A Whole-of-Government Approach to Tackling PFAS in Acton

by Kim Kastens, Chair, Green Acton Water Committee

PFAS — per- and polyfluoroalkyl substances — comprise a family of harmful chemicals that is found in tap water and in many consumer and industrial products. This post suggests that a whole-of-government approach — one that enacts collaborative efforts across municipal departments and boards toward a shared goal — would be a useful framework for addressing PFAS exposures in the community. The post also outlines potential strategies that Acton Town government could take to understand, and then minimize, Acton residents’ exposures to PFAS.

In a recent press release, the Environmental Protection Agency (EPA) stated, “Communities across this country have suffered far too long from the ever-present threat of PFAS pollution. That’s why President Biden launched a whole-of-government approach to aggressively confront these harmful chemicals, and EPA is leading the way forward.” A whole-of-government approach to the PFAS problem recognizes that humans can be exposed to PFAS via many different pathways, works to better understand what these pathways are, and then takes actions to eliminate or weaken significant pathways.

The Acton Select Board has begun its annual goal setting process. During the public input phase of this process, the Green Acton Board of Directors suggested that one goal should be “a program of actions to understand better, and then minimize, Acton residents’ exposure to PFAS compounds.” Green Acton’s input then listed seven potential strategies that might be undertaken to accomplish this goal, suggested in the spirit of a whole-of-government approach. This article provides background and rationale for some of these strategies.

[Clarification added June 7, 2023: This article addresses only steps that could be taken by the municipal government of the Town of Acton, and thus are within the scope of the Select Board’s goal setting process. The Acton Water District (AWD) is an independent municipal entity established in 1912 by a separate charter from the Commonwealth of Massachusetts, governed by its own elected Board of Commissioners. Steps already taken by the AWD to understand and mitigate PFAS in Acton’s drinking water are detailed here.]

Potential strategies:

(1) Designate a staff member as the Town’s point person on PFAS, in order to coordinate a whole-of-government approach to PFAS mitigation, and to act as a liaison with the Acton Water District (AWD) and its parallel efforts.

(2) Conduct research on the PFAS content of consumable/disposable products (e.g., cleaning supplies, food packaging, and storage supplies) purchased by the municipality, and substitute PFAS-free items wherever possible. (Parallel, and collaborative, efforts by the Acton Boxborough Regional School District and the Acton Water District would be excellent additions.) As PFAS are increasingly evaluated and recognized as persistent and dangerous pollutants, the federal government has begun to take steps on mitigating the problem. States are mobilizing, as well: Massachusetts has published A Slick New Guide to Avoiding PFAS (Forever Chemicals) in Products, Using Massachusetts Statewide Contracts, which aims to support municipal PFAS efforts as well those of state agencies. Safer States provides an overview of actions across states.

(3) Educate the public about the PFAS contamination of consumer products and ways to minimize their exposure to PFAS across the lifestyle. Because PFAS compounds are found in thousands of consumer products, an important front in reducing residents’ exposures is education about how consumer choices (and other behaviors) can help limit the dispersion of these chemicals into the environment and humans’ subsequent exposures. There are many resources available to inform such an educational effort, including from: (1) the National Institutes of Health (NIH); (2) the Public Employees for Environmental Responsibility (PEER); (3) the Silent Spring Institute; (4) The New York Times; and (5) the Michigan PFAS Action Response Team (MPART), among many others.

(4) Coordinate regular sampling of PFAS in the influent water at the municipal sewage treatment plant with the Acton Water District’s PFAS sampling of its finished water, in order to better understand the magnitude of PFAS exposures due to pathways other than drinking water. On August 9, 2022, a PFAS concentration of 29.4 ppt (parts per trillion) was measured in the influent water at the South Acton Wastewater Treatment Plant. A few days earlier, on July 27, the PFAS concentration of the finished water being delivered from the plant had been only 18.2 ppt (see Note 1). The difference between these two values is compatible with an explanation that Acton homes and businesses in the sewer district are being exposed to substantial additional sources of PFAS, above and beyond that in the tap water. But this was just one measurement at one moment in time, and PFAS values in the AWD tap water have been variable. A regular, coordinated sampling program would provide more insight about how much PFAS exposure Acton residents are getting from non–tap water sources. These data and a lay-language interpretation of their meaning should be made available to the public.

(5) Add PFAS sampling to the ongoing annual program of monitoring ground- and surface water around the closed municipal landfill at the Transfer Station. On the site of the Acton Transfer Station is the (capped) Acton landfill, the repository of Acton’s refuse from 1950 to 1971. Following the practices of the time, the landfill was unlined, so it is possible that pollutants are leaching out of the landfill and into the groundwater and/or surface water. To monitor for this risk, the Town contracts with an environmental consulting company to take samples of water and soil gas at monitoring wells and in brooks around the perimeter of the landfill, and have them analyzed for a suite of potential pollutants (see Note 2). The monitoring program has been testing for dissolved metals, ammonia, volatile organic compounds (VOCs), 1,4-dioxane, and other potential pollutants — but not for PFAS. The source(s) of PFAS in Acton’s groundwater have not been ascertained; the landfill should be considered as one potential source. When the Minnesota Pollution Control Agency tested for PFAS in groundwater at 102 closed landfills, they found 62 sites where PFAS concentrations exceeded the Minnesota Department of Health drinking water guidance levels; among them were 15 sites that exceeded the health guidance by 10 times or more.

(6) Provide technical support (assistance in collecting samples, finding a lab, and interpreting data) to property owners with private wells who want to know the PFAS content of their well water. At its April 4, 2023 meeting, the Board of Health heard an update on Acton’s water quality, including PFAS. One alarming statistic was that testing of private wells in Acton has yielded PFAS concentrations ranging up to hundreds of parts per trillion. For comparison, the Massachusetts drinking water standard for public water suppliers is 20 ppt for six specified PFAS compounds in the aggregate (see Note 3). For homeowners who want to know the PFAS content of their private wells, it is possible but not all that easy, to get an analysis. There are a limited number of labs certified to analyze for PFAS at the ppt level; some labs are fully booked with commercial and municipal customers; collecting a clean sample is tricky; and the resulting multi-page, fine-print reports can be a challenge to parse. The Town could, for example, support a coordinated effort to collect clean samples from the wells of interested homeowners, negotiate a group purchase with a qualified lab, and then host an online workshop to review the interpretation of results. Such an effort might be coordinated with Boxborough and/or Carlisle, neighboring towns with large numbers of private wells.

(7) Review the Town’s Groundwater Protection (GWP) bylaw, and consider whether there are practical ways to strengthen the suite of activities prohibited in GWP Zones 1 and 2 so as to prevent future discharges of PFAS-laden materials within those zones. The GWP Zone section of the Town of Acton Zoning Bylaw (section 4.3) designates “groundwater protection zones” within which certain activities are restricted or prohibited so as to minimize the possibility that toxic materials will percolate into the aquifers from which Acton draws its water supply. Table 4.3.7.2, on pages 58 and 59 of the Zoning Bylaw, specifies which activities are restricted or prohibited within GWP Zones 1, 2, and 3. Prohibited activities focus on petroleum products, pesticides, herbicides, animal manure, and other materials known to be problematic when the bylaw was written; PFAS were not on the radar screen at that time. Acton might want to consider adoption of useful PFAS-oriented GWP restrictions that have been put in place by other municipalities. As with any change to zoning bylaws, a change to the GWP bylaw would apply only to new uses of the land.

Collectively, this suite of strategies would begin to reveal and tackle the many pathways by which Acton residents may be exposed to PFAS. The problem of PFAS — accrued over many decades — will take far longer than one year to address and remediate. But by making the address of this issue one of its 2023–2024 goals, the Select Board can elevate PFAS awareness and action across all departments of Town government, and help change public knowledge and behavior — thereby advancing the complex process of solving this pervasive problem.

NOTES

Note 1: PFAS measurements in AWD finished water are posted here. The 2022 PFAS measurements from the wastewater treatment plant were provided to the Green Acton Water Committee by email communication from the Town Manager.

Note 2: The Town’s current contractor for landfill water and gas sampling is Green Seal Environmental. The environmental contractors submit landfill monitoring data to the Massachusetts Department of Environmental Protection (DEP), which provided the Acton reports from 2018–2023 in response to a request from the Green Acton Water Committee.

Note 3: The Massachusetts drinking water standard does not currently apply to a system that serves fewer than 25 individuals. Senate bill S.482, filed by our own Senator Jamie Eldridge, would allow DEP to set standards for private water quality and provide low-income homeowners with financial assistance for testing. The bill is currently in the Committee on Environment & Natural Resources.