This letter was submitted by Peggy Stevens of East Charleston.
Standing room-only attendance at the 8-24-21 public meeting with Agency of Natural Resources Secretary Moore, on the health of Lake Memphremagog and plans to protect and restore water quality, was a reflection of the intense concern on the part of many local citizens about this issue.
The practice of treating and disposing of toxic landfill leachate in the Memphremagog watershed was roundly criticized by the majority of attendees, as was the fact that the State’s only landfill is sited in such a perilous location adjacent to wetlands, the Black River and Lake Memphremagog.
Much information was provided by ANR as to efforts to better understand what is threatening the water quality in the lake.
Unfortunately, some of the information provided was misleading at best.
For one, in reviewing results from tests conducted to measure PFAS chemicals, it is important to remember that there are nearly five thousand PFAS chemicals, only a fraction of which we tested for.
A PFAS measurement of 22 parts per trillion (ppt) in effluent from Newport’s Waste Water Treatment Facility does not tell us the whole story about total PFAS chemicals entering the lake from that WWTF.
Also, no tests were done in effluent from Barton or Orleans WWTFs to measure what their contribution of PFAS chemicals may be.
Also, no information was provided on whether tests were done for the hundreds of other toxic contaminants contained in leachate.
The fact that “only” 2 ppt of PFAS were measured in two locations in the US section of the lake may be cause for false optimism.
The state of Wisconsin regards 2 ppt of PFAS in surface water to be an “action” level, meaning that at that level the source of that contamination must be discovered and action taken to mitigate that source and its effects.
This is because it is known that these chemicals accumulate in the environment and bioaccumulate in the species that live in and drink that water.
Vermont has no such action level.
Of serious concern is the quote from Vt Fish and Wildlife Biologist Emerson about the cancers found in 30% of Brown Bullhead that, “We’re not saying this is a contaminant related issue specifically. We don’t necessarily believe that at all.”
What would have been more accurate to say is that no cause for these cancerous melanoma lesions has yet been found.
In reading research on cancers in Brown Bullhead, including research done by Dr. Vicki Blazer of the USGS, several facts emerge.
One, that a rate of cancer in 30% of the fish population is significantly high as compared to rates in other places these cancerous Bullhead are found.
Two, that the cause of these cancers of the skin, and liver as well, are multifactorial, meaning that there could be a combination of factors including viruses or genetics and exposure to chemical contaminants.
In fact, the concern is that viruses and genetics alone are not necessarily causative, but that exposure to chemical contaminants can create an environment in which those other factors become activated, resulting in cancer.
Those in attendance also heard about a plan by ANR to award a permit to NEWSVT Coventry landfill to pilot a project to pretreat leachate generated by the landfill.
A public comment period of 30 days from issuance of the permit is required.
I encourage citizens of the NEK concerned about this issue to read and comment on this proposed permit.
Your concerns about the possibility of pretreating leachate anywhere within the Memphremagog watershed are legitimate.
The Act 250 ban on treatment or disposal of toxic landfill leachate anywhere in the Memphremagog watershed has been extended until 2026.
There is time to develop an alternative plan and alternative site for this “pilot project” outside of this watershed.
Discovering an effective method to filter leachate for toxic contaminants is essential.
So is protecting the water quality of Lake Memphremagog from further environmental contamination for all those who drink from and depend on the good health of this cherished natural resource.