Last week the Wisconsin DNR released documents pertaining to perfluorinated compounds (PFCs)—also commonly called poly- or per-fluoroalkyl substances or PFAS—at Truax Field’s Wisconsin Air National Guard (WANG) base.
One of the documents released, the March 27, 2018, “ FY16 Phase 1 Regional Site Inspections for Perfluorinated Compounds,” includes data showing that all but one of the shallow groundwater samples from the site had PFC levels well over the EPA’s health advisory level of .07 ug/L. PFC levels in groundwater samples in one area were 39.841 ug/L–about 569 times the health advisory level. Several soil samples also had PFC levels well over the screening levels. See tables and maps at the end of the document.[1],[2]
Meanwhile, in August and December 2017, the Madison Water Utility detected several PFCs in municipal drinking water well #15, about one mile southeast of the base in Reindahl Park—the direction groundwater flows from the base. Well 15 provides drinking water to a large portion of the northeast side of Madison. On March 19, 2018, further testing, which included 12 PFC compounds (more than the six done in the 2017 sampling) was done in Well 15 and the total levels of PFCs in Well 15 increased because one new PFC was detected. See yellow highlighted table here (the March 2018 results are not posted on the Water Utility site). Well 15 currently has a filter to remove the tetrachloroethylene (PCE) and trichloroethylene (TCE) already found in this well—possibly also from Truax Field–but this type of filter doesn’t remove PFCs.[3]
The PFC levels found in the well were not above current EPA health advisories, but some PFC experts and environmental organizations say that far too few PFC compounds are being tested in drinking water, significantly underestimating the amount of PFCs actually present–and therefore also underestimating the risks to people drinking this water. In Well 15, only 12 PFCs were assessed, and in the recent Truax WANG investigation, only six PFCs were measured. If more PFC compounds were measured, many more would likely be found. [4]
Fire-fighting foams with PFCs used at Truax Air National Guard
PFCs are used in many consumer products, industrial applications, and in fire-fighting foams—especially “aqueous film forming forms” or AFFF, which have been used at the Truax WANG base and adjacent fire training areas for a long time.
According to EPA, PFCs, “can cause reproductive and developmental, liver and kidney, and immunological effects in laboratory animals,” and “have caused tumors in animal studies.” In human epidemiological studies, PFC exposures have been associated with increased cholesterol levels, low birth weight, effects on the immune system, thyroid hormone disruption, and cancer.
Water utility officials and their technical advisors are considering the Truax Air National Guard base a potential (if not likely) source of PFCs to the well, because of its proximity to the base and because the mix of PFCs found in Well 15 matches the types used in fire-fighting foams. They are also exploring other sources, including fire departments and landfills.[5]
Much more groundwater PFC testing needed, says DNR
The recent PFC report is just the first phase of investigation of PFCs at Truax Field. A very limited number of shallow soil and groundwater PFC samples were gathered in this initial phase. Wider and deeper groundwater testing is highly likely to reveal a deeper and more widespread problem—extending far off the base.
After reviewing the report, on April 26, 2018, the DNR issued a Spills Law “Responsible Party” letter to the Air National Guard, and on May 7, 2018, sent a letter to the consultant asking for further soil and groundwater testing. Notably, the letter states: “There needs to be additional offsite groundwater investigation to the southeast. Groundwater is expected to flow to the southeast and the results from the boundary wells indicate the probability of offsite impacts. Further Madison City Well 15 lies about one mile southeast of the air field. This well has shown detects of perfluorinated compounds. Offsite monitoring well nests to detect shallow and/or deep contaminant migration are required.”
More groundwater testing to delineate the extent of the plume is critical , and the DNR letter to the consultant includes other good recommendations, including assessing the vapor intrusion pathways at the site (more on this later).
What about Starkweather Creek?
There is, however, one glaring gap in the letter—the DNR does not ask the ANG consultant to test sediments and/or water at the base’s stormwater outfalls to Starkweather Creek, or from the creek itself, which flows around three sides of the base. All stormwater runoff from the base is routed to the creek through a system of ditches and drains.
In earlier documents, the Air National Guard consultants explicitly recommended testing outfalls to the creek. The Air National Guard’s 2015 Perfluorinated Compounds Preliminary Assessment stated: “Further investigation is recommended at the Base to monitor and characterize any groundwater, soil, sediment, and/or surface water PFC contamination onsite. Sampling of soil and groundwater within the Base and at the outfalls of Starkweather Creek is recommended at a minimum to evaluate the potential of migration of PFCs.” (highlights added)
On February 14, 2017, the Air National Guard officials, ANG consultants, contractors, and a DNR representative met in Madison for the “PFOS/PFOA Site Investigation Truax Field ANG Base Kickoff Meeting.” The powerpoint from the “Kickoff” meeting said they planned to “Conduct Site Investigation (SI) Activities to determine the presence or absence of PFOS/PFOA in all potential media (soil, groundwater, surface water and sediment).” It also said that “Stormwater outfalls, wet wells, drainage basins and ditches will be sampled at the last available downgradient location on ANG property.”[6]
Further, the August 2017 Final Work Plan stated that “Surface water at the Base is limited to the man-made surface drainage and storm sewer system… Precipitation is generally collected by the stormwater sewer system and discharged to Starkweather Creek, which runs north, west, and south of the Base” and “[b]ased on historical practices, COCs (contaminants of concern) could be present in sediment in locations that have received drainage from the Base storm sewer system. In general, surface releases at the Base would enter series of man-made ditches and culverts and ultimately discharge to Starkweather Creek.”
Despite saying the above, the 2017 Final Work Plan didn’t recommend any stormwater outfall or Starkweather sampling— and therefore the PFC data released on March 7 (linked to above) does not include any data from stormwater ditches or drains, Starkweather sediments or water.
Why not?[7]
Why isn’t DNR requiring the Air National Guard to follow Wisconsin laws?
The Wisconsin “Spill law” (Section 292.11 (3) Wisconsin Statutes) states that “A person who possesses or controls a hazardous substance which is discharged or who causes the discharge of a hazardous substance shall take the actions necessary to restore the environment to the extent practicable and minimize the harmful effects from the discharge to the air, lands or waters of this state.” In fact, this sentence is highlighted in the Responsible Party letter sent to Air National Guard on April 26. Starkweather Creek and Lake Monona definitely qualify as “waters of the state.”
Wisconsin law NR 716 also says responsible parties should assess “The known or potential impacts of the contamination on any of the resources listed in s. NR 716.07 (8) that were identified during the scoping process as having the potential to be affected by the contamination.” As described above, the Air National Guard’s own reports indicate that Starkweather Creek is likely to be affected by the PFC contamination.
It is well documented scientifically that PFCs build up in fish—and people eat fish from Starkweather Creek and Lake Monona, which the creek flows into about 2 miles south of Truax Field. NR 716 says investigative work plans for contaminated sites should include evaluation of “Potential hazardous substance migration pathways” and “[t]he impacts of the contamination upon receptors.” In this case, Starkweather Creek and Lake Monona, wildlife and other biota in them, and people who eat fish from them, are “receptors” that will be impacted by contamination at Truax Field.
DNR is charged with protecting public and environmental health. The agency should ask the Wisconsin Air National Guard to follow all Wisconsin environmental laws and test for PFCs—and the many other toxic contaminants that have been found at soils and groundwater at the base—in Starkweather creek water, sediments, and fish.[8]
Where’s the Community Outreach & Engagement?
Page 13 of the powerpoint from the “PFOS/PFOA Site Investigation Truax Field ANG Base Kickoff Meeting” says they would do “community outreach” from October 2016 through September 2018. To date, there has been no community outreach or engagement about the PFC investigations and contamination at the Truax WANG base. The community, including the people drinking water from Well 15, is in the dark.
To be continued…
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[1] The focus in this investigation was on two types of PFCs, PFOA (perfluorooctanoic acid) and PFOS (perfluorooctane sulfonate), which have been found to be particularly toxic. Several other types of PFCs were tested in the investigation, and significant levels found, but they were not flagged as being over the advisory level, because no advisory levels have been established for these compounds yet.
[2] The site investigations and report were done by Amec Foster Wheeler, consultants hired by the National Guard Bureau.
[3] PCE and TCE were found in soil and groundwater at Truax ANG base in past investigations.
[4] Further, at the Water Utility Technical Advisory Committee on March 26, 2018, when these results were discussed, TAC member Dr. Henry Anderson, former Chief Medical Officer for the Wisconsin Department of Health Services, advised that the current health advisory is likely to go down (to be more protective) by at least 50% in coming years. Several other states have already proposed more protective PFC standards for drinking water.
[5] The closed, unlined Truax Landfill just south of the base and the former Burke Waste Water Treatment plant, could be additional sources of PFCs to the well. Both facilities took wastes from the city and Truax Field military operations.
[6] At least one DNR representative attended this meeting. It is not clear if Michael Schmoller, who has been the Wisconsin DNR project manager for Truax WANG for many years, participated though his name is on the powerpoint from the meeting. He did, however, receive the powerpoint from the meeting afterwards, which included recommendations about testing stormwater outfalls to Starkweather Creek.
[7] When the ANG consultants sent Mr. Schmoller at DNR the draft of the 2017 Work Plan (with no Starkweather outfall sampling) for his review, he said he “had no major comments or concerns” about the proposed work and they should go ahead.
[8] Tetrachloroethylene (PCE), trichloroethylene (TCE), polycyclic aromatic hydrocarbons (PAHs), petroleum compounds, metals, and a plethora of other contaminants have been found on the Air National Guard base since the late 1980s. Many of the contaminants that are highly likely to be used and released at the base—PCBs, radioactive compounds, PAHs, and more—have been inadequately measured or not assessed at all at the base.
