Fish caught by children at the mouth of Starkweather Creek in June 2018 (they did not eat the fish).
A MEJO post last May linked to an Air National Guard report showing very high levels of highly toxic PFAS (per- and polyfluoroalkyl substances, also called PFCs) in shallow soils and groundwater at Madison’s Truax Air National Guard (ANG) base. See more documents & DNR letters for the site here.
PFAS were also recently found in drinking water Well 15 in Reindahl Park a little less than a mile from the base, and the Madison Water Utility suspects they are from Truax ANG and possibly also two nearby fire-training burn pits (see below) and/or Truax Landfill. Well 15 provides drinking water to a large part of Madison’s east and northeast sides.
PFAS have been associated with numerous health problems, including low infant birth weights, neurological and developmental effects in children, increased cholesterol levels, immune system and metabolic dysfunction, thyroid hormone disruption, and cancer—see here and here.
Truax ANG, which is on land owned by Dane County, has used PFAS in fire-fighting foam for decades. Nearly all of the Truax ANG base’s stormwater runoff is routed to Starkweather Creek—carrying PFAS contaminated surface soils with it. The highly contaminated shallow groundwater under the base has also been seeping into Starkweather Creek for a long time. Starkweather Creek flows into Lake Monona, a very popular local and regional fishing destination about two miles downstream.
There is an active fire-training area just south of the Truax ANG base (on MATC property) certain to be PFAS-contaminated from fire-fighting foams. It is right next to Starkweather Creek. It isn’t clear whether or not PFAS investigations have been initiated at this site.
There is also a former fire-training burn pit on county land just south of the Dane County Regional Airport (DCRA)–and like the other one, right next to Starkweather Creek. It was used by the City of Madison, Dane County, and the Air National Guard/Department of Defense from the 1950s through 1987.
DNR told us in a July 2 2018 letter (see end of letter) that this area had never been remediated, but the agency sent the potential responsible parties a letter asking that they begin PFAS investigations this summer. It’s unknown whether these investigations have been done. This site is also contaminated with many other chemicals (see footnotes)[1],[2]
People who eat fish from downstream waters are at risk
A growing body of scientific studies show that PFAS can travel very far in water, and are so long-lasting in the environment that one expert called them “virtually indestructible” and they are sometimes referred to as “the forever chemicals.”
Some types of PFAS, especially longer-chain compounds like PFOS, build up in fish to high levels, posing significant risks to people who eat the fish, particularly sensitive groups like children and pregnant women. Once in the human body, some types of PFAS—again, especially the longer-chain compounds–are not eliminated for a very long time (some reports say never). Subsistence anglers, often low income and minorities, are likely to ingest more of these compounds because they eat more fish than others.
Several states, including Minnesota, Michigan, and New Jersey, have been testing fish downstream of known PFAS-contaminated sites for some time, and issuing fish advisories when needed. Michigan recently issued a “do not eat” advisory on a five-county stretch of the Huron River contaminated with PFAS and posted signs in fishing locations along the river. Minnesota has also issued “do not eat” advisories for lakes downstream of PFAS sources.
Wisconsin has not developed statewide PFAS advisories (see more details below).
What is DNR doing about PFAS?
The Wisconsin DNR is currently proposing to develop new surface water quality criteria for two types of PFAS (PFOA and PFOS) during their 2018-2020 Triennial Standards Review process. The agency’s current TSR draft proposes that these criteria take fish consumption into consideration, as EPA recommends.[3]
This is good. On October 3, MEJO sent a letter supporting the DNR’s proposal to consider PFOS and PFOA in its water quality criteria, but also supporting the recommendations in the PFAS Community Campaign letter (organized by Citizens for Safe Water Around Badger, CSWAB) that DNR consider total PFAS as a class, not just two types.[4] MEJO also recommended that DNR prioritize the testing of PFAS in fish near sites known to be contaminated with the compounds—as DNR’s own studies recommend.
However, even if these criteria are approved, new standards will not be promulgated and go into effect for several years.[5] By themselves, they will do nothing to protect fish consumers in the near-term or to clean up PFAS contaminated waterways—though they will allow regulators in the future to better assess whether or not PFAS levels in waterways are posing risks to people and the environment (and hold polluters more accountable if standards are violated).
But in the meantime, anglers who eat fish from Starkweather Creek and Lake Monona, downstream of Truax Air National Guard, could be eating PFAS. Will any government agencies here—city, county, or state—test to find out?
How far can PFAS travel?
Investigations done at many other industrial, military, and airport sites show that PFAS can travel via groundwater and surface water very far from sites where they are released.
For instance, PFAS compounds were manufactured at several 3M sites near St. Paul, Minnesota and disposed of in landfills in the region. A September 28, 2018 presentation to the DNR Brownfields Study Group by the Minnesota Pollution Control Agency (MPCA) depicted a “co-mingled” groundwater plume of PFAS that covers over 130 square miles surrounding these sites.
The MPCA presentation also showed groundwater PFOS levels alone were 10-50 times above Minnesota’s drinking water “health-based value” or HBV over two miles downstream of one of the 3M sites and 1-5 times the HBV about four miles downstream.
Further, fish in a lake at least two miles from the sources (Lake Elmo) had high enough PFAS levels that a “do not eat” advisory was issued for the whole lake; these PFOS traveled there via groundwater and surface water. Moreover, PFOS traveled in surface water and groundwater over 8 miles east of one of the 3M sites, to the Mississippi River, where fish have been on advisory for PFOS since 2007 (see later section on fish advisories).
Studies done downstream of airport and military sites that used PFAS-containing fire-fighting foams also show how far PFAS can travel. A study downstream of an airport in Canada found that PFAS levels at a lake over 8 miles from the airport were 3-7 times higher than levels found in the comparison site upstream of the airport. PFAS released from the Wurtsmith Air Force Base in Michigan affected groundwater over an area of approximately 5.7 square miles. PFAS compounds were also found over approximately 9.37 miles of a downstream river and a 3.06 mile stretch of a nearby lake.
How much PFAS can build up in fish? Do water quality standards protect fish consumers?
Some PFAS, especially longer chain compounds like PFOS, can accumulate to thousands of times more than the levels in water—even if the water PFAS levels aren’t that high. So water quality standards don’t necessarily protect fish consumers. One Canadian researcher calculated that PFOS in fish could accumulate to over 100 times greater than the Canadian “do not eat” advisory benchmark for sensitive populations (children and women of childbearing age) without even exceeding the country’s drinking water guideline. The draft “fish consumption based water quality guidelines” they calculated for PFOS–< 1-12 ng/L (parts-per-trillion, ppt)—are within the range of those drafted by MPCA and Canadian agencies to protect fish consumers.
PFOS levels measured in surface waters at and downstream of military sites that used fire-fighting foams with PFAS exceed this proposed water quality guideline by many orders of magnitude. A 2016 study by the Air Force Civil Engineer Center that assessed PFAS levels at ten military bases found that the median PFOS levels in surface waters were 2,170 ng/L (ppt) and the maximum levels found were 8,970,000 ng/L (ppt).[6]
Not surprisingly, fish tested at or near sites with known PFAS releases also have much higher PFOS levels than those tested in areas not near known sources. (Fish PFAS levels are typically reported in parts-per-billion or ppb, whereas water PFAS levels are often reported in parts-per-trillion or ppt).
A study of water, sediments, and fish downstream of an Air Force base in Louisiana found PFOS levels in surface water downstream of fire training areas of up to 1,800 ng/L (ppt)—and a sunfish at this site had 9,349 ppb (9,349,000 ppt) PFOS in its tissues. At Wurtsmith Air Force Base in Michigan, up to 9,580 ppb (9,580,000 ppt) PFOS was found in fish and at Barksdale Air Force Base in Louisiana, up to 9,349 ppb (9,349,000) PFOS was found in fish. Very elevated levels of PFOS in fish have also been measured downstream of airports that used fire-fighting foams containing PFAS.
If you are interested in citations for the studies above, please email: mariapowell@mejo.us.
Why aren’t Starkweather surface waters, sediments, and fish being tested for PFAS?
At the Truax Air National Guard site in Madison, Wisconsin, combined PFOS/PFOA levels of up to 39,841 ng/L (ppt) (nearly all of this was PFOS) were found in limited investigations of shallow groundwater that feeds directly into Starkweather Creek. Even this limited, preliminary data shows a high potential that fish downstream from the base could have significant PFAS levels.
To date, however, PFAS levels in sediments, surface water and/or fish from Starkweather Creek and Lake Monona have not been tested, even though DNR’s own studies support testing near known PFAS sources. A 2016 DNR study by Williams & Schrank states clearly that based on their study of Wisconsin fish (gathered from 2007-2012) “proximity to a PFC source is an important factor affecting concentrations” in fish. Further, they recommend that “Monitoring fish from Wisconsin’s rivers and Great Lakes for PFCs should continue. In particular, future work should target analysis of fish collected near possible sources or uses of PFCs.”
The fish in the DNR study were gathered from 2007-2012. The testing was limited. The study was published in 2016. Has any further fish testing been done anywhere in Wisconsin since then? We cannot find any. When we queried, DNR said the agency would be doing some PFAS fish testing in 2018, but when we asked where this testing would be done, they did not respond.
PFAS levels found in some fish greatly exceed existing PFAS fish advisories
Several states have issued advisories for PFAS in fish, and more are under development. Based on these advisories, many fish in waterways directly downstream with PFAS uses and releases (such as some of those listed above) are orders of magnitude over most advisory “do not eat” levels.
For instance, Minnesota’s 2018 advisories recommend “unlimited consumption” only for fish with PFOS levels under 10 ppb, increasing limitations on consumption of fish levels from 10 ppb up to 200 ppb, and “do not eat” for fish with over 200 ppb.
Even more conservative advisories being drafted by New Jersey recommend unlimited fish consumption only if fish have less than .56 ppb PFOS. New Jersey’s draft recommendations recommend that “high risk populations” (infants, children, nursing mothers, women of child-bearing age) not eat any fish with PFOS levels over 17 ppb.
The Wisconsin Department of Natural Resources (DNR), meanwhile, has not yet developed statewide PFAS fish advisories (DNR told us they are waiting for the Department of Health Services to develop a reference dose; why haven’t they done so yet?)[7]. In 2007 the DNR developed PFOS advisories only for a stretch of the Mississippi River downstream of 3M—advising “unlimited consumption” only for fish with PFOS levels under 38 ppb, increasing consumption restrictions for fish with from 38 ppb to 700 ppb, and “do not eat” for fish with levels over 700 ppb.
Based on current science, Wisconsin’s Mississippi River fish advisory levels are completely inadequate and unprotective, especially for vulnerable groups like children and pregnant women. Wisconsin should develop updated PFAS fish advisories for the whole state without delay. While new Wisconsin PFAS fish advisories are under development, Wisconsin should use Minnesota’s current and much more protective PFOS advisories (above), issued in April 2018. This also makes sense since Minnesota and Wisconsin share borders (including part of the Mississippi River).
The state, city, or county should test fish downstream of Truax ANG immediately
Fish from Starkweather Creek and Lake Monona, downstream from a known PFAS source, should be tested as soon as possible—and if high PFAS levels are found, government officials should warn fish consumers immediately, as is being done in other states.
To date, the Wisconsin Department of Natural Resources (DNR) has not acknowledged our requests about testing fish from Starkweather and Lake Monona. Dane County has also not acknowledged our requests—in emails and comments at county meetings—nor have City of Madison officials.
Most recently, we asked Public Health Madison Dane County (PHMDC) if they could allot resources to test fish to protect Madison and Dane County fish consumers, especially vulnerable people like children, pregnant women, and subsistence anglers.
Will they do the right thing? Time will tell…
[1] We recently asked city and county elected officials if these investigations were done but have not received answers yet.
[2] The 1988 investigative report on Truax Field also found that surface waters and groundwater near the burn pit were contaminated with methylene chloride, benzene, toluene, xylene, transdichloroethylene, thiobismethane, tetrachloroethylene, lead, and more. The July 2 2018 letter said that this area had never been remediated but they would ask the potentially responsible parties to do so–but only for PFAS. We subsequently asked the DNR if they would also require responsible parties to test the area for other contaminants in addition to PFAS but they did not respond to this question. Notably, the Truax Field site received a high enough Hazardous Ranking System (HRS) score that it qualified to be considered under Superfund. However, as far as we know, it never was. Instead, this report was buried until we discovered it in an appendix of another site ESA in spring 2018.
[3] Industries and other entities that have used and released PFAS will fight protective PFAS criteria tooth and nail (as they have been for years already). At the DNR’s Sept 19 public hearing on the TSR, three representatives (likely attorneys) from the paper industry, which uses and releases PFAS into waterways, testified strongly against the DNR adopting EPA’s water quality human health criteria (HHC) that incorporate exposures from swimming or eating fish.
[4] Dr. Linda Birnbaum (Director of the National Institute of Environmental Health Sciences and National Toxicology Program of the National Institutes of Health) supports this recommendation. In her testimony before a Senate Committee and Subcommittee on Sept. 26, 2018, she said “Approaching PFAS as a class for assessing exposure and biological impact is the best way to protect public health.”
[6] These high levels are particularly remarkable given that this study excluded sites with AFFF releases from fire-training areas, and the sites’ AFFF releases occurred (purportedly) between 1970-1990.
[7] The DNR’s 2015-2020 “Monitoring Strategy for Fish Tissue” states that “Current funds allow for limited monitoring of dioxin/furan and emerging chemicals” (which would include PFAS) but does not mention testing for them.
Under “Monitoring Objectives,” the document states that “The objectives of the fish contaminant program include but are not limited to protection of fish consumers, resource management, and environmental protection.It also lists the “Clean Water Act Objectives” that should guide the program:
-Determining water quality standards attainment – determine ‘fishability.’
-Identifying impaired waters – identify waters with bioaccumulative chemicals
-Identifying causes and sources of water quality impairments – fish tissue monitoring assists in determining sources or location of contaminated sediments.
-Evaluating program effectiveness information to evaluate remediation of sediment. Fish tissue monitoring has in the past reflected efforts to control direct discharges of bioaccumulating chemicals. Fish tissue monitoring may also be helpful in evaluating success of control of other sources of pollutants.
