OSCODA – In addition to an Aug. 31 meeting hosted by the Air Force Civil Engineer Center (AFCEC), the proposed interim remedial action (IRA) plan for Van Etten Lake (VEL) at Ken Ratliff Memorial Park was also discussed at the latest Wurtsmith Restoration Advisory (RAB) meeting. It was a hybrid event, with some people participating online and others joining in person, at the Shoreline Players Community Theatre.
The IRA options laid out on Aug. 31, which included talks on the preferred approach for reducing the per- and polyfluoroalkyl substances (PFAS) entering VEL at the park in Oscoda, were summarized in the Sept. 15 edition of this publication. As noted, the IRA will address PFOS and PFOA, which are two types of PFAS compounds. These and other PFAS are migrating into VEL from the former Wurtsmith Air Force Base (WAFB), via groundwater (GW), as a result of the aqueous film forming foam (AFFF) used at the site when it was an active base.
The remedial action alternatives proposed were pump-and-treat using granular activated carbon (GAC), pump-and-treat by ion exchange or no action, with the AF’s preferred route being the GAC option.
This was described in detail on Aug. 31, by Aerostar Senior Project Manager Paula Bond, who also spoke at the RAB meeting. For this story, then, the focus will be more on the questions and comments shared, rather than a synopsis of the actual project.
Video of the meeting can be viewed at https://www.youtube.com/watch?v=mv4Y0vgphoU. It can be accessed through AFCEC’s webpage at https://www.afcec.af.mil/Home/BRAC/Wurtsmith.aspx, as well, which also contains the meeting materials and other WAFB documents.
Starting things off were the stakeholder updates, and RAB Co-Chair Dr. Catharine Varley – who is the Base Realignment and Closure Environmental Coordinator for AFCEC – was among those to speak. She said that a lot of fieldwork is being done at WAFB, they have made it through step one of collecting GW samples and, for step two, the collection of soil samples has been well underway. The third step, entailing vertical aquifer sampling (VAS), was to begin in September. “Along with that, we also are planning on moving forward as far as the IRAs go.”
When RAB Member and Need Our Water (NOW) Co-Lead Cathy Wusterbarth spoke, she mentioned the report which was recently released by NOW, in conjunction with the National Wildlife Federation (NWF) and the Great Lakes PFAS Action Network.
Entitled, “PFAS Contamination at the Former Wurtsmith Air Force Base, The True Story,” Wusterbarth read some of the report, which she said is a hard look at the actions taken – or not taken – by the federal government and the state of Michigan to mitigate harm to the community and clean up PFAS pollution at this site.
The report highlights what must change in order to rebuild trust with the Oscoda community and see meaningful action on PFAS cleanup, she described.
According to the document, the Department of Defense (DoD) Inspector General (IG) report evaluation of the DoD’s action to control contaminated effects from PFAS at DoD installations, released on July 22, found that DoD officials are not applying an enterprise-wide approach to mitigating PFAS contamination at military sites – and that people and the environment may continue to be exposed to the contamination, unnecessarily, as a result.
The NOW and NWF report which was created for Wurtsmith illustrates how the inactions outlined in the DoD report have materialized in real time, Wusterbarth continued. “It is a testament of what needs to change.”
The government must do more, and do it better, to protect people and wildlife, she said. “And we need stronger policies at the state and federal level to hold polluters and regulators responsible for timely cleanup.”
The report is sectioned out into actions which took place with the Air Force (AF) and the state of Michigan. It describes the issue or the need that occurred at the site, what should have happened and then what really happened, according to Wusterbarth.
She said that the sections include AF actions which are inconsistent with the known severity of the problem, for which 14 of these are listed; false promises; endless delays; and the state’s inability or unwillingness to protect people and natural resources in Oscoda.
She noted that the report, with 86 references, was thoroughly researched and can be found on the Great Lakes PFAS Action Network website, at glpan.org.
When Wusterbarth elaborated on this later in the meeting, during public comments, she said that for more than 50 years, the U.S. military has used AFFF containing high concentrations of PFAS. These chemicals are extraordinarily toxic and persistent in the environment. They have been linked to cancer, kidney disease and numerous birth and developmental disorders. PFAS are widespread in the environment because they take decades to break down and many tend to bioaccumulate in people, fish and wildlife.
The report goes on to discuss when PFAS were first discovered at WAFB – more than 20 years ago – and claims that the contamination is running largely unchecked through the Oscoda area, due to the AF’s failure to control and clean up the PFAS plumes from the base.
The AF has known about the toxic nature of PFAS since the early 1970s, Wusterbarth said. Despite this knowledge, the AF has been extremely slow to address the devastating effects of its historic discharges of AFFF at WAFB. When it has responded, the AF has taken inadequate actions which have only worsened the public crisis in Oscoda.
The report also accuses the state’s actions of being deficient. Although the state has played a significant role in uncovering the extent of PFAS contamination at WAFB, it has frequently been slow, opaque and ineffective in warning Michiganders of the dangers of exposure to this contamination at WAFB. Furthermore, the state has generally failed to use the strict PFAS cleanup standards that have developed over the past few years to its advantage.
NWF representative Jennifer Hill stated that the federation stands behind the report it released with NOW. “We have shown that the [AF] and the state of Michigan can and should be doing more to address PFAS cleanup at this site, and we look forward to working with both entities to get to meaningful cleanup as quickly as possible.”
“The [DoD] IG report that Cathy just mentioned is huge,” said RAB Member Arnie Leriche.
Many people have known that the federal government, EPA, DoD and the Office of Management and Budget have not taken action and asked for the budget to do what’s right and required under DoD policies and CERCLA, he said.
Leriche implored the public to speak with their representatives in Congress, ask if they read the IG report and, if they understand it, ask what they’re going to do about it. “Because if the [DoD] is not pushed to follow their policies after this report, then we’re going to lose the momentum. They will not ask for the money because they need money for other things. And we’ve seen that happen at this site – we don’t get our fair share.”
Beth Place of the Michigan Department of Environment, Great Lakes and Energy (EGLE), who is the project manager for the former base and also serves on the RAB, spoke as well. Along with her briefing, she addressed the NOW/NWF report.
She first mentioned the AF’s GW monitoring well and soil sampling activities which have begun. EGLE has been on hand to perform oversight and collect select quality assurance samples. “So, basically a duplicate of [AF] samples that we’re having analyzed at a separate lab, just to really have a peace of mind or insurance on the analytical results.”
Place said that EGLE has also been participating in discussion on the VAS locations, “and that has been going well.”
As for the report, she said the state wants people to know that there is a complete time line – with more steps than what was provided in the document – on the Wurtsmith page of the Michigan PFAS Action Response Team (MPART) website.
She also advised that Michigan has had a proactive and transparent approach to PFAS contamination, and has been widely recognized as the national model for addressing what was once considered an emerging class of contaminants.
When the state created MPART in November 2017, and since that time, Place says that in their opinion, no state or federal agency has done more to address PFAS contamination or hold responsible parties accountable and educate the public about this class of contaminants.
She notes that EGLE agrees with many of the findings made by the NWF and NOW, regarding the AF’s response to the contamination at WAFB. “However, having said that, the report fails to reveal a complete time line of the state’s work that’s available on the MPART website.
“And so, EGLE agrees that the lack of federal action on PFAS and the DoD’s reliance on the slow-moving CERCLA process has certainly complicated Michigan’s efforts to accelerate the U.S. Air Force cleanup on [WAFB],” she proceeded. “But MPART will continue to advocate for the public and do everything within the state’s power to see that this former federal facility is cleaned up to state standards and the public’s drinking water and environment is protected.”
She added that, although they will always strive to have a faster pace, they have been seeing action occurring at WAFB. For example, EGLE is pleased with the two IRAs – one for VEL at Ken Ratliff Memorial Park and the other for Clark’s Marsh – as well as the AF being in the field to perform the remedial investigation (RI).
More remarks were later shared by Wusterbarth, when she summarized the formal comments provided to the AF from NOW, regarding the VEL IRA.
As reported, the 30-day public comment period for the proposed plan was open through Sept. 3, and some of NOW’s feedback was noted in the Sept. 15 edition of this publication.
One of the group’s comments referenced a concern which was also expressed by some of the other meeting goers.
NOW says that the VEL plan includes a new GW extraction well field, paralleling F-41. It will capture PFAS-contaminated GW, direct it to the existing central treatment system (CTS) plant at WAFB, and the treated water will then discharge to Van Etten Creek. NOW believes that the AF should expand the plan footprint to the north of the current proposed extraction well field along F-41.
“Waiting years to act while more study of the problem is undertaken is unnecessary,” Wusterbarth said in her summary of the group’s comments. They state that this is a situation where there is a clear imminent and substantial endangerment of the public and the environment. More study is not going to make the known plume stop discharging into VEL.
“It should be understood by everyone that this interim action, while helpful towards a final cleanup of [VEL], is incomplete as even a short-term solution, and that much more effort is needed to reduce the impacts on the lake and citizens,” Wusterbarth said.
However, overall, NOW is pleased that the AF has doubled the treatment capacity of the CTS plant, and is cutting off much of the plumes which discharge at Ken Ratliff Memorial Park.
The desire to expand the plume capture area in the VEL IRA was echoed by NOW Member Anthony Spaniola, who also owns property on the lake. He said the community has been told that there are data gaps. “And we have experts on our team who are telling us that this is not, in fact, the case.”
He added that it was in April 2020 when the AF said they didn’t have enough data to even do an IRA at Clark’s Marsh, or to do one at VEL. But when Congressman Dan Kildee went to the Pentagon, “suddenly we had enough data,” Spaniola contends.
He said one issue is that, over and over again with this project, corners have been cut and efforts have not been taken to properly manage and deal with the full extent of contamination, “when we know that we have a problem.”
At the time of the meeting, he noted that his concern – which he said is shared by many others – is that they were near the end of the public comment period for the VEL plan. “This has been going on for more than a year. The Air Force has not explained adequately why it’s not addressing the additional contaminant plume, and now is the time to do it.”
Further, he said they were told that money wasn’t going to be an issue, but his strong suspicion is that money is driving this and that the AF really just doesn’t want to do it. “So I’m asking for action; I’m asking for action to make that happen.”
Varley said that they were in the middle of doing the RI at that point. “We’ve already started, we got the gears rolling and we are collecting data. We are closing those data gaps as fast as we can, and as we do that, we will be programming to take care of any human health concerns, or any ecological concerns.”
Bond said she has also had conversations with others, regarding why the AF isn’t going further north with the IRA at VEL, and she explained that data gaps are one of the reasons.
Like Varley, she said they are in the process of looking at this in the RI, to fill those data gaps.
Additionally, a goal of the IRA is to find the best option to cut off the higher concentrations of PFOS/PFOA that are moving into VEL at Ken Ratliff Memorial Park, and Bond said that this area is indeed where the highest concentrations/risks are present. “So that’s what we tried to focus on.”
When the CTS was constructed in 2018, she said it was built to house a second treatment train on the other side, and that was already in place. So when the AF asked about the fastest way to get some action and mitigate the VEL issues at the park, it was decided that they would take advantage of the existing CTS, which was built to expand, and use that to wrap into the IRA.
Bond said that the treatment capacity in the current CTS is 500 gallons per minute (gpm), and that it was designed to handle another 500 gpm on the other side. “So with the 500 [gpm] capacity that we have, and the IRA that we’re looking at, the 12 wells that we’re proposing in the proposed plan, will use the capacity of the [CTS].”
She said the quickest way to mitigate the issue of the higher concentrations of PFOS/PFOA, is to use the existing infrastructure for the purpose it was meant for.
She also referenced the discussion from the Aug. 31 meeting, which was attended by Project Engineer Jim Romer.
Bond said Romer had mentioned that as part of the design, they are adding in one additional blank so that if, based on operational data they can add another well, that might be possible.
“Depending on our optimizations that we do, maybe we can add another well, and that additional capacity will not overwhelm what we already have going into the CTS,” Bond said. “So we do have some capacity from the original train because we’re not actually pumping it at 500 [gpm] right now. So we could use that, but we need to get the system up and running to see what we could do if we needed another well.”
And the key thing is the purpose of the IRA, Varley added, which is to protect human health and to address hydraulic control/capture at the most severe areas. “And that beach is a serious issue.”
When RAB Alternate Rex Vaughn asked if the engineering design team ever evaluated what it would take to expand the CTS plant to allow the pipeline to run farther to the northwest, along F-41, and pick up some of the additional plumes which have been identified by EGLE, Bond confirmed that this was looked at.
She said they are confined by the capacity at CTS, the way that it’s built, but they also looked at building a completely new treatment system, expansions and more. They settled on using the infrastructure which was already in place as the best path forward at the current time, because they knew that where the highest concentrations were, they could capture that and treat it with the existing system – and get to treatment more expeditiously.
“So everything to the north will be addressed once the RI is complete,” Bond continued. Or, “If there is something that we find during the RI that leads us to another interim action or another early action, then the Air Force will look at that and take that on. But everything to the north will be addressed. We’re not saying it’s never going to be addressed; just for this current interim action, this is, we thought, the best path forward.”
Among the other takeaways from the RAB meeting were:
• According to the fieldwork time line – which is subject to change based on weather conditions, procurement of materials and so on – construction of the Clark’s Marsh IRA is to begin at the end of October, with startup in May 2022. The VEL IRA construction is also expected to begin this fall, with startup planned in August 2022.
• Fieldwork will continue for as long as the weather holds out this season, and the teams plan on continuing their RI/IRA work, collecting data and more during the winter months. This includes the hope of having the building constructed for the Clark’s Marsh project, so that crews can work inside throughout the winter, get this up and running and have it ready to go in the spring.