Internal memo shows how state could have informed public about pollution levels
The Alaska Department of Environmental Conservation refused to communicate to the public in English about its decision to allow higher levels of PFAS pollution before requiring responsible parties to provide alternative drinking water supplies.
The state hid behind this bureaucratic language posted on its website: “On April 9, 2019, ADEC published a revised Technical Memorandum on Action Levels for PFAS that supersedes the 2018 action levels memorandum and aligns the action levels with EPA’s Lifetime Health Advisory (LHA) levels for PFOS and PFOA.”
It turns out that in an internal memo dated March 28, DEC Commissioner Jason Brune gave a much better explanation of the new PFAS strategy to Tuckerman Babcock, the chief of staff for Gov. Mike Dunleavy.
The new plan for the state is to measure PFAS pollution based on the sum of two chemicals, instead of five chemicals. A sixth chemical remains subject to a separate measurement.
If the two chemicals, PFOS and PFOA, add up to a concentration of more than 70 parts per trillion, then the water will be deemed contaminated and alternative drinking water will have to be supplied by the state or whoever is determined the responsible party.
Under the plan announced last August, if five PFAS chemicals added up to more than 70 parts per trillion, the water was deemed contaminated.
By excluding three chemicals from the calculation. the state is redefining water as safe that was previously considered unsafe.
Alaskans who are now getting alternative drinking water from the state or other parties will have grandfather rights of a sort, according to the internal memo.
Brune said the state and private parties considered to be responsible for pollution based on the five-chemical standard will continue to provide alternative drinking water supplies. If the underground plume expands and more properties are polluted, alternative drinking water will be provided based on the old standard of the sum of five chemicals.
But at new sites across the state where contamination is detected, drinking water will only be provided if the sum of the two chemicals exceeds 70 parts per trillion, according to Brune. The old margin of error of 5 parts per trillion will no longer be used.
There is a both a public health question and a public relations question raised by this double standard.
New sites with PFAS pollution in which the sum of the two chemicals is below 70 parts per trillion will not be eligible for alternative drinking water supplies though they may have more contamination than 70 parts per trillion when the three other chemicals are included.
But no one will know because the state will not measure those three other chemicals in the water.
This is going to end up in court with each new site discovered to have PFAS pollution. The state will be telling residents in some areas that although the pollution level is higher than in other areas getting alternative drinking water supplies, they are not eligible because the state has a double standard based on when the contamination was documented.
Much of the contamination in Alaska has been found near airports and other facilities where a fire-fighting foam was used. The compounds have made their way into the ground water. Communities with drinking water impacts and contaminated sites identified so far include Fairbanks, North Pole, Eielson, Utqiagvik, Dillingham, Gustavus, Yakutat, Galena and King Salmon.