The Department of Natural Resources has weighed in on a statement Rhinelander city administrator Daniel Guild included in a recent notice to city water utility customers in which he appeared to question the "veracity and accuracy" of test results made public this summer showing PFAS chemical contamination in a municipal well.
According to Steven B. Elmore, program director of the DNR's Bureau of Drinking Water and Groundwater, it is the agency's opinion that there is "no reason to question the accuracy of these previous PFAS sampling results, the laboratory or the test methods upon which they were based."
Rhinelander municipal well 7 was taken out of service June 24 after the test results referenced by Elmore - which were collected in May - showed signs of per-and polyfluoroalkyl substances (PFAS) contamination.
PFAS are man-made chemicals that have been used in non-stick cookware, water-repellent clothing, stain resistant fabrics and carpets, some cosmetics, firefighting foam, and products that resist grease, water and oil.
In a letter dated Nov, 19, Elmore tells Guild that the DNR "appreciates actions taken to date and those actions planned by Rhinelander Water and Wastewater utility (Rhinelander) relating to PFAS, as described in your November 5, 2019 Notice to Water Utility Customers."
He then reminds Guild of the importance of providing "clear" and "accurate" information to the public on this matter.
"As we all learn more about PFAS and how it moves through the environment, we want to make sure that all of us are providing clear and the most accurate information to the public," Elmore wrote. "The reason for this letter is to highlight language from your November Notice that may not be consistent with our drinking and groundwater experts' understanding of the PFAS situation in Rhinelander and its impacts on your municipal wells."
Elmore then goes on to quote the key paragraph in Guild's Nov. 5 notice to water customers.
"I am happy to report to you that we have no repeated detections of the previous PFAS chemicals first sampled in May 2019," Guild told water customers. "This has raised several questions about the both the accuracy and veracity of the original sample which the detect was previously discovered. Remember these detections were incredibly small, in the range of trillioneths, making sample contamination a theoretical possibility."
In his letter, Elmore summarizes the history of PFAS detection in Rhinelander municipal wells and explains the testing method.
"As you'll recall, the City first detected PFAS in 2013 during monitoring required by EPA's Unregulated Contaminant Monitoring Rule (UCMR 3)," Elmore wrote to Guild. "PFAS discovered in Well #7 in 2013 was again confirmed to be present in 2019. The laboratory method used, EPA Method 537, was developed with particular attention to accuracy and precision, went through multi-lab validation, and was demonstrated during UCMR 3 to be a robust and reliable method. The use of field and trip blanks are included to determine sample contamination and ensure the integrity of the results. Northern Lake Service (that lab that tested the May 2019 sample) was one of the laboratories approved by EPA to analyze PFAS under the UCMR3 and continues to use this method to analyze drinking water samples for PFAS. Therefore, the department has no reason to question the accuracy of these previous PFAS sampling results, the laboratory or the test methods upon which they were based."
Elmore's letter also mentions there is still a PFAS source that is likely impacting Well 7 and, while PFAS levels are low in the well, it is probably due to the well not being pumped and drawing in contamination.
"The downward trend in PFAS concentrations found in Well #7 is more likely due to inactivity - that is, the lack of pumping the well may have resulted in not drawing contaminated groundwater into the well's zone of influence," Elmore wrote. "It is likely that under normal use (if it were put back in service), the concentrations of PFAS in well #7 would again increase. The department requests well #7 not be returned to service without first consulting the WI DNR Drinking Water Field Engineer for Rhinelander, Aryn Webster."
The well remains offline.
"As you know, there is a drinking water advisory issued by the US EPA for PFOA and PFOS combined of 70 parts per trillion (ppt), and the Wisconsin Department of Health Services (DHS) has recommended to the department a health-based groundwater standard of 20 ppt for those same compounds," Elmore continued. "Additionally, PFOA and PFOS are not the only PFAS substances for which there are recognized health concerns. Other states have set drinking water or groundwater standards or guidance values for other PFAS, including PFHxS which is found in stain-resistant fabrics, fire-fighting foams, food packaging, and as a surfactant in industrial processes. Results from Well 8 indicate that the concentration of PFHxS is increasing. At this time, DHS is working on developing recommended groundwater standards for up to 20 other PFAS. Because of the potential health risk from other PFAS, continued monitoring is advised when other PFAS are detected in water, even if levels of PFOA and PFOS are below the recommended groundwater standards of 20 ng/L."
Elmore ends the letter with a recommendation that Guild post all PFAS test results on the city website as soon as possible.
"In the letter dated July 11, 2019 the department outlined additional actions that could be taken including notifying the public of the ongoing sample results," the letter states. "The department recommends that Rhinelander accomplish this effort by posting all PFAS results on the city website as soon as reasonably practicable."
According to the DNR, PFAS contaminants have made their way into the environment in a variety of ways, including spills of PFAS-containing materials, discharges of PFAS-containing wastewater to treatment plants and certain types of firefighting foams.
PFAS can persist in the environment and the human body for long periods of time, according to the DNR, and recent scientific findings indicate that exposure to certain PFAS may have harmful health effects in people. According to the EPA, exposure to some PFAS substances above certain levels may increase the risk of adverse health effects, such as thyroid disease, low birthweights and cancer.
The DNR's Elmore is not the only person to question Guild's Nov. 5 notice to customers.
In an interview with the River News Nov. 6, R.T. Krueger, the president and CEO of Northern Lake Service, Inc., expressed his own concerns about Guild's interpretation of the recent results.
When asked to respond to Guild's statement in the notice to customers that questions have been raised regarding "both the accuracy and veracity of the original sample," Krueger stated the city "made no contact with us regarding checking into this."
Later he added, "If those questions do exist they were not presented to me" and "I have not been asked if there was a problem on our end."
Any assertion that the original sample may have been contaminated, or the analysis somehow flawed, is unfounded, Krueger continued.
"From our end, there is absolutely no indication that there were any problems with the sample collection or the analytical," he said.
Later, he added, "I have indicated to him (Guild) that I am not sure where those assertions (in the notice to customers) came from because there is nothing on our end to indicate that that's the case."
In response to an inquiry regarding how the water samples were collected and who was responsible for that aspect of the process, Krueger stressed that his firm analyzed the samples but did not collect them.
"We did not sample," he said. "We did the analytical work."
Krueger also noted that the Crandon-based company, founded by his parents in 1974, has a "40-year track record of being a partner with the city" with respect to water testing, however this particular experience has been quite unusual.
"I'm not used to being in this position because normally when I'm working with a municipality they are very open with potential public health issues," he said. "I'm not used to this. It puts me in a very strange position, but I can assure you, and I definitely want the people of Rhinelander to understand, that my priority is public health."
When asked if he could offer any guidance to Rhinelander water customers, Krueger carefully explained that it is not his place to offer such advice.
"That is not my role. That is definitely not my role," he said. "My role is not at all to instruct them what to do with their system, it's not to speculate on any causes of any issues. It's to provide the data and if the data is being, I believe, misinterpreted or incompletely interpreted, then I'm helping, whether they want it or not, to interpret that data. I think it's the responsibility of the regulators to do those other things."
In response to Guild's description of the detections in Well 7 as "incredibly small in the range of trillioneths," Krueger offered the following statement. "I would take the opportunity to say that while those are very, very low levels, as a lab we're very confident in our ability to measure the levels as they were reported and appropriately qualified."
Throughout the interview, Krueger stressed that virtually everything associated with the testing and regulation of water with respect to PFAS is extremely complex and thus it's essential that everyone act with the utmost care.
"I understand how incredibly complicated this is from a scientific and regulatory standpoint, but because of that everybody has to be even more careful than usual and understand that this is extremely complex. It's a multi-headed monster," he said. "We have to be very, very careful with our assumptions..."
The River News offered Guild an opportunity to respond to Elmore's letter.
He emailed the following message, which he signed "regretfully yours".
"When trying to address complex public policy questions, such as the continuing conversation regarding PFAS chemicals in the environment, it has been my experience that it is beneficial to have a local new (sic) agency writing on such topics, provided the agency is committed to fact-based reporting and unbiased journalism. I am sure it is clear to you, Heather, given the current publishing/reporting standards of the Northwoods River News, that my opportunities to provide comment to your questions and participate in these reports remain extremely limited."
Heather Schaefer may be reached at firstname.lastname@example.org.
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