We Need Real Solutions Now to End Toxic Pollution from New Hampshire Superfund Site

Tom Irwin | @TomIrwinNH

Over the past year, high levels of toxic chemical pollution have been found in Berry’s Brook, near the Coakley Superfund Site in North Hampton, New Hampshire. While the N.H. Department of Environmental Services has recognized that the problem of pollution migrating from the site is unacceptable and must be addressed, the EPA – while committing to further study of the issue – is not addressing the problem with the urgency it requires.

You can make your voice heard on this critical issue at a public meeting with EPA on November 15 at 6:30pm at the North Hampton Town Hall.

How We Got Here: Water Tests Reveal Toxic Contamination

A year ago, CLF’s Great Bay-Piscataqua Waterkeeper collected water samples from brooks near the Coakley Landfill Superfund Site. At that time, no testing had been done by regulators to determine whether toxic perfluorinated chemicals – in particular, PFOA and PFOS – were making their way from the site into local surface waters.

What we found was troubling: These emerging contaminants of concern – pollutants that are highly persistent, accumulate in the environment, and harm human health – were indeed present in brooks near the landfill. The pollutant levels were especially concerning in Berry’s Brook, which flows several miles through Rye into Little Harbor.

Prompted by CLF’s testing, both the N.H. Department of Environmental Services and the Coakley Landfill Group (consisting of numerous responsible parties who sent waste to the landfill) engaged in water quality testing themselves. What did they find? Pollutant levels even higher than those found in CLF’s samples. In fact, the combined levels of PFOA and PFOS they found in Berry’s Brook exceeded 1,000 parts per trillion at multiple locations, with one location exceeding 1,500 ppt – levels of significant concern to human health. What’s more, another type of perfluorinated chemical, PFNA, was found at a level considered extremely high for that contaminant.

The State’s Assessment: An Unacceptable Situation That Must Be Addressed

In light of these facts, in July, the N.H. Department of Environmental Services issued a letter stating that such contamination of Berry’s Brook is “unacceptable and need[s] to be addressed.” In that same correspondence, the agency wrote: “NHDES believes that actions need to be implemented at the [Coakley] site to provide additional removal or containment of the contamination, in order to mitigate these surface water quality impacts.” The agency concluded that “in the long run, this will be the most reliable way to limit exposure to site contaminants.”

In outreach to both EPA and Governor Sununu, CLF has voiced its strong agreement with the Department of Environmental Services’ assessment. The situation is not just unacceptable, but urgent, particularly where the strategy EPA implemented for the Coakley landfill in the 1990s was to construct a cap to prevent rainwater and snowmelt from percolating through the many wastes consolidated on the site, and then to simply allow hazardous wastes on the site to “naturally attenuate” – i.e., to break down on their own over time.

Not Surprisingly, EPA’s Plan Isn’t Working – and It Isn’t the Solution

Considering the incredible brew of hazardous wastes dumped at the Coakley landfill during operations that began in the 1970s, it should come as no surprise to anyone – least of all EPA – that such a passive remedy is not working. PFOA and PFOS do not break down naturally over time. Quite to the contrary, they require active forms of remediation, such as physical removal or, at the very least, “pump and treat” approaches that prevent their migration through groundwater.

EPA Says More Study Needed, But Site Poses No Threat in the Short-Term

Instead of taking immediate action, EPA says it wants more data – about whether people eating fish caught in Berry’s Brook are being exposed to perfluorinated chemicals and about the pathways through which the pollution migrates in the deep bedrock beneath the Superfund Site. It recently announced that it will require the Coakley Landfill Group to engage in these studies. In the meantime, EPA itself intends to conduct additional risk evaluation for exposures caused by the incidental consumption of surface water or sediments.

At the same time, EPA has announced that its remedy at the site (remember that big cap it built back in the 90s?) “is protective in the short term because the data indicates no human exposures to [perfluorinated chemicals] at levels exceeding either State Standards or EPA [Cleanup Limits].” While EPA has not rendered a long-term protectiveness determination, its conclusion, not surprisingly, has been met with surprise and frustration by members of the public who are concerned about the safety of their water.

EPA’s Assurances Aren’t Good Enough

Absent the information it is seeking above, how can EPA conclude that conditions are protective in the short term? Moreover, can the public really take comfort in EPA’s observation that perfluorinated chemicals have not been found at levels that exceed certain state standards? After all, states such as New Jersey and Vermont have adopted groundwater and drinking water standards for PFOA and PFOS that are much more stringent than New Hampshire’s (which are based on EPA’s). What’s more, combined concentrations of PFOA and PFOS in Berry’s Brook far exceed surface water guidelines adopted by Michigan, and drinking water and fish consumption guidelines adopted by Minnesota.

Fortunately, and hopefully with success in the upcoming session, State Representative Mindi Messmer will again pursue efforts addressing the need for New Hampshire to adopt stricter standards for these toxic chemicals that will better protect human health and the environment.

Make Your Voice Heard: EPA’s Upcoming Public Meeting

On Wednesday, November 15, at 6:30pm, EPA will hold a public meeting at the North Hampton Town Hall to discuss its recent assessment of the site. As stated in a recent letter from the EPA, the agency claims it “has a very positive message to share” about that assessment. However, unless and until EPA agrees with the Department of Environmental Services that the migration of perfluorinated chemicals from the Coakley Landfill Superfund Site into Berry’s Brook is unacceptable and must come to an end, it’s difficult to imagine the public receiving any message from that agency in a positive light.

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