In November of 2012, after several years of negotiating, testing, applications, approvals and permits, the Kimball Lane Well (also known as the Kennebunk River Well, or KRW) was placed into service. The well ran flawlessly since that time, providing approximately one fourth of the District’s total water supply needs. By all accounts it was producing the best quality of water of any public water groundwater supply in the region.
On April 15, 2016, the District was notified by the Maine Drinking Water Program that a small amount of two man-made chemicals (PFOS and PFOA) were detected in the KRW. The information submitted with the notification described the family of chemicals (known as PFAS) in some detail. Being that the level detected was 0.05 parts per billion (which is the same as 50 parts per trillion, or 50 PPT) and that the then current EPA-established Health Advisory Level (HAL) was 200 PPT for PFOS and 400 for PFOA, the detection didn’t raise much concern at the time. After all, the sampling was taken as part of the USEPA’s Unregulated Contaminant Monitoring Rule, Phase 3 (UCMR-3), which is essentially a forward-looking investigation into the existence of chemical contaminants that might be regulated by the USEPA at some point in the future.
On May 25, 2016 the USEPA announced, in the Federal Register, that it had lowered the HAL to 70 PPT for PFOS and PFOA. Although we fully understood that the HAL was based upon a lifetime of exposure to these contaminants, the lower HAL prompted us to investigate the issue to find the source of the contaminants and to also determine the likely fate of the KRW as a long-term source of water. We began our own testing of the KRW and of its surrounding monitoring wells for PFOS and PFOA in an attempt to find the source of the contaminants. Being that the relatively new and elaborate test had a 25 to 30-day turn-around time, it took several months to finally determine what direction the contaminants were coming from. The determination (which later proved to be accurate) was that the contaminants came from material that was spread on a farm field in Arundel, across the Kennebunk River from the District’s KRW. In November of 2016 we notified the farmer of the issue and supplied him with some pertinent information on the topic.
During this process we were also educating ourselves about these contaminants, including scientific, regulatory and societal perspectives. By February of 2017 we chose to shut down the KRW as a precautionary measure. Our justification for doing so was multi-faceted, and can be best explained as follows:
- There was ongoing discussion, on state and federal levels as to the appropriateness of 70 PPT as the HAL. Some states were proposing 20 PPT or less.
- In dealing with the EPA and the Maine Department of Environmental Protection (DEP) it was becoming increasingly apparent that any regulatory direction (in the form of new guidance or standards) was not going to occur for months, if not years.
- We weren’t in desperate need of the well during the low-demand winter months and we could shift the load to our Branch Brook Filtration Plant until more information was available or until the issue was resolved
Since shutting down the KRW, we have begun conducting pilot studies to determine the best and most cost-effective process for the long-term removal of the contaminants from KRW’s water. When it comes to water quality, we have a long history of consistently erring on the side of caution, deferring to our in-house motto, “When in doubt, leave it out”.
At about that time we also began a more intensive dialog with the DEP and provided all of our information and findings to them for their investigation into the source(s) of the contamination. Several months later they issued a Phase 1 report, which confirmed our findings; the contamination came from the spreading of paper mill ash and/or sludge on the neighboring farm fields about 30 years ago, which was approved by the DEP at that time. Being that this study was described by the DEP as being preliminary, the District agreed to their request that the study and its results not be publicized until the purportedly more conclusive Phase 2 study was completed. With this understanding but with EPA’s requirement that we post any detected UCMR-3 results on our annually published Consumer Confidence Report (CCR), we informed the DEP that we needed to comply with our primary regulatory agency’s requirements. The DEP then requested to see what we were going to publish. We then submitted our draft CCR to them.
As time went by we were becoming concerned that the DEP Phase 2 report had not yet been completed and were becoming increasingly uncomfortable with our prior agreement with the DEP, especially in light of news reports of related incidents involving PFAS in the region. We informed them of our concern. On July 28th, 2017 the DEP gave us their Phase 2 report. From our perspective, it provided no conclusive insight into the issue. We then realized that we were really on our own. Being that a local dairy farm had been shut down and that some legal action had been threatened between some of the other involved parties, we found ourselves in a very uncomfortable position. Even though we had done the right thing for our customers by erring on the side of caution, we were uncomfortable and frustrated with the whole situation.
After much deliberation we then decided to go public with what we knew. The plan was to roll it out in January of 2018. We were to time a public presentation with the publication of our semi-annual newsletter, What’s on Tap, along with a presentation at the Maine Water Utilities Association’s annual convention in Portland. Everything was executed as planned, with the exception of the publication of the newsletter, which is now being printed and should be in our customers’ hands by around February 25th.
In closing, by having only operated the Kennebunk River Well on a seasonal basis for just over four years and with the average levels of PFOS and PFOA at about 50 parts per trillion (which was less than those of the USEPA’s lifelong exposure health advisory), we want our customers to know that we are confident their health was not adversely affected in any way by these trace chemical contaminants.
For more information please contact Norm Labbe, Superintendent, at 207-985-3385 or at email@example.com.