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Please comment to NJDEP – Clean up groundwater contamination! Support Ground Water Quality Standards to remove PFNA and other hazards

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Please comment to NJDEP – Clean up groundwater contamination!

Support Ground Water Quality Standards to remove PFNA and other hazards

New Jersey Department of Environmental Protection (DEP) is proposing to add perfluorononanoic acid (PFNA) to the Hazardous Substances List; amend the Ground Water Quality Standards to include interim standards; and use alternative scientific analyses to best protect consumers. Write them or attend the Public Hearing to tell them we need clean drinking water and these changes will help get us there. Comment period ends June 2; Public Hearing is May 5.

The proposed amendments will:

-add highly toxic PFNA as a Hazardous Substance under the Spill Compensation and Control Act, requiring stricter control of the substance and prevention of spills, making those responsible for spills liable for cleanup, and allowing Spill Fund monies to be used to clean up contamination and compensate those harmed by discharges;

-better protect the public by allowing the most advanced scientific methods to be used to develop standards;

-incorporate interim specific groundwater quality standards, interim practical quantification levels (PQL), and interim standards for 23 identified constituents into the official Standards, making them permanent.

Public Hearing: Friday, May 5, 2017, 10:00 am to noon, NJDEP Public Hearing Room, 1st floor, 401 E. State St., Trenton, NJ 08625

Background

NJDEP adopted an interim specific groundwater criterion of 0.01 ug/L (10 ppt) for PFNA in 2015 and is proposing to establish it as a permanent groundwater standard and add PFNA to the list of hazardous substances under the Spill Act. Both these actions are of great importance to ensure PFNA is cleaned up from our environment. PFNA is highly toxic, doesn’t break down in the environment, builds up in the human body, and is linked to serious diseases. DEP describes it as a “…developmental toxicant, liver toxicant, and immune system toxicant…” P.12 at http://www.nj.gov/dep/rules/notices/20170403b.html There are NJ municipalities that have been plagued by PFNA, costing huge sums and harming public health.

Regarding DEP scientists employing alternative methods, where appropriate, to derive interim specific and specific ground water quality criteria, it is important to ensure that the best available science is used, even if modified equations and values are necessary. For example, if it isn’t possible to develop a reference dose, an equation may be modified to use the lowest level at which effects are seen. P.11 at http://www.nj.gov/dep/rules/notices/20170403b.html

It is extremely important for DEP to establish groundwater standards to address our State’s ongoing water quality contamination. As stated by NJDEP, as of the end of 2016 “…there are 14,357 active site remediation cases in New Jersey. Ground water contamination has been found in approximately 60% of those cases.” P.15 at http://www.nj.gov/dep/rules/notices/20170403b.html

DEP Rule Proposal for this rulemaking: http://www.nj.gov/dep/rules/notices/20170403b.html

DEP Basis and Background Document for this rulemaking: http://www.nj.gov/dep/rules/notices/bbdoc-20170403b.pdf

DRN Comment to DEP on PFNA Interim Specific Groundwater Criterion: http://bit.ly/2puYOWB

DEP Actions – More Needed!

The NJ Drinking Water Quality Institute (DWQI) recommended a Maximum Contaminant Level (MCL) of 13 ppt for PFNA in July 2015 but DEP hasn’t adopted it yet. In fact, they haven’t even proposed regulations to adopt a MCL for this very dangerous contaminant after more than 20 months, prolonging the exposure of residents to contaminated drinking water. DEP must act to promulgate the rulemaking to adopt the recommended MCL for PFNA immediately to protect people’s health and provide safe drinking water.

In February 2017 the DWQI also recommended, after more than a year of research and analysis, a MCL for Perfluorooctanoic Acid (PFOA), which now needs to be promulgated as a safe drinking water standard by DEP. The MCL for PFOA will then set the specific groundwater criterion, facilitating cleanup of PFOA contamination, an urgently needed action.

There are many very toxic chemical compounds that have recommended MCLs but are languishing, such as 1,2,3-Trichloropropane, perchlorate and radon – DEP must take action to adopt MCLs for these and other dangerous but unregulated chemicals, which would in turn establish groundwater criterion, needed to clean up contamination. DEP must do more to protect our drinking water and environment!

DRN comments to DWQI on PFNA and PFOA MCL, PQL, and Treatment:

PFNA MCL: http://bit.ly/2oA4bq6

PFNA PQL: http://bit.ly/2oYZveJ

PFOA MCL: http://bit.ly/2o7nMuX

PFOA PQL: http://bit.ly/2o7cmHA

PFC Treatment: http://bit.ly/2otQI2Q

More information about PFCs in New Jersey and Pennsylvania: http://www.delawareriverkeeper.org/ongoing-issues/perfluorooctanoic-acid 

You can send a letter by using the language below as a template – here are some helpful talking points. You can also use these points to develop testimony for the public hearing May 5 in Trenton – please join us!

To send in your comment to NJDEP online, fill out the form found here (be sure to select 'Ground Water Quality Standards' under Rulemaking): NJDEP comment submission page

Tell NJDEP:

-Add PFNA as a Hazardous Substance under the Spill Compensation and Control Act in order to remove this highly toxic contaminant from the environment to protect our drinking water sources, ecosystems and public health.

-Take immediate action to adopt more MCLs such as 14ppt for PFOA, recommended by the NJ Drinking Water Quality Institute, to get this toxic compound out of our drinking water and to establish the specific groundwater standard to remove it from our environment; immediately promulgate rulemaking to adopt the recommended 13ppt for PFNA.

-Use the most valid scientific methods available to develop water standards that will best protect the public and most effectively remove contaminants from the environment.

-Incorporate interim specific groundwater quality standards, interim practical quantification levels (PQL), and interim standards for the listed constituents into the official Standards.

Please be sure to write in the box below by using the above points as a guide or your own take on issues in the rulemaking or the letter they get will be very short! Add what you think is most important to support the NJDEP proposal and push for more action by NJDEP. Then just send it off with a click, it will be delivered automatically to NJDEP.

Re: Proposed Amendments: NJAC 7:1E Appendix A on Ground Water Quality Standards and 7:9C Appendix List of Hazardous Substances

I support the above referenced rulemaking to facilitate the cleanup of contaminants that are polluting our groundwater, including the proposed listing of PFNA as a hazardous substance.

I also urge DEP to take further action to promulgate rulemaking to adopt the Drinking Water Quality Institute’s recommended MCLs for PFNA, PFOA, and MCLs for other contaminants the Institute has recommended but DEP has not acted on. Those MCLs can then be used to establish groundwater criterion to clean up contamination.