Senate bill SB455 seeks to compel the NHDES to conduct rulemaking to protect our drinking water from three additional PFAS compounds; perfluorobutanoic acid (PFBA), perfluoroheptanoic acid (PFHpA); and perfluorodecanoic acid (PFDA).The latter two have been regulated already by several states (MA, VT, and others) and others have taken action to protect drinking water from PFBA including Minnesota.

Regulating PFBA is of particular interest to the people of Merrimack, NH where taxpayers have footed the bill to make sure their water is safe while NHDES has failed to protect them from corporate polluter, Saint Gobain. The state has recently admitted that kidney cancers are higher than they should be in Merrimack, a community that is exposed to PFAS emissions from Saint Gobain. Read a recent article here.

The water System in Merrimack consistently sees PFBA breakthrough the treatment system. PFBA is a short-chain PFAS that is consistently detected in MVD raw well water at mid-to-high single-digit ppt concentrations. MVD’s wells 4/5 PFAS treatment system has twin lead-lag granular activated carbon (GAC) vessels in series. PFBA was the first PFAS compound that broke through the lead vessel after about 8 months and broke through the lag vessel after about one year and is now the only detectable PFAS compound passing through both vessels, and entering the drinking water supply, based on the 25 PFAS compounds being sampled for monthly.  

In 2019 MVD customers voted to approve raising $14.5 million to build PFAS treatment plants at all 4 remaining MVD wells (2, 3, 7, & 8) that are not covered in the Saint-Gobain / MVD settlement agreement for wells 4/5. 92% of the voters present at the 2019 annual meeting voted in favor of this funding because they did not want ANY PFAS compounds in MVD water. The goal of that proposed PFAS treatment was presented to MVD customers was a level of non-detect of all PFAS compounds being measured in the drinking water. One PFAS is considered just as harmful as any other, particularly with the literature suggesting that PFBA attacks the lungs. The combination of the several PFAS compounds detected is worse in combination, when considered as a class. We know most PFAS compounds are cause for concern, so why would we assume that all other non-regulated PFAS are safe until proven otherwise? It's unfortunate that DES opposed this bill, on behalf of the polluter rather than the taxpayers, in Senate public testimony that can be viewed here.

If PFBA were to become regulated, it could require MVD to need to change out the lead GAC vessel media more frequently, keeping PFBA, and therefore, all other PFAS compounds out of MVD’s drinking water, as MVD customers expect. The cost of that burden can be borne by the polluters responsible for that contamination, instead of the MVD customers. That would be exactly in-line with exactly what is already happening in Hoosick falls, NY, where the state of NY requires Saint-Gobain & Honeywell to change the lead GAC vessel media at the first instance of breakthrough of the first PFAS compound, which has consistently been PFBA. That would provide consistency between New York and New Hampshire in how it deals with PFBA as a trigger for PFAS treatment maintenance, and it would memorialize what MVD customers are expecting.  

PFBA Impact on health – PFBA is a “short chain” PFAS that is found in water systems like in Merrimack. Studies have shown that short chain compounds, like PFBA concentrate in the lungs, kidneys and liver. We believe there is sufficient evidence to support an MCL rule-making process for PFBA especially in light of the continuing pandemic as evidenced below.

PFBA exposure linked with worse COVID-19 outcomes

People who had elevated blood levels of a toxic chemical called perfluorobutanoic acid (PFBA) had an increased risk of a more severe course of COVID-19 than those who did not have elevated levels, according to a new study led by Harvard T.H. Chan School of Public Health. PFBA is part of a class of man-made chemicals known as perfluorinated alkylate substances (PFASs), which have previously been shown to suppress immune function.

The study, published December 31, 2020 in PLOS ONE, was led by Philippe Grandjean, adjunct professor of environmental health.

PFASs have water- and grease-resistant properties and are used in a wide variety of products, including nonstick cookware, waterproof clothing, food packaging, and firefighting foams. PFBA, more than other PFASs, is known to accumulate in the lungs, according to the study.

Researchers looked at PFAS levels in blood samples from 323 Danish individuals infected with the coronavirus. They found that those with higher PFBA levels had higher odds of being hospitalized, winding up in intensive care, and dying than those with lower levels.

The findings suggest that further study is needed to determine whether elevated exposures to other environmental immunotoxicants may worsen COVID-19 outcomes, the authors wrote.

Read the PLOS ONE study: Severity of COVID-19 at elevated exposure to perfluorinated alkylates

Please write to the Senators and members of the House to raise awareness of this issue and ask them to overturn the Senate Energy decision to recommend killing the bill. Other states value clean water, NH deserves it too.