OSCODA – A proposed plan to address per- and polyfluoroalkyl substances (PFAS) contamination in Clark’s Marsh has drawn criticism from those in the community, as well as others. While some say they are happy to see steps being taken at this site, they also argue that it is still not enough. Others stress that the suggested move should be more aggressive now, in order to avoid additional time and money having to be spent down the road to enhance the treatment.
The Air Force Civil Engineer Center hosted a meeting on March 24, as part of the effort to obtain comments on the plan to tackle the perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) – two types of PFAS – which are migrating via groundwater (GW) to Clark’s Marsh from the former Wurtsmith Air Force Base (WAFB) in Oscoda.
The Air Force (AF) has evaluated three alternatives for reducing the GW plume migration into the marsh. Alternative No. 1 entails no action, Alternative No. 2 involves expanded hydraulic control using a pump-and-treat system (PTS) with ion exchange and Alternative No. 3 – which the AF has noted as the preferred method – would be expanded hydraulic control using PTS with granular activated carbon (GAC).
The Clark’s Marsh interim remedial action (IRA) meeting began with an overview of the proposed plan. Attendees could then take part in an informal question-and-answer session with the AF, which was followed by a verbal, formal public comment period.
For the latter, meeting goers were advised that the AF wouldn’t be addressing the remarks that night. However, a court reporter recorded the comments, and the AF is to respond to same within a summary that will be included in the Clark’s Marsh interim record of decision (ROD). The ROD will be prepared following the 30-day public comment period.
Dr. Catharine Varley – the Base Realignment and Closure (BRAC) Environmental Coordinator for WAFB – said the AF will take time to consider each of the remarks, along with all of the formal comments submitted by mail or e-mail.
As reported, the AF is also accepting written comments on the proposal during the 30-day period, which began on March 18 and will run until Saturday, April 17.
Letters must be postmarked by April 17, and should be submitted to: Dr. Catharine Varley, BRAC Environmental Coordinator, Air Force Civil Engineer Center, 2261 Hughes Avenue, Suite 155, JBSA Lackland, TX 78236. E-mails can also be sent to Varley at firstname.lastname@example.org.
The proposed plan is available for viewing via the AF’s administrative record file, at https://ar.afcec-cloud.af.mil. It can also be accessed from the information repository in the Robert J. Parks Library, located at 6010 N. Skeel Ave. in Oscoda.
Varley told meeting goers that the proposed plan is just that – proposed. “It is the best that we have been able to come up with, based on the information that we’ve had available. So, your reviews matter. And we will consider each formal comment before any final decisions are made.”
A synopsis of the plan was provided by Paula Bond, a senior project manager at Aerostar.
She said this move is building on the successes of the fire training area (FT-02) treatment system which already exists at WAFB, while the involved agencies continue to determine the nature and extent of the GW plume there.
Bond said that this is an early interim action which is being conducted before the remedial investigation (RI) and feasibility study (FS) have been completed.
She gave some background details on FT-02, which is located in the southwest corner of WAFB. It operated as a fire training area from 1958-1991, and aqueous film forming foam (AFFF) was used there between 1970-1991. AFFF containing PFOS and PFOA were released during the fire training exercises to the underlying soil, leaching into GW, where they have migrated into Clark’s Marsh.
Bond said that PFOS and PFOA concentrations in GW at FT-02 and the marsh exceed Michigan’s Part 201 GW cleanup criteria.
She also described the existing PTS at FT-02, which was installed in 2014-2015 as a time-critical removal action to reduce the migration of PFAS into the marsh. GW is pumped from seven extraction wells, at about 241 gallons per minute, and is treated by GAC absorption before it is discharged to GW infiltration galleries.
According to Bond, FT-02 has reduced PFOS and PFOA concentrations at locations downgradient of the extraction well field by up to 90 percent since start-up.
She then summarized the remediation alternatives, as follows:
Alternative No. 1:
The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) requires the team to evaluate the “no action” alternative.
“And we use that as a baseline against which all other alternatives are compared. Under this alternative, no actions are taken, including monitoring,” Bond said. “And obviously the cost is zero. Under this scenario, no additional work would be done but the existing FT-02 treatment system would continue to operate.”
Alternative No. 2:
Also evaluated was expanded hydraulic control using a PTS with ion exchange resin. Hydraulic control would be increased by adding five new extraction wells with this remedy. It would increase the GW extraction capacity by 40 percent, and would use ion exchange resin to treat the extracted GW.
A new treatment facility will have to be constructed to house the ion exchange system, and this alternative will continue to discharge treated effluent to GW with one new infiltration gallery. The existing GAC system would also continue to operate.
The estimated total cost, including operations and maintenance (O&M), is $11,813,962.
Alternative No. 3:
Expanded hydraulic pump-and-treat with GAC would also increase the hydraulic control by adding five new extraction wells and, like the second alternative, would increase the GW extraction capacity by 40 percent.
“We would use GAC to treat the extracted [GW],” Bond said of the preferred method. This requires expansion of the current facility, to up the GAC treatment capacity. It would continue to discharge treated effluent to GW with one new infiltration gallery. The estimated cost, with O&M, is $9,983,562.
Bond said that each alternative was evaluated, as required, against nine CERCLA criteria: Overall protectiveness of human health and the environment; compliance with applicable or relevant and appropriate requirements (ARARs); long-term effectiveness; reduction of toxicity, mobility or volume through treatment; short-term effectiveness; implementability; cost; support agency acceptance; and community acceptance.
For the third alternative, Bond said this option meets the interim remedial action objective of reducing the migration of PFOS and PFOA into the marsh. It is protective of human health and the environment, complies with ARARs, is effective in the short- and long-term, reduces mobility of PFOS and PFOA through treatment, is implementable and is more cost-effective than Alternative No. 2.
The FT-02 expansion would increase backwash capability with two additional settling tanks. Three, six-foot diameter media beds would be installed, each containing 5,000 pounds of GAC. It also includes pre-treatment to reduce treatment system biofouling.
When the meeting shifted to the question-and-answer period, there were 10 people who spoke, including Oscoda-Wurtsmith Airport Authority and Wurtsmith Restoration Advisory Board (RAB) Member Mike Munson.
He said he thinks this a good plan; however, he didn’t see even a tentative date for when some of these actions will be implemented.
According to Bond, the schedule currently shows that they are going to be mobilizing to the field to start the IRA this July, pending the approval of the ROD.
AuSable Township Trustee Jeff Moss mentioned the new extraction wells proposed at FT-02. For the water coming out of the marsh currently – which flows to the AuSable River and then Lake Huron – he asked what is being done now to affect the actual PFOS and PFOA entering the river. He also noted that the plan involves GW, but he questioned what is being done about surface water (SW).
Bond said the goal is to reduce PFOS and PFOA from going into the marsh. GW moves through the marsh, and part of the RI is trying to determine where and how that GW makes it’s way to the surface.
“We know that in the pond that we showed in the figure, that there’s seeping there,” she continued, in reference to one of the slides shown during the meeting.
Bond said there are SW seeps which come from GW, and there has to be an understanding of this before moving to a remedy for the river.
“It’s coming from FT-02, and the data that we have clearly states that,” Moss replied. But, he said, the issue for the community is that the SW is contaminating the AuSable River and Lake Huron.
He added that he thought the SW was part of the investigation and remedial action. “But it’s clearly not included in there.”
“I think you’re mixing two projects,” Varley said. “We have the remedial investigation; that’s not what this meeting is for.”
The RI is separate, and what is being discussed is the IRA, she advised. “The goal is to implement the [IRA] as soon as possible, with the goal that we have hydraulic capture, so that we are not continuing to have that effect that you are stating.”
“What you’re doing is to extend the curtain of FT-02 leaching into the marsh and I think that’s a great action,” Moss said. But the community wants to know if there’s additional action that could be taken for the water leaching into the river from SW, and actions that can be included in this project to reduce the high levels of toxins entering the river system now.
“Absolutely. And this is the reason why you have this public comment period, so that you can go ahead and submit those questions to me and provide your constructive criticism,” Varley said. “Because I believe you actually have some ideas on how to do that, right?”
Moss said there have been ideas presented by RAB Co-Chair Mark Henry. Additionally, this question has been ongoing for three years, that Moss is aware of. “But if that’s the next process, then that’s the next process. So we will address that through the public comment period.”
“Correct,” Varley said. “It’s very, very important that we do get your comments, because your comments actually help us make decisions.”
Next to speak was Anthony Spaniola, who owns property on Oscoda’s Van Etten Lake and is a member of the local Need Our Water activist group.
He said the plan is very clear, in that the AF does not intend to comply with Michigan law, either the GW cleanup standards or the Rule 57 GW/SW interface (GSI) standard.
Spaniola said that in March 2017, the AF notified the Michigan Senate that it was working with the Michigan Department of Environmental Quality – now the Michigan Department of Environment, Great Lakes and Energy – to ensure compliance with applicable Michigan promulgated SW standards for PFOA and PFOS in GW entering Clark’s Marsh.
“That’s specifically the GSI standard. Why is the Air Force not living up to that promise?” he questioned.
Varley said the CERCLA process is being followed. They are trying to get the IRA in place now, while still conducting the RI, the FS and then the proposed plan, which is where the ARARs come in. “So, we are following the law. And with that, we are doing our best to protect the area, protect the environment, protect the people.”
“So, in effect, the Air Force is going to be treating water and then pumping it back into the ground in excess of what’s allowable under Michigan law, at least for the time being,” Spaniola said.
There are several plumes and maybe a more continuous one depicted on the map that is shown in the proposal, he said. “I’m concerned about the lack of context there, because there’s a lot more involved at the marsh.”
Spaniola said that under CERCLA, interim actions are called for when there’s an imminent and substantial threat to human health or the environment. But he didn’t see this delineated anywhere in the plan. “What are the threats, where do they exist and then how does the plan propose to address those specific risks – not just by popping in three or four wells? I’m not trying to diminish the fact that that’s being done, but there’s no real context given or rationale for measuring success against the CERCLA standard. Can you explain why that’s not in the plan?”
Sharon Vriesenga, an attorney with the AF, went back to the first question about why there aren’t ARARs in the IRA that take in the state standards. “This is, as Catharine said, an interim action and it’s building on an existing system that’s in place,” she began.
“The existing system is governed by a state substantive requirements document, which sets standards for what we can have in our discharge from that system for PFOA and PFOS. Since we’re building on an existing system, it makes sense that in the interim – while we’re trying to figure out what the final answer is going to be at the end of the [RI], [FS], the final [ROD] – until we get there and we’re building on an existing system, the standards governing that existing system hasn’t changed,” she said. So, as explained in the proposed plan, those are the standards this interim action will meet.
Vriesenga said it is very clear in the proposal that when they get to a final action, the state’s GW cleanup criteria or any other state standards which qualify as applicable or relevant requirements will be complied with.
Rule 57 is SW only, she noted. What is being talked about is GW and the GSI. If the 12 parts per trillion for GSI and the other GW cleanup criteria apply when reaching the final action, then they’re going to be chosen as ARARs at that time. “They just aren’t ARARs for this interim action that are building on an existing system.”
She then responded to the inquiry about interim remedial measures which are called for under CERCLA, when there is an imminent and substantial threat to human health and the environment.
“And in this plan, there is no delineation of the threats and no correlation stated as to how those threats are going to be addressed by the plan – in other words, how widespread are the problems,” Spaniola said, adding that he believes they are much wider than what is shown in the plan, given all the other plumes there. “So my question is, why that omission?”
“When you talk about the imminent and substantial endangerment, that is something we use as a measure when we’re taking a removal action,” Vriesenga said, noting that several such actions have occurred at WAFB to address PFOA/PFOS.
“Particularly, we were worried about it being in the drinking water,” she said. “This is an [IRA], which is a little different than that. So it’s not that we have identified another imminent and substantial endangerment right now, where there’s a pathway to somebody’s drinking water that we have to stop. This is taking a system that exists, and while we’re trying to evaluate through the remedial investigation and the rest of the CERCLA process what the holistic answer will be – either for Wurtsmith as a whole or for Clark’s Marsh as a whole – we’re looking at what can we do in the interim, literally, to improve on the system that was put in place under a removal action.”
She added that this is optimizing a current system, to do as much as possible until they have the data needed for a final answer.
“There’s no delineation of any of the [GW] cleanup standards for any of the other constituents, other than PFOA and PFOS. I’ve been under the impression that that information was going to at least be provided. Could you explain?” Spaniola asked.
“Again, under this IRA, we’re looking at PFOS and PFOA,” Bond said. Other PFAS which Michigan has established GW cleanup criteria for, or are in the process of doing that but have maximum contaminant levels for, will be addressed in the RI.
Bond said the figure depicting the PFOS/PFOA plume is from an area of FT-02 with some of the highest concentrations. The goal of this remedy is to reduce the volume of that material moving into the marsh. Even though other PFAS may be within this plume, as well, those concentrations aren’t depicted on the map because it just gets too busy in one figure. “But we’re capturing everything that’s in the water. We’re not just capturing PFOS and PFOA. But this is the focus of this action, is PFOS and PFOA.”
More than a dozen people then spoke during the formal public comment period, including representatives of the National Wildlife Federation and the Michigan League of Conservation Voters. A summary of these remarks will appear in next week’s edition of this publication.