June 6, 2003


Good afternoon everyone.  My name is Bob Griffin.  I am general manager of the Little Hocking Water Association, Inc.  I would like to thank the EPA for this opportunity to comment.  I would like to share our perspective on the C-8 contamination of our water supply.  To the best of our knowledge, our water system has the highest level of C-8 contamination of any public water supply in the United States, if not the world.  The C-8 level in the water currently being delivered to our customers on a daily basis is about 2.0 ppb.  This is twice DuPont’s historic community exposure guideline of 1.0 ppb.
The Little Hocking Water Association is located in Washington County, Ohio. We are a rural water system serving about 12,000 people.  Our water wells are located along the Ohio River directly across from DuPont’s Washington Works plant in Wood County, West Virginia.  The prevailing wind blows from the DuPont plant toward our well field.     Last year DuPont discharged a total of 20,000 pounds of C-8 from the Washington Works plant.  Other Ohio water systems both upstream and downstream from us have C-8 contaminated water supplies.   The Tuppers Plains-Chester Water District is about 15 miles downstream from us and their aquifer is contaminated with C-8.

One of the goals of this EPA investigation is to understand how the general public is being exposed to C-8.  Unfortunately, in our case we already know some of the pathways by which people in our community are being exposed.  Twenty years ago, DuPont knew C-8 contaminated our water but we didn’t find out about it until about a year and a half ago.  Since then we have learned that C-8 not only contaminates the aquifer from which we pump our drinking water, but it also contaminates our soil and the air that we breathe.  In water samples from our well field we have found C-8 levels as high as 8.6 ppb in a production well; up to 78.0 ppb in a test boring.  In soil samples we have found levels as high as 170 micrograms per kilogram.  It is now apparent that our community has probably been unknowingly exposed to this chemical for more than 50 years. 

It is my understanding that the EPA will not pursue human biomonitoring through the ECA’s that we are discussing today.  Even so, the EPA recognizes that the population living near the industrial sites have not been sampled and that these people may have PFOA blood serum levels that are higher than the general population.  Based on a chart developed by DuPont, there have been newspaper articles suggesting that people in our community may have higher C-8 levels in their blood than DuPont’s own workers. 

Therefore, I recommend that our community should be a targeted sampling group.   Not only are we exposed through the same products that the general population uses nationwide, we are also exposed through our air, soil, and water.  Unfortunately, we are a ready-made study group.
Under the West Virginia Consent Order, a C-8 ‘screening level’ of 150 ppb for water was established. However, the very industry responsible for the contamination of our air, water, and soil was heavily involved in all aspects of this Consent Order work.    Consequently, based on newspaper polls, the majority of the people in our community do not have confidence in the 150 ppb number.
Because of the controversy surrounding this issue, there is a need for a study of the problem that is truly independent of industries that have a vested interest in the outcome, so that the residents of our community can have some confidence about the quality of their air and water.
Therefore, we are requesting that we not be forgotten in this investigative process that the EPA is undertaking.  People in our community and other communities along the Ohio River are drinking water every day that has C-8 in it, without truly knowing the long-term health effects to them, or their children and grandchildren.   PLEASE DO NOT FORGET US.   Please give us data and information that we can have confidence in.