PFAS Contamination

The Threat

PFAS — “forever chemicals” — have been detected at the Four Hills Landfill site, with higher concentrations found near the fire training grounds. Despite this, the City is moving forward with plans to build a permanent Fire Training Facility at this location.

In January 2026, the City awarded a $236,800 contract to Sanborn Head & Associates for a PFAS Site Investigation and Evaluation. The investigation scope reveals the scale of the problem — but also what it deliberately excludes.

What We Know

Confirmed PFAS Presence

Historical PFAS monitoring at the closed, unlined landfill areas has shown low-level contamination
Recent sampling near the fire training grounds found HIGHER PFAS concentrations (Jeff Lafleur memo, January 2026)
The city’s own consultant acknowledges contamination severe enough to warrant a $236,800 investigation
NHDES Director Michael Wimsatt confirmed to the NH Senate (Feb 4, 2026): “soil and groundwater at that site are impacted by PFAS contamination associated with prior fire training activities”

State-Level Confirmation (February 2026)

On February 4, 2026, Michael J. Wimsatt, Director of the NHDES Waste Management Division, wrote to Senator Kevin Avard to correct testimony he gave before the Senate Energy and Natural Resources Committee regarding SB 536:

“Work done to date indicates that soil and groundwater at that site are impacted by PFAS contamination associated with prior fire training activities. The City will need to further investigate the fire training site and develop a remedial solution for any contamination prior to moving forward with plans to construct a new public works building on that site.”

Key revelations from this correspondence:

The DPW garage expansion is displacing the fire training facility — the fire training facility must relocate because the DPW garage needs the space where it currently sits. These are separate projects, but the DPW expansion is the reason the fire training facility has to move
The state requested PFAS testing 5-6 years ago — the city did not act until they needed to build on the contaminated site
NHDES requires remediation before construction — the contamination must be addressed, not just documented
This has escalated to Senate-level scrutiny — Senator Avard is asking questions; Senator Rosenwald was CC’d

The Investigation Contract

Contractor: Sanborn Head & Associates (Bedford, NH)
Approved: Board of Public Works, January 22, 2026
Memo: City Purchasing Department #26-127, January 28, 2026
Amount: $236,800 (not to exceed)
Schedule: February–July 2026

What the Investigation Includes

Soil sample collection near the Fire Training Area source area
Installation and development of groundwater monitoring wells
Laboratory testing for PFAS compounds
Historical evaluation of past fire training area uses
Draft Site Investigation Report with conceptual site model

What the Investigation EXCLUDES

The scope explicitly does not include:

Air permitting — no assessment of airborne PFAS from combustion
Remedial Action Plan — no plan to actually clean up contamination
Remedial design — no engineering for remediation
Soil management plan — no protocol for handling contaminated soil

The investigation will document the problem but not solve it.

The “Presumptive Remedy”

The investigation scope references a presumptive remedy approach:

Soil capping via planned buildings and paved areas (covering contamination, not removing it)
On-site soil management (keeping contaminated soil on-site)
Activity and Use Restriction (AUR) — legal acknowledgment that the site is contaminated
The investigation scope states the remedy would be “integrated into the DPW Garage project design” — the DPW garage would be built on top of the contaminated current fire training site

In other words: build on top of the contamination and restrict future use of the land.

Escalation: From Fire Training to “All Hazards” Regional Facility

The scope of this project has grown far beyond what was presented at ZBA hearings:

At the ZBA, Chief Buxton described usage as “once or twice a week” for Nashua, plus a 30-day spring recruit school and ~6 visits/year from abutting towns
The ZBA denied the variance partly because even that frequency was “not tenable for the kind of quiet residential neighborhood”
The city’s own CIP request to the Finance Committee (Feb 2026) states: “the Fire Service has transitioned from just fighting fires to an all-hazards agency” and the new site will “allow us room to expand our training needs”
$1,980,000 requested for FY27 — for the building alone. Road access and water line are separate budgets on top of this
City officials and engineers indicate upwards of 12 departments are expected to use the expanded facility (conversations with city officials)
This means daily operations with fire trucks and hazmat vehicles from across the region
More frequent burns = more PFAS released into already-contaminated soil and groundwater
More hazardous materials training = new categories of chemical exposure for surrounding residents

The PFAS investigation scope was already inadequate for a small fire training facility. It is completely insufficient for a $2 million regional all-hazards training center.

Source: Finance Committee CIP Agenda — Feb 2026

Why PFAS Matters

Health Effects

PFAS exposure is linked to serious health conditions:

Cancer: Kidney, testicular, bladder, and prostate cancers
Immune suppression: Reduced vaccine response, increased infection susceptibility
Lung inflammation: Airborne PFAS from combustion causes respiratory damage
Developmental effects: Low birth weight, thyroid disruption, elevated cholesterol

The “Forever Chemical” Problem

PFAS do not break down in the environment — they persist for decades
Once in soil and groundwater, contamination migrates through connected water systems
The wetlands and vernal pools near this site are part of an interconnected hydrologic network
Remediation costs typically range from $10 million to $100+ million per site

No Federal Air Standards

There are no federal air emission standards for PFAS as of 2026
Few states have PFAS air restrictions — New Hampshire has among the strictest standards in the nation
Fire training activities release PFAS into the air through combustion and foam application
Studies document PFAS deposition 1 to 25+ miles from emission sources

PFAS and Neighborhood Character

On October 14, 2025, the ZBA denied the road application 5-0 on criteria 2 (traffic) and criteria 5 (neighborhood character). The chairman stated: “this is really buried in a residential neighborhood. I can’t get past the degree to which the character of this neighborhood would change irreparably.” (ZBA Hearing — Oct 14, 2025, 2:16:49)

Cancer-causing forever chemicals confirmed in the soil and groundwater of a residential neighborhood are the very definition of a character change. NHDES Director Michael Wimsatt confirmed to the NH Senate that “soil and groundwater at that site are impacted by PFAS contamination” — and that “the City will need to further investigate the fire training site and develop a remedial solution for any contamination” before construction (NHDES letter, Feb 4, 2026).

The city’s “presumptive remedy” is not to remove the contamination — it is to build on top of it through soil capping and activity use restrictions (Purchasing Memo #26-127). Residents living next to a capped contamination site, with legal deed restrictions acknowledging the land is polluted, face a fundamentally different neighborhood than the one they moved into.

Expanding fire training on contaminated ground — with more frequent burns releasing more PFAS into an already-impacted area — transforms the character of this neighborhood from residential to industrial-adjacent. The city’s own CIP document confirms the facility has grown into an “all-hazards agency” with daily operations from upwards of 12 departments (Finance Committee CIP, Feb 2026). This is not the quiet residential neighborhood the ZBA said would change “irreparably” — this is something far worse than what the board rejected.

PFAS Was Never Mentioned at the ZBA

Across all five ZBA hearings (September 2025 through January 2026), the words “PFAS,” “AFFF,” and “forever chemicals” were never spoken — not by the applicant, not by the city’s attorney, not by the city’s environmental consultant, and not by any board member.

The closest anyone came was resident Weiss at the November 25 hearing [1:02:37], who raised concerns about “hazmat training chemicals.” But the specific PFAS contamination that prompted a $236,800 investigation was never disclosed to the board making the decision.

The ZBA voted on this application without knowing that the site they were approving had documented PFAS contamination linked to the very activity — fire training — that would be expanded there.

Analogous Cases

This is not hypothetical. It has happened before:

Denver, CO: Major lawsuit over PFAS contamination from firefighting foam at training facilities
300+ US military bases: Documented PFAS contamination from fire training activities
Contamination timeline: Sites contaminated in the 1970s are still being discovered and remediated today

New Hampshire PFAS Limits

New Hampshire has among the strictest PFAS standards in the nation:

PFOA: 12 parts per trillion (ppt)
PFOS: 15 ppt
PFHxS: 18 ppt
PFNA: 11 ppt

The investigation at Four Hills is being conducted under Env-Or 600 rules governing investigation and remediation of contaminated sites.

What Needs to Happen

Complete the PFAS investigation before any construction proceeds
Conduct air emission assessment — currently excluded from the investigation scope
Evaluate downstream contamination pathways through the connected wetland system
Consider the Ridge Road alternative — a site without existing contamination
Full public disclosure of all sampling results as they become available