News from the New Hampshire Department of Environmental Services

FOR IMMEDIATE RELEASE

DATE: June 28, 2018

Opinion/Editorial
Addressing the PFAS Threat to Our Drinking Water –
Robert Scott, NHDES Commissioner
des.nh.gov
twitter.com/NHDES
"Earlier this week (June 25-26), I attended an important community engagement event sponsored by the United States Environmental Protection Agency (EPA) to address the challenge of per- and polyfluoroalkyl substances (PFAS) in our environment. In an effort to promote a greater understanding, it is important to provide clarity on recent information released from the federal government that you may have heard in the news and share an update on our ongoing efforts.

PFAS contamination of our environment, especially our groundwater and drinking water, is an issue of growing national concern. While many other states are just becoming educated on PFAS, New Hampshire has been working with PFAS impacted communities for more than four years.

PFAS are a very large group of man-made chemicals that are prevalent in many commercial products, including stain- and water-repellent or nonstick products that we have all used at one time or another. They are also used in industrial and manufacturing processes, and certain types of fire-fighting foam. These chemicals do not break down in the environment and are persistent in the human body causing significant concerns about potential adverse health effects.

In 2016, my department established an Ambient Groundwater Quality Standard (AGQS) for two PFAS chemicals – Perfluorooctanoic acid (PFOA) and Perfluorooctanesulfonic acid (PFOS) – based largely on a new EPA lifetime Health Advisory of 70 parts per trillion (ppt) for each of the chemicals separately or in combination. This is not a drinking water standard but rather an enforceable cleanup standard when contaminants are found. New Hampshire is a national leader, being one of only a few states that currently have an enforceable standard in this area.

Additionally, Governor Sununu is poised to sign legislation that provides my department a toxicologist position and a human health risk assessor position that will allow us to propose state rules establishing drinking water standards (MCLs) for the following PFAS chemicals: PFOA, PFOS, perfluorononanoic acid (PFNA), and perfluorohexanesulfonic acid (PFHxS) by January 1, 2019. To accomplish this, we will use the most up-to-date, science-based information available, including the new toxicological profiles recently released by the Agency for Toxic Substance for Disease Registry (ATSDR), which identify Minimal Risk Levels (MRLs) for these chemicals. It is important to note, these are not intended to be regulatory standards, but are used as a screening level that is specific to the investigation of Superfund sites to determine the need for further investigation.

A drinking water standard (i.e., MCL), on the other hand, is a specific enforceable regulatory standard for public water systems that is focused on the protection of human health for all life stages and exposure periods associated with the ingestion of contaminants in drinking water, and is developed using assumptions about other sources of exposure to the contaminant. They also take into account practical considerations such as the extent to which the contaminant is found in New Hampshire, the ability to detect and treat the contaminant in public water systems, and the costs and benefits to affected parties that will result from establishing the standard.

In New Hampshire, because of our proactive sampling efforts, we currently have 40 active PFAS drinking water contamination investigations, and are witnessing first-hand the impact that these PFAS contaminants are having on communities and residents in the Granite State. We look forward to working closely with our community leaders, other states and our federal partners to advance this issue in the coming months and to create a clear path toward greater regulatory certainty and public health protection related to PFAS contamination."

You can access our previous webpage for archived information: https://www.des.nh.gov/organization/commissioner/pfoa.htm .

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According to NH Department of Environmental Services, they estimated NH's life cycle and operating costs, and breakdown of capital improvement expenses that should be per year.

CAPITAL COST

EQUIPMENT ANNUAL COST LIFE CYCLE COST

Heat Pumps 015 Units ------------- 190,400.00

030 Units ------------- 358,600.00

Pumps Close Loop ------------- 20,000.00

Piping Steel Piping ------------- 340,629.00

Chiller 430 Tons ------------- 200,000.00

Cooling Tower Electricity ------------ 100,000.00

OPERATING COST

EQUIPMENT ANNUAL COST LIFE CYCLE COST

Heat Pumps 015 Units 7,076.99 88,194.90

030 Units 18,506.55 20,632.53

Pumps Closed Loop 2,274.27 28,342.49

Piping Steel Piping 205,035.04

Chiller ------------- 22,539.85 280,896.37

Cooling Tower Electricity 5,907.88 73,625.19

Water Loss 398.40 4,964.94

CAPITAL AND OPERATING COSTS TOTALS 56,703.94 1,911,320.46

CAPITAL IMPROVEMENT PLAN

2018 34,000,000

2019 52,000,000

2020 192,000,000

2021 50,000,000

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New Hampshire Town And City

New Hampshire’s Water Assets Under Pressure: Public Drinking Water Systems

Tim Fortier, a Government Affairs Advocate for the New Hampshire Municipal Association, reported back in October 2011, valuable important point of facts - "In the first of a four-part series focusing on the State's water infrastructure: public drinking water, wastewater, storm water and dams. Each article will spotlight a municipal system; address critical needs of that infrastructure system; and outline funding sources available to municipalities today that may be used to maintain and sustain these critically important infrastructure systems.

We have basic water infrastructure systems that go generally unnoticed by us—the consumers. We pour tap water into our glass and drink reassured that it is safe to drink. We flush our toilets and the waste simply vanishes. When it rains, contaminants are washed off rooftops, parking lots and streets, and this runoff is channeled through a series of catch basins, drains and underground pipes to places unknown. New Hampshire municipalities own nearly 400 dams statewide that provide recreational lakes, fire ponds, flood control and water supply storage. Yet the public pays very little attention to these basic water systems, that is, until a pipe bursts, the toilet clogs, the streets flood or, more tragically, a dam fails.

We hope by highlighting these important water assets, ordinary citizens and policymakers alike will better understand the value these assets provide for the protection of public health and safety and in supporting economic growth and development in all of our 234 communities.

Whatever infrastructure a municipality owns, the challenges are generally the same:
(1) aging infrastructure systems that have not been consistently maintained due to funding shortfalls;
(2) a continually evolving regulatory environment; and
(3) declining state and federal funds that municipalities have historically depended upon to finance these capital improvements. A growing population and increasing demand has also put mounting stress on these water systems.

The first article in our series will focus on public drinking water systems.

Background: Public Drinking Water Resources
New Hampshire lays claim to one of the earliest underground water systems in America. In 1797, a private company called the Portsmouth Aqueduct Company brought water some 2.5 miles within the city compact through a system of wooden pipes. The City of Portsmouth ultimately purchased the system in 1892.

Municipally-delivered drinking water is derived from two primary sources—surface water and ground water. According to the New Hampshire Water Resources Primer, about 39 percent of the State's population is served by community systems using only surface water (lakes and rivers) and 38 percent by systems using only groundwater. Another 23 percent is served by systems using both surface and groundwater sources.

Regardless of the source, municipal drinking water is typically treated, filtered and disinfected, and then pumped or gravity fed through a distribution system to residential and business customers. It all sounds so simple, but the true cost to deliver this essential service to the public is not cheap, and these true costs are rarely reflected in rates to consumers. In fact, water is priced well below the full cost of providing this critical service, with the statewide average annual cost to a household ($503) less than what is typically spent yearly for cable television.

Local governments invest significantly in projects that build and maintain our water system infrastructure, but not at a rate to ensure system adequacy for the future. In a perfect world, municipalities would be charging the full cost of delivering safe tap water and would have fully-funded asset renewal accounts and very little deferred maintenance.

In the real world, however, there is only one municipal checkbook with many competing needs that have resulted in limited investment in water systems at all levels of government. The water system investments that are occurring are made with annual operating funds raised through low user charges, municipal bond issuance, plus federal and state loan and grant programs such as the State Revolving Funds, which are declining. Few municipalities have the ability to fully fund asset replacement accounts or maintain their systems to industry-specified standards.

In 2011, a Department Environmental Services study concluded that the gap between the capital investment needs and current funding levels for drinking water infrastructure was $1.173 billion over 20 years (the period covering 2010-2030), and this does not take into account other costs driven by population growth, increased demand, emerging technologies or regulatory changes.

This underfunding has resulted in deferred maintenance and underfunded asset renewal accounts, and this is the primary reason why our State's water infrastructure has been in decline.
State legislative and executive branch leaders are aware of the problem with our aging water infrastructure and the significant challenges surrounding it.

Declining State and Federal Funding Support
The ability for municipalities to fund future investments in water systems and comply with new regulations is reliant upon adequate funding. Clearly, municipal funding is limited and competes with many other compelling needs while, at the same time, the federal and state resources available to assist cities and towns in maintaining these water systems are shrinking fast.

Like most other states, New Hampshire's water infrastructure was built over the past century with significant grant and loan funding. With the passage of the SDWA in 1974, significant investments were made by the federal, state and municipal governments in New Hampshire's public water systems. "Most of these past grant programs were designed to be 'one-shot deals' with the concept that the local utility would build asset renewal or replacement costs into their rate structure so the utility could operate sustainably without additional subsidies," said Brown. "Unfortunately, this did not happen in many cases and we now need creative thinking as to how we will accomplish the backlog of infrastructure work."

Another member of the Governor's Commission, Robert Beaurivage, agreed. "One major problem is the lack of adequate financial resources to rehabilitate piping systems, treatment plants and storage reservoirs. The decline in state and federal funding simply aggravates the problem," said Beaurivage. "And the concept of raising water rates is challenging particularly during the current economic downturn."

The EPA provides annual capitalization grants to each state Drinking Water State Revolving Fund (DWSRF) program to promote safe and affordable drinking water as authorized by the SDWA. These grants are available for existing system improvements and, on average, provide New Hampshire's water systems with about $8 million annually.

In 2011, the DWSRF allotment to New Hampshire (referred to as the capitalization grant) was $8,248,520 (including 20 percent state match) for infrastructure projects. In addition, another $7.4 million in repayment funds collected over four years is also available for water infrastructure projects. Many New Hampshire municipalities fund the planning, design and construction of these projects through this fund. The DWSRF has provided public water systems funding for various projects such as the development of new wells, upgrade or installment of treatment facilities, replacement of water mains and the installation of new storage tanks.

Historically, municipal demand for these funds has far outpaced available funding. The current demand for DWSRF funding (based upon 41 new applications) is nearly $58 million, which far exceeds the available loan funds. For municipalities, utilization of state and federal loan and grant programs helps keep the local user fees low. When these funds, grants and loan programs dry up, however, most municipalities will be forced to borrow from other sources with higher borrowing costs to complete these projects with resulting impacts on user rates.

To worsen matters, the recent debt ceiling deal signed into law by President Obama will set into motion years of spending cuts, at least $1.5 trillion in deficit reduction starting in 2013, and will likely impact many federal grants that go out to drinking water programs. Unfortunately, the EPA's Clean Water State Revolving Loan Fund, which currently hovers around $800 million a year, is a vulnerable target for Congress. As such, the real implications of future budget cuts are not fully understood at this time, but it certainly does not bode well for future federal investments in our nation's water infrastructure systems.

"The State and local government partnership is unpredictable," said David Bernier, Superintendent of the North Conway Water Precinct and a member of the Governor's Water Commission. "As a public water system, we must first gain public trust and support, second procure affordable funding, and lastly engineer and construct. All this takes years to accomplish, but this relationship is in jeopardy and is now compounded by the State's default on paying their fair share of these projects."

As we move forward, municipalities must assume the leadership role of sheparding these important assets onto a sustainable path forward. This will require, among other things, educating the public about the true cost of water service and involving them in tradeoff decisions concerning level of service and cost of service.

Because of declining state and federal funds, municipalities need to charge customers the true cost of water up to some affordable threshold. Advocating for continued state and federal support is also part of the solution, as is exploring new ways to pay for these water infrastructure improvements. These investments are necessary to address both increasing infrastructure asset renewal demands to comply with new regulations and to accommodate increased growth and demand.

"Failure to reverse the trend of declining infrastructure will have many undesirable consequences and will place an unfair burden on future generations," said Brown. "The only responsible path forward is to reverse this trend and support municipal efforts to restore sustainable stewardship of these assets now."

"By all accounts, the current rate of investment is grossly insufficient to fund the infrastructure that will be required to assure continued safe and reliable water service across New Hampshire. However, some State legislators, municipal leaders and water utility experts are increasingly worried that the traditional funding sources will not be sufficient to address future anticipated costs. Now is the time for State leaders to collaboratively forge a path toward a sustainable water infrastructure for all of New Hampshire."

Tim Fortier is Government Affairs Advocate for the New Hampshire Municipal Association. Contact Tim at 800.852.3358, ext. 384, or by email.

Grant and Loan Sources

Community Development Block Grants (Public Facilities Grants)
NH Community Development Finance Authority
100% grant up to $500,000 for planning and construction; 1-to-1 match
Deadline: January and July for construction grants; April and October for planning grant

Drinking Water State Revolving Fund (SRF) Loans
NH Department of Environmental Services
0.895% to 2.864% interest; 5 to 20 years; capital improvements, design and constructionDeadline: July 1 for pre-applications; August and after for final applications

USDA Rural Development Water & Wastewater Loan/Grant
US Department of Agriculture, Rural Development
Direct and guaranteed loans and grants; 2.5% to 4.25% interest (rates change quarterly); 30 years; grant amounts are a function of program funding and project-specific factorsDeadline: Rolling application

Timothy fortier's Sources and Author Acknowledgements
Special credit and recognition to New Hampshire Department of Environmental Services' (DES) Administrator, Drinking Water and Groundwater Bureau, Sarah Pillsbury, and Wright-Pierce's CEO and President, Bill Brown, who spent much time and energy peer reviewing this article and providing their expertise on the subject matter.

Valuable input and contributions also from: North Conway Water Precinct Superintendent David Bernier; Camp, Dresser & McKee consultant Bill Hounsell; City of Manchester Water Works's Bob Beaurivage; and New Hampshire Water Works Association's Steve Del Deo.

This article cites extensively from the 2008 New Hampshire Water Resources Primer (prepared by DES); Drinking Water Infrastructure in New Hampshire: A Capital Investment Needs Analysis (prepared by Wright-Pierce); the 2011 Drinking Water State Revolving Fund: Intended Use Plan (submitted by DES to EPA dated August 2, 2011); and the Town of Conway's Master Plan (adopted May 29, 2003). Additional information for this article also gleaned from DES' website, including fact sheets and other educational materials on the topic."
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Reported in September 2016 by Mike Carraggi, Patch National Staff -
"A new report shows many drinking water supplies in New Hampshire have the cancer-causing toxin chromium-6, which became a household name after Julia Roberts' 2000 megahit based on the real-life environmentalist Erin Brockovich's investigation of groundwater in Hinkley, California.

Chromium-6 has been linked to cancer, reproductive problems and liver problems, but the measurements in New Hampshire communities fall well short of the levels in Hinkley — about 1.19 parts per billion, with a peak of 3.09 ppb — according to the report from the Environmental Working Group.

Furthermore, none of the towns on the list come close to exceeding the U.S. Environmental Protection Agency's maximum of 100 parts per billion of total chromium. The highest result in New Hampshire came from two water sources in Portsmouth at .46 parts per billion.

The Environmental Working Group identified towns that exceed 0.02 parts per billion in tap water, a level that California's Office of Environmental Health Hazard Assessment set as a public health goal in 2011. The goal was set after Brockovich was successful in building a case against the Pacific Gas and Electric Company of California in 1993 that blamed the company for contaminating local water.

Officials in California believe even that level of the contaminant can be harmful and pose a cancer threat — not just for people who drink the water, but also bathe in it or have any contact.

Before you run out to buy a water filter, it is important to understand the context. At California's recommended level of chromium-6, "one out of 1 million people is likely to get cancer after drinking that water for 70 years," reports The Verge.

The Environmental Working Group, a non-profit organization dedicated to protecting human health and the environment, analyzed federal data from nationwide drinking water tests showing that the compound contaminates water supplies for more than 200 million Americans in all 50 states.

"Yet federal regulations are stalled by a chemical industry challenge that could mean no national regulation of a chemical state that scientists in California and elsewhere say causes cancer when ingested at even extraordinarily low levels," according to the report.

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