Ray Frigon
Assistant Director
Remediation Division
Department of Energy and Environmental Protection
79 Elm Street Hartford, CT 06106

Connecticut River Conservancy Comment on the Draft PFAS Action Plan

In response to the request for public comment on CT DEEP’s Draft PFAS (Per- and polyfluoroalkyl substances) Action Plan, and on behalf of the Connecticut River Conservancy (CRC), please consider the following comments for integration into the final PFAS Action Plan. The Connecticut River Conservancy is a nonprofit citizen group established in 1952 to advocate for the protection, restoration, and sustainable use of the Connecticut River and its four-state watershed.

The PFAS Task Force has compiled a substantive Action Plan for Governor Lamont’s review, and CRC supports the comprehensive efforts to 1) minimize PFAS exposure, 2) curb future release and 3) clean historic releases of PFAS. The PFAS Action Plan should consider regional implications of PFAS and work across state lines to ensure a holistic approach to mitigating the harms of PFAS. Our comments mirror the structure of the three primary categories included in the Action Plan:

Minimize environmental exposure to PFAS for Connecticut residents.

  • In addition to a ban on firefighting training with Aqueous film forming foam (AFFF), the Action Plan should include a timeline for phasing out all uses of AFFF in favor of PFAS-free foam that meets the necessary performance requirements.
  • In addition to testing drinking water for PFAS, the Action Plan should include steps to evaluate the effect of PFAS on the aquatic environments not considered a source of drinking water.
  • While requiring water bottlers to test for PFAS is a critical step, water bottlers should also be required to demonstrate that PFAS is not used in manufacturing plastic bottles.
  • Banning PFAS in firefighting foam and food containers is a priority due to the high frequency of exposure to humans and the environment, but should be the first steps of an effort to comprehensively ban the use of PFAS chemicals in all products and manufacturing.

Minimize future releases of PFAS to the environment.

  • The Action Plan should include steps to create an inter-state coalition to address PFAS contamination at the regional and watershed levels. Connecticut must work with New Hampshire, Vermont, Massachusetts, New York and Rhode Island in order to create a consistent
    action plan throughout the region. PFAS contamination will freely move over state lines and should be addressed accordingly.
  • PFAS should be added to the list of banned toxics in food packaging under Section 22a-255g-m of the Connecticut General Statutes. Similar legislative action was successfully introduced in the state of Wahsington through the Toxics in Packaging Law (RCW 70.95G).
  • While sampling for PFAS at wastewater treatment plants will provide valuable data, the Action Plan should also include support for additional sampling at ambient locations throughout Connecticut’s watersheds.
    Identify, assess, and clean up historical releases of PFAS to the environment.

Identify, assess, and clean up historical releases of PFAS to the environment.

  • When establishing cleanup standards, CT DPH and DEEP and the interagency working group should consult existing standards and work with neighboring states to establish consistent standards for the region.
  • The Action Plan does not include sufficient steps to research and understand how PFAS may affect aquatic life and the overall health of Connecticut’s waters. In particular, the Action Plan should outline how resources will be used to measure to cumulative and long-term impacts of PFAS on native aquatic species.

Thank you for your consideration of these comments. I can be reached at kwentling@ctriver.org or (860) 704-0057.

Kelsey Wentling