OSCODA – The following is the second of a two-part story, the first of which ran in last week’s edition of this publication. As reported, the Air Force (AF) Civil Engineer Center recently hosted a public meeting to receive input on a proposed plan to address per- and polyfluoroalkyl substances (PFAS) contamination in Clark’s Marsh, adjacent to the former Wurtsmith Air Force Base (WAFB) in Oscoda.
Provided last week was a summary of the three alternatives that were explored to tackle the perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) – two types of PFAS – which are migrating via groundwater (GW) to the marsh, due to the past use of PFAS-containing firefighting foam near the site. Meeting participants also had both an informal question-and-answer session with AF representatives and a verbal, formal public comment period.
As noted, the Clark’s Marsh interim remedial action (IRA) meeting featured a synopsis of the alternatives for reducing the GW plume migration into the marsh. Alternative No. 1 entails no action, Alternative No. 2 involves expanded hydraulic control using a pump-and-treat system (PTS) with ion exchange and Alternative No. 3 – which the AF has deemed as the preferred method – would be expanded hydraulic control using PTS with granular activated carbon (GAC). Based on the current schedule, the IRA work at the marsh will start in July.
The AF is to respond to the formal public comments within a summary that will be included in the Clark’s Marsh interim record of decision (ROD). The ROD will be prepared following the 30-day public comment period.
Dr. Catharine Varley – the Base Realignment and Closure (BRAC) Environmental Coordinator for WAFB – said the AF will take time to consider each of the remarks, along with all of the comments shared by mail or e-mail. The AF is accepting written comments on the proposal during the 30-day period, which began on March 18 and will run until Saturday, April 17.
Letters must be postmarked by April 17, and should be submitted to: Dr. Catharine Varley, BRAC Environmental Coordinator, Air Force Civil Engineer Center, 2261 Hughes Avenue, Suite 155, JBSA Lackland, TX 78236. E-mails can also be sent to Varley at email@example.com.
The proposed plan is available for viewing via the AF’s administrative record (AR) file, at https://ar.afcec-cloud.af.mil. It can also be accessed from the information repository (IR) in the Robert J. Parks Library, located at 6010 N. Skeel Ave. in Oscoda.
As for the informal questions, among those who spoke was Jacob Bennett, of Congressman Dan Kildee’s office. He asked if the plans are in compliance with the applicable or relevant and appropriate requirements (ARARs), as well as what the goal level is – in parts per trillion (ppt) in PFAS – that the AF is judging by the ARARs. Additionally, he inquired about the ion and GAC treatment options outlined in two of the alternatives, and wondered whether one is better than the other.
For the latter, Aerostar Senior Project Manager Paula Bond explained that these both use absorption technology. “So, as the water moves through there, the PFOS and PFOA will absorb either onto the ion exchange resin or the GAC.”
According to Bond, both options are very efficient. The difference, though, depends on the quality of the water entering the system. “For the ion exchange resin to be the most effective, the quality of that water has to be much better so that we don’t have biofouling in those tanks. So there would be additional pretreatment to remove bacteria and different things like that.”
As reported, the second and third alternatives would increase hydraulic control by adding five new extraction wells. Each option would also increase the GW extraction capacity by 40 percent, and would continue to discharge treated effluent to GW with one new infiltration gallery.
With Alternative No. 2, a new treatment facility would have to be constructed to house the ion exchange system, and the existing GAC system would also continue to operate. The estimated total cost, including operations and maintenance (O&M), is $11,813,962.
Alternative No. 3 would require expansion of the current facility, to increase the GAC treatment capacity. The estimated cost, with O&M, is $9,983,562.
Bennett’s question about the ARARs for this particular IRA was addressed by Sharon Vriesenga, an attorney with the AF, who said that the discharge limits in the state substantive requirements document (SRD) are 20 ppt for PFOS and 40 ppt for PFOA.
Bond then pointed out that the second and third alternatives would both meet this.
“What do you expect the levels to be when they come out of this unit, whether it’s GAC or ion?” Bennett asked.
Bond said the existing system operating at the former fire training area (FT-02) is achieving some non-detect levels while discharging. “So, as absorption sites get taken up, of course the concentrations that are making their way through increase, and that’s when we do the O&M – to change out those media beds. But currently, the fire training area is achieving, in some cases, non-detect levels of those going through.”
Bennett said he was guessing, then, that it could theoretically meet the Rule 57 standards of 12 ppt, if that was the level.
“Correct,” Bond said. “As you go lower in concentration, it just increases your O&M also.”
Vriesenga has advised that this is an interim action which is building on a current system already in place. The system is governed by a state SRD, which sets standards for what there can be in the discharge for PFOA and PFOS. These standards haven’t changed. “So, as explained in the proposed plan, those are the standards this interim action will meet.”
Vriesenga said it is very clear in the proposal that when they get to a final action, the state’s GW cleanup criteria or any other state standards which qualify as ARARs will be complied with.
Rule 57 is surface water (SW) only, she noted. What is being talked about is GW and the and the GW/SW interface (GSI). If the 12 ppt for GSI and the other GW cleanup criteria apply when reaching the final action, then they’re going to be chosen as ARARs at that time.
Varley later added that, whether or not they’re saying that they’re adhering to the SRD, they still expect non-detect results when installing a new system, and anticipate being below the state levels.
Robert Delaney, who worked for the Michigan Department of Environmental Quality and has years of firsthand knowledge with the situation at WAFB, also spoke.
“One of the things that’s clear to me from listening in on the public’s questions and comments is that they don’t know the true conceptual model of what’s going on at the Clark’s Marsh,” he began.
Delaney said there are essentially five, maybe six, plumes which flow into the marsh; not just FT-02. A huge plume that’s moving into the marsh, as well as the swamps to the west, is coming from the wastewater treatment lagoons and the old infiltration beds which were used by the AF.
Another thing he said the public doesn’t understand – and he’s not sure if the AF does, either – is that there are plumes in GW which go past Clark’s Marsh. “They don’t discharge into Clark’s Marsh; rather, they discharge into the AuSable River directly.”
He said he is concerned that the public isn’t being told or shown these things, which makes it impossible for them to evaluate how good a remedy may be for same.
Delaney said the water in the marsh is not going to be cleaned up just because FT-02 is no longer discharging. There are still going to be other plumes coming in, the water will continue to be contaminated and it will continue to move out into the AuSable River – in addition to the ongoing GW plumes.
He also said that the AF isn’t talking about how much sediment contamination there is that will continue to bleed off for years and years. “Those are important things for the public to know, and I’d like to know that the Air Force is going to be presenting that stuff.”
He asked where the conceptual site model (CSM) for Clark’s Marsh can be found within the AR, if there is currently a demonstration of physical capture by the existing extraction system and where the cross sections of the plume in this area can be found.
Bond said that all of the documents which have been produced that are related to the investigations of Clark’s Marsh/FT-02 are available on the AR, or within the IR at the library. This includes the site inspection (SI) report, the expanded SI (ESI) report, the ESI addendum and annual GW monitoring reports from FT-02, which show the concentrations, GW results, GW flow maps and so on.
Bond said the CSM is currently being refined and will be presented in the remedial investigation (RI) work plan which is under development and will be available when the RI report goes on file.
Delaney said one of his concerns is that the AF never reported any of the state data in the SI reports. “And so those [SI] reports don’t show all the information that’s available, and people won’t see the plumes discharging into the AuSable River directly.”
He said he would like to see a better job done, as far as explaining to people what the situation is, and exchanging information with the public. He also noted that if he hadn’t worked on this site for so long, nobody – except for maybe the Wurtsmith Restoration Advisory Board (RAB) co-chair – would be able to actually evaluate whether this IRA is a good idea.
When the formal comment period was open, there were more than a dozen people who spoke, including members of the community, Need Our Water (NOW), RAB, PFAS Alliance, National Wildlife Federation (NWF) and Michigan League of Conservation Voters (LCV).
Delaney again addressed the AF, saying that one thing they need to do is develop a baseline ecological impact at the marsh. This would be to determine the effects on the wetlands and wildlife as the contamination is being reduced. Seeing the impact on wildlife is critical, because it is the pathway to people.
“I guess my confusion throughout this whole conversation is a remedial action for Clark’s Marsh,” AuSable Township Board of Trustees Member Jeff Moss said. “And what seems to be happening is that you’ve identified that you have an existing treatment plant at FT-02 which is on base, that has a direct plume that you’ve identified and that you’re looking at further, but what’s the remediation in Clark’s Marsh?”
He said the millions of dollars being discussed for FT-02 is phenomenal, since the community has wanted an extension of wells in this area for quite some time. But, he wondered what the consideration of spending this money has been to affect the SW that’s currently being contaminated at thousands of ppt.
“So I’m thrilled that the detection levels at FT-02 coming from the GAC are near non-detect. But that’s not the case of the water flowing at Clark’s Marsh from the surface water, not the aquifer,” Moss continued.
“And what we’re talking about – remediation of Clark’s Marsh – is not FT-02. And I don’t quite understand how you’re calling this action a remediation in the marsh,” he said. “Because what you’re doing is extending the curtain at FT-02, which affects Clark’s Marsh.”
He added that the ramifications of this are being seen in AuSable, to where they don’t know where the contamination is coming from because it can’t be identified due to the dilution levels in the foam in the river and in the foam in Lake Huron. “Everything being addressed at the big lake and the river, at the mouth, is not attributed to Clark’s Marsh, which is exactly the point source of where it’s all coming from.”
Therefore, Moss said he would like to know where the roughly $10 million can be spent, so that some action can be taken in the marsh itself, along with extending the curtain at FT-02.
Formal remarks were also given by NOW member and Van Etten Lake property owner, Anthony Spaniola.
He said it would have been far more efficient and appropriate for these comments and questions to have been received and thought about much earlier in this process – not after two alternatives have been pointed to and presented.
“This process by which this proposal has been developed has been conducted in secret and has not involved a single soul from Oscoda,” he said. “There’s nothing in CERCLA that says the Air Force and the state agencies are to conduct this review in secret. There is nothing anywhere that would have even prevented the Air Force from contacting the community when this went up on the [AR] on March 1st. We had to find out from the news media.”
Spaniola said he suspects that the plan might also be far more comprehensive, because right now, it is much too narrow. “Secondly, I want to point out that I keep hearing that because this is an IRA, that somehow the Air Force can do something less than what should be done in the end. That is a poor use and poor management of taxpayer’s dollars. Do it right and do it now.”
He also said the AF promised the state four years ago that it was working to comply with the GSI in Clark’s Marsh. “Again, there is nothing in CERCLA – nothing – which prohibits the Air Force from fulfilling that commitment. And to say that the Air Force is going to wait for another so many years and do some more studies really undercuts the voracity and integrity of that promise that was made to the state of Michigan and to our community. We’re looking for the Air Force to be a partner. And by those comments, and the way that this process has been handled, we really are treated more as an outsider and almost as the enemy in this.”
RAB Alternate Rex Vaughn mentioned the discussion on the differences between the SRD, at 20 ppt for PFOS and 40 ppt for PFOA, and the current state regulations at much lower levels – which he says will probably be in effect at the time this goes to a final solution. “It seems to be an unwise and really inefficient approach to spend $10 million on a system that will only do 20/40 when, if you drop in a couple more carbon tanks and maybe change a couple pumps, you could be in the position that that system would be ready to meet those requirements down the road, without spending another nickle. So I think it’s an unwise use of taxpayer money to restrict that system to a 20/40 condition, when you know right now that you’re going to have to do a lot better in a couple of years.”
Jennifer Hill of the NWF said she echoed many of the comments that were shared, and there are a lot of concerns regarding the stringency of the plans and the standards that are being talked about to be met for these plans.
She encouraged the AF follow through on its commitment to thoughtfully consider the public comments about what has to happen to make these plans meet the needs that are being expressed by the community.
While there may be minimum standards that have to be met, the longer the agencies wait to address the problems, the more costly the solutions are and the more impacts there will be to the people, wildlife and economy in Oscoda, Hill said.
A.J. Birkbeck, managing director of PFAS Alliance, said he believes that the Part 201 GW cleanup criteria should all be considered as ARARs, in spite of the fact that the state did issue guidance some time ago – before those were put into place – to the AF for discharges from their system.
“So my question would be, what is the basis for not including those as ARARs at this interim action?” he asked. “Again, those are targets and I don’t see why we shouldn’t be aiming towards targets that are, in fact, existing law here in Michigan – that’s the whole purpose of the ARAR system, is to incorporate state standards that may be more stringent than federal.”
“First, I think transparency needs to be at the forefront,” said LCV representative Bentley Johnson, who also noted that there seems to be a challenge when it comes to getting information.
With presumably everyone having similar goals of protecting public health and cleaning up this mess, he said he thinks it’s vital to work off of the same information, and that those inputs from very knowledgable experts be brought in. “Because I’m worried about the big picture and about different plumes and different areas being missed because of a piecemeal approach and not making – whether it’s the underlying data or maps – available, and making it clear about where and how you can access that information.”
Bentley pointed out that this will not only, and most importantly, help save lives and prevent exposure, but it will also help use taxpayer dollars wisely.
Taking a different stance from many of the other speakers, Paul Rekowski said he wanted to congratulate the AF on the job they’re doing. “And I think they’re going above and beyond what might be necessary. And I commend them for wanting to take an approach where they have all the data that they need to gather during the RI, before they make a decision on a final remedy.”