Poisoned fish and water in Brunswick, Maine
The threat of PFAS in fish is real.
By Pat Elder
October 2, 2024
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The Naval Facilities Engineering Systems Command will be holding a virtual meeting of the former Naval Air Station (NAS) Brunswick Restoration Advisory Board (RAB) on Wednesday, October 2, 2024.
Time: 6:00 pm - 8:00 pm
Location: Virtual Access Only
Connection Details: click this link
Meeting Agenda: click this link
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Be careful, Brunswick! Fish like this fried smallmouth bass from the Androscoggin River may be loaded with carcinogens.
Poisoned fish and seafood are the greatest threat posed by the August 19 PFAS foam spill at the former Brunswick Naval Air Station. We must keep this simple fact in mind as state, local, military, and federal agencies jockey for public attention.
Most of the PFAS in our bodies is from the food we eat, especially the fish. The Maine Department of Environmental Protection, (DEP) has published 12 reports on the spill since August 21, 2024. In these reports to the public they have mentioned “water” 149 times, “fish” 12 times, and they have never never mentioned the air. Fish and air are also regarded as primary pathways to human ingestion for these chemicals.
The Brunswick-Topsham Water District says the public drinking water supply is safe to drink and is not affected by the chemical spill. We have no reason to doubt them.
The Maine Department of Environmental Protection sampled 34 water supplies in the area of the spill and has contacted property owners to discuss the results which have not been made public. It is becoming apparent that drinking water wells east of the release site may not have been heavily impacted by the spill. However, it may be a matter of time before the carcinogens reach the depth of the wells.
Without a great deal of testing at various levels below the ground surface at multiple locations we won’t know the depth of the toxins or their direction. Regular testing safeguards human health. The Maine DEP says the handful of wells will be tested every three months for just one year. It should go on indefinitely.
The military has played a kind of shell game with the depth of testing at contamination sites around the country, reporting low concentrations of toxins close to the gound surface where levels may be low after years of seeping into the soil. They will often accompany these results with reports of low levels several hundred feet down, when the highest concentrations may be somewhere in between. People in Brunswick must be eternally vigilant. They must study the complexities to safeguard human health and they must demand to know the depth of the water samples taken from homes and test wells.
We took well water samples from two homes about a mile and a half east of Hangar 4.
Blue X – Hangar 4
Red X – 90 Thomas Point Rd. - 0 PFOS; 2.4 total PFAS
Yellow X – 32 Coombs Rd. – 2.0 PFOS; 7.4 ppt total PFAS
Jennifer Navarro reported that her well at 90 Thomas Point Rd. is 430 feet below the ground surface. She was so concerned for her family’s health that she had the well tested for PFAS.
Navarro said, “I was relieved the results were so low but I worry that the chemicals may eventually sink deep enough to poison my family.”
The U.S. EPA says PFOS, (perfluorooctane sulfonate) is the dominant PFAS compound in Brunswick’s foam. The agency also says PFOS bio accumulates in fish up to 4,000 times the levels in the water.
Since the Navy owns the land and improvements where Hangar 4 is located, the Navy, theoretically, retains the ultimate responsibility to address all past or current contamination. The Navy is responsible for poisoning people and the environment and must be held accountable.
In a farcical September 26 letter, the EPA informed the Navy it is responsible for protecting human health and the environment. It sounds hopeful, but in reality, the Navy holds all the cards. The Navy, rather than the EPA dictates environmental policy in these matters. Watch it play out in Brunswick.
To its credit, the Maine DEP immediately issued a fish consumption advisory for bodies of water close to the spill, although they still say it is OK to consume any species of fish from parts of Mare Brook.
PFOS may travel many miles in the water.
Maine CDC Scientific Brief: 2023 PFOS Fish Consumption Advisory April 20, 2023
The Maine DEP has published this advisory for levels of PFOS in fish caught throughout the state, including the Androscoggin River.
The levels are not protective of human health and they leave out other toxic varieties of PFAS that gather in fish tissue. Fish act like sponges and soak up the PFOS and other PFAS chemicals in the river.
Like state authorities across the country, the folks in Maine will point to the Agency for Toxic Substances and Disease Registry (ATSDR) of the federal government for the scientific advice used to come up with these numbers, but the feds are way off the mark. We have to look at the European Union for much more responsible guidelines. It is frightening. Their wastewater regulations are also much, much more stringent.
Generally, the European Union suffers less from the influence of corporate dollars in the political process. Consequently, their citizens enjoy cleaner air and water.
In America, individual states are in the clutches of corporate dollars. For the most part, legislative and executive avenues of redress from the harm caused by these chemicals are forelclosed. It is the judicial route that is the least unpromising.
“Ng/g” means nanograms per gram.
ng/g = 1 part per billion (ppb)
1 part per billion = 1,000 parts per trillion. (ppt)
3.5 ng/g = 3,500 parts per trillion
The state is saying it’s OK to consume 3,500 ppt of PFOS in a serving of fish. Maine regulates 6 varieties of PFAS in drinking water: PFOS, PFOA, PFHxS, PFNA, PFHpA, and PFDA. They must be kept under a total of 20 ppt.
It just doesn’t make sense.
I asked Linda Birnbaum, the former Director of the National Institute of Environmental Health Sciences (NIEHS) and the National Toxicology Program if such disparities between drinking water and fish made sense. "Oral is oral," she explained. “Both are routes of ingestion. Whether you eat it or drink it, PFAS go to the same places in the body and do the same thing,” she said.
The European Food Safety Authority (EFSA) has set a safety threshold for four PFAS compounds: PFOS, PFOA, PFHxS, and PFNA that accumulate in the body. The group’s “tolerable weekly intake” is 4.4 nanograms per kilogram of body weight per week.
So, according to this guideline, an expectant mom weighing 50 kilos (110 pounds) can safely consume 220 nanograms of the combined total of four PFAS per week. (4.4 ng x 50 kg = 220 nanograms per week)
We’ll say mom consumes an 8-ounce serving or 227 grams of a fish containing 3.5 nanograms per gram.
3.5 ng/g x 227 g = 794.5 ng of PFOS.
Keep in mind here, that “ppt” and “ppb” and “ng/g” are concentrations of the chemical, while “nanograms” are an amount. We must also keep in mind that PFOS is just one variety of dozens of toxic PFAS chemicals regularly found in fish.
The EFSA’s tolerable weekly intake is 220 nanograms of the carcinogens so the American advisory is 3.6 times greater than the more prudent European limit.
But the state of Maine has reported fish with 1504 ng/g of PFOS! Let’s run the numbers on this fish..
Please don’t let the math chase you away. Just read it a couple of times!
First of all, 1,504 ng/g = 1,504,000 ppt. of PFOS. The EPA is now regulating the substance at 4 ppt in drinking water.
1,504 ng/g x 227 grams (8 oz.) of a fish = 341,408 nanograms.
For our pregnant mom, the EFSA’s tolerable weekly intake is 220 nanograms. The levels of fish in Maine may be 1,552 times over the European limit.
Let’s examine this chart from the Maine DEP.
The chart shown here is overwhelming and does not make sense to most people. The Maine DEP must send things out at a mid-high school level, and it must do a better job communicating the dangers to public health posed by these chemicals.
Maine is tracking 20 PFAS compounds in the fish. How many have you heard of? They may harm you and the unborn. Look at the top of the chart where it says “mean.” That’s the average concentration for each chemical. Because the numbers are in parts per billion we have to multiply by 1,000 to know what they are in parts per trillion. So, looking at the top row of data, a fish was found to have 2,760 parts per trillion of 5:3 FTC.
What’s that?
5:3 FTCA, or 5:3 Fluorotelomer carboxylic acid is an ingredient found in carpets. 5:3 FTCA is less toxic than PFOS, but it can still poison fish and humans. This is not all about the Navy. It’s also about poorly regulated wastewater treatment plants in Brunswick and throughout the state.
Here’s an easier way to comprehend the gravity of the situation. The Maine DEP tested 51 fish throughout the state, according to the 2023 report. The table below shows six compounds that were found in most of the fish.
All 51 fish were contaminated with PFOS. Their average concentration was 113,980 parts per trillion in their fillet. Look at the column showing maximum concentrations. People should understand the diseases and disorders associated with these chemicals. The 174,100 ppt of PFUnDA in one of the fish is dangerous. The chemical is associated with diabetes mellitus type 2, eczema, testicular diseases, etc. This is just one glimpse of one pathway to human exposure.
See Update 10: “DEP issues recent test findings from the Androscoggin River in relation to the Brunswick AFFF spill.”
September 20, 2024 - Analytical results for samples collected by the Department of Environmental Protection from the Androscoggin River on August 27 and September 5, show concentrations of 5.1 parts per trillion (ppt) and 4.6 ppt above the Brunswick Sewer District effluent outfall and concentrations ranging from 3.9 ppt to 6.5 ppt at three locations below the outfall. Test results are posted on DEP's website.
These concentrations are based on the sum of the following 6 PFAS compounds that are used as the current Maine interim drinking water standard (PFHPA, PFHXS, PFOS, PFNA, PFOA, PFDA). These samples were collected from locations above and below the outfall of the Brunswick Sewer District in the center of the river, to be representative of overall river water concentrations.
Why is DEP reporting on surface water using the six types of PFAS they monitor in drinking water? Shouldn’t they be testing for compounds in the river that are known to aggressively bio accumulate in fish? Will they be testing sediments and the riverbanks? Will they be testing the air and the dust in people’s homes? The DEP promises to test fish but it will likely drag its feet in providing the public with results.
Help is not on the way, despite what the Navy, the EPA, and other federal entities may be hinting, while even partial remediation of the Navy’s disaster will run into the billions of dollars. Brunswick is on a steep learning curve. It must rely on its own devices and increase the pressure on the folks in Augusta. Although public attention will likely fade, this problem will never go away.
The Downs Law Group helps to make this work possible. Their support allows us to research and write about military contamination around the world. They’ve helped us buy hundreds of PFAS kits and they’ve helped pay for flights and hotels. The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to a host of contaminants.
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