From: Noah Karberg Sent: Friday, June 7, 2019 2:51 PM To: Information, BWSC (DEP) Cc: Tom Rafter Subject: Public Comment, 310 CMR 40.0000 (MCP) Ms. Callahan, Thank you for the opportunity to provide public comment on proposed revisions to 310 CMR 40.0000 (MCP), or more informally – PFAS Standards. I represent the Nantucket Memorial Airport Commission, owner and operator of Nantucket Memorial Airport (ACK) on Nantucket Island, MA. ACK is a FAR Part 139 certificated airport, and the second busiest in Massachusetts. We are currently cooperating with a proactive PFAS investigation at ACK in coordination with our Licensed Site Professional Consultant, Weston Solutions. I offer the following comments and Proposed MCP revisions: 1. Table 1, Revision of GW-1 Standard for PFAS to 0.02 ug/L. Airport such as ACK cover large tracts of lands, and are subject to a variety of past use categories could have generated documented and undocumented source inputs of PFAS. These include dry cleaning facilities, septic fields, sewer leaks, WWTP effluent, FUDS contamination, and misc. commercial/industrial uses that have occurred in addition to and Airport’s own AFFF usage. Given that general background levels of PFAS range from 3-10 ppb, triggering the MCP at a 20 ppb threshold is fairly certain conclusion. The concern of ACK, is that airports may assume responsibility for many other release categories and uses that have been discovered on Airport property. The situation ACK would like to avoid, is having Airports bear the burden of mitigation and identification of contamination that occurred elsewhere at multiple small inputs. At a 20 ppb threshold, how will source partitioning of the discovered PFAS – that attributable to AFFF, and other sources – be determined? Will municipal airport sponsors bear the costs of a general community cleanup, and what funds are available to assist in that mitigation? Thank you for the review of these comments. Sincerely, Noah Karberg Noah J. Karberg, A.A.E., ACE Assistant Airport Manager Nantucket Memorial Airport 14 Airport Rd. Nantucket, MA 02554 O: 508-325-7531 F: 508-325-5306