7 Investigates: Testing the Waters
CRANDON, Wis. (WSAW) – Curiosity is growing among municipalities, businesses, and individuals as more communities around Wisconsin learn their drinking water is contaminated with what are known as, “forever chemicals,” per- and polyfluoroalkyl substances, or PFAS.
“We are interested. We are curious. We want to have this information for the people that are consuming our water,” RT Krueger said he is increasingly hearing from those groups.
He is the president of Northern Lake Service, a three-generation, family-owned water testing lab in Crandon.
“Northern Lake service was started by my father in 1974. He left the Department of Natural Resources. He was a lake biologist, and he went out on his own to do lake studies.”
Crandon was where the family’s cabin was and it became home. Water became their life.
“When I was a little kid I got to drive the motor a little bit and I got to collect the weeds and identify him with him.”
Eventually, the lab swelled from surface water to testing groundwater and drinking water sources, including helping municipalities and businesses stay in compliance with water system regulations.
After gaining a degree in biology, the ownership trickled down to Krueger.
“We’re providing drinking water compliance data for just about every municipality in the state, just about all 600 or so municipalities,” he stated. “And it’s, it’s exciting to me to be a part of something that’s in the middle of nowhere, that’s in Crandon, Wis., that is you know, the primary drinking water lab for the 20 largest municipalities in the state.”
Their staff of more than two dozen people can test for things not found at a lot of other labs in the state. That includes PFAS. It is one of two labs in the state that are state certified to test for the forever chemicals. He gave 7 Investigates a tour.
A little, family-owned lab
“PFAS preparation,” he gestured to a small room filled with little machines, plastic beakers, and water samples. “This is the area where we do the prep steps for that. And those samples, while we won’t get into specific customers of ours, happened to all be Wisconsin River Valley municipal drinking water samples.”
Some of the municipalities that had detectable levels of PFAS were getting another round of samples tested to see if their mitigation strategies were working. Others, he said, have decided to test for the first time, especially as surrounding communities find levels above recommended health advisory limits.
NLS has been certified to test for PFAS compounds since 2012 through the Environmental Protection Agency’s Unregulated Contaminate Monitoring Rule. It is a program that the EPA uses “to collect data for contaminants that are suspected to be present in drinking water and do not have health-based standards set under the Safe Drinking Water Act.” It tests large and some small water systems for the contaminates using federal funds. Each cycle happens over four years. Every five years a new list of contaminants is created for public water systems to monitor.
UCMR 3 tested for a handful of PFAS compounds between 2012-2016. The next cycle that is starting in 2023 is almost exclusively made up of PFAS compounds as part of the EPA’s PFAS Strategic Roadmap. Those participating in the UCMR program have certain analytical methods they must follow for testing.
For other water systems, businesses, and private well owners, testing remains voluntary for now. Those seeking to test for PFAS compounds currently have two options in Wisconsin, though some other labs in other states have their own methods, though they are not necessarily recognized universally.
The method used nationally is the EPA 537.1, which is an update from earlier EPA methods, with more updates coming as UCMR 5 begins next year. The other is the Wisconsin 33 guidance. Both methods have an option to test with or without field blanks; the published methods include field blanks.
What are field blanks?
Both testing methods include two empty containers for the customer to collect samples, following strict instructions. For those who elect to test with field blanks, they receive an additional empty bottle and a bottle full of water that is determined to not contain PFAS. It is a quality control piece to the testing. Since PFAS chemicals can be found in dust, air, clothing, cosmetics, etc., the field blank allows analysts to know whether PFAS came from the sample collection or whether it came from the sample source.
“Field blank will come back with no detects, while the source water comes back with some detects, that helps us gives us another level of assuredness that that sample does have it has good accuracy,” Kyle Burton, the drinking water and groundwater field operations director for the Department of Natural Resouces explained.
The tests for PFAS, generally, are expensive, costing anywhere from $367.50 for the EPA method to $472.50 for the Wisconsin guidance without field blanks. The field blank option adds to the expense, increasing the cost to $552.50 and $657.50, respectively.
Krueger said for compliance monitoring and for anything that needs to be legally defensible, field blanks are necessary. For those just looking to gain information, he said that may not be essential, especially when considering the cost.
“If I had my well tested without that blank along with it, and I did have some detects and I was concerned about it, I would probably consider going back and retesting it with all of the defensibility whistles and buzzers. But if I got it done and I had nothing in there, I know that I haven’t contaminated it with nothing.”
Krueger noted that in the roughly 22,000 samples of PFAS NLS has tested, few field blanks come back contaminated. He said it is about being mindful of what can cause contamination, and reading all of the sampling instructions.
Both Krueger and the State Lab of Hygiene, the other lab in Wisconsin certified to test for PFAS, state that they will not test and charge a customer for a field blank if the sample water comes back with results below the minimum reporting level.
Expense in every drop
The reason the field blanks add to the cost is that they must be processed like a water sample. The entire process to test a sample comes with a lot of expense.
“Those are the two instruments that run the PFAS samples,” Krueger pointed out two large machines during the tour. “These boxes,” he gestured to giant stacks of boxes sitting in front of the machines, “are the replacement instruments. These are being replaced. That is half a million dollars worth of equipment you’re looking at right there.”
How long the instruments last is a complicated answer because they can be calibrated to perform other types of testing too. In Krueger’s experience, their machines have lasted a little less than 10 years. The breaking point for replacement is when analysts determine the instrument can no longer reliably produce measurements at very low levels, and be able to perform using the latest methodology.
In addition to the machines themselves costing so much, he said the liquids and materials needed to calibrate them can be thousands of dollars each and they expire relatively quickly.
“It’s very, very cookbook; you have to follow it to the letter, but it also takes a lot of finesse from guys like him to make that recipe come out right,” Krueger explained. “Everybody can follow a fondue recipe, but that doesn’t mean that it’s going to come out right in the end.”
Expertise is costly, especially when the tests take a lot of time to prepare and process. Tom Trainor, a DNR audit chemist who certifies labs in the state said a single analyst can take two days from beginning to end to complete tests.
However, the turnaround time depends on each lab’s testing capacity, whether they have analysts dedicated to that type of testing, how finicky the samples are in testing, and whether field blanks need to be tested.
“If we don’t run field blanks, that could double the amount of samples we can get through,” Erin Mani, the organic chemistry supervisor at the Wisconsin State Lab of Hygiene said. She said when they are running at capacity, they can reliably get test results back to customers in about a month, which includes getting the results peer-reviewed.
“Samples come in, say on a Thursday; they’re not going to be started ‘til the following week, and then it’ll take us about a week to get through it and the review,” she explained. “Some of the samples in that batch may need to be reinjected for certain reasons. If that happens, it’s going to kind of hold the whole batch up a little bit, and then more samples will go out the following week. We like to say that it will take about a month from the time we receive your sample to get results out just so we don’t have people calling every five minutes asking where are the results. That’ll just put the analyst farther behind.”
NLS being a smaller lab with two machines, Krueger said it can turn out samples as quickly as a week if needed.
The testing method can make a difference in the cost too for a few reasons. Krueger said the EPA’s method, which can test for 18 compounds (though new updates ahead of UCMR 5 now allow labs certified in the updated method to test for 29 contaminants), can be a little more automated.
“And therefore even though it’s very expensive to pay for the equipment and the people and so forth, it’s not quite as labor-intensive. And so, we can offer it for approximately $300-$350,” Krueger noted.
Mani also mentioned the EPA’s method takes less time.
“The state guidance is very, very labor-intensive,” Krueger continued.
The state guidance he is referring to is Wisconsin 33, which tests for 33 compounds.
For both methods, there are a lot of quality controls and criteria analysts have to meet so that the results of each batch of samples are defendable. That could mean having to go back a step or two in the process, or start over if certain criteria do not line up, as Mani alluded to earlier.
“The Wisconsin guidance is a little bit more susceptible to having some of those issues and that’s where a significant part of the expense comes in, is where there’s a lot higher likelihood that we may have to go one or two steps back in that process and redo it,” Krueger explained.
While some customers may look at the sticker price for the Wisconsin 33 and think labs are getting rich off of performing it, Krueger noted it is just the opposite. Their lab gets paid once to potentially perform a test three times in order to have confidence in the results.
He said the reason the state’s guidance is more prone to issues during the testing process is that some of the compounds are more similar than others.
“I can jump on a bathroom scale, and it’s going to work great for me. Somebody’s a little bigger than me, it’ll work fine. Somebody’s a little smaller, it’ll work fine. But if I have a butterfly, and I have an elephant, that bathroom scale is not going to work well for those.”
When it comes to which test is best for what scenario, Krueger, Mani, Burton, and Trainor all say it depends on the customer’s needs, but it is clear some have their favorite. Mani was the only one not to indicate a preference.
“When PFAS sampling is done in the state of Wisconsin, and we’re consulted ahead of time, we recommend using that Wisconsin 33 because that gives us all of the information we need,” Burton stated. It includes all of the compounds that have state health advisory levels.
Trainor agrees, saying that they (the DNR) are interested in public health; the more PFAS tested and monitored for, the more we can know. He said it gives them a bigger picture than what the EPA has.
Both note that there is nothing wrong with the EPA method, it is just missing a few of those compounds with Wisconsin health advisories.
“We would look at that information,” Burton said about a customer who tested using the EPA method, “give them advice on the results we have, and depending on those results, we might recommend they do additional sampling using the Wisconsin guidance.”
The DNR established the Wisconsin guidance using a variety of regulatory programs and advice from PFAS experts. Trainor said it is a “method expectations” document that labs use to become certified to test for the compounds in the state. He affirmed that it essentially is a roadmap the DNR gives to labs as to how to get to the measurements of those compounds by setting certain criteria but provides them the ability to create their own method.
“There are various methods to analyze PFAS,” Trainor continued. “An example of this is EPA method 537.1 and 533. These are two entirely different EPA methods that analyze the same 14 PFAS. Knowing this, we offer labs flexibility in how they perform their in-house method but expect them to meet the quality control criteria in the guidance document. It is the results of the quality control that demonstrate the accuracy of the method.”
Krueger believes the EPA’s methods are more defensible due to the process those methods are developed and the national acceptance.
“The Wisconsin guidance will give you more pieces of information, but it lacks that, it lacks that authoritative step. We can’t step out of the state of Wisconsin and use that data,” he said.
He continued that they can place a lot of confidence in it, however. He said NLS would not put their name on a piece of data that they could not defend, but it might take processing the sample three times before they are confident.
The EPA’s method is what the federal government is requiring to be used in the free, voluntary municipal testing program Gov. Tony Evers announced in February.
“It was something we worked with EPA to be able to use that funding they were really interested in us using their approved method,” Burton said.
He added municipalities that participate and come back with PFAS levels above minimum reporting requirements or recommended health advisories will receive existing DNR funds to retest their wells using the Wisconsin 33. Looking at other states that have done broad sampling, Burton does not expect that PFAS will negatively impact every municipality tested, so he anticipates that retesting will happen for only a portion of participants.
Competing with free
Krueger said NLS invested in the instruments and gained the necessary certification to test for PFAS because they saw a huge national need on the horizon in 2012. While they got contracts outside of Wisconsin, he said in their home state, despite advocating for testing, it has been slow.
Then, some results from EPA testing in the state came back at concerning levels for municipalities like Rhinelander in 2019. Gov. Evers declared 2019 as the Year of Clean Drinking Water.
“We kind of thought drinking water be a priority,” Krueger hypothesized. “We’ll get something going. The EPA has a 70 parts per trillion health advisory; let’s get something going. It’s been extremely, extremely slow-moving.”
Burton said it has taken a lot of time to work with the EPA, the State Lab of Hygiene which partners closely with the DNR, and the Department of Health Services to create a project plan and secure funding.
Municipalities, individuals, and businesses that want to get tested have been able to do so for years, but Krueger said the costs of the test, the lack of guidance for what water systems should do with the results, and the finger-pointing that comes along with those results deterred most. There also has been hope that federal or state funding would provide testing for free, which has added to the reasons some water systems waited.
The Wisconsin customers NLS has seen for PFAS, Krueger noted, are the curious ones. Curious, sometimes for the sake of public health knowledge, or for scenarios like what the Wausau metro area is currently experiencing. Communities nearby known contamination that may share part of the same aquifer testing to find out if their wells are contaminated too.
“We’ve seen kind of a domino effect where somebody had been waiting and waiting and finally said I need to do this I want to find out that system was impacted, which made another system think about it. Then, that one was impacted, and now we see again, some systems moving toward this.”
The state has made some progress as it relates specifically to PFAS, such as prohibiting the use of firefighting foams that have intensional PFAS additives, with a few exceptions. It also is on its way to passing some drinking and surface water standards. Though, the drinking water standard that passed the Natural Resources Board was diluted from the recommended standard.
However, statewide testing – a crucial interest of a private laboratory business – has not happened. Until now, though only one lab in Wisconsin will be taking on the $600,000 in testing municipal wells – the State Lab of Hygiene.
“It’s super difficult for us to compete with free,” Krueger said, disheartened.
Burton said the testing is solely being done through the State Lab of Hygiene because it is already government-funded and does not need to go through a bid process. He explained the EPA also wanted the testing to remain consistent by having one lab handle the process.
“We have six analysts qualified on PFAS and we are taking three of them, setting them aside solely for this project,” Mani said.
She explained they are working to determine what their testing capacity for this project will be. She noted the variables in each sample, like having to redo tests, having to run field blanks, etc. make it so they cannot easily say they will be able to process X number of samples per week.
“We are going to be working closely to schedule the samples to come in to create our maximum capacity here at the lab to try to get all the samples through as quickly as possible.”
She said talking with the DNR Monday, so far about 84 municipalities have signed on to test through the program. Burton said testing remains voluntary, but funding will only be available through the end of the year.
This month, the DNR is communicating with interested municipalities about the project and the next steps after test results come in, including creating a communications plan before they need one. Burton hopes they will be able to start sampling in April, with results expected in late-April, early May.
To Krueger’s concerns about not having the opportunity to help process those tests, Burton said it is still possible, but just not through this specific program, in part due to the EPA’s quality assurance method.
“As we were partnering with the State Lab of Hygiene, we really honed our project through that. Now, if we were to do this in a different way, maybe use different kinds of funding, open it up to all other labs where we didn’t have those restrictions of the quality action or quality assurance project plan.”
For Krueger, that answer is not satisfactory after years of encouraging testing and setting themselves up to have as much expertise on PFAS as possible.
“I’m extremely glad that the citizens of Wisconsin are going to get what, what they deserved several years ago. I have to be a little bit careful though because I’m concerned about how giving it away for free is going to impact our ability to keep doing what it is that we do.”
7 Investigates reached out to the EPA, but appropriate members were not available to answer questions in time for this publishing.
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