OSCODA – Oscoda Township community members have long stressed the importance of tackling the area’s per- and polyfluoroalkyl substances (PFAS) contamination at the source. One such move was made recently at the former fire training area (FT-02) of the Wurtsmith Air Force Base (WAFB), where 24,780 tons of PFAS-impacted soil were hauled away from the site.
The project was described during a Wurtsmith Restoration Advisory Board (RAB), where updates were also given on the Air Force’s (AF) remedial investigation (RI) and interim remedial action (IRA) work.
The AF must follow the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) process, and Aerostar SES Project Manager Paula Bond said that the RI scoping is complete. Ongoing is the field data collection, as well as the AF’s work with the Michigan Department of Environment, Great Lakes and Energy (EGLE) to address comments on the Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP) and the risk assessment work plan, so that these documents can be finalized. When the ongoing items conclude, the RI Report will follow.
In the CERCLA process for the FT-02 at Clark’s Marsh IRA, the scoping, proposed plan, interim record of decision (ROD), remedial design and IRA work plan are complete. “So all that’s left now is to implement that action,” Bond said.
She added that those who joined the site visit on Nov. 16 were able to see some of the progress which has been made. This includes grading and prepping the area for a building expansion to accommodate the pre-treatment system which will be installed.
Site work began on Oct. 14 for the Clark’s Marsh IRA, and underground utilities have been installed beneath the concrete slab for the building addition. To date, six performance monitoring wells (MWs) have also been installed for the treatment system.
“Those are the piping for the extraction wells that we’re going to put in; that’s where they’re going to come into in the slab,” Bond said, when showing a photo of some of the project plumbing.
With the CERCLA process for the Van Etten Lake (VEL) at Ken Ratliff Memorial Park IRA, the scoping and proposed plan are complete. The interim ROD, remedial design and IRA work plan are all ongoing and under AF review. “So we hope to get those over to EGLE very soon, and the schedule for [VEL] is to start that work later in the spring, once all of these documents are signed and we get approval of those moving forward,” Bond explained.
The next step, then, will be implementation of the IRA. Bond said that this is running a little further behind than the Clark’s Marsh IRA; however, it is still on schedule.
She also shared additional details about the ongoing RI fieldwork, the first step of which entailed groundwater (GW) sampling. From July 19 through Oct. 21, samples were taken from 96 existing MWs at the site which had not previously been sampled for PFAS.
This data was fed into the second step, that being the soil sampling fieldwork which was initiated on Aug. 16. According to Bond, more than 1,000 soil samples, taken from 231 locations across WAFB, have been analyzed. “We are very close to being finished with the soil sampling, and we hope to finish that up in the next week or so,” she said, at the time of the Nov. 17 RAB meeting.
The third step in the RI UFP-QAPP is the vertical aquifer sampling (VAS) which began on Sept. 13. So far, roughly 100 GW samples have been taken from 16 locations. Bond said that if the weather allows, the plan is to proceed with VAS through the end of December. All of the RI fieldwork is still ongoing and, once the weather breaks, these efforts will continue in the spring.
As the anticipated time line stands currently, everything will be done by the fall of 2022 for the IRAs and the RI work.
One element of the fieldwork which Bond referred to as particularly exciting, is the action that was completed at FT-02 in November. “We removed over 24,000 tons of soil,” she said of the undertaking, which was accomplished in about one month.
Prior to this, the concrete pad which once existed at the former fire training area of WAFB was removed in the spring. The soil underneath the former pad had to then be hauled away, as it created a situation where the exposed soil could increase the migration of PFAS from the surface, down into the GW. “So that was the rationale for implementing this soil removal action,” Bond pointed out.
The PFAS-impacted soil that was taken from the site was transported to and disposed of at the US Ecology hazardous waste landfill in Belleville.
“But I do want to make the important distinction that, even though we are transporting the soil to a hazardous waste landfill, this waste is not a hazardous waste,” Bond said. She explained that the soil is being disposed of at this facility as a conservative approach because the landfill is made for higher toxicity chemicals, so that they don’t leach into the GW.
When RAB Member Joe Maxwell said it didn’t make sense to him that these soils aren’t deemed as hazardous waste, Bond noted that there is a difference between contaminated materials and those designated as hazardous.
She said that, in short, this type of waste has a very specific, regulatory meaning and that the definition of same is determined through various processes, testing and so on. “So PFAS, currently, is not regulated as a hazardous material by the EPA.”
Elaborating on Bond’s presentation was RAB Co-Chair Dr. Catharine Varley, of the Air Force Civil Engineer Center’s (AFCEC) Base Realignment and Closure (BRAC) Program Management Division.
She said that removal of the concrete pad at FT-02 allowed the teams to conduct the actual sampling. “The probability of leaching and the proximity to Clark’s Marsh was the reason for doing the time-critical removal action this year, before we have snow and everything else going right through all of that.”
In 30 days, based on rough calculations, “we removed a concentration equal to or greater than what we’ve removed from the FT-02 treatment system that’s been operational since 2015,” Varley continued.
Based on the data the AF has, she said that the mass of PFOS and PFOA – two types of PFAS – which was removed from the soil during the excavation was approximately 46 pounds. Making this even more significant is that it doesn’t include any of the precursors that could turn into PFOA/PFOS, the other compounds, the fuels or anything else which was at that site.
Bond said that the excavating portion of the project was finished the week before the RAB meeting. “We are ready to backfill and we’ll start doing that either later this week or early next week.”
She remarked that the excavation was impressive and that a lot was accomplished in a short period of time, which is thanks to the team of people working on the project. “So I think that’s a great success for the [AF] and we’re happy to be part of it.”
RAB Member Dave Winn expressed his appreciation to the crews for initiating the soil removal and, in reference to the high levels of PFAS, “everybody in this room has always talked about, get rid of the source, get rid of the source,” he pointed out.
He said that in 30 days, the team did a heck of a job getting rid of what he considers a source.
Winn also mentioned the posters which were displayed in the lobby of the meeting venue, showing the data that’s been collected so far during the RI fieldwork. Based on this and some of the other charts and information, he said he can see that there other holes which will have to be dug, and he wondered when this may occur.
“So what we need to do is keep working on our programming planning and we’ll do that, and I’m glad you support it,” Varley replied.
As far as he’s concerned, Winn said that whatever they need to do as a community to help push this along and get rid of all of the sources, he’s ready for that.
“I’m serious, this is great stuff,” he continued. “This is stuff that should have been done years ago, but I’m really, really appreciative of the fact that you guys have took the initiative in order to do it.”
While he was pleased with the soil removal, Winn raised a concern which has also been discussed at prior RAB gatherings, regarding the timeliness of receiving the BRAC Cleanup Team (BCT) meeting minutes.
The AF holds the monthly BCT meetings with representatives of EGLE and the Michigan Department of Health and Human Services, and Winn – who noted that he hadn’t seen any of these minutes in several months – said that he would like this information as quickly as possible.
He added that the minutes are important for those in the community so that they know what’s going on at WAFB, as well as in other parts of Oscoda and the surrounding areas.
“There was difficulty getting access to the recordings again,” said RAB Member and EGLE Project Manager for WAFB, Beth Place.
She explained that it is the AF which releases the minutes to the public, but that they are posted on the EGLE website when the AF has these finalized. She said that she can also let the RAB group know once EGLE has provided their comments/review back to the AF on the latest sets of minutes.
Further, Place said there have been past discussions about the potential of having transcripts from the BCT meetings. So she asked meeting facilitator Tim Sueltenfuss to capture, as a RAB action item, determining whether the minutes can be transcribed. “Because then that will really alleviate this whole issue and they can be provided to the community in real time.”
Added to this action item later on, at the request of RAB Member Arnie Leriche, was for the entities to also consider the best process by which to release the minutes in a timely fashion, if transcribing is not an option.
As for the time-critical removal action involving the approximately $6 million soil project at FT-02, RAB Member Cathy Wusterbarth agreed that this is very exciting. However, she said it was her understanding that this was recommended more than a decade ago, so she’s concerned that it took so long to get it done.
She asked if Varley had any insight as to why, when she took over the BRAC Environmental Coordinator duties at WAFB, this suddenly got done “and why your predecessors did not.”
Varley answered that she has experience with moving projects forward, which is a team effort and requires the community’s support. “We all need to be involved and working together.”
She said they were able to do this work because everything fell into place, it was good timing, there was a community effort, people were asking the right questions at the right time and they were able to start the sampling and get the ball rolling.
Varley said that hopefully this can continue as they proceed through the CERCLA process, as well as move forward in the IRAs.
Chiming in was Attorney Sharon Vriesenga, who advises the AF on restoration matters at WAFB. She said that there are rules and regulations about when a removal action can be done.
According to Vriesenga, the only reason the AF was able to remove the soil at FT-02, was because the concrete cap/cover was taken off as a part of the other work that was going on there. When that was done and the soil was sampled, they realized they had a scenario – as the time-critical removal action memo talks about – that there was an increased risk of contamination now getting into the GW, because the cap had been removed. “That was the driver for this removal action.”
She said it’s not as though they can just go right out and start digging up contamination anywhere on the base. “There has to be a driver to take action this fast. This one had it, and maybe we’ll have it somewhere else on the base and maybe we won’t.”
But as things move ahead in the CERCLA process, Vriesenga said they will get to the feasibility study (FS) and something that they’ll need to consider is, whether to do more soil removal or to implement another technology. “And we will get there.”
Wusterbarth said that maybe she wasn’t clear, but she thinks that the recommendation in the past had been to remove the cap, specifically.
“So the cap was removed for fuels. It was a 2017 work plan,” Varley said. “When I was coming on board, it was already in motion and going. So, once the cap was removed, we needed to know what was under it. So we were able to sample it and get everything removed.”
RAB Member Rex Vaughn asked if any simulations had been performed which estimate the impact that the soil removal will have on the shrinking of the plume flowing into Clark’s Marsh.
Bond said that it had not. “We haven’t done any modeling with that yet.” However, now that the soil is gone, they’re really going to start closely looking at the extraction well data from FT-02.
It will require some time, though, for any action which is taken that far upgradient to show an impact down where the other MWs are, closer to the treatment system itself. “But yes, when those wells are sampled, we’re definitely going to be looking to see what impact this has had,” Bond assured.
Related to this, RAB Co-Chair Mark Henry said there are multiple MWs immediately downgradient of the excavation. So, he asked if there are any plans to monitor those periodically to see the short-term impacts.
Bond said there is not, but she knows that under other programs which are going on at the site, there is some annual sampling that takes place at FT-02. So while there isn’t a specific plan just for the dig and haul, as data is collected for all of the other activities – including the RI – all of it will be looked at to see what the impact is. “But we’re not going to be focusing on the impact of that immediately, right away, by developing a plan for monitoring that and looking at that.”
Varley added that the key thing is this was a time-critical action to remove the area directly under the pad, as well as the small area adjacent to it, because they were seeing signs of leaching. It was an action in and of itself, separate from the other projects at WAFB. It was removed as quickly as possible, and now they’re back to the RI. “We’ve got to look at how this will impact the RI and moving this site into a feasibility study, because it’s time to start looking at that.”
To Wusterbarth’s point, RAB Member and Oscoda Township Trustee Timothy Cummings said it is concerning that this was talked about 10 years ago. But the big concern is that, in order to continue the accolades, this has to maintain the speed of progress.
In reference to such moves as the soil project at FT-02, Cummings said that they’ve been through a few folks who were in the position Varley is now. “You’ve done more in the short time you’ve been here than anybody we’ve seen prior,” he told her. “And I’m at least encouraged by what you’ve been able to produce, so I thank you personally, on behalf of Oscoda Township.”
He also asked Varley what she sees as the next steps for this site. “What do you see down the road?”
“So what we’re doing right now is, we’ve collected a lot of RI data,” Varley said, which is being analyzed to ensure they have full capture.
If they don’t have capture, she said they need to step in and do something to expand, to make sure that they’re not contaminating such locations as the AuSable River, Clark’s Marsh and VEL.
“So we’re going for capture, as well as pursuing the CERCLA process,” she said, adding that with the investigation, she’d like to start the FS as soon as there is enough data to support it.
In other business, Oscoda Township Trustee William Palmer asked about the AF’s plan to install more test wells along VEL, and where these may be located.
According to Varley, there are a number of Rights of Entry documents which have been sent out so that the AF can actually delineate the plumes, of which there are several in this area. For now, the intended MWs will all be situated on the west side of VEL.
Approval allows the team to move forward, and currently this involves VAS sampling. Varley said this is where a hole is punched into the ground, samples are taken on the way down and water is collected at the water table, all the way down to the confining clay layer. Once it has served its purpose, “we seal that well up so that it’s no longer there.”
She said that there will also be some permanent wells in the future which the AF will seek access for, and that this access is extremely important in understanding where there is contamination and where action needs to be taken. For those who may receive such Rights to Entry requests, she asked that they at least consider it, as it will make the remediation process much better if everyone does it together.
Bond said she didn’t have the exact number, but she believed that about 20 of these letters had gone out, as of the meeting. Depending on how many people grant permission, other letters will then be sent to adjacent areas.
The latest quarterly RAB meeting was held in the Oscoda United Methodist Church, but could also be viewed online that evening. For those who missed the hybrid event, a video recording is available on the Wurtsmith page of the AFCEC website. It can be found by going to https://www.afcec.af.mil/Home/BRAC/Wurtsmith.aspx and clicking on “RAB Meeting Materials.” This contains a link to the video, as well as copies of the posters which were shared during the meeting and other WAFB information.