Over two and a half years ago, June 2018, we asked DNR to include PFAS monitoring in Dane County airport’s WPDES permit, which includes requirements for regular monitoring of Starkweather Creek upstream and downstream of the airport.
Truax Air National Guard, Army National Guard, Fed Ex and other entities operating at the airport are co-permittees–but Dane County is the lead. The permit states: “Dane County, as the owner and airport authority, shall act as the airport representative and shall coordinate co-permittee efforts to achieve permit compliance.”
In July 2018, DNR acknowledged that we had asked to include PFAS in the permit, but didn’t respond to the request (see pg 3 of letter under MEJO info request #3). [1]
The airport’s WPDES permit expired at the end of 2019, but still hasn’t been renewed by DNR. So the airport and base are still operating under it, with no ongoing PFAS monitoring requirements at all. In fact, PFAS isn’t even mentioned in it or the required Stormwater Pollution Prevention Plan (SWPPP).
Really? We now know that PFAS in Starkweather Creek sediments, water, and fish, (which DNR has publicly stated is mostly from Truax Field) has made its way through all the Yahara Lakes. PFAS monitoring data from Starkweather Creek before and after it goes through the airport and base would be extremely valuable to track changes in PFAS levels in the creek through time, whether remedial approaches at the airport and base are working or not, effects of construction projects, seasonal changes, and more. Re-issuing the permit with these monitoring requirements should be an urgent priority for DNR as well as city, county, and state officials.
Apparently that is not the case. Why not?
[1] DNR’s July 2018 response to our letter stated: “As you know, many site investigations are performed in an iterative manner. We intend to require testing of surface water and sediment for PFAS at the Truax ANG site. We are initially concentrating efforts on investigating and characterizing PF AS in soils and ground water. Once the nature and extent of PF Cs in these media are better defined, we will be in a better position to more accurately determine appropriate locations for surface water and sediment sampling. You should also note that the need to perform surface water and sediment sampling will be fo1mally communicated to ANG in the very near future (they are aware of the need for this sampling and they are in agreement with the concept).”
To date, DNR has not still not asked DCRA or Truax ANG to test PFAS in sediments at the site or in Starkweather Creek even though they know that many of the most toxic long-chain PFAS, like PFOS, build up in sediments and slowly release into the water. In late 2019, MEJO and East Madison Community Center teens gathered creek sediments and had them tested. Our results are on the map linked above; more detailed info here.
