In their pursuit of a new artificial turf field at Allen’s Meadow, town officials last week announced the results of recent water testing in the area of Wilton’s two existing artificial turf fields (Wilton High School‘s Fujitani Field and Kristine Lilly Field).
On Wednesday, March 29, Wilton’s Environmental Affairs Director Mike Conklin issued a statement explaining the town’s testing results and methodology.
The statement was positioned to refute concerns that harmful PFAS (per- and polyfluorinated alkyl acids) from the turf materials may be impacting the watershed area. Town officials have since said that results should put residents at ease about artificial turf fields.
“The results showed the two most important samples taken, the samples from the direct water runoff from both Lilly Field and the WHS Stadium, are safe to drink relative to PFAS under current federal and state guidance and more importantly under the more stringent national drinking water standards for six PFAS proposed by the EPA this month,” First Selectwoman Lynne Vanderslice told GOOD Morning Wilton.
However, the Town’s recent testing may not satisfy all opponents of the new turf, especially the Norwalk River Watershed Association, which conducted its own testing that it said does show the presence of PFAS (also known as “forever chemicals”) at harmful levels in areas near the two existing fields.
Vanderslice is eager for residents to trust in the efforts she, Conklin and other town officials have put forward to reassure everyone of the safety around artificial turf fields, calling them “fact-based,” “transparent,” and “consistent.”
Conklin’s townwide statement Wednesday called the town’s approach “science-backed,” and he later told GMW that town testing was done according to how the “U.S. Environmental Protection Agency (EPA), Interstate Technology and Regulatory Control (ITRC) and Michigan Department of Environmental Quality (MDEQ) have standardized the guidance pertaining to collection and analysis of surface water samples for PFAS.”
“This high level of care is necessary to eliminate the possibility of cross-contamination from clothing, cosmetics or equipment,” he added.
In contrast, Conklin’s statement to the town on Wednesday also included a remark about the testing methods used by the NRWA, questioning whether it was done up to standards.
He later told GMW that based on what both the NRWA president and the individual who performed testing for the NRWA relayed to him about how their samples were taken, he believed their tests don’t reach that threshold and were “not consistent with the detailed precautions outlined in the EPA, ITRC & MDEQ guidance,” and that the person who took the samples “was not aware of the PFAS sampling guidance” to prevent contamination.
Representatives of the group have pushed back on Conklin’s characterization of the NRWA’s testing protocols as well as the interpretation of the Town’s own test results — starting with Dick Harris, who performed NRWA’s sampling.
“He’s wrong. I didn’t say that to him. We filed a test that York Laboratory gave us, they gave us the procedures on how to do these tests,” Harris said. Harris was the executive director of Harbor Watch, the Westport-based water monitoring program, for 26 years.
Harris said he followed everything as instructed by York Labs, and specified the lab told him nothing about possible PFAS contamination from clothing. “We followed the advice from York Labs by employing the use of nitrile disposable gloves for each water sample collected, following temperature recommendations and strict handling procedures for PFAS sample collection.”
Like Wilton, Harris also sampled “blanks” — clean water sent by the lab and sampled in the field alongside actual field samples and then tested. If PFAS are found in the blank samples, the conclusion is that the contamination came from the person taking the samples.
“We had to make that transfer for the blanks right in the middle of where we were testing. We’ve done it five different times. We got total zero with no contamination,” Harris said. “They’re grasping at straws.”
The York Labs reports also stated that NRWA’s “analyses were conducted utilizing appropriate EPA methods … [and] all samples were received in proper condition meeting the customary acceptance requirements for environmental samples…” Harris said York did not flag any exceptions to this statement.
“It is incorrect to question the quality of the testing through York Labs,” NRWA President Louise Washer told GMW.
Going further, Washer suggested the Town’s statements about testing methods are a diversion from the most important issue.
“[This] seems to be an attempt to divert the conversation to one about testing [protocols]. The real issue is that turf fields contain PFAS and micro-plastics, and those chemicals will leach into the soil, water and air if the fields are installed at Allen’s. There isn’t any real question about that being the case,” she added.
Washer said the town’s results are similar to what her organization has found, and that it actually does indicate that water below the fields is showing PFAS levels that should concern the public. Washer is not wavering from her overall position against adding a new artificial turf field at Allen’s Meadow.
“Turf fields at Allen’s Meadow pose a threat to the health of the Norwalk River, the quality of the drinking water aquifer that lies under Allen’s Meadow, and potentially to nearby private wells,” she wrote in a statement to GMW.
We break it all down further, here.
The Town Takes on Testing
In February — just weeks after the Town secured the right to use the state-owned land at Allen’s Meadow for an artificial turf field, lighting, and a seasonal bubble — the NRWA provided town officials with data from water samples it had collected, which it said shows the presence of PFAS in surface water.
Washer said testing was paid for by NRWA, which works to protect water quality in the river, and Norm Bloom & Son Oysters, the largest oyster fisherie in the state’s $30 million oyster industry situated at the mouth of Norwalk Harbor.
Both Wilton and Norwalk have plans to add artificial turf fields near the Norwalk River. “The York tests were done as baseline testing in case the fields go in and we see rising levels of PFAS,” she said.adding the tests could “offer a way to seek financial help in case well water is contaminated by the PFAS brought in by the fields.”
In its February letter, the NWRA urged Wilton officials not to add another turf field, stating it was concerned about contamination of ground and surface water from the construction of a third artificial turf field due to PFAS leaching. Multiple residents also raised environmental concerns, prompting town officials to conduct their own assessment.
The Town hired Thunderbird Environmental to conduct sampling and report on specific chemical compounds it found. A full report, including all of the specific chemical compounds measured in the test, can be found on the Town website.
Conklin’s statement on Wednesday detailed the steps taken by town officials and Thunderbird, which he said was “a methodical approach to evaluate the water draining directly from the Lilly turf field and the WHS Stadium turf field/track and waters within the watershed areas, which include Allen’s Meadow and the Wilton School Sports Complex.”
- Public Works Director Frank Smeriglio created field-verified computerized maps of the watershed areas maps to select water sample locations near Allen’s Meadows and the WHS athletic complex
- Water Sampling: Thunderbird’s scientists conducted sampling on March 15, 2023. Conklin specifically noted that water sample collection for PFAS “is a highly technical task due to the potential for sample cross-contamination.” He specified that Thunderbird was “an independent environmental consulting firm” that “followed the U.S. Environmental Protection Agency (EPA), Interstate Technology and Regulatory Control (ITRC) and Michigan Department of Environmental Quality (MDEQ) guidance pertaining to collection and analysis of surface water samples for per- and polyfluoroalkyl substances (PFAS) because these methods are the standard for the industry.”
- Sample locations: Conklin said six locations were chosen above and below the fields at sites to establish a baseline of existing PFAS chemicals and determine if there was any PFAS runoff from the artificial turf fields.
- Lab Testing and Results: Conklin said lab testing was done on equipment able to detect PFAS down to 2 ng/L (nanograms per liter); anything below 2 ng/L is reported as ND (non-detect).
Conklin’s Summary of Findings:
- Stormwater discharge from fields — No PFAS Detected: Samples were taken from stormwater runoff samples at each of the existing artificial turf fields. According to Conklin, “No PFAS chemicals [were] detected in the stormwater discharge points from the artificial turf fields.” Lilly Field runoff discharges in the Norwalk River; WHS Stadium runoff discharges into the Play Field Pond.
- Surface Water — Very Low-Level PFAS detected: “Some very low-level PFAS chemical compounds [were detected] in the surface water bodies tested,” Conklin reported.
- Some of the elevated compound results were found upstream from Allen’s Meadows — and thus before any possible contamination from the two existing fields.
- Samples taken from Goetzen Brook — just north of Olmstead Hill Rd. and therefore upstream of Allen’s Meadows — showed PFBS found at 2.1ng/L. A sample taken from Goetzen Brook east of Lilly Field did not detect any PFAS chemicals. Goetzen Brook flows into the Norwalk River under Danbury Rd.
- A sample taken from Stadium Stream — which is runoff water from the uphill areas at a higher elevation than the athletic fields, including residential properties to the west of the athletic field complex — contained both PFOA (3.4 ng/L) and PFOS (3.7ng/L). Stadium Stream drains into the Playing Field Pond.
- Elevated compounds were found at the outlet of the Playing Field Pond — below the athletic fields — in a sample that contained PFBS (2.7 ng/L), PFHpA (2.0ng/L), PFHxA (2.0ng/L), PFOA (3.6 ng/L) and PFOS (3.7ng/L).
- A sample taken from the Norwalk River where the discharge from the Playing Field Pond empties into the river showed PFOA (2.1 ng/L) and PFOS (2.1 ng/L).
- Some of the elevated compound results were found upstream from Allen’s Meadows — and thus before any possible contamination from the two existing fields.
Vanderslice Confident in Results, NRWA Less So
Vanderlice focused on the town’s testing results of the samples taken from the water runoff directly at the fields, what she called “the two most important samples taken.”
According to Conklin, water samples were taken on March 15, 2023, at the tail end of a storm. He explained that each of the artificial turf fields has an underground drainage system that guides stormwater from the field into specific discharge pipes. Samples from the fields were taken from those pipes before that water mixed with any other stormwater.
“This is the first time the direct water runoff from the two turf fields have been tested for PFAS and is important information for residents to have when evaluating for themselves whether to be concerned about the water running off from the two turf fields,” Vanderslice told GMW.
She said they show that field runoff water is “safe to drink relative to PFAS under current federal and state guidance and more importantly under the more stringent national drinking water standards for six PFAS proposed by the EPA this month.” [her bold emphasis]
She cited proposed EPA standards for PFOS and PFOA released on March 14, which would set a maximum contamination level (MCL) of 4 nanograms/Liter for each.
“The sample of the direct water runoff from each field was non-detectible. The lab tests down to 2 nanograms for each, meaning at a minimum, the samples were at least 50%+ lower than the threshold requiring the need to treat for PFOS and PFOA. The other results (PFNA, PFHxS, PFBS, HFPO-DA) were all non-detectible, and for these four significantly lower than the EPA proposed drinking water thresholds for need to treat,” she wrote, referring to the EPA chart for proposed national drinking water standards (below).
Vanderslice compared the test results to the EPA’s proposed drinking water standards for a reason.
“The accusation had been made that if we put a turf field on Allen’s Meadow we will contaminate any potential drinking water. The proposed national drinking water standards are standards for providers of public drinking water. The results are such that the water running off the turf field is under the EPA’s proposal for a national drinking water standards, the most stringent standards ever proposed for the 6 PFAS chemicals,” she said.
But Washer said she’s looking at different standards — the EPA’s 2022 Interim Health Advisories for PFOA and PFOS in drinking water, which are the EPA’s non-regulatory health guidance for PFAS in drinking water in place until the EPA’s recently proposed (March 14) National Primary Drinking Water Regulation (NPDWR) is finalized, something the EPA hopes to do by the end of 2023.
Those interim Health Advisory Levels are much lower: 0.004 parts per trillion (ppt) for PFOA and .02 ppt for PFOS. The town’s results are much higher than those advisory levels.
“The point is, though, any PFAS in drinking water is too much and poses a very serious health risk. Private well owners should have their water tested,” Washer said.
While the NRWA didn’t test the runoff from the fields, Washer doesn’t think the town should rely on the results from those testing spots.
“The subsurface pipes tested … carry stormwater, and depending on the weather might not show the chemical runoff that occurs during a rain event,” she said, pointing to higher levels found in the playing field retention pond holds water.
Harris also referred to those higher numbers at the pond. “All the fields drained down into that. That’s what we tested. We tested the outflow of that pond and we did get PFAS. We got some fairly high numbers.”
But does that mean those higher levels found at the playing field retention pond are coming from the field or elsewhere? There could be several sources for contamination there, as it’s a retention basin for the large watershed as depicted on the watershed map (above), including from the residences on Catalpa Rd. and beyond above the field, the rubber in the running track surrounding the stadium turf field, Kristine Lilly Way, and more.
“We tested only two areas in the watershed: the stream running from the top of Catalpa and the Stadium. The result for PFOS in the stream sample was higher than the pond sample. The PFOA was slightly lower than the pond. There were three PFAS chemicals detected in the pond that weren’t detected in the stream nor the Stadium. Only one is proposed to be regulated by the EPA,” Vanderslice said, who added that the pond is not used for drinking water.
Vanderslice didn’t want to speculate as to where else in the watershed those chemicals might have come from, as the town didn’t test other watershed areas.
Nonetheless, she wanted to reassure residents along and above the stream, who “should understand the PFOS and PFAS detected were within the acceptable proposed and more stringent water standards for drinking water.”
There was one other point that Washer wanted to make about the differences in testing results.
“York Labs reported results below 2ng/L, while the town tests labeled anything below 2ng/L as ND (not detectable). That made the York totals for all PFAS come out higher — we had several ranging from 1.4-1.9. But if you compare individual chemicals above 2ng/L, the results were similar,” she said.
To Field or Not To Field, That’s the Question
Washer and Harris said where the testing sites do overlap, the NRWA results are not that far apart from the town’s results.
“The Town’s findings and those of NRWA’s lab, York Labs in Stratford, are quite similar,” Washer said. “Both the Town and [NRWA] found higher levels of PFAS in the retention pond below the current turf fields than we found above those fields at Allen’s.”
Harris said that while the results didn’t exceed existing state or federal guidelines, the town should still push ‘pause’ on an artificial turf field at Allen’s Meadow.
“The question remains, why install artificial turf fields that contain PFAS chemicals that may add these chemicals to the existing background levels, especially where Allen’s Meadow is over a major drinking water aquifer and hosts sizable community vegetable gardens only a few hundred feet to the north end of the property?” Harris asked.
Washer echoed that sentiment. “Allen’s is almost pristine, now. We should keep it that way.”
There is a segment of the community opposed to the field, with a Change.org petition launched by the “Friends of Allen’s Meadow.” As of press time Sunday afternoon it had 497 signatures.
The testing results released by the town Wednesday have strengthened some of that support for a turf field among some residents. Vanderslice reported her office received emails from 19 residents in support of an artificial turf field at Allen’s, with some noting the results of the tests.
She hopes other residents will feel as confident in the way the town has investigated any concerns and what officials have concluded.
“I hope the residents will take away that our decision-making is fact-based and consistent. The manner in which we handled resident concerns in this case is the same as how we have handled matters of great concern to residents. Whether it was the removal of hazardous materials during the Miller-Driscoll construction or concerns about crumb rubber infill raised during the 2015 public hearings, or concerns of inequity in determining road paving or the choice of materials for guiderails. We listened to residents’ concerns and in a transparent manner, we investigated their concerns and we actively and transparently shared and explained the results of our investigation,” she wrote in an email to GMW.
She’s banking on that same type of transparent information and data to convince her fellow selectmen at their meeting on Monday, April 3 when they’ll vote on whether or not to pursue bonding for an Allen’s Meadow field.
Conklin will be presenting and explaining the test results, and town attorney Nick Bamonte will address questions residents had raised about any potential legal liabilities. Following the presentation from WARF at the last BOS meeting about issues with turf field availability, Vanderslice has asked Parks and Recreation Director Steve Pierce to provide data on current field usage and requests. Pierce and Town Administrator Matt Knickerbocker will provide information about the cost of maintaining a turf field versus a grass field, and Town Engineer/DPW Director Frank Smeriglio will present a preliminary design concept and cost estimate for the field.