PROPOSED PLANS – This slide from the Air Force Civil Engineer Center was shared during the latest meeting of the Wurtsmith Restoration Advisory Board. It depicts the preliminary extraction well locations at Van Etten Lake, left, and Clark’s Marsh, right, which will be included with the Interim Remedial Action steps being taken at the former Wurtsmith Air Force Base in Oscoda, to address the PFAS contamination.

OSCODA – An update on the Air Force Civil Engineer Center (AFCEC) and Aerostar’s remedial investigation (RI) at the former Wurtsmith Air Force Base (WAFB) in Oscoda, was shared at the latest Restoration Advisory Board (RAB) meeting. Held virtually on Oct. 21, participants were briefed on both the RI and the interim remedial action (IRA) status by Paula Bond, a senior project manager at Aerostar.

A number of other topics associated with the per- and polyfluoroalkyl substances (PFAS) contamination in and around WAFB were also discussed. This included public comments and questions specific to Van Etten Lake (VEL), miscellaneous stakeholder updates and details on a letter which was sent to both the state and the U.S. Air Force (USAF) from the Need Our Water (NOW) group, regarding the USAF being accountable for all known contamination plumes. These items will be summarized in next week’s edition of this publication.

For the RI and IRA updates, background information was first given by Mike Neller, the remediation and redevelopment division (RRD) director at the Michigan Department of Environment, Great Lakes and Energy (EGLE).

He advised that the state of Michigan entered the Defense State Memorandum of Agreement in 1992, in order to expedite the cleanup of hazardous waste sites on Department of Defense installations within the state, and to ensure compliance with the applicable state laws and regulations. As part of this agreement, EGLE is participating in the planning and scoping meetings which are occurring during WAFB’s RI phase.

Neller reminded meeting goers that the USAF is moving forward with two interim response activities, concurrent with the RI. 

“I think it’s important to note that the Air Force is not precluded from implementing other response activities, if warranted, during the remedial investigation phase,” he also pointed out.

According to Neller, EGLE is entering the RI stage with a mindset of looking for other opportunities to undertake additional response activities which could justifiably be carried out to quicken the cleanup efforts at WAFB. 

Ahead of Bond’s presentation, David Gibson of the AFCEC – who also serves as co-chair of the Wurtsmith RAB – spoke, as well.

He was asked how far outside of WAFB the RI is going to encompass, to determine how far the PFAS contamination has gone, and whether this will possibly extend to such other areas as VEL and the AuSable River.

Gibson explained that the RI must delineate the plumes which are the result of USAF operations. If the plumes migrate off-base, the Air Force is tracking these.

As has been mentioned in past RAB meetings, Gibson said there is PFAS contamination in the community which exists outside the hydraulic boundaries of what’s occurring at WAFB, and this will not be explored by the USAF. But if a plume is in fact shown to be the result of USAF activity, then they will be delineating and defining it, and providing any risk assessment remedies necessary.

When Bond spoke, she informed attendees that the involved parties are currently in the planning stage, with developing the work plan for the RI and the IRA.

She said that the objectives for the RI are to delineate the nature and extent of the PFAS compounds PFOS, PFOA and PFBS in groundwater (GW), surface water (SW), soil and sediment. The objectives also include developing a comprehensive understanding of the routes of exposure from the source areas to receptors, assessing the baseline human health and ecological risk and identifying a list of potential Applicable or Relevant and Appropriate Requirements (ARARs) for the project.

According to Bond, ARARs are federal or state laws, rules or regulations that are used to determine the concentrations, to delineate or to use in the cleanup stage as remedies are developed for the site. The intent of the USAF at this time is to delineate six of the seven PFAS compounds for which Michigan has established maximum contaminant levels (MCLs). Not all seven were included, as one of the compounds does not apply to the activities which took place at WAFB.

As reported, Michigan adopted a ruleset in August, creating some of the nation’s most comprehensive regulations limiting PFAS contamination in DW. The new rules provide DW standards for public water systems to achieve.

The MCLs proposed by EGLE, which were then adopted by the legislature, are: PFNA, 6 parts per trillion (ppt); PFOA, 8 ppt; PFHxA, 400,000 ppt; PFOS, 16 ppt; PFHxS, 51 ppt; PFBS, 420 ppt; and HFPO-DA, 370 ppt.

Bond noted that the Office of the Secretary of Defense (OSD) will decide whether the USAF can consider these MCLs as potential ARARs for the Record of Decision (ROD).

RAB member and NOW representative, Cathy Wusterbarth, asked whether the USAF is considering the Rule 57 Water Quality Values as a potential ARAR, and Bond confirmed that they are looking at Rule 57.

Wusterbarth then asked when the actual ARARs will be finalized and set.

Bond explained that the ARARs are not part of the RI phase. They come into play once the project moves into the feasibility study, where remedial alternatives start being evaluated and cleanup levels have to be developed. So, the ARARs will have to be finalized at the feasibility study phase.

As previously reported, the USAF’s investigation work and response actions are guided in part by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) process. The preliminary assessment  (PA) and site inspections, including the expanded site inspection, have been completed at WAFB and the next step is the RI phase.

The PA first identified areas with potential releases of aqueous film forming foam. This PFAS-laden foam was used at WAFB by the USAF, beginning in the 1970s.

Aside from the RI, the remaining CERCLA steps are a feasibility study, proposed plan, ROD, remedial design, remedial action construction/remedial action operation and long-term management.

As part of the RI scoping process, Bond said the team is analyzing the existing data they have, reviewing the conceptual site model (CSM) and then identifying data gaps based on the existing data they have on hand. “We’re developing the data quality objectives for the site characterization for the risk assessment, and the analytical methods that we’re going to use for the samples that we collect.”

Dave Winn – a former RAB alternate who was approved to join the board upon primary member Catherine Larive having stepped down – asked Bond about the existing data they have and what they’re analyzing right now.

She said there is data collected from PFAS samples taken by EGLE, going back to 2011; USAF data beginning in 2012; GW data collection information; and more.

She added that one of the goals is to compile everything that has been gathered so far into one place, to help develop the CSM, so that they can start to plan any future sampling based on all of the existing data that’s available.

In terms of the human health and ecological risk assessments, Bond says they are going to be identifying the pathways and the receptors for both of these.

For the human health side, this will include looking at on-site receptors and residential receptors for DW, commercial/industrial workers, construction workers, hypothetical residents, hunters, recreators, anglers and so on. On the ecological end, the primary receptors they will be exploring are microphytes and algae, as well as invertebrates, fish, mammals and aquatic birds.

“What’s the risk that the OSD is going to not consider the MCLs as potential ARARs, and we end up in a big mess?” asked RAB Alternate Rex Vaughn.

Gibson said he didn’t want to conjecture on this, but noted that the USAF is delineating the plume down to the Michigan MCLs, to try to be at a point where they only have to delineate one time, based upon whatever’s going to be happening in the future with defining the potential list of ARARs.

Continuing with her presentation, Bond said they are in the process of developing the Uniform Federal Policy Quality Assurance Program Plan (UFP QAPP), which will present the goals and objectives of the RI. This will include the background and current CSMs; it will document the sampling provisions made during the scoping  meetings; it outlines the field tasks to be performed; it establishes the data quality objectives and presents the quality control and assurance procedures that will be followed for all of the sample collections; and it documents the location and frequencies of the sampling efforts.

Bond reports that the intent is to have the UFP QAPP completed by March 2021, so the field work can also begin in 2021.

She mentioned the scoping meetings with EGLE, sharing that the parties met on Aug. 20 to go over the initial planning information for the project. Another scoping meeting occurred on Oct. 7, to discuss the IRAs, which was followed with an Oct. 15 meeting to go over the preliminary outline of the data quality objectives.

At the time of the RAB meeting, Bond said that a risk assessment call with EGLE was also being planned, to specifically discuss the assessment, the data quality requirements for same, the EGLE Part 201 requirements pertaining to GW and soil cleanup criteria and screening levels, and the potential ARARs in the future.

As for the two IRAs being planned, Bond says that one addresses the GW plume at VEL, near Ken Ratliff Memorial Park, and the other addresses Clark’s Marsh.

Additional extraction wells will be installed at VEL, and the central treatment system (CTS) at WAFB  will be adapted to accommodate the extra volume from the new wells.

“At Clark’s Marsh, we’re going to install additional extraction wells there, and we’re going to upgrade the existing facility at the fire training area to handle the larger volume of water from the new extraction wells, and expand the existing infiltration gallery,” Bond said.

She added that the group is working on an interim proposed plan and an interim ROD for both of those actions.

RAB Community Co-Chair Mark Henry asked if the goal of the pump-and-treat system for the VEL interim RI is to stop all the flow from that plume from reaching the lake.

“No. The goal of that interim remedial action is to reduce the mass of contamination from entering Van Etten Lake; the majority of the mass,” Bond answered.

She said there isn’t an exact number on this yet, as far as how much it will be reduced. “But remember, these are interim remedial actions; this is not the final  action or the final remedy for the base.” So, the goal is to stop the majority of the mass – or the high concentration areas – from moving into Clark’s Marsh and VEL.

When it comes to the IRA execution plan, Bond repeated that the existing data is being analyzed and that data needs are being identified to support the remedial design. “We’re working on the interim proposed plans for the designs, which outline the alternatives that we evaluated and proposes the preferred alternative.”

There will be a 30-day public comment period for the proposed plan, after which the interim RODs – which document the final decisions for the IRAs – will be prepared.

“We are doing all this in parallel, while we’re preparing the designs,” Bond said, noting that this is so the IRA designs can be finalized by April 2021.

While there isn’t a set date at this point, the team is looking at the December 2020/January 2021 time frame for the public comment period.

Bond provided a general idea of the project time line, but pointed out that there are several factors which could impact the startup of the IRAs. Among these are weather; setbacks from the ongoing COVID-19 pandemic; finalizing the location of the new extraction wells and working out the utility connection details; consideration of the building infrastructure the team will have to work with at the CTS and former fire training area; any delays which may arise in the interim proposed plan and interim ROD review periods; and working with non-USAF property owners to make sure the USAF has access to the infrastructure needed.

As for where the team hopes to be with the time line, Bond says that the target completion of the RI report is June 2022. “For the IRAs, we began the design work in September of this year, and we hope to start the installation work in April 2021, and complete the IRAs by the end of the year.”

RAB representative and member of the AuSable Township Board of Trustees, Jeff Moss, asked for EGLE’s input on the AFCEC/Aerostar proposed actions, time line, et cetera.

Project manager Beth Place, of EGLE’s RRD, said that the department thinks these are really good plans, overall. And personally, she feels that the objective to reduce the highest concentrations is a very good aim, adding that addressing the PFAS going into VEL is something the community has been requesting for a long time.

She remarked that there are some details that still need to be ironed out in the plans – which EGLE expects to see when they actually review the designs – but, in general, she believes these are good plans.

Neller also chimed in, reminding meeting participants of the letter EGLE sent to the USAF earlier this year, requesting that they look at the possibility of doing four IRAs. Two of the four are being addressed, so he agreed that those from EGLE believe this is a positive step and that things look promising. “And we’re happy to see that it’s moving forward fairly quickly, as far as this sort of work goes.”

The next meeting of the Wurtsmith RAB is anticipated to occur in January. Details on the exact date and time will be shared in a future edition of this publication.

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