Thank you for the opportunity to offer comments on the NC Environmental Management Commission’s (Commission) proposed triennial review of surface water quality standards. ​North Carolina’s surface water quality standards must protect our children and other vulnerable populations. The current proposals fail to address PFAS discharges and do not provide adequate protection from 1,4 dioxane in drinking water sourced from contaminated rivers. The scientific and technical evidence to support these claims have been thoroughly outlined in a public comment letter submitted by North Carolina Conservation Network, Southern Environmental Law Center and Toxic Free NC.

We urge the Commission to do the following:

> Adopt the 0.35 µg/L standard statewide for 1,4 dioxane.
> Immediately create surface water quality standards for PFAS as a class.
> Adopt a health protective surface water quality standard of 1 ppt as the total concentration for the sum of all PFAS.

Our primary source of drinking water comes from the Cape Fear River which is the largest watershed in the state and supplies drinking water to approximately 1.5 million North Carolinians. The Cape Fear River has a long history of being polluted by upstream industrial dischargers and municipal wastewater treatment plants.

Releases of 1,4 dioxane are regularly reported in the drinking water for residents who rely on the Haw and Cape Fear Rivers at levels well above what NC’s Department of Environmental Quality (DEQ) recognizes as safe to drink. The EPA lists 1,4 dioxane as a probable human carcinogen with toxic effects to the kidneys and liver. We urge the Commission to adopt the 0.35 µg/L standard statewide for 1,4 dioxane.

Additionally, for decades we have been highly exposed to PFAS chemicals discharged from the former DuPont, now Chemours, manufacturing facility in Fayetteville, NC. Multiple studies and reports show North Carolina suffers some of the worst PFAS chemical pollution in the United States.

The best available science suggests PFAS exposures, even in small amounts, can increase the risk for severe health effects, including cancers of the thyroid, kidney, bladder and testicular. Human exposures to PFAS have also been linked to preeclampsia, obesity, liver and kidney damage, endocrine disruption, immune suppression, and elevated cholesterol. A greater burden is placed on vulnerable populations, like firefighters, developing fetuses, infants, and children. NC’s Department of Health and Human Services has already identified possible cancer clusters for testicular and thyroid cancer in our region.

The letter, helmed by NC Conservation Network, Southern Environmental Law Center and Toxic Free NC, explains in great detail the devastating PFAS exposure levels experienced by communities who use both the Haw and Cape Fear Rivers as their primary source for drinking water. This letter also outlines the harm done to aquatic life within NC from chronic and unregulated PFAS exposures. PFAS exposures have also been found in aquatic plants, algae and invertebrates; which leads to biomagnification within the ecosystem food chain.

Coastal communities within the Cape Fear estuary rely on tourism, recreational water sports, fishing and shellfishing. Multiple studies from other states and countries have already documented exposures of PFAS within seafood. In order for overexposed communities like those in Pittsboro, Brunswick, New Hanover and Pender counties to have a fighting chance--it is imperative our Governor and his administration address PFAS exposures by creating health protective surface water quality standards immediately.

While DEQ has taken some measures to address the extreme PFAS contamination coming from the Chemours facility in Fayetteville, local tap water samples taken regularly by Brunswick County and CFPUA still show combined PFAS levels regularly above NC’s provisional health goal and the federal government’s lifetime health advisory limit for PFAS. This is unacceptable.

It’s our understanding approximately 40% of the PFAS detected in our tap water is coming from sources other than Chemours. We deserve protections from these additional releases contaminating our drinking water supply.

Water districts are not equipped to filter out industrial contaminates like PFAS and 1,4 dioxane. NC ratepayers are currently being forced to absorb costly upgrades and increased water rates. Brunswick County spent $167.3 million on a reverse osmosis plant and Cape Fear Public Utility Authority spent $46 million on deep bed granular activated carbon filters with recurring annual costs of $2.9 million in filter maintenance. Both utilities were forced to provide these advanced treatments to address, what we feel are, preventable contaminations due to a lack of health protective surface water quality standards.

A pediatric kidney cancer survivor in Wilmington, NC was told by her doctor drinking lots of water was her best medicine. Yet, the tap water in her area is contaminated daily with excessive levels of PFAS. A cancer diagnosis can lead to medical treatment costs in the hundreds of thousands of dollars. Inaction on PFAS exposures at all levels of state governance--including surface water quality standards, threatens to leave North Carolinians sicker, fatter and poorer than those states who are actively and appropriately addressing their 1,4 dioxane and PFAS contamination problems.

Failure by our Governor and his administration to do their part and act on PFAS contamination can have costly repercussions for North Carolina residents. A 2019 report from the Nordic Council estimated healthcare costs alone due to PFAS exposures could cost Europeans 52 - 85 billion EUR annually. ​It’s reasonable to assume a similar proportional correlation could be made for the cost of inaction to North Carolinians.

We believe the Division of Water Resources (DWR) within DEQ has the power and authority to create surface water quality standards for PFAS using the best available science. DWR should not wait on information from the US EPA to begin the process of collecting the required data needed to develop and propose PFAS surface water quality standards. We have already waited long enough and many North Carolinians are paying the ultimate price.

It is our understanding the EPA’s PFAS Action Plan will only provide ambient water quality criteria for aquatic life for PFOA and PFOS only--both of these compounds are no longer in commercial use. States, like Vermont and New Hampshire, are taking the initiative to create PFAS surface water quality standards in the absence of federal guidance. DWR should do likewise.

To genuinely protect North Carolinians of all ages, DWR should immediately set a health protective surface water quality standard of 1 ppt as the sum total concentration for all PFAS. The sad reality being, this is the most health protective level for this class of “forever chemicals” which is confirmed by multiple studies and leading experts.

Thank you for your time and attention to this important topic.