OSCODA – For years, the per- and polyfluoroalkyl substances (PFAS) contamination at the former Wurtsmith Air Force Base (WAFB) in Oscoda has been a passionate subject for residents, as well as those outside of the community. With politicians, the public and others maintaining that the remediation efforts aren’t as robust as they should be, a particularly significant amount of attention has been given to this topic in recent weeks.
This has included a meeting hosted by the Air Force (AF) to obtain comments on a plan for addressing two types of PFAS – perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) – which are migrating via groundwater (GW) from WAFB to Clark’s Marsh, due to the past use of firefighting foam. As reported, the three alternatives being explored are to take no action, to expand hydraulic control using a pump-and-treat system (PTS) with ion exchange or to expand hydraulic control utilizing a PTS with granular activated carbon.
Following this, AF representatives fielded questions from the media during a press briefing on April 9, which included talks on the cleanup efforts at WAFB.
Then, more than 200 individuals, businesses and organizations signed on to a letter prepared by the Need Our Water (NOW) community action group – which appeared in its entirety in last week’s publication – to serve as formal comment on the AF’s proposed interim remedial action (IRA) plan for Clark’s Marsh.
The letter was submitted on April 16 to the AF’s Base Realignment and Closure (BRAC) Environmental Coordinator, Dr. Catharine Varley. On this same date, the NOW Leadership Team also sent Varley a technical letter regarding the plan. It was accompanied by a series of slides, depicting such maps/images as that of the PFAS which is discharging into area water bodies.
The AF is to respond to this and other comments received during the 30-day period, which ended on April 17, within a summary that will be included in the Clark’s Marsh interim record of decision.
A community update meeting on WAFB and the Oscoda Area PFAS investigation was then hosted on April 20, by the Michigan PFAS Action Response Team and District Health Department No. 2 (see separate story).
The next day, April 21, a Wurtsmith Restoration Advisory Board meeting was held, which will be summarized next week.
Also on April 21, U.S. Senator Gary Peters (D-MI) and Congressman Dan Kildee (MI-05) took part in a press conference with NOW representatives, which was organized by the National Wildlife Federation (NWF) and the Michigan League of Conservation Voters (LCV).
A news release was shared after the event by Drew YoungeDyke, director of conservation partnerships for the NWF’s Great Lakes Regional Center.
He wrote that a broad coalition of 40 organizations, more than 20 businesses and hundreds of individuals is calling on the AF to substantially strengthen its proposed interim cleanup plan for PFAS contamination at Clark’s Marsh in the Huron-Manistee National Forest near WAFB.
In a formal public comment letter to the AF, YoungeDyke says the coalition has noted that the plan addresses only a small portion of the contaminated PFAS GW plumes impacting Clark’s Marsh and the AuSable River, where public health warnings have been issued. “The group urges the Air Force to fully clean-up those plumes without further delay.”
“The Air Force has been promising to clean up Clark’s Marsh for years. Its current proposal barely scratches the surface and puts off meaningful cleanup until well into the future, if at all,” said attorney Anthony Spaniola, a NOW member who also owns property on Van Etten Lake. “Our community deserves far better than this.”
Peters and Kildee have also said that the existing AF plan is not enough.
“The Air Force’s remediation plans are insufficient to address the PFAS contamination coming from Wurtsmith and to prevent significant damage to the environment and the people of Oscoda. That’s why I led an effort with members of the Michigan congressional delegation to push the Air Force to engage with the community in good faith and make substantive changes to their plans,” Peters said.
“The advocates and community have been doing incredible work to bring attention to this issue and to push for change, and I’ll continue to work to press the Air Force to take more action. Families in Oscoda have been working on this effort for years, and we can’t wait any longer,” he stressed.
“I’ve been pretty disappointed with the slow speed and the lack of transparency that the Air Force is showing concerning this issue,” Kildee remarked. “We expect them to take more significant steps to address this contamination at Wurtsmith. I’m very concerned that the Air Force’s proposed remediation plan still fails to comprehensively address the PFAS plumes spreading in this area.”
The NOW coalition letter calls on the AF to make technical revisions to the proposed plan to better capture PFAS contamination in the Clark’s Marsh area; to immediately implement additional cleanup actions to address the full extent of PFAS plumes in the area; and to open the AF cleanup development process at the front end to include input by community voices, YoungeDyke states.
“What happens in Oscoda serves as a bellwether for the hundreds of PFAS-contaminated military sites nationwide,” said Jennifer Hill, associate director at the NWF Great Lakes Regional Center. “Here in Michigan, we expect the Air Force to abide by Michigan’s new PFAS clean-up standards and to listen to the needs of impacted community members. It’s past time to clean up these toxic chemicals that are hurting Michigan’s people, water, fish, and wildlife.”
In March, Governor Gretchen Whitmer invoked her authority under the National Defense Authorization Act, requesting that the AF meet Michigan’s stronger PFAS cleanup standards.
“Last year, after extensive review and comment from experts and the public, Michigan put in place strong standards for PFAS that are protective of public health. The Air Force owes it to the people of Oscoda to use those standards as it cleans up toxic PFAS contamination from the Wurtsmith Air Force Base,” said LCV Executive Director Lisa Wozniak. “Now is the time for the Air Force to do the right thing and adequately clean up its mess that has impacted this community for far too long.”
As for the second letter which the NOW group sent to Varley, they advised that they had completed their technical review of the proposed IRA plan for Clark’s Marsh. They say that it describes the actions planned by the AF to remediate, to a limited degree, the contamination entering the marsh. The proposed plan outlines interim actions, as defined under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
NOW states that interim actions at a CERCLA site such as WAFB are intended to rapidly address situations where an imminent and substantial endangerment of the human health or the environment from contaminants, pollutants or hazardous chemicals is occurring.
In the case of the Clark’s Marsh wetlands system, they say that PFAS emanating from WAFB and discharging into the marsh, the AuSable River and the connecting waters in the marsh’s wetlands system have contaminated biota throughout the marsh system and the river. This has resulted in state-issued health advisories to not eat fish, deer or other game animals from this area. It has also resulted in a “Do Not Eat Fish” advisory for the AuSable River.
As the advisories are not enforceable and are impossible to monitor for compliance, the level of contamination in the animals is resulting in unacceptable human exposure to PFOS, and possibly other PFAS, found in the biota.
The proposed plan is to expand the current interim action controlling some of the fire training area (FT-02) plume and removing some of the PFAS in the GW by using a PTS with reinjection of treated water into the aquifer. The treated water, or effluent, discharge to GW is controlled by a substantive requirement document (SRD) that limits the discharge of PFOS to 20 parts per trillion (ppt) and discharge of PFOA to 40 ppt.
As stated in the letter, “no other PFAS is regulated the SRD in this discharge to groundwater, and the result of sampling of influent and effluent concentrations of other PFAS chemicals in the influent and discharge were not discussed by the AF in the proposed plan.”
Additionally, the remedy described is to only capture PFOA/PFOS in the plume that exceeds a combined 70 ppt of PFOS and PFOA. The 70 ppt is from a health advisory issued by the Environmental Protection Agency for PFAS concentrations in drinking water.
NOW says that the AF BRAC office does not acknowledge the state of Michigan PFAS Part 201 Cleanup Criteria in either their plan to capture the PFAS plume at FT-02, nor in their discharge of effluent to GW.
In summary, they wrote that NOW’s comments on the Clark’s Marsh proposal are as follows:
• Activated carbon as a treatment technology appears to be the correct choice of treatment using the nine CERCLA balancing criteria for selecting a remedy.
• NOW cannot find evidence of effective monitoring of the current FT-02 plume capture and treatment. Is the plume breaking through the extraction well capture zone? The AF should present to the public and elected officials the monitoring results for the FT-02 remedy and explain the plan for future monitoring of the remedy described in the proposed plan.
Also, because the AF does not present the other PFAS chemicals in the influent and effluent data, is the carbon treatment able to remove all the PFAS contaminants and pollutants that are entering the system? Are there illegal discharges of PFAS, other than PFOS and PFOA, in the treatment effluent?
• NOW is not confident that the AF’s remedial site team accurately understands the site contamination. The conceptual site model that the AF presents to the public clearly lacks a great deal of information that is known to the Michigan Department of Environment, Great Lakes and Energy (EGLE).
NOW is not certain if the AF team understands the site, or if this seeming lack of understanding is just the legacy of previous AF site teams and lack of institutional knowledge. The current team should not repeat the same mistakes and should present a coherent conceptual site model for the Clark’s Marsh wetland system PFAS contamination.
• The AF needs to present all the data and the full extent of contamination to the public and elected officials in understandable ways. There is no law preventing the AF from informing these individuals of data gathered by others, nor is the AF prevented from presenting all the chemical data – not just PFOA and PFOS – on other contaminants and pollutants or suspected contaminants and pollutants at the site.
• The AF should expand this proposed plan footprint or outline the next interim actions that will be taken in the Clark’s Marsh wetlands area. Waiting years to act while more study of the problem is undertaken is unnecessary. 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 plumes stop discharging into the marsh and the AuSable River and creating dangerously contaminated fish.
• NOW concurs with EGLE’s request for additional interim actions at the entire site. NOW cannot affirm the locations discussed in the March 23 letter to the AF, from EGLE’s Remediation and Redevelopment Division Director Mike Neller, as the referenced map is not included in the copy of the letter provided to the public. But NOW knows that there are multiple areas around WAFB and the wetlands system that pose imminent and substantial endangerment to the public.
The AF has been entrusted with the responsibility to protect human health and the environment. CERCLA provides the AF with the tools to carry out that responsibility. CERCLA is not designed to prevent irresponsible behavior. The AF can address any contaminant or pollutant released at the site and can do so at any time if the contamination presents an imminent and substantial endangerment. The AF response is not limited by CERCLA to address only PFOS and PFOA with interim actions or CERCLA removal actions.
• The AF has delayed investigating the impacts of PFAS on biota in Clark’s Marsh for nine years. The data from EGLE fish and muskrat sampling and surface water sampling contains a great deal of information that is not being used to understand the impacts of PFAS, other than PFOS and PFOA.
The AF needs to start monitoring the impacts of PFAS on the biota in the Clark’s Marsh wetland ecosystem. This will document the effects of AF remedial actions over time and inform decisions made at Wurtsmith and other sites across the nation.
“It should be understood by everyone that this interim action, while helpful toward a final cleanup of the Clark’s Marsh wetland system, is incomplete as even a short-term solution, and that much more effort is needed,” the letter goes on. “NOW expected a greater effort by the Air Force to address the PFAS problems in the wetlands with this action and is disappointed with their proposal.”