Frequently Asked Questions 2
The following information has been grouped in nine categories for the ease of the reader and linked to corresponding questions and answers below. The categories include:
1. PFAS Use and Current Regulations
2. PFAS Exposure and Safety Measures
3. History of PFAS Use at Nantucket Memorial Airport
4. Investigation and Remediation of PFAS
5. Groundwater and Drinking Water Sampling and Results
7. Residential Connections to Public Water
9. PFAS Remediation Funding and Procurement
1. PFAS Use and Current Regulations
What are PFAS?
PFAS is the collective acronym for Per- and polyfluoroalkyl substances, a group of manmade chemical compounds that have been manufactured and used in a variety of industries for many decades. PFAS compounds are often referred to as “forever chemicals”, as some persist in the environment through resistance to natural biodegradation or the ability to reconstitute themselves.
Some PFAS such as perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS), are byproducts of other commercial products that are released into the environment when other products are made, used, or discarded which has resulted in widespread wildlife and human exposure.
In Massachusetts, six PFAS compounds are currently regulated and often referred to as “PFAS6.” The regulations apply to the allowable limits of the concentration found in drinking water and soil. These six PFAS compounds include:
Perfluorooctane sulfonic acid (PFOS)
Perfluorooctanoic acid (PFOA)
Perfluorohexane sulfonic acid (PFHxS)
Perfluorononanoic acid (PFNA)
Perfluoroheptanoic acid (PFHpA)
Perfluorodecanoic acid (PFDA)
Why are PFAS used?
PFAS are most often used commercially to create grease-, water-, and stain-resistant barriers and coatings for materials, including TeflonTM, grease-resistant takeout containers, and upholstery and carpet treatments, as well as components of fire-retardant and control agents.
Also, due to the use of PFAS compounds by many industrial and manufacturing processes to reduce friction, they have been used in a variety of other applications, including military, aerospace, automotive, construction, firefighting, and electronics.
What common products contain PFAS?
According to the U.S. Environmental Protection Agency (USEPA), PFAS compounds can be found in the following common products and locations:
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Food packaged in PFAS-containing materials, processed with equipment that used PFAS, or grown in PFAS-impacted soil or water.
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Commercial household products, including stain-resistant and water-repellent fabrics, nonstick products (e.g., TeflonTM), polishes, waxes, coatings, paints, cleaning products, and firefighting foams (a major source of PFAS-impacted groundwater and soil at airports and military bases where firefighting training has historically occurred).
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The workplace, including production facilities or industries (e.g., chrome plating, electronics manufacturing or oil recovery) that use PFAS.
Why are PFAS a concern?
PFAS compounds are very persistent in the environment and in the human body – meaning they do not break down, and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects.
Are PFAS still used or manufactured in the United States?
Certain PFAS chemicals are no longer manufactured in the United States as a result of cooperative initiatives including the PFOA Stewardship Program where eight major chemical manufacturers agreed to eliminate the use of PFOA in their products and the resulting emissions from their facilities.
Although the majority of PFOA compounds are no longer manufactured or used in manufacturing in the United States, many are still produced internationally and can be imported into the United States in consumer goods such as carpet, leather and apparel, textiles, paper and packaging, coatings, rubber, and plastics.
Are PFAS regulated?
The United States Environmental Protection Agency (USEPA) began regulating PFAS in 2016. The Massachusetts Department of Environmental Protection (MassDEP) began regulating PFAS in 2018. For further information published by the USEPA and MassDEP, please review USEPA PFAS Fact Sheet (2016), USEPA PFAS Technical Fact Sheet (2017) and the MassDEP PFAS Fact Sheet (2020).
On October 2, 2020, MassDEP published its PFAS public drinking water standard, that called for a Maximum Contamination Level (MCL) of 20 parts per trillion (ppt). The 20 ppt threshold applies to each of the six individual PFAS compounds and applies to the sum of the six PFAS compounds currently regulated by the State of Massachusetts. These six compounds are referred to as PFAS6.
The six regulated PFAS compounds by MassDEP include the following:
Perfluorooctane sulfonic acid (PFOS)
Perfluorooctanoic acid (PFOA)
Perfluorohexane sulfonic acid (PFHxS)
Perfluorononanoic acid (PFNA)
Perfluoroheptanoic acid (PFHpA)
Perfluorodecanoic acid (PFDA)
This 20 ppt MCL for drinking water has been set by MassDEP to protect public health. Additional information regarding PFAS is found on the MassDEP website as well as the MassDEP PFAS Fact Sheet (2020).
2. PFAS Exposure and Safety Measures
How do I reduce my exposure to PFAS?
Personal exposure to PFAS can be reduced by not choosing products or packaging that contain PFAS, such as stain treatments, water repellents, and grease resistors. A few recommendations are as follows:
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Avoid the optional stain treatment on new carpets and furniture.
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Avoid clothing that is labelled stain-resistant or water-repellent and has not undergone TeflonTM or Scotchgard™ treatments.
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Avoid non-stick pots and pans and kitchen utensils; opt for stainless steel or cast iron products instead.
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Avoid foods (typically “fast” foods) that are packaged or wrapped in material that repels grease, oil and water since these are typically PFAS-treated.
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Avoid microwaveable popcorn since the bags are often coated with PFAS on the inside.
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Avoid personal care products and cosmetics with Polytetrafluoroethylene typically listed as “PTFE” or “perfluoro” in the ingredients.
Is it safe for residents within a mile of the airport to drink their well water?
As a result of the investigation conducted by the Airport, the three areas of PFAS-impacted drinking water have been identified adjacent to the airport, but not all homes within this area are affected. The three areas are indicated by the yellow circles on this PFAS Study Area Map. Residences located outside of these three areas are not expected to have PFAS-related impacts from the Airport.
It should be noted that PFAS compounds are being detected in drinking water and groundwater throughout the United States. PFAS detected in drinking water can originate from other sources that are not related to the Airport. The Town of Nantucket is currently conducting an island-wide study to assess and identify the potential for other sources of PFAS that could impact groundwater and drinking water. The Massachusetts Department of Environmental Protection has also opened its own source area investigation for other PFAS impacts on Nantucket.
Are residents being advised to not drink or cook with their well water?
Residents whose private well water has tested with PFAS6 above 20 parts per trillion are advised not to drink or cook with their private well water until a treatment system is installed, known as a Point-of-Entry Treatment (POET) system or the Wannacomet Water Company water line extension project is completed.
In an abundance of caution, bottled water has been provided and will continue to be provided to all residences with any detectable concentrations of PFAS6 located in the three study areas, even if below 20 parts per trillion regulatory standard set by MassDEP, although results less than 20 parts per trillion are considered safe to drink.
Is dermal (or skin) contact a concern? Can I shower or bathe with my well water?
MassDEP has advised the Airport that concentrations of PFAS6 greater than 200 parts per trillion could pose a long-term health risk through the dermal (skin) contact.
As a result, residents whose private well water has tested with PFAS6 above 200 parts per trillion are being advised to limit bathing or showering with this water to limit contact with the skin until a treatment system is installed, known as a Point-of-Entry Treatment (POET) system or the Wannacomet Water Company water line extension project is completed.
Can I do laundry, and brush my teeth with my private well water?
Residents whose water has tested with PFAS6 above 200 parts per trillion are being advised to limit washing laundry with their private well water to limit contact with the skin until a treatment system is installed, known as a Point-of-Entry Treatment (POET) system or the Wannacomet Water Company water line extension project is completed.
For water contaminated by PFAS6 above 20 ppt, it is recommended that an alternative water source be used any activity in which water might be ingested, such as brushing teeth, to reduce the likelihood of exposure until a POET system can be installed or the Wannacomet Water Company water line extension project is completed.
Will the airport firefighters be tested for PFAS?
The Airport Commission has reviewed what other commercial service airports that have tested Aqueous Film Forming Form (AFFF) as required by Federal Aviation Administration (FAA) have provided blood testing for airport firefighters. As of late 2020, we have found no example of any other airport doing so. In addition, other agencies that have considered this issue have declined to provide such testing.
The official stance of the United States Department of Defense (USDOD) appears to be to not test their designated firefighters for PFAS during their annual medical exams. The USDOD states: “At this time, there is no requirement for the medical exams to include testing for Per- and polyfluoroalkyl substances (PFAS), some of which are present in AFFF, specifically PFOS and PFOA. The CDC does not recommend PFAS blood testing for anyone at this time because the results have no clinical value for diagnosis and/or treatment.”
Similarly, the Agency for Toxic Substances and Disease Registry (ATSDR) explicitly states “[PFAS] blood test will not provide information to pinpoint a health problem nor will it provide information for treatment. The blood test results will not predict or rule-out the development of future health problems related to a PFAS exposure.... test results will tell you how much of each PFAS is in your blood but it is unclear what the results mean in terms of possible health effects.”
Finally, the official stance of the United States Department of Veterans Affairs does not recommend blood tests to determine levels of PFAS in any individual. This is because “most people in the U.S. have measurable amounts of PFAS in their blood and normal ranges have not been established. Also, blood tests cannot be linked to current or future health conditions or guide medical treatment decisions.”
Overall, all three agencies seem to fall back on the following logic:
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PFAS is so prevalent in background levels that individual testing will not lead to conclusive results.
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The only way to start determining any sort of linkages would be to start extensive testing at the community-wide level.
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There is currently no mandate (or money) for that breadth of testing, either from local, state, federal officials, and even if there was, it seems the scientific community wouldn’t know what to make of the results.
3. History of PFAS Use at Nantucket Memorial Airport
How did groundwater at the Airport become impacted by PFAS?
Groundwater may have been impacted by the Airport’s use of a specific type of firefighting foam known as Aqueous Film-Forming Foam (AFFF). This foam, containing PFAS compounds, has been required for use by the Federal Aviation administration (FAA) for training and aircraft emergencies. In both scenarios, the AFFF has been released onto the ground surface. Based upon written records held at the Airport, this foam has been used at the Airport from 1989 to 2018.
However, non-Airport generated sources of PFAS are likely present in the groundwater as well and are also being investigated.
What is Aqueous Film-Forming Foam (AFFF) and why is it used at the Airport?
AFFF is used as a fire suppressant to respond to aircraft emergencies. Recurrent firefighter training is required by the Federal Aviation Administration (FAA) for Commercial Service Airports (also known as a “Part 139” airports). Nantucket Memorial Airport falls in the category of a Part 139 airport and has been required to conduct yearly on-site training using AFFF.
The FAA is currently researching alternative fire suppressant foams that do not contain PFAS compounds.
How much of the PFAS-containing foam was discharged on the Airport?
Airport records indicate that between 1,910 and 2,535 gallons of Aqueous Film-Forming Foam (AFFF), known to contain PFAS, had been discharged at nine distinct locations on the Airport. These nine locations are shown as solid orange dots on this PFAS Release Location Map.
Is this PFAS-containing foam currently stored on the Airport?
The inventory at the Airport indicates that a total of 1,780 gallons of Aqueous Film-Forming Foam (AFFF) is currently stored on the Airport. The firehouse contains 325 gallons of AFFF and the firefighting trucks contain 1,425 gallons of AFFF.
When did the Airport start using PFAS-containing AFFF and is it still used?
Airport records (available since 1989) indicate that Aqueous Film-Forming Foam (AFFF) was used at the Airport from 1989 to 2018. The last known release to the ground surface occurred on October 15, 2018 as part of the testing and firefighting training required by the Federal Aviation Administration (FAA).
The FAA authorized the use of "foam-free" testing operations which allows the AFFF to be recirculated within vehicles, and its firefighting properties to be tested without requiring on-the-ground application. The Airport has been using an E-ONE AFFF testing system for its firefighting training to prevent the further release of AFFF onto the ground.
The airport is also in the process of converting its fuel farm fire suppression system to a form that is free of fluorine. The conversion is anticipated to be complete by June 2021. This fluorine free foam is an acceptable alternative for the fuel farm as the fuel farm is not regulated by the FAA.
No future release of PFAS-containing AFFF is anticipated unless it is as part of a response to an actual aircraft emergency before an alternative type of foam is allowed for use by the FAA.
How long has the groundwater at the Airport been impacted by PFAS?
The date from when groundwater impacts occurred from PFAS compounds is unknown. The PFAS-containing Aqueous Film-Forming Foam (AFFF) has been used at the Airport since 1989.
The groundwater at the Airport was first tested for the presence of PFAS in February 2020 in response to a MassDEP Request for Information (RFI) / Notice of Response Action (NORA) regarding the Airport’s AFFF use.
4. Investigation and Remediation of PFAS
What is the Airport doing about the PFAS groundwater impacts?
The Airport is currently working with MassDEP through its Licensed Site Professional (LSP), according to statutory provisions under the Massachusetts Contingency Plan (MCP), to investigate and mitigate any PFAS-impacted groundwater.
All investigation and remediation work is under the supervision of the MassDEP. All reports and results generated are posted for public review on the Study Documents page of this website. Updates are posted as they become available.
What is the extent of the PFAS plume and why hasn’t this been determined already?
The Airport has been working with the MassDEP to identify the extent of the PFAS-impacted groundwater on and near the Airport and to provide treatment and alternative sources of potable water. The initial focus of the investigation was to determine which residences near the Airport may have had their private wells impacted with PFAS.
The extent of the PFAS plume on and in the vicinity of the Airport property is continuing to be assessed according to the regulatory timeline provides under the MCP.
Is soil being investigated for potential impacts?
Yes, the Airport is working with the MassDEP to determine the extent of the PFAS-impacted soil on the Airport. Results of the investigations conducted thus far are included on the Study Documents page of this website. Updates are posted as they become available.
Is the Airport looking for other contaminants, or just testing for PFAS?
PFAS is the only group of chemical compounds that may be attributed to historic use of Aqueous Film-Forming Foam (AFFF) at the Airport. The airport is not required to investigate other contaminants at this time.
5. Groundwater and Drinking Water Sampling and Results
What sampling was/is being done and what are the results?
All sampling and results are posted on the Study Documents page of this website. Updates are posted as they become available.
May I pay for my own test during this phase?
If private and personally funded sampling is your preference, there are laboratories that can analyze your water sample for PFAS. A few of the options include:
Any decision you make for private testing is beyond the Airport’s investigation and would not be considered participatory under the Massachusetts Contingency Plan (MCP) or reimbursable by the Airport.
Why did the first round of testing well water only include the residences on Madequecham Valley Road and not on the west side of the Airport?
The Airport has been working with experts from MassDEP and their Licensed Site Professional (LSP) to identify groundwater flow patterns and PFAS migration, to assess which areas adjacent to the Airport are potentially at risk for PFAS contamination from Aqueous Film-Forming Foam (AFFF).
Based on the initial investigative work conducted by the LSP and in consideration of the statutory provisions of the Massachusetts Contingency Plan (MCP), it was determined that the residential water wells that abut and are to the south (downgradient) of the Airport, which are those along Madequecham Valley Road, were of most concern and tested first.
The areas to the west (cross-gradient but close to several known AFFF application areas) were the next concern and were sampled next.
What other residences were tested?
The presence of PFAS generated from the Airport is unlikely to be located to the north of the Airport because that area is up-gradient, or “up-stream”, from the direction of groundwater flow.
Based on the results of the initial sampling conducted by the Licensed Site Professional (LSP) and in accordance with the statutory provisions under the Massachusetts Contingency Plan (MCP) additional testing was done at the residences located to the west of the airport, including residences on Monohansett Road, Nobadeer Way, Evergreen Way, and in the Skyline Drive area.
Details regarding the sampling and results are included on the Study Documents page of this website. Updates are posted as they become available.
6. Residential Bottled Water
Will you provide bottled water until we are tested?
Residences will be offered bottled water based upon the following two scenarios:
Scenario 1 - Bottled water will continue to be provided if PFAS6 have been detected above 20 parts per trillion, until the Point-of-Entry Treatment (POET) system has been installed or until the Wannacomet Water Company water line extension project is completed, whichever comes first.
Scenario 2 - Bottled water will continue to be provided if any level of PFAS6 is detected below 20 parts per trillion, until the final Feasibility Study is conducted and confirms that PFAS6 do not exist above established background levels.
I have heard carbon filters don’t work. What kind of filter is necessary for PFAS?
The specialty systems that are currently being installed use either a specific synthetic resin or granular activated carbon (GAC) to remove the PFAS compounds.
Both the resin and granular activated carbon, or a combination of both, have been shown to effectively remove PFAS compounds down to the very low levels needed. Recurrent testing has confirmed that these systems are effective at meeting the 20 parts per trillion standard set by MassDEP.
Although domestic water filtration systems found at home improvement centers may be able to remove some PFAS from drinking water, depending on the size and type of filter used, they are not designed to attain the very low concentrations, below 20 parts per trillion, needed to meet the current MassDEP drinking water standards.
Where can I purchase an effective filter system?
The Airport is purchasing and installing specialty water filters on residences where PFAS6 have been detected above the 20 ppt standard. Additional information for home water filters can be found on the MassDEP website.
Can more houses have the Point-of-Entry-Treatment (POET) system installed?
POET systems are being installed in homes near the Airport where PFAS6 concentrations have been found to exceed the 20 ppt standard for drinking water set by the MassDEP.
Homes with PFAS6 concentrations below 20 ppt will not be provided with POET systems but have been offered bottled water.
7. Residential Hookup to Public Water
What is the status of providing public water to impacted residences?
The water line extension is currently being designed, and the Airport is securing the regulatory approvals needed prior to the start of construction. Approval is required from the Massachusetts Natural Heritage Endangered Species Program, Nantucket Conservation Commission, and Federal Aviation Administration.
Will town water be supplied to Madequecham Valley Road?
The Town of Nantucket, the Airport, and Wannacomet Water Company are actively working together to extend the water line to PFAS-impacted residences.
What is the protocol to request testing?
There is no protocol to request testing. If your residence has been identified for inclusion in the Airport’s investigation, you will be contacted directly by the Licensed Site Professional (LSP).
8. Public Communications
How will you communicate with residents?
This website is routinely updated with the latest results, maps, and reports related to the PFAS investigation and remediation measures. In addition, the Airport Commission has held public meetings (virtual format) where updates are provided and questions from the public are answered. Town of Nantucket meeting announcement procedures are followed. The public meetings are held on Zoom and streamed on YouTube and recorded for future viewing.
Why didn’t you notify the residents sooner, back in April 2019?
Although the Airport responded to a Request for Information (RFI) / Notice of Response Action (NORA) from the MassDEP in April of 2019, testing was not required until February 2020.
Upon receipt of testing results, the Airport knew if and where PFAS-impacted drinking water occurred and responded according to MassDEP requirements. Notifying residences was done in accordance with MassDEP requirements.
Due to the serous impacts of this, can we officially request that a more widespread testing around the airport (including the north side) be undertaken?
Requests for testing are not necessary. The Airport is currently working with the MassDEP through its Licensed Site Professional (LSP) to continually identify any testing required to satisfy the requirements of the MassDEP.
9. PFAS Remediation Funding and Procurement
What does the recent town emergency declaration do regarding funding sources?
The Airport and Town of Nantucket have sought and obtained approval to spend above their current appropriation. This is a temporary step that allows the Airport to continue Phase I work efforts for the investigation of the presence of PFAS.
Can you appeal to the State of Massachusetts for remediation funds?
Any party can appeal to the Massachusetts Legislature for project funding. However, at this time, grant funding is not readily available for PFAS. Existing programs provide low interest loans or other access to capital for specific programmatic areas that may be available to address aspects of PFAS mitigation but would need to be approached by the individual eligible party.