ONE OF MANY

The Michigan PFAS Action Response Team hosted a virtual town hall meeting on July 21, to discuss the contamination in Oscoda Township. Among the updates, participants heard that 97 sites in Michigan have been identified where concentrations exceed the regulatory cleanup criteria for two types of PFAS – PFOS and PFOA – in groundwater. This photo of a map presented by the Michigan Department of Environment, Great Lakes and Energy, shows the current sites being investigated.

OSCODA – Per- and polyfluoroalkyl substances (PFAS) contamination has been heavily discussed in Oscoda Township, and this past week was no exception.

In addition to a press conference with Congressman Dan Kildee, and the announcement that Michigan is adopting a ruleset creating comprehensive regulations limiting PFAS contamination in drinking water (see separate stories), a virtual town hall meeting was hosted by the Michigan PFAS Action Response Team (MPART) on July 21. The next day, members of Need Our Water (NOW) held a rally ahead of the Wurtsmith Restoration Advisory Board (RAB) meeting, which will be summarized in next week’s edition of this publication.

As for the 2½-hour town hall, participants heard from such speakers as Beth Place and Amanda Armbruster of the Michigan Department of Environment, Great Lakes and Energy’s (EGLE) Remediation and Redevelopment Division; Tammy Newcomb, Water Policy Advisor for the Michigan Department of Natural Resources (MDNR); Puneet Vij, Michigan Department of Health and Human Services (MDHHS) toxicologist; and AECOM representative Jeremiah Morse.

Place, who is the EGLE project manager for the former Wurtsmith Air Force Base (WAFB) in Oscoda, started things off by giving some background details on the MPART advisory body, which was formed in 2019 and includes participation from several key state departments.

She also provided details on the contamination of concern in Oscoda, noting that PFAS are a class of man-made chemicals which have one of the strongest bonds in chemistry. They are surfactants, are highly stable and repel water, oil, fat and grease. With the development of PFAS beginning in the 1940s, there are more than 5,000 such compounds in existence today.

“And, while there are thousands of PFAS that have been made, the focus is on just a few compounds,” Place said.

When it comes to the concerns, she explained that PFAS are widespread and can be found in several locations; do not break down easily; are bioaccumulative/build up in the body; and may cause potential health affects.

“In Michigan, 97 sites have been identified where groundwater [GW] concentration exceeds the regulatory cleanup criteria,” Place continued, in reference to the 70 parts per trillion (ppt) for two types of PFAS – PFOA and PFOS – in GW. “This is more sites than other states, but don’t be alarmed; it just means that we are looking more. It doesn’t mean that we’re more contaminated.”

Place said that multiple other investigations are underway, and are prioritized based on potential sources which may impact DW.

She also described the Citizen’s Advisory Workgroup formed by MPART, which involves residents from communities impacted by PFAS. Key charges of the group include recommending how to engage and empower communities, and recommending how to educate the general public. Those interested in joining can learn more via the MPART website, at Michigan.gov/pfasresponse.

Place says that the website has a number of other resources, as well, for those wanting to stay up-to-date on the PFAS situation in Oscoda and other areas.

She handed things over to Vij, who reiterated that PFAS are found in a wide range of products – and are also present in nearly 98 percent of the U.S. population.

He advised that research is still ongoing to understand the effects PFAS might have on human health. For PFOS and/or PFOA, some studies have shown that these may lower a woman’s chance of getting pregnant; increase the chance of high blood pressure in pregnant women; increase the chance of thyroid disease (PFOA only); increase cholesterol levels; change immune response; and increase the chance of cancer, especially kidney and testicular cancers.

Exposure to PFAS, or having this in one’s body, doesn’t necessarily mean that he or she will have health problems now or in the future, according to Vij. “And the important thing to note here, is most people do not experience any health problems, even when exposed to high amounts of PFAS.”

One way to learn about these chemicals is to conduct lab experiments with animals, but Vij points out that humans and animals react differently to the chemicals, and not all the effects observed in animals may occur in people. So, it is difficult to prove that PFAS is the cause, and these health effects are only linked by association, based on the available science.

As for the different routes of exposure, Vij said the immediate concern is with drinking PFAS-contaminated water. Other routes include eating fish from water bodies contaminated by PFAS; occasional swallowing of contaminated soil or dust; eating food packaged in materials containing PFAS; and using consumer products which contain PFAS. Additionally, while current findings indicate that PFAS absorption through the skin is not typically a concern, research into this is ongoing. Further, in areas where the contamination level is particularly high, health advisories will be issued for foam contact.

For instance, as previously noted, one such advisory is in place at Van Etten Lake (VEL) in Oscoda. Multiple instances of PFAS-laden foam have been reported here, and those who may come in contact with it are encouraged to rinse off afterward.

Following Vij’s presentation, Morse gave an overview of the Oscoda Area Conceptual Site Model.

He began with some PFAS history involving WAFB, saying that EGLE collected soil, GW, surface water (SW) and fish samples in 2010-11. This confirmed the existence of PFAS, from the widespread use of Aqueous Film Forming Foam (AFFF) by the U.S. Air Force (AF), which then prompted the AF to begin base-wide PFAS sampling in 2012-13.

Morse summarized the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) process being followed by the AF, for which the AF is now moving into the remedial investigation phase. This will be followed by several more steps – including remedial action construction and long-term management – before site closure can be complete at WAFB.

“The Air Force has confirmed with EGLE that the remedial investigation contract will also include interim actions,” Morse said, noting that the AF was to go into greater detail on this at the July 22 RAB meeting.

In terms of the conceptual site model, this includes the entire Oscoda area. Morse showed a series of maps, the first of which outlines all the analytical results for GW, from samples collected through October 2019.

“After PFAS was found widespread across the former Air Force Base, EGLE focused efforts to determine if there were impacts outside the former base boundary,” he said. “And, as you can see, PFAS is found all throughout the Oscoda area.”

He pointed out that not all of these spots are the result of on-base activities, such as the PFAS-impacted GW in the Colbath area which – as previously reported – was the result of AFFF being used on a house fire.

Morse added that other areas, including north of VEL up to Cedar Lake, currently do not have an explanation as to the source of the PFAS detected in GW.

He said that WAFB sits on the remnants of the Algonquin Delta, which is topographically higher than the AuSable River to the south, and VEL to the northeast. VEL is a low area between the land north and east, up to Cedar Lake, which sits approximately 20 feet above VEL.

Morse showed a figure of GW elevation and the general direction of GW movement in the Oscoda-Wurtsmith area. Two sets of elevations, from separate measuring events, were displayed – one being the 1983 U.S. Geological Survey report, and the other being from the 2018 elevations.

“Groundwater generally flows from topographic highs to topographic lows which, in this area, are surface water bodies like the AuSable River, Van Etten Lake and Lake Huron,” he explained. GW on WAFB flows from the west, moves across the base and divides in two directions – east, discharging into VEL; and south, into Clark’s Marsh and eventually the AuSable River.

On the east side of VEL, GW is flowing south from a high at Cedar Lake, then divides either west into VEL or east into Lake Huron. This divide extends all the way south, between VEL and Lake Huron, according to Morse.

Because of the opposing GW flow direction and elevation on either side of VEL, it is highly unlikely that GW can flow under the lake to the opposite side, he explained. “It is most likely that groundwater on both sides of Van Etten Lake discharge directly into the lake; however, previous and current studies indicate a potential influence of nearshore groundwater levels at the southeastern end of Van Etten Lake, due to the seasonal artificial raising and lowering of lake level.”

The next few slides of his presentation gave a closer look at this, and included GW elevation maps from two different times within one year, focused on this section of VEL. The first slide depicts GW conditions from December 2018, when the lake is at its lower winter level, which Morse says is approximately four feet lower than in the summer.

However, when looking at GW elevations from July 2019 – when VEL’s water level is at a summertime high – he said there is a significant change. He pointed to the difference in GW elevation and flow, especially along the southeastern shore of VEL and near the dam. This shows that, during this time, the lake is potentially affecting the GW levels and/or flow direction in nearshore GW within a few hundred feet of shore.

Morse said this is further verified by EGLE’s transducer study, which has also been described previously in this publication.

Based on both prior studies and the current set of data, combined with the present hydrogeologic understanding of this area, he again said it is unlikely that PFAS-impacted GW from WAFB is migrating beneath the lake and impacting GW north and east of VEL. But there is potential influence of nearshore GW levels around the southeast end of VEL, due to its raising and lowering, which have implications for understanding detections of PFAS in GW within a few hundred feet of the shore.

According to Morse, there are three different possibilities. One is that elevated nearshore detections of PFAS may be from the undetermined sources of GW gradient, such as areas farther up toward Cedar Lake, or toward Lake Huron from VEL. Two, PFAS-impacted GW is discharging from WAFB into VEL and could be impacting the SW, with the SW then infiltrating to nearshore GW along the southeast end of the lake. Or three, it could be a combination of these two processes.

He went on to explain the current PFAS investigations, noting that the EGLE Superfund Section will mainly be dealing with oversight of the AF’s environmental activities, which include the CERCLA process. EGLE’s Saginaw Bay District is doing two investigations right now that are outside of the former base boundary, and include quarterly GW sampling and the AuSable River boat launch investigation.

The launch project is being managed by Armbruster, with Morse saying it was initiated because of elevated PFAS levels found in monitoring wells (MW) installed in 2017. Last October, AECOM installed temporary MWs and took SW samples to try to delineate and see the extent of the PFAS-impacted GW.

“We’ve also completed the fourth quarter of quarterly groundwater sampling this past week, and should be starting to write up a report and our findings with that project,” he continued. In conjunction with this, four quarters of MW sampling were conducted, in several areas throughout Oscoda.

Morse said that Armbruster will be posting all of the tabulated results from each of the quarterly sampling events, so that people can look at them in detail.

From here, meeting participants again heard from Vij, who has taken over the Wurtsmith toxicology work, upon Abiy Mussa having moved on to a new position with a different agency.

Vij’s second presentation began with a talk on MDHHS PFAS comparison values. The department has listed screening levels for several specific types of PFAS, and these levels are for the amount of chemicals at or below which there is small to no risk of health effects to the people who are exposed. These were shown alongside the proposed maximum contaminant levels (MCLs) for PFAS in DW (which have since been adopted), as well as the MDHHS comparison values.

Vij said the comparison values are the lowest of the two, when looking at the MDHHS screening levels and the MCLs. It is this lower value that is used when formulating public health recommendations. For example, the screening levels for PFOS are 8 ppt and the proposed MCLs are 16 ppt. “For our comparison value, we use the lowest number, which is eight.”

As a result, any data above the comparison value will often trigger a precautionary public health action, such as the distribution of filters. Although the water is fine to drink in this situation, according to Vij, the distribution of filters ensures extra protection while the investigation continues.

He also shared an update on MDHHS’s resampling effort, as of July 20. Vij said that this work is being done to understand PFAS fluctuations in DW wells. Along with the source area characterization – or extent of plume contamination – this will help support MDHHS’s public health determinations.

He noted that 272 of 427 wells have already been tested in phase one of the quarterly resampling efforts. The results are still coming in but, as of the meeting, the number of non-detect wells were at 92. Of the 83 wells which have detections, the PFOA and PFOS levels ranged from 2.04 ppt to 50 ppt, while the range of total PFAS was 2.02 ppt to 83 ppt. Vij reports that 15 wells exceeded the MDHHS comparison values.

His presentation also highlighted the foam situation, such as the difference between naturally occurring foam on water bodies and PFAS-containing foam, all of which have previously been described in this publication.

Vij added that foam samples were collected from VEL in the fall of 2019, and from Cedar Lake this spring. PFOS levels in the VEL foam were about 200,000 ppt, and the levels in Cedar Lake were approximately 7,200 ppt.

In other new developments, he said that MDHHS issued a statewide press release earlier this month to avoid foam on water bodies that are known to have high levels of PFAS.

As for the fish in the area, Vij says EGLE is currently analyzing the latest samples from Cedar Lake, VEL and Clark’s Marsh. He summarized the types of fish tested, the chemical causing the serving recommendation for same, the size of fish to which this applies and the recommended servings per month (a number of which are labeled as “Do Not Eat”) in each of these water bodies.

To learn more about the guidelines, visit www.michigan.gov/EatSafeFish. The Agency for Toxic Substances and Disease Registry was noted as an additional resource for PFAS information, as well, and this website can be accessed at https://www.atsdr.cdc.gov/pfas/.

Also speaking during the town hall was Newcomb, who described some of the work MDNR has been doing in collaboration with MDHHS and EGLE.

She said that MDNR’s role in the whole PFAS issue is essentially to help MDHHS understand wildlife behavior which, in turn, helps evaluate risk.

Newcomb says that MDNR collects animals and fish for parts of the program, and this information is shared with their stakeholders. “And then we also contribute to the fisheries and wildlife science part of this. So, there is a wildlife technical group that works on looking at different aspects related to the environment and PFAS accumulation.”

As for the 60 additional white-tail deer which were taken from the Clark’s Marsh area – following the 20-deer sampling event which led to the Do Not Eat advisory – she said the MDNR laboratory is still closed because of COVID-19. The samples also have to first be tested for tuberculosis and chronic wasting disease, before they can be checked for PFAS. “So, we are awaiting to get those results done, and then get the tissue sent over to DHHS lab for the PFAS testing.”

Newcomb advised that the samples MDNR has on hand now are 40 deer from the greater five-mile Clark’s Marsh area, and 20 samples from either right within or closely adjacent to the marsh. The goal is to get this information analyzed in time for the Oct. 1 start of bow season.

She also reported that MDNR received in its budget this year $115,000 for the purposes of PFAS and wildlife. “The DNR took all $115,000 and put it out for a research proposal because, what’s really important to us, DHHS and EGLE, is to understand how PFAS is moving through that ecosystem.”

She said the ecosystem serves as a model, so to speak, of understanding where the chemicals could reside. “And again, PFOS is the chemical of concern for us here.”

Using a competitive process to look for an investigator to help them out, Newcomb said an entity was selected which has done work in the Clark’s Marsh area and already has some baseline data.

She added that they have developed a project where they will research everything from algae, all the way up through turtles, to look at levels of PFAS. “And what they’re doing with their study design will be able to help put a rate of transfer from one level of the food chain to another. And why that’s important, is a couple of reasons; it will help us understand more readily where the PFOS may be residing in the system, as well as understanding the rate of transfer from one level to another.”

As this information starts to be assembled, she said a better risk understanding can also be assembled, and then projected out into the future. This ties into the questions which have been posed from the public about when the Do Not Eat advisories will be lifted.

According to Newcomb, if this type of work – sometimes called an ecological risk assessment – is done and the rate of reduction of PFAS going into the environment is looked at, then some projections can be made about what might be seen in terms of reductions in the environment and the animals which live there. “Unfortunately, right now because of uncertain budget situations, that project has been put on hold. I’m hoping to hear later this week whether or not we can continue to move forward with that.”

For other updates, she said the wildlife workgroup will be looking at waterfowl, and the potential for PFAS to accumulate in ducks and geese. “Now we know there are samples that have been taken throughout different places that have shown there is some accumulation. But again, those samples are relatively limited in that they are sort of a point in time, and they don’t really have a good study design around them to be able to actually answer questions.”

Therefore, the goal is to try to build a base for asking some of those questions, she said. “And we’re going to start with waterfowl, ducks and geese in the fall, at the time when hunters would be taking them as part of the harvest, and then consuming them.”

A question-and-answer period was then held, bringing in remarks from more than 20 individuals.

“I’m really concerned that the state staff, including our site manager and our epidemiologist, are minimizing the extent of our health risks – especially exposed at the levels that we are here in Oscoda,” said NOW Co-Leader Cathy Wusterbarth. “And to make a point to our citizens that 97 sites in Michigan should not be alarming, is irresponsible and condescending to our state. We are contaminated and we must fix it.”

She said she hopes that MPART Executive Director Steve Sliver will correct this in future presentations, where this exposure is minimized. “We need to take this seriously, and Oscoda is tired of waiting for state action.”

Wusterbarth also mentioned the status of the Oscoda citizen’s request for testing Lake Huron foam, saying she understands that the plan is to not do anymore testing for foam, including in Lake Huron.

“Currently, we have no plans to sample foam from Lake Huron,” confirmed EGLE representative Mike Jury.

“Your concerns were that there may be health issues with foam,” he said, reiterating that there is a statewide advisory which says to stay out of the foam, to avoid contact with it and so on. Further, EGLE has worked on testing the SW coming out of the AuSable River. Additionally, the municipal water supply from the Huron Shore Regional Utility Authority – which draws water from Lake Huron – is also tested. “So, we are testing the drinking water that people are using.”

“What would be the expected cost of maybe two samples of foam, if we were to report them?” Wusterbarth asked, to which Jury said a typical sample such as those done at Cedar Lake and VEL would be somewhere between $300 and $500.

“Well, I would expect that the state would figure out a way to cover that cost, because we want the source of our drinking water tested,” Wusterbarth said, adding that there is visible foam on Lake Huron right now.

Sliver said he thinks part of the challenge is where to devote the sampling and analytical resources. Along with the public water supply testing, as well as the ongoing testing conducted last year of SW intake, he added that the new MCL drinking water standards in Michigan will ensure that testing continues on an ongoing basis, in all water systems across the state.

He also said there is a study going on for Lake Huron to try to delineate if they can, in the water column, any contamination that might be coming down from the AuSable River, along the shore, towards the south. “So, we’ve got a number of different studies underway and ongoing testing.”

Sliver said he hears what Wusterbarth is saying, in terms of understanding the foam value, but when he mentioned what he called a challenge in getting out and actually capturing the foam, Wusterbarth argued that a sample from a foam occurrence just one day prior could have been easily obtained.

“So, I don’t think that capturing the sample is the difficulty,” she remarked. “I think there is a reason why you’re not testing Lake Huron.”

Meeting participants also heard from a man who was born on WAFB in 1974, and has developed a series of significant health problems. He asked a few different questions, including how people can know whether or not their health issues are related to the WAFB contamination.

Upon hearing from some of the state agency representatives about both the past and ongoing work related to this – including a nationwide, multi-site health study – they also said they would keep the man informed on any such future activities and updates.  

To view all of the presentations from the town hall event, visit www.michigan.gov/pfasresponse.