‘Little Pockets of This All Over’

Where historic use of firefighting foam threatens drinking water, municipalities bear the burden of responding

In a wooded Ogunquit neighborhood, a narrow side road leads to the Seacoast Training Complex where a tower-like structure perches, soot-stained and stark in an expanse of grass. Firefighters from southern Maine and New Hampshire come to this site to build essential skills, and they leave behind a wake of chemical foam.

For decades, aqueous film-forming foam (AFFF, called “A triple-F”) was among the mix of foams applied at this site. Its use in firefighter training was banned three years ago because it contains toxic and persistent per- and polyfluoroalkyl substances, or PFAS.

At regional centers like this one, departments might experiment with a new foam or train with foam they no longer need, recalled Russell Osgood, Ogunquit’s fire chief. Firefighters would learn techniques for applying foam and often they would leave a blanket of it covering the fire site, he said: “That was a common thing so you wouldn’t have any rekindle following live fire training.”

Given the property’s history of AFFF use and the many health risks associated with PFAS, Osgood was concerned about potential water contamination at nearby residences. “We have a responsibility as a town if people are being affected by what we do,” he said.

The risk extends far beyond his small community. “Who manages this? Who is going to follow up?” Osgood asked. “You’re going to find [PFAS from AFFF] in more places than you could think.”

Maine has roughly a dozen current and former regional training sites for firefighting, as well as former military training areas, dozens of airports, and potentially hundreds of sites where local fire departments conducted trainings or discharged AFFF. “I suspect there are tons of little pockets of this all over,” Osgood added.

Some of those pockets of PFAS contamination could be endangering household wells while others threaten drinking water at fire stations, aggravating health risks for firefighters who have, in national studies, PFAS blood serum levels somewhat higher than the general public.

No state funding is currently dedicated to foam-related PFAS investigations so the Maine Department of Environmental Protection (DEP) has not systematically sampled fire training sites or other locations with high historic use of AFFF. Ogunquit approached the agency for help testing wells near the Seacoast Training Complex, and the “DEP is directing the project, but the town is paying for it,” Osgood explained, which to date has cost the town roughly $50,000.

Initial testing done in 2022 of 14 neighboring wells found low to moderate PFAS levels. Results are not yet back from recent water retesting and new soils testing.

Osgood recommended that Ogunquit investigate the training facility soon after becoming the town’s fire chief because he knew first-hand about the risks of PFAS from AFFF in drinking wells. In prior work at the Portsmouth Fire Department in New Hampshire, he was stationed at the former Pease Air Force Base when news broke in 2014 that wells there were contaminated following decades of historic AFFF use. City firefighters had been drinking, showering in and cooking with contaminated water for years, alongside their occupational exposure applying AFFF foam and what he calls the “toxic soup” of chemicals (including PFAS) generated by structure fires.

As firefighters have grown more aware of PFAS and the many other chemical hazards they face, they’ve begun adopting practices on and off the job to reduce health threats, explained Osgood, who serves as vice president of education for the Firefighter Cancer Support Network. “We talk about modifiable risk factors a lot,” he said, reminding firefighters “you can control your personal risk factors” by eating right, exercising and getting regular wellness checks.

"Testing the wells they’re drinking [from] has got to be the first step. We can find that and fix it … There has to be money for investigations."

Russell Osgood, Ogunquit fire chief

But clean water is a basic precondition to maintaining health, Osgood said, and “test[ing] the wells they’re drinking [from] has got to be the first step. We can find that and fix it … There has to be money for investigations.”

Recommendation to test water never reached fire departments

In a survey of Maine fire departments conducted last summer, only 11% of those on wells had tested the water for PFAS. Four out of five of the departments that had not tested indicated that it was because “it has not been discussed/suggested.” A smaller number “don’t know how to get the test done.” One fire chief commented, “Will test now. Never thought to.”

Four years earlier, a PFAS Task Force established by Gov. Janet Mills recommended in its final report “that private drinking water should be tested for PFAS in areas where groundwater is likely to have been impacted by PFAS at unsafe levels, such as: 1) manufacturing locations that utilized PFAS; 2) unlined landfills; 3) areas where Class B AFFF has been discharged or stored; and 4) residuals [wastewater sludge] land spreading sites.”

Maine subsequently invested tens of millions of dollars to test sites permitted for sludge, a process still underway, and to sample landfill leachate. To date, the state has tested well water at only a handful of sites related to firefighting and — judging from survey responses — never informed fire departments that the task force recommended water testing or indicated how they could undertake water testing on their own.

In the recent survey, 20 Maine fire departments requested screening kits to test for PFAS in well water and surface pumping water sources. Those who undertook water-sampling, a random and geographically diverse group of both volunteer and career departments, agreed to share testing results with Maine Morning Star.

The DEP assesses water samples for 28 PFAS compounds, but its interim drinking water standard covers just six. Commercial water tests, which report on up to 55 compounds, still only capture a sliver of the PFAS that might be present.

Analysis for 55 PFAS compounds in each of 31 water samples (some of the 20 departments tested multiple sites) revealed five distinct PFAS, most at relatively low levels. Among the samples tested, three came back with no detectable PFAS.

Only two of the five compounds found fall under Maine’s drinking water standards: PFOA (perfluorooctanoic acid) and PFOS (perfluorooctanesulfonic acid). These two “legacy” PFAS were phased out of U.S. production in the early 2000s but remain prevalent in the environment.

Among the departments that conducted water sampling, most reported that they had “rarely or never” used AFFF historically, and there was minimal evidence of PFOS, an ingredient in early AFFF formulations, in the samples tested. Only one well reported a level of PFOS over the federal drinking water guideline of 4 parts per trillion or ppt.

Two of the other compounds reported include PFBA (perfluorobutanoic acid) and PFBS (perfluorobutane sulfonic acid), which persist in humans for days or weeks rather than years.

About water-screening test kits

PFAS water tests from laboratories certified by the U.S. Environmental Protection Agency (EPA) can cost upward of $275 per sample. For a fire department needing to test water at multiple stations and pumping sources, expenses could escalate quickly. More affordable screening tests can indicate where high PFAS concentrations may be endangering drinking water. Costing less than a third of what certified tests do, screening kits are easier to administer and mail back.

The water-screening kits used in this project came from a materials science lab using analytical methods similar to those used by the EPA (although not certified). A split-sample analysis done in Maine comparing data from these sampling kits with PFAS reports from three certified labs found the kits delivered comparable findings.

More information on water-testing options for fire departments and homeowners appears on this project’s resource page.

The struggle to identify contamination sources

Sampling water for PFAS is complicated by the sheer number of compounds in this vast chemical class. Scientists have identified nearly 15,000 PFAS to date, yet fewer than 100 of them have received much study. Given the use of PFAS in a wide range of consumer and industrial products, and the proprietary nature of many manufacturing processes, tracing the sources of PFAS found in samples can be challenging.

The compound that appeared most frequently in fire department water samples, N-Ethyl perfluorooctane sulfonamidoethanol or NEtFOSE, is not included on state-certified water tests, so little data exists on its presence in Maine and little is known about toxicological effects. It surfaced in two-thirds of the water samples at low levels (averaging 2 ppt), roughly an order of magnitude higher than background levels found in rainwater collected during 2020-2022 federal sampling at a site in Freeport.

A volatile compound associated with waterproofing treatments on paper and textiles, NEtFOSE is a precursor, one of many PFAS that can break down over time into more more enduring compounds. It can potentially transform into PFOS, a possible carcinogen that can remain in human bodies for years and in ecosystems for centuries.

If NEtFOSE were used in treatments on firefighters’ protective jackets and pants, known as turnout gear, “It could have come off of the fabric during the washing process, and then could have ended up in the water,” observed Bryan Ormond, a textile researcher at North Carolina State University who analyzes PFAS treatments and non-fluorinated substitutes.

Scientists find it challenging to track what specific PFAS compounds might have been used, given that “different manufacturers of the different layers of the turnout gear have used different versions of repellent treatments,” Ormond added, and each of the companies has likely “changed up the finishes on their products over time.”

“AFFF is probably not the major source [since NEtFOSE] is not a common PFAS to find in AFFF formulations or at AFFF-contaminated sites,” noted Heidi Pickard, a postdoctoral researcher in environmental chemistry at Harvard University who studies PFAS precursors. If NEtFOSE derives from other sources, it may or may not originate in the fire stations.

PFAS moving through sub-surface waters

Risks to drinking water increase markedly in settings where AFFF use occurred repeatedly and where the area’s hydrogeology — the soils, bedrock material and location of aquifers and surface waters — is conducive to the migration of PFAS. One such location lies in Carmel, a small community west of Bangor where a fire retention pond behind the fire station and town office has high levels of PFAS. Near that engineered pond, constructed as a pumping source for fire trucks, the municipal fire department historically held trainings.

To determine the extent of contamination, Carmel’s town manager asked the DEP in 2023 to follow up on a preliminary water sample done at the town office. The state’s test found levels over 1,000 ppt for the sum of six PFAS compounds, two of which now have federal maximum contaminant levels of 4 ppt each. Six nearby residences registered levels over Maine’s interim drinking water standard of 20 ppt, and received whole-house filtration systems.

The DEP covered initial testing and filtration using the state’s Uncontrolled Sites Fund, which provides limited liability exemptions for public treatment facilities and public water works but not for fire departments. “Carmel has been made aware of DEP-incurred costs and been made aware that DEP may seek reimbursement,” noted David Madore, the agency’s spokesperson. “The DEP is reviewing its program budgets in advance of the legislative session to determine if it will be necessary to request additional funding for PFAS programming,” he added.

To date, the DEP has invested roughly $30,000 testing water and installing filtration systems in Carmel, said Andrew Hart, the town’s manager, with $18,000 annually projected to maintain those systems. The agency has been “more than willing to work with the Town of Carmel,” he added, but in addition to the mounting costs for water sampling and filtration, the town is paying for legal consultations and an environmental assessment. That work is not yet complete so the full scope of contamination remains uncertain.

Carmel’s experience demonstrates another PFAS risk related to the fire service that has received little attention. Fire tanker trucks hold up to 3,000 gallons while smaller “Class A pumper trucks” might transport and release up to 1,000 gallons of water. If those trucks draw from local sources with high PFAS levels, “there’s a lot of opportunity to move a lot of contaminated water to another spot,” Osgood said. A structure fire can require several thousand gallons of water, he added, while extinguishing a sustained blaze could take hundreds of thousands of gallons.

To assess that risk of inadvertent PFAS spreading, Maine Morning Star’s survey asked fire departments where they fill their pump trucks. Eighty-seven percent of them draw from local surface waters. Among those, a third pull from a farm pond, 7% from a transfer station, and 6% from a fire training site — all settings that could potentially have elevated PFAS.

Looking beneath the surface

Design and construction errors at fire stations can also lead to local water contamination, as Rhode Island learned in a community where a single 20-year-old station tainted the drinking water of more than 40 households, necessitating the extension of municipal water at a cost of $1.7 million. In that instance, trench drains from the truck bay were improperly connected to an underground injection control system (UIC, a shallow gravel drainage area intended solely for stormwater runoff) so AFFF from trucks and equipment ran almost directly into soils and then an aquifer.

In Maine’s recent fire department survey, 5% of respondents reported having trench drains connected to UIC systems. Another 15% have trench drains that empty into septic tanks and leach fields, a less direct route but still a potential pathway for PFAS in AFFF to enter groundwater.

“There’s no UIC that won’t be a problem for PFAS. Ultimately, it’s an underground injection of water,” observed Nicholas Noons, an environmental engineer at the Rhode Island Department of Environmental Management. Even with oil/water separators and other technology to clean the water, he added, “the trucks have to drain and that water has to go somewhere.”

“We view every fire station as a source of PFAS,” Noons said. “We have yet to find one that hasn’t affected water.” Rhode Island has investigated half a dozen stations to date and has identified about 40 more (out of 160 total) that are of high concern due to potential impact on nearby drinking-water wells.

To cover the costs of investigating and installing filtration, Rhode Island is dedicating some of the federal funding it has received through the Bipartisan Infrastructure Law’s Emerging Contaminant Grants for Small and Disadvantaged Communities. To stretch the grant money, Noons said, the state is considering installing point-of-use filters (such as under-sink units) rather than whole-house filtration to ensure that more residents get at least that minimal level of drinking water protection.

"Everyone knows the fire stations are an issue. The challenge is that without a responsible party, the environmental assessment and filtration costs can fall to municipalities."

Nicholas Noons, environmental engineer at the Rhode Island Department of Environmental Management

Maine is receiving $45 million (for 2022-2026) from the Emerging Contaminant Grants program, which can support filtration of both public drinking water supplies and private wells. Roughly half of Maine households are on private wells, but the entire sum has been allocated for public water systems, according to a spokesperson for the Maine Center for Disease Control & Prevention.

‘Opening a can of worms’

Funding remediation of AFFF sites is a universal challenge, according to Noons. At New England meetings of water professionals, he said, “everyone knows the fire stations are an issue. The challenge is that without a responsible party, the environmental assessment and filtration costs can fall to municipalities.” Towns like Carmel and Ogunquit are learning this the hard way.

Nearly five years ago, the governor’s PFAS Task Force recognized the need for state support so that fire departments and municipalities “are not financially burdened for environmental clean-up incidental to Class B AFFF ….” It essentially called for the sort of safety net that the state eventually established for farmers affected by PFAS-laden sludge. Farmers who test for PFAS and find contamination encounter a coordinated agency response that helps ensure they receive technical, financial and health-related support, backed by a $70 million PFAS Advisory Fund.

“It’s clear from our experience in Maine with farmers that having that safety net is critically important,” observed Tricia Rouleau, farm network director for the nonprofit Maine Farmland Trust. It can quell the financial fears and liability concerns that might deter people from testing for PFAS, she said: “Otherwise, you’re opening a can of worms with no way to deal with it.”

“People are scared of liability” when it comes to AFFF, said State Fire Marshal Shawn Esler. The U.S. Environmental Protection Agency (EPA) recently added two PFAS compounds to its “Superfund” list of hazardous materials, while also issuing guidance to staff that it does not consider entities like fire departments and public water utilities “responsible parties” under that legislation. No such liability exemption applies at the state level, however, so when the Maine DEP steps in to investigate and remediate AFFF-contaminated sites, it can seek to recover those costs from municipalities.

"It’s clear from our experience in Maine with farmers that having that safety net is critically important."

Tricia Rouleau, Maine Farmland Trust

Where the responsibility rests

In Maine’s farming community, there’s less concern now about liability, Rouleau said, because “it became clear that the responsibility goes much higher than that,” resting with chemical corporations that manufactured and promoted products that their own scientists knew were problematic.

“It all starts with the chemical industry having free rein to pump this into our environment unchecked,” in Osgood’s view: “If PFAS had gone under the scrutiny that a drug has to, they never would have been launched into the environment.” Instead, these persistent chemicals went unregulated for decades, and all but six compounds remain so. “I’d like to think the chemical industry didn’t intentionally, knowingly put it out there,” he added, “but the evidence talks differently. It’s kind of criminal.”

In March 2023, the Office of the Maine Attorney General filed a lawsuit against chemical manufacturers of AFFF seeking compensation for damages to the state’s communities and natural resources from PFAS-laden foam. The suit names 3M and DuPont (and companies spun off in a corporate reorganization), along with foam manufacturers.

While the Attorney General’s Office does not comment on pending litigation, state lawsuits involving AFFF typically become part of federal multidistrict litigation, which consolidates similar cases for greater efficiency. More than 10,000 cases related to AFFF are amassed in the U.S. District Court of South Carolina, and — as has happened in recent PFAS cases where water utilities were the plaintiffs — the corporate defendants may settle rather than going to trial.

In settlements, states often “take a discount on what they truly need,” said John Gardella, a trial attorney and shareholder at CMBG3 Law in Boston who writes about PFAS litigation in The National Law Review. States face a “kind of a Catch-22,” he added, because in order to recover funds they need to thoroughly document “the true scope of the damages,” but that rigorous investigation can be an added financial drain.

As Maine’s investigation of sludge sites begins to wind down, research on AFFF sites may start ramping up—with three bill titles related to AFFF already submitted by state Rep. Dan Ankeles (D-Brunswick).

‘All the pieces are there’

There are lessons from the agricultural sector that could help. “At this point, we know so much more, and we can learn a lot from what farmers experienced and carry [that] over to firefighters,” Rouleau said, such as having “resources available immediately for water filtration and health monitoring.”

Maine needs to “have staff in place to help people [in affected fire departments and communities] navigate the response and figure out next steps,” Rouleau noted, explaining that support mechanisms must be flexible and long-term, since each situation is unique and changes over time.

What’s critical to keep in mind, Rouleau added, is that for farmers and firefighters alike, the accumulated occupational exposure to PFAS means “they’re the ones who are going to bear the brunt of this issue.”

The collaborative work that went into shaping guidelines for the PFAS Advisory Fund, which provides support to affected farmers, should make the path forward easier for communities affected by AFFF, suggested Kate Dufour, director of advocacy and communications at the Maine Municipal Association. “There’s a real opportunity to build on what we have and make it better if it needs to be better.”

With plans underway for an Office of Community Affairs designed to help municipalities with major challenges, “all the pieces are there to have a collaborative approach” that engages multiple agencies, Dufour said. She hopes that some of the bills under consideration this winter will ignite a constructive discussion about how to support communities facing potential PFAS contamination from past use of firefighting foam. The upcoming legislation session, she added, offers “an opportunity for everyone to say how we are going to work together to get this done.”