[Above: surface water flowing through the highly contaminated Darwin burn pit area (adjacent to the airport cell phone lot) into Starkweather Creek–several feet to the right (east) of the photo. Has this surface water ever been tested for PFAS? To see how much is flowing into the creek there? No.]
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Dane County calls its decades of failure to clean up its burn pits “a robust scientific process”!
Wow. Laugh, cry…or scream?
As Mike Farin, a retired chemical engineer and eastside community activist aptly said: “Makes perfect sense if the science being referred to is called Deception.”
The city, county, and Air National Guard began using the Darwin burn pit in the 1950s, and have been aware of significant toxic contamination there since the 1980s. Since then, these parties have bickered endlessly over who is responsible, passing the blame around to each other in repeated circles, while nothing whatsoever was done to clean it up.
Zoom forward many decades. What are they doing now? Here’s the latest Dane County burn pit “Status Report,” in a September 7 letter to DNR by airport Director Kim Jones. What’s planned? Pilot testing experimental technologies that have failed to date. Finally lining the storm sewer pipes now that they found a contractor who bid low enough. (Will this reduce discharge of PFAS into the creek? Hard to say. PFAS seeps into the creek from soils and contaminated groundwater as well as via stormdrains. Lining the pipes may funnel PFAS into the creek through stormdrains even faster.)
What else is in the burn pit “Status Report”? More plans, more investigations, and more plans, which may lead to more investigations. “Additional sampling” was mentioned several times.
No burn pit cleanup. No timelines for anything.
In other words, they are “fixing to do something.” Or perhaps more fittingly, as a friend of mine says, they are “fixing to get ready” to do something.
But have hope, people! This is cooperation and science, not failure…
DNR first informed the City of Madison, Dane County Regional Airport, and the Wisconsin Air National Guard (now collectively called the “RP Group”) that they were “responsible parties” (RPs) for the PFAS at the burn pits on June 18, 2018. Last spring, after saying it would investigate the burn pits, the Air National Guard quietly dropped its plans to do so.
On July 5, 2022, DNR sent the RP Group a letter stating that their activities at the Dane County fire-fighting training areas (FFTAs, or burn pits) “are documented to have caused per and polyfluoroalkyl substance (PFAS) contamination of the soil and groundwater.” (Yeah. You could say that. Up to 86,247 parts-per-trillion of PFAS (total) were found in groundwater at the Darwin burn pit in 2020 (see data here). Most of this (67,300 ppt) was PFOA. This is 16,825,000 times higher than the drinking water “interim lifetime health advisory level” (HAL) of 0.004 ppt for PFOA recently issued by EPA. Who cares? See footnote 1 below).
In her September 7 response to DNR (presumably on behalf of the RP Group) Airport Director Kim Jones called their four-year delay following the DNR’s 2018 letter, and dubious “pilot” remedial efforts to date, a “robust scientific process,” rather than “failed,” as DNR had called them previously. This letter was likely actually written by, or at least heavily advised by, Dane County Corporation Counsel Amy Tutwiler.
Tutwiler-Jones wrote, “[w]e also trust that the Department recognizes that past efforts once characterized as failed are in fact part of the robust scientific process that have (sic) led to these hopeful developments.”
So, these “hopeful developments” reflect a heart-warming turn! Now, instead of the DNR pointing out that past efforts had failed, “the Guard and DCRA are working in cooperation with DNR to facilitate a pilot study,” Tutwiler-Jones wrote, and “we appreciate DNR’s participation in these research efforts…”
I’m so glad the RP Group and the regulator (DNR) have kissed and made up, and are now doing “robust science” together! This is so reassuring!
So have hope, people out there in the community who have been asking for years that these burn pits be cleaned up! The RPs and the regulator are back in bed together, so now certainly meaningful actions will be taken to clean up the toxic mess ASAP. [Sarcasm emoji here?]
Thanks for the comedic relief?
WTF? Is this supposed to be comedy? I did laugh out loud when I read Tutwiler-Jones’ letter, spitting coffee onto my computer screen. But…
Sadly, it is not a joke. This is a serious letter, written by public officials in one of the most highly educated and privileged counties in the state (if not the country), home of a major research university, many PhDs, technical experts, engineers and home of state environmental and public health agencies. And in a city and county that claim to be “progressive.”
But wait, there’s more, for laughs (or cries)! Tutwiler-Jones referred to the “pilot tests” the Guard and DCRA are working on with DNR–bacterial injections that, even if successful in small areas (which hasn’t been shown yet, because the results are “proprietary” for now), cannot be scaled up to remediate large burn pit and other PFAS hotspot areas, and definitely not the huge PFAS plumes beneath them, which have traveled far and wide by now.
Community activist and engineer Mike Farin called this a “bacteria injection smokescreen.” Indeed. And the experimental “bioabsorbent media” (BAM) booms already implemented have clearly failed to date.
Nevertheless, Tutwiler-Jones ended the letter with some impressive doublespeak PR: “Our continuing objective is to use public resources to address PFAS impacts as effectively as possible, including avoiding duplicative efforts.”
What Dane County is actually doing–while arguing that they are “using public resources as effectively as possible” and avoiding “duplicative efforts”–is legally fighting the DNR in an effort to get out of the PFAS monitoring and PFAS stormwater discharge prevention requirements in the WPDES (stormwater) permit they were issued last spring.
The county is also trying to spend as little money as possible (that part is true). But the preventive steps, or Best Management Practices (BMPs), required in the WPDES permit cost very little, and the required stormwater PFAS testing would cost around $8,000 per year.
Privileged Dane County can’t afford this tiny amount? Really? But it can afford to tinker around with dubious experimental remedial technologies (that have already sucked up hundreds of thousands of public dollars) and pay a former corporate attorney to help the county get out of following laws?
What about the human beings exposed to these poisons while the RPs fight DNR regulations and do their “hopeful” cooperative “robust science”?
Who is exposed to carcinogens and myriad other poisons spewing from the burn pits while the RP Group is “fixes to do something”–er, I’m sorry, engages in “robust scientific processes”? The people downstream, especially those living near Starkweather Creek, particularly those who drank PFAS-contaminated Madison municipal water for decades (from Well 15) and eat the toxic fish from Starkweather Creek and Lake Monona.
The DNR’s July 5 letter says the RP Group is “responsible for ensuring that impacts to human health and the environment from PFAS are fully addressed at all areas where known discharges have occurred at the airport complex.”
Are the experimental technologies and purported “robust scientific research” Tutwiler-Jones refers to the Sept. 7 letter “ensuring that impacts to human health and the environmental from PFAS are fully addressed”?
NO.
And where is Public Health Madison Dane County (PHMDC)? The Wisconsin Department of Health Services? Why aren’t these public health agencies insisting on more urgency in cleaning up these toxic leaching hotspots?
For shame, Dane County and City of Madison. We don’t expect the U.S. Department of Defense to care about our community, but your job is to serve and protect us, especially the most vulnerable people.
I’ll say it again. For shame!
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**Hmmmm. Perhaps Dane County Regional Airport is more interested in the profits from its ever-expanding airport than in cleaning up the burn pits? And following DNR laws? Below, signs in front of the Darwin burn pit area in 2021 (Photo by Maria Powell)
[1] Some bullet points about the basis for these proposed interim PFAS advsory levels from the powerpoint presented in August to the DNR Technical Advisory Group by Dr. Gloria Post, a top PFAS expert and regulator from New Jersey (highlights added):
• Draft Reference Doses based on human data for ↓ antibody response to vaccines in children.
• Several orders of magnitude below previous (2016) Reference Doses based on animal data.
• PFOA: “Likely to be carcinogenic to humans.” Revision from previous “suggestive evidence.”
• Draft cancer slope factor based on National Cancer Institute study of PFOA and kidney cancer in
U.S. general population.
• Much more stringent than previous slope factor based on rat tumor data.
• USEPA policy for “likely carcinogens” has traditionally been MCLG of “zero” (aspirational goal).
• Protective for lifetime exposure, but also apply to short–term exposure.
• Effects of short–term exposure in children identified as most sensitive – more sensitive than
chronic effects.
