicals on the immune system of children 4-6 years of age. Fish and other food could be additional routes of PFAS exposure. It is likely that PFAS chemicals bioaccumulate through the aquatic food chain like PCBs and methyl mercury (later poses a health threat in Ashumet Pond). I serve in an citizen advisory capacity for these two grants. During the ASTDR (Agency for Toxic Substances & Disease Registry) study of increased breast cancer rates on Cape Cod, community health activists felt that aerial exposes from exploding munitions and the fire training area were more important expose routes then groundwater. Since this project was never completed, it is unknown whether PFAS chemicals could have exposed sensitive populations via atmospheric transport. Studies has suggested that incineration of AFFF fire fighting foams doesn’t destroy all of the PFAS components. In addition, GAC (granular activated carbon) doesn’t remove the lower molecular weight PFAS components (reverse osmosis; ion exchange resins; Cyclopure absorbents; etc. maybe required). Not being a chemist or chemical engineer, I can’t provide specific comments on the technologies required to remove PFAS chemicals as a class for mcl's and waste site sediments or soils to levels which ensure safety for sensitive populations (the Conservation Law foundation and Toxics Action enter proposed 1 ppt as the health standard for PFAS chemicals as a class). I will let others discuss the the PFAS contamination emanating from the Barnstable County Fire Training and Rescue Academy with has contaminated public drinking water wells in Hyannis. The STEEP and REACH grants focus on this area and there are a number of regulatory issues and who will pay for the cleanup of the drinking water and waste site that require resolution if the MCP PFAS mcl is reduced from 70 to 20 ppt. Thanks for your consideration of these comments. Dr. David D. Dow East Falmouth, Ma. 02536 ------------------------------------------------------------------------------------------------------------ From: David Dow <@comcast.net> Sent: Friday, May 31, 2019 2:14 AM To: Information, BWSC (DEP) Cc: David Dow Subject: Re: Addendum to Massachusetts Contingency Plan PFAS Proposed Regulation Changes Comments Thanks for the notification. I read a story in the Cape Cod Times on the recent Massachusetts Contingency Plan PFAS public meting in Hyannis, Ma. from 12:30-2:30 PM. The article mentioned that this meeting was attended by less than 25 people and only three testified, so that it ended in 35 minutes. It was nice to have a public meeting on Cape Cod to seek input from concerned residents, but scheduling it in the middle of the day after the Memorial Day Holiday might not be the optimum way to seek verbal community input. I gather that a previous meeting in Westborough, Ma. (?) only had 5 attendees. As the former Recreational Fisheries Coordinator in the Northeast at the federal Fisheries Lab in Woods Hole, Ma., this doesn’t seem to be the optimum use of scarce state resources ($ and people). I used to meet with salt water angling groups between 5-8 PM in the evening in locales between Rhode Island and New Hampshire. During the Cape Cod Commission/Ma. DEP/EPA Region 1 development of the Targeted Wastewater Management Plans to reduce nitrogen loading from septic systems that impacted water quality and habitat in over 50 Cape Cod embayments, the public hearings were held between 5-7 PM. This process was supported by the Conservation Law Foundation; Coalition for Buzzards Bay and the Association to Preserve Cape Cod. This process was carried out under section 208 of the Clean Water Act and will cost $ 4-6 billion over the next 20-30 years. The PFAS cleanup of public and private drinking water sites contaminated with PFAS will cost significant public moneys at the local/state level. I gather that Ma. DEP has paid the costs of GAC treatment for the public drinking water wells in Mashpee contaminated by PFOS and PFOA from the Ashumet Valley Plume which emanates from Joint Base Cape Cod. The AVP has also contaminated 22 private drinking water wells in Falmouth, while the Otis Rotary PFAS plume has contaminated private wells in Bourne. Since PFAS chemicals are not listed as hazardous chemicals under RCRA or CERCLA, it is not apparent to me that other the federal government or fire fighting foam manufacturers will bear the costs of the cleanup of PFAS plumes emanating from JBCC. Thus Cape Cod residents are likely to have to support portions of the infrastructure and operational costs of GAC or alternative treatments of PFAS contaminated public drinking water. The Falmouth Ashumet Valley Public Drinking Water Well was closed in the mid-1980’s by the AVP contamination. Given the recent WOTUS (Waters of the US) definition changes proposed by EPA, it is not clear to me that groundwater-based watersheds will be included under the jurisdiction of the CWA, SDWA, CERCLA, etc. Thus federal grant funding for PFAS cleanup by EPA maybe limited. Dr. David D. Dow On May 30, 2019, at 10:51 AM, Information, BWSC (DEP) wrote: Dr. Dow, MassDEP is in receipt of your comments. We will consider them as we work to finalize proposed amendments to the Massachusetts Contingency Plan, 310 CMR 40.0000. Thank you for your review and comments. Best regards, Elizabeth Callahan Acting Division Director Policy and Program Development MassDEP Bureau of Waste Site Cleanup One Winter Street, Boston, MA 02108 (617)348-4056 From: David Dow [mailto:@comcast.net] Sent: Wednesday, May 29, 2019 7:04 AM To: Information, BWSC (DEP) Cc: David Dow Subject: Fwd: Addendum to Massachusetts Contingency Plan PFAS Proposed Regulation Changes Comments Elizabeth Callahan