Fish advisory for PFOS in North Carolina’s Cape Fear River warns pregnant women to stay away from certain species of fish
Limited scope of advisory leaves the public vulnerable
By Pat Elder
July 19, 2023
North Carolina has issued its first fish advisory for PFOS. The North Carolina Department of Health and Human Services is advising women who are pregnant or may become pregnant to stay away from eating five species of fish caught in the Cape Fear River. The women are also advised to limit consumption of three species of fish to one meal per year. The advisory area extends from the Fayetteville Boat Ramp to the Bluffs on the Cape Fear River, about 12 miles northwest of Wilmington. The advisory limits the same five species to one meal per year for all other individuals, with seven meals allowed from the three species.
It is good to see the “Do Not Eat” advisory, even if it is only for some fish. The state is taking a courageous, yet limited first step toward protecting public health from these carcinogenic fish. The women should not eat any of these fish and neither should anyone else!
All the rivers in North Carolina can be expected to be contaminated with these toxins, so the advisories ought to be state-wide.
It's dangerous for the health of the mother and the child for the state to say it’s OK for pregnant women to eat one meal per year of American Shad, Blue Catfish, or Channel Catfish. The Department of Environmental Quality (DEQ) reported that an American Shad contained about 8,000 ppt of PFOS, while the EPA’s 2018-2019 National Rivers and Streams Assessment Fish Tissue Study shows dangerous levels of a host of PFAS compounds in fish in the Cape Fear River.
The DEQ’s press release announcing the fish advisory stated, “PFOS concentrations were similar to those measured in fish from other states, based on recent data from the USEPA.” The state is referring to the EPA’s 2018-2019 National Rivers and Streams Assessment Fish Tissue Study, a five-year-old study that has recently been made public.
It’s the way the EPA does things. This is a great human health crisis and they are not in front of it. Their immediate focus ought to be investigating and regulating the impact of PFAS on fetal placental nutrition.
Have we become so inhumane? It shouldn’t be up to the state of North Carolina to rediscover the wheel on this!
In 2018 the EPA tested five Channel Catfish in the Cape Fear River, 60 miles upstream of the Chemours plant, just north of Raven Rock State Park, in a region not covered by the PFOS fish advisory on the Cape Fear River. The mean concentrations are shown below.
Channel Catfish Cape Fear River
EPA #117673 35.50852 -78.96071
Compound ppt
PFDA 1,580
PFNA 247
PFUnA 2,630
PFDoA 2,950
PFTrDA 1,900
PFTeDA 1,370
PFOS 3,370
PFDS 241
PFOSA 474
Total 14,762
The state says it’s OK for anyone to eat this fish.
Although states across the country are rushing to establish fish advisories for PFAS they are concentrating almost exclusively on the deadly PFOS, to the detriment of public health. The compounds listed above regularly accumulate in fish from sea to shining sea. They’re dangerous and it’s time to address them.
PFDA is closely regulated in drinking water in several states because it has been linked to male and female reproductive effects, as well as pre-eclampsia and delayed effects due to prenatal exposure. This compound aggressively bioaccumulates in fish, in some species even more so than PFOS. PFNA is also regulated in drinking water in several states. It is associated with perinatal death, prenatal exposure, and delayed puberty. PFDA and PFNA may not exceed 20 ppt in drinking water in several states. PFOSA is associated with Teratogenesis, the process by which congenital malformations are produced in an embryo or fetus. PFUnA reduces serum testosterone levels during pubertal exposure. PFDoA induces cognitive deficits in laboratory animals.
Nonetheless, Dr. Zack Moore, NCDHHS State Epidemiologist, says there are no easy answers regarding the establishment of fish advisories. “We hope this information will help residents to make the best decisions for themselves and their families.”
Dr. Elizabeth Cuervo Tilson, State Health Director and NCDHHS Chief Medical Officer explained the state’s position, “Studies have documented the many benefits of eating fish,” she said. “We want residents to have these recommendations so they can make informed decisions about fish consumption, particularly if they regularly catch and eat fish from this part of the Cape Fear River.”
This is not the time to stress the benefits of fish! Sorry, doctors. Residents don’t have enough information to make these decisions for themselves. If you and the EPA had been doing your jobs all along, people would be more knowledgeable of the threat and more protected.
The state must establish a rigorous, routine testing regime and it must promulgate advisories that get closer to mirroring the EPA’s anticipated maximum contaminant level of 4 ppt for both PFOS and PFOA in drinking water. All PFAS compounds ought to be regulated as a class.
Why the double standard between the fish and the water?
The state tested fish at the 11 locations shown here. Partial results were made public from Site 4 up to Fayetteville. The highest concentrations were reported between Site 8 and Site 10, downstream of the Chemours Works plant and the Wastewater Treatment Facility in Smithfield. - map by NCDEQ
Snapshot of Site 9 on the Cape Fear River
People don’t pay much attention to fish advisories if the state doesn’t aggressively advertise and enforce them.
Site 9 is downstream of the Chemours Works plant in Fayetteville, North Carolina and directly south of the Wastewater Treatment Facility in Smithfield, North Carolina. It’s a double whammy.
According to the NC DEQ’s 2022 Water and Fish Collection Project, (February, 2023), this area on the river contained 20 ppt of PFOS, along with 17 other PFAS compounds in the water. We don’t know how much, if any, of the contamination is caused by Chemours or the treatment plant. The state should tell us.
Although the state has not released the database showing exact levels of concentrations of PFAS compounds in the water or in the filet of the fish, they have published bar graphs that give us a pretty good idea of the levels in the fish. Two Largemouth Bass were found with an average of 50,000 ppt of PFOS at Site 9.
Like the other fish, the Largemouth Bass also contained various concentrations of: PFUnA, PFDoA, PFTriA, PFDA, PFTA, PDFS, N-MeFOSAA, PFHxS, and PFOSA. We don’t know the exact concentrations.
The 50,000 ppt of PFOS in the Largemouth Bass is 2.5 million times above the EPA’s .02 ppt advisory for PFOS in drinking water. It is a good thing they think pregnant women shouldn’t eat this fish, but they’ll have to spend a lot of money telling people about it and enforcing it.
At site 9 the sum of 5 Bluegill Sunfish had a mean value of 35,000 ppt of PFOS while the sum of 5 Blue Catfish averaged about 18,000 ppt of PFOS.
Let’s look at how these chemicals bioaccumulate in fish.
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Excellent work by the North Carolina Department of Environmental Quality, although they don’t return phone calls.
“Bioaccumulation” is a developing study that is complicated by the fact that these pesky fish travel about. The state’s scientists sampled 37 Largemouth Bass and they sampled the water where they were caught. With the measurements, they calculated the Bioaccumulation Factor, or BAF.
PFOS has a BAF of 1,539. That means if the fish is in water that has 10 parts per trillion of PFOS, the fish can be expected to have 15,390 ppt of the toxins in its filet. The state reported a high of 30 ppt of PFOS in the Cape Fear River, but these are relatively low levels compared to areas near military bases.
The military poisons rivers and fish throughout North Carolina
The state’s advisory is very limited. An examination of poisoned fish must focus on military installations like Seymour Johnson Air Force Base, Camp Lejeune, or Fort Bragg. They are the heavy hitters.
Seymour Johnson AFB
North Carolina environmental activists Bobby Jones, Lib Hutchby, and Emily Keel on the banks of the Neuse River in Goldsboro, North Carolina on February 17, 2022. Bobby is holding the water sample he collected.
The groundwater at Seymour Johnson AFB contains 300,000 ppt of PFOS and 12,000 ppt of PFOA. These carcinogens find their way into the Neuse River. Surface water draining from the base had concentrations of PFOS at 3,100 ppt. This level is a hundred times higher than the highest levels reported in the Cape Fear River advisory area. Why doesn’t the state have an advisory for the Neuse River?
The activists reported 132.6 ppt total PFAS in the Neuse River. The Red X is the source of the surface water contamination at Seymour Johnson Air Force Base. The Blue X shows the spot where the trio tested water on the Neuse River, about 3 miles downstream of the PFAS releases.
Camp Lejeune
Photo - Camp Lejeune Fire and Emergency Services
The heavily publicized Camp Lejeune Justice Act of 2021 does not cover exposure to PFAS. The Navy reported PFOA in groundwater at 25,000 ppt while PFOS was reported to contain concentrations up to 172,748 ppt. The Navy refuses to publicize the levels of PFOS in surface water, although they are likely to be extraordinarily dangerous, especially considering the state’s work on the bioaccumulation factors.
On October 29, 2018, a failure in one of the AFFF suppression systems in a building on base resulted in a release of 1,000 gallons of AFFF concentrate to the sanitary sewer via the floor drain. 3 parts of the concentrate are mixed with 97 parts of water to create 33,000 gallons of foam, enough to cover numerous aircraft in a large hangar. A teaspoon of the foamy bubbles could poison a small city’s drinking water reservoir. 33,000 gallons will poison fish for miles, forever.
An overhead fire suppression system like this one drained into the local waterways at Camp Lejeune. Much of the PFAS used at Camp Lejeune empties into the New River. What’s in the seafood and what is the state going to do about it?
Fort Bragg
The Army is the least transparent of all the military branches in these matters. The Army has failed to publish a single report pursuant to the CERCLA process at Fort Bragg, so we don’t have any data. CERCLA is the Comprehensive Environmental Response, Compensation, and Liability Act, otherwise known as the Superfund Act.
We felt it was imperative to test the waters flowing out of the base for PFAS to gain some sense of the Army’s impact on the environment.
The Red X shows the likely site of the fire training area. We don’t know for sure because the Army is secretive about these things. The Little River flows east just to the north of the base. We collected the sample discussed below, where NC Rt. 24 crosses over the river. 35.194308, -78.987017
Results by Cyclopure
Our test location on the Little River was almost two miles from the suspected burn pit. The water was found to contain a total PFAS concentration of 107.1 ppt, while PFOS measured at 45.9 ppt. This is a higher concentration than anything we saw reported in the Cape Fear River.
We talked to several locals who said the fish in the river are too small to eat at this spot, but the fishing improved much further downstream
The Redbreast Sunfish
In Maryland, a Redbreast Sunfish caught in Piscataway Creek 3 miles downstream from the burn pit at Joint Base Andrews was found to contain 417,000 ppt of PFOS in its filet. No one eats these fish in Maryland! No one, that is, except for the Largemouth Bass who prowls in the tidal portion of Piscataway Creek.
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The Maryland Department of the Environment reported that a Largemouth Bass caught in the tidal portion of Piscataway Creek contained 94,200 ppt of PFOS in its filet. Joint Base Andrews is about ten miles upstream.
The state allows three meals of these fish to be consumed monthly by pregnant women and everyone else. When we compare Maryland to North Carolina, we see more grownups are making decisions in North Carolina. Still, the Tar Heel state has some heavy lifting to do. The fish are poisoned pretty much everywhere.
More results from the EPA’s 2018-2019 National Rivers and Streams Assessment Fish Tissue Study
Channel Catfish Roanoke River
EPA #116553 36.48171, -77.65994
One mile southwest of Gaston.
PFDA 534
PFUnA 1,090
PFDoA 530
PFTrDA 817
PFOS 4,080
PFOSA 199
Total 7,250
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Rock Bass Yadkin River
EPA #138173 36.21492, -80.96029
One mile west of Ronda, NC.
PFDA 259
PFUnA 872
PFDoA 1,100
PFTrDA 1,310
PFTeDA 794
PFOS 3,750
Total 8,085
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"Largemouth Bass Catawba River
EPA #116833 35.82241, -81.18404
Riverbend Park, Catawba, County
PFDA 836
PFUnA 2,550
PFDoA 2,420
PFTrDA 4,040
PFTeDA 1,170
PFOS 5,830
PFDS 353
Total 17,199
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I will be travelling to Japan in September and October with a delegation from Veterans for Peace to address audiences and to test surface waters for PFAS in 20 cities. It is expensive! Please help us! Please make a note that your contribution is for the Japan delegation. - Pat Elder
Financial support from the Downs Law Group makes this work possible. The firm is working to provide legal representation to individuals with a high likelihood of exposure to PFAS and other contaminants.
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Interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Join the Veterans & Civilians Clean Water Alliance Facebook group. (2.4 K members and growing rapidly.)