plume

PLUME MAP – Need Our Water (NOW) Oscoda members have sent a letter to the U.S. Air Force (USAF) asking that a proposed line of extraction wells be extended, to better address per- and polyfluoroalkyl substances (PFAS) contamination. They contend that draft maps which have been shared since January understate and/or omit PFAS plumes which were previously identified. It should be noted that the handwritten portions on the map above were added by the NOW group. 

OSCODA – Members of Need Our Water (NOW) Oscoda are awaiting a reply from the U.S. Air Force (USAF), to a letter they sent regarding the per- and polyfluoroalkyl substances (PFAS) plumes which are present in the township.

The letter was sent on Oct. 20 to David Gibson of the Air Force Civil Engineer Center (AFCEC), who is also co-chair of the Wurtsmith Restoration Advisory Board (RAB).

NOW is a community group which was formed in response to the ongoing PFAS contamination spreading from the former Wurtsmith Air Force Base (WAFB) in Oscoda. Representatives mentioned the letter they submitted to the USAF, during the Oct. 21 RAB meeting.

NOW Co-Lead Cathy Wusterbarth said the communication was also sent to the state, and it involves a request for the Michigan Department of Environment, Great Lakes and Energy (EGLE) to hold the USAF accountable for all known contamination plumes – not just those on the conceptual maps. “We’re noticing a difference there, and we’re asking that those entities make sure the plumes are defined accurately.”

When she questioned whether the USAF would be responding to the letter, Gibson said he received it, that it is being looked at and that there will be a reply “coming back shortly.”

At press time, Anthony Spaniola – a NOW member and Van Etten Lake (VEL) property owner – advised that he had yet to get a response. Spaniola, an attorney, penned the communication on behalf of NOW.

He began by writing that, in a meeting at WAFB in late August,  John Henderson – Assistant Secretary of the Air Force for Installations, Environment and Energy – provided Congressman Dan Kildee and Oscoda Township Supervisor Aaron Weed with maps, labeled as “preliminary conceptual drafts.” These depicted the USAF’s planned interim remedial actions (IRAs) at the former base.

One of the draft maps showed a proposed line of extraction wells running parallel to VEL and F-41, Spaniola continued. He attached a copy of same with the letter, and labeled this first attachment as the “F-41 Extraction Well Draft.”

In reviewing the draft maps that Henderson provided to Kildee and Weed, the NOW group says it has become apparent that those maps, including the F-41 Extraction Well Draft, understate and/or omit PFAS contaminant plumes previously identified by the USAF and/or the state of Michigan.

For example, Spaniola referenced a map dated Jan. 17, 2020. He stated that in this map, the AFCEC depicts an area of contamination with PFOA plus PFOS – two different types of PFAS – at levels between 70-700 parts per trillion (ppt), which is left out entirely from the F-41 Extraction Well Draft.

For purposes of identification, he wrote that the Jan. 17, 2020 map will be referred to as the “January, 2020 Map.” He provided a copy of this as his second attachment in the correspondence, with the map marked to show the approximate location of the omitted portion of the plume.

This general location was also depicted on a marked-up version of the F-41 Extraction Well Draft, which Spaniola included as the third attachment.

“As noted in both Attachment 2 and Attachment 3, the proposed line of extraction wells in the F-41 Extraction Well Draft does not extend far enough to the north to capture the contaminant plume omitted from the F-41 Extraction Well Draft,” he wrote. “This issue can be addressed by extending the proposed line of extraction wells by approximately 1,500 to 2,000 feet to the north, and I respectfully request that the Air Force make this adjustment.”

Spaniola also stated that, during the interim remedial phase, the expense to add the requested extraction wells would be minimal. In fact, it would be far more cost-effective and beneficial than allowing the contamination to continue migrating into VEL for remediation at a later date.

On behalf of NOW, he also asked the USAF to confirm that the draft maps provided by Henderson are not intended to, and in fact do not, fully depict the USAF’s understanding of the PFAS plumes which have already been identified.

“I understand that these maps are ‘drafts,’ and I appreciate that the Air Force provided them to our congressional and township representatives, so that input from community members like me can be reviewed and considered at this stage of the process,” Spaniola went on. “Community input at this stage is vitally important, and I sincerely hope that the Air Force will work to engage in an informed and meaningful dialogue with community members at all phases going forward, beginning at the earliest planning stages.”

He elaborated on the NOW letter during the public comment portion of the RAB meeting.

As reported, the event included an update on AFCEC and Aerostar’s remedial investigation (RI) at WAFB, as well as the IRA status at the site. The briefings were given by Paula Bond, a senior project manager at Aerostar, and Gibson.

Spaniola said he knows that the USAF intends to delineate the plumes to the maximum contaminant levels (MCL). However, the Rule 57 limit for PFOS is lower than the MCL. So, he asked if they will be delineating in the groundwater-surface water interface (GSI) area to the Rule 57, which has a 12 ppt criteria for PFOS.

Bond answered that yes, they are delineating to the GSI – which is the location at which groundwater vents to a surface water body – in the GSI areas.

In looking back at the map which the USAF presented in January, Spaniola reiterated that the portion of the plume which has been omitted was shown to be 70-700 ppt for PFOA plus PFOS.

“But whether it’s one or the other or both, there has to be a pretty substantial exceedance in those areas, of either one or more of the MCLs, or in the GSI,” he said. “And so, as we’ve indicated in our letter, we’re asking that that extraction field be extended by that 1,500-2,000 feet, in order to capture that as part of this whole process.”

He then asked if Bond had a comment on the issue about the excluded plume being between 70-700 ppt.

Bond explained that AFCEC and Aerostar are still in the planning stages of the project and, as they obtain and collect additional data, these entities are updating the plume maps.

She added that they are using all of the data which is available to them at this point, from all of the sampling that has been carried out by both the USAF and EGLE.

Bond said that the maps shown at the RAB meeting look slightly different from the original ones that were shown a couple months ago. “So, as we move through the process and we refine our conceptual site model and we obtain additional data, that plume will continue to move just a little bit.”

She also noted that the plume areas are not small. “The scale is very large. So, when we have a data point that we’re looking at and the modeling projects out in the distance where we don’t have data, we’re going to refine all of those points as part of the RI. But the data for developing the IRAs is based on the data that we have in our hands right now, and those prior plume maps are based on the data we had in our hands at the time those maps were generated.”

Spaniola asked if Bond was saying that the map from January is inaccurate, in that the plume has shrunk.

“No, not at all,” she replied. “I’m saying that when we created the maps we had, based on the data that we had in our hands, that was the way that the plumes were projected.” As more data is gathered from EGLE and the USAF, and those additional points are incorporated, that plume has been more refined.

Therefore, she said if it is compared to the plume maps that were shown at the RAB meeting, she thinks it looks more similar than what was seen in the 2020 report.

Spaniola asked if the January 2020 map is accurate, to which Bond said it is, based on the data which was used to generate the plume map.

“And that was generated by the Air Force?” Spaniola questioned, which Bond confirmed.

Spaniola said he was still confused, because in later maps, he’s noticed that this part of the plume was not depicted.

Gibson asked if what Spaniola was pointing out was that he wants the extraction system that’s being installed for VEL to be larger, because there’s other plumes on the base. “Is that the bottom line?”

“No. What I’m saying is, it should be larger to encompass the plume that’s already depicted that this is a part of,” said Spaniola, adding that  it stops before the end of the plume, based on the map from the USAF.

Bond showed meeting participants a slide with the map for PFOS. She said that if they look at the plume configuration, the map includes data from monitoring wells, vertical aquifer sampling points and additional visional data points that they have, which may not have been available in January.

Gibson sought confirmation for attendees, as to whether the PFOA map is actually larger than the plumes which were shown that night.

Bond said the PFOA map does cover a larger extent, but the concentrations are lower. This is why they used PFOS just for that map background, because the PFOS concentrations are higher and the hot spot area that’s going into VEL can be seen more clearly.

Gibson added that they are trying to attack the area that’s going into VEL, as well as that entering Clark’s Marsh. Although there is a plume going into VEL that’s to the north of that area, and a plume further to the west at WAFB that eventually goes to Clark’s Marsh, he said these are the IRAs that affect the highest concentrations, closest to the areas of concern.

Spaniola remarked that the explanation made no sense. “Again, you have data from January 2020 that clearly shows this area, and it’s depicted very differently than in this map. And I find it incredibly difficult to believe that, all of a sudden, you’ve collected more data and you’ve found a smaller plume.”

Bond noted that this is not what they were getting at.

“Then what you’re saying here is wrong. This is not an accurate depiction of what’s going on there,” according to Spaniola.

“This is an accurate depiction, based on the current data that we have,” Bond repeated, pointing to the lines of the plume boundaries  that are dashed, which indicate there are data gaps that need to be filled in.

The meeting facilitator, Tim Sueltenfuss, then brought up the NOW letter. “And Dave, I believe you had mentioned the Air Force would be considering a response to that letter. Is that correct?” he asked.

Gibson said yes, an answer will be given, and it might be in the meeting minutes or it might be in a letter back to NOW. “But I’m hearing loud and clear that there is a concern there are plume maps shown in January 2020 that differ from these plume maps, and therefore, that then creates confusion or concerns about, is the Air Force addressing the proper location for this interim action.”

“That’s correct,” said Spaniola.

“Then we’ll answer that question,” Gibson assured.

The NOW group has advocated for PFAS cleanup in and around WAFB, at all of the areas of concern. And this is not the first time they have made requests pertaining to VEL, in particular.

As previously reported, NOW called on the USAF this spring to stop the flow of PFAS contaminants from Wurtsmith into Oscoda area surface waters by no later than 2023, and to immediately begin remediation of the PFAS plumes impacting VEL.

When the USAF responds to the NOW letter, an update will be shared in a future edition of this publication.

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