Military responds to EGLE concerns regarding PFAS investigation

The National Guard Bureau recently responded to a December 22, 2022 letter from the Michigan Department of Environment, Great Lakes, and Energy (EGLE) Gaylord Office that said the PFAS investigation at local military sites whas been too costly to the state and is not making enough progress.

“The Army National Guard prioritizes actions to address locations both on and off its installations where Army National Guard activities have impacted drinking water above 70 parts per trillion for Perfluorooctane sulfonic acid (PFOS) and/or Perfluorooctanoic acid (PFOA). Outside of Camp Grayling, the Army National Guard has completed (Comprehensive Environmental Response, Compensation, and Liability Act) removal actions at 18 drinking water locations by connecting to municipal water, installing whole house filtration systems, or by providing bottled water. To date, the Army National Guard has sampled 378 private-well locations around Camp Grayling to evaluate impacts to drinking water and to assess response actions that may be taken under CERCLA. Additionally, the Army National Guard continues to monitor the locations where it installed whole house filters and replace filters as needed. The Army National Guard will continue to sample drinking water wells downgradient from Army National Guard-identified release areas to evaluate what additional actions are necessary and will continue to take interim removal actions and evaluate more long-term actions that may be taken to protect human health and the environment,” according to a letter dated May 24, 2023 from Colonel Anthony Hammett, U.S. Army Chief, G-9 Army National Guard.

The December 22, 2022 EGLE Gaylord Office letter to Dr. Bonnie Packer, Army National Guard Cleanup and Restoration Branch Acting PFAS Program Manager, from Randall L. Rothe, District Supervisor of the EGLE Remediation and Redevelopment Division, said “EGLE has been waiting on significant remedial progress for five years while continuing to drive further Army National Guard investigation at the state’s expense. During these past five years, (Army National Guard) has repeatedly stated they are working quickly to address all PFAS impact. This week we were told the (Army National Guard) does not intend to extend drinking water from Beaver Creek Township to Grayling as part of an interim remedial action. EGLE considers this unacceptable given the known PFAS impacts to private wells emanating from cantonment on Lake Margrethe and Grayling Army Airfield.”

During meetings of the Camp Grayling Restoration Advisory Board on January 17 and May 16, Dr. Packer said the National Guard is still having discussions with local officials about the possibility of Grayling Charter Township and Beaver Creek Township extending their Four Mile Road municipal water system into PFAS-affected areas in Grayling to provide a clean water option for residents.

“In accordance with the CERCLA process, the Army National Guard reviews and considers various removal actions that may be taken to address known site conditions, and this includes the possibility of connecting properties to an alternative water supply. Connection to public water systems and extension of waterlines is currently being evaluated for this site. When considering connection/extension of public water systems, the Army National Guard will work closely with EGLE and local governments to assess the viability of this option based on site circumstances and CERCLA requirements,” according to the National Guard Bureau response letter.

The Grayling Charter Township Board conducted a public hearing about the potential water system extension on Tuesday, May 30, at the Grayling Township Hall.

Grayling Township Supervisor Lacey Stephan III said the hearing featured one attendee from the public and the board then voted to “accept the plan to extend the Beaver Creek Grayling Township Utility Authority to affected residents.” The township has applied for funding through EGLE/Michigan’s Drinking Water State Revolving Fund – the deadline was June 1 – but township officials are expecting the Department of Defense to pay for the water system extension, Stephan said.

The letter from Rothe questioned a “pause” in the MATES Remedial Investigation and said more testing is needed around the site.

“This week we were told the (Army National Guard) intends to pause the Remedial Investigation at MATES until 2024 or, possibly, 2025,” according to the Rothe letter. “Impacts at MATES have been known since 2018. The current investigation does not include the MATES buildings where PFAS impacts likely originated. The current timeline is unacceptable given the unknown PFAS extent and possible wetland/ecological impacts. Only a small subset of drinking water samples in a one-mile radius have been sampled in the area surrounding MATES. Sampling was conducted by the Michigan Department of Military and Veterans Affairs with detections found in drinking water samples. (Army National Guard) needs to sample all drinking wells in a one-mile radius in the area surrounding MATES. This has been the best indicator of true PFAS extent at cantonment and (Grayling Army Airfield). Ecological risk assessment is necessary.”

During the January 17 meeting of the Camp Grayling Restoration Advisory Board, Dr. Packer said the MATES investigation was “on pause” due to “insufficient funds” and “pending new contract for new Remedial Investigation.”

“The contract for the Range 30/MATES (Remedial Investigation) is currently coming to an end, but Army National Guard is contracting for additional work and anticipates contract execution later this fiscal year (2023) or early in fiscal year 2024. However, if additional drinking water locations downgradient of the Range 30/MATES are identified as requiring sampling, Army National Guard will continue to sample drinking water wells on an expediated timeline, irrespective of the (Remedial Investigation) contracts and timelines,” according to the May 24, 2023 National Guard Bureau letter. “The (Remedial Investigations) for Camp Grayling Army Airfield, and the Camp Grayling Cantonment Area and Lake Margrethe are ongoing and will include risk assessments in accordance with CERCLA and EPA guidance.”

According to the Rothe letter, “the CERCLA investigation progress has been too slow and costly to the State of Michigan.”

“The Army National Guard must follow federal laws associated with its cleanup action, including acquisitions regulations. Army National Guard has been taking action to address PFAS releases pursuant to the CERCLA process,” according to the Colonel Hammett letter. “The CERCLA phases step us through evaluations that conclude in necessary final remedial action, but also include the ability to take immediate action at any time when necessary and supported. With all ongoing work by the Army, the CERCLA process allows us to prioritize limited resources, where most needed, including taking immediate action to address Army National Guard PFAS-impacted drinking water. Comprehensive (Remedial Investigations) are being conducted where PFAS exceeds regional screening levels developed by EPA at: 1) Camp Grayling Army Airfield; 2) Camp Grayling Cantonment Area and Lake Margrethe; and 3) Range 30/MATES, and Army National Guard is conducting additional (Site Inspection) work for North Post, in areas identified after the initial (Site Inspection) work was completed.”

“The Army National Guard has been proactive in its investigation into potential releases of PFAS. After the EPA published the non-enforceable Safe Drinking Water Act lifetime Health Advisories for the emerging contaminants PFOS and PFOA in May 2016, the Army National Guard, following Department of Defense policy, began its assessment of PFAS as pollutants and contaminants under the Defense Environmental Restoration Program and CERCLA by sampling its airfield perimeter and then subsequently sampling homeowner wells in 2016 and 2017. The Army National Guard continues to adjust its actions as more is understood about PFAS, and as law and policy also evolve,” according to the Colonel Hammett letter.

“The Army National Guard has worked diligently, while keeping EGLE and other stakeholders informed. Army National Guard held numerous public meetings to communicate its efforts and to solicit questions and feedback. CERCLA (Preliminary Assessment) interviews began in February 2018, and the Camp Grayling installation-wide (Preliminary Assessment) was completed in August of 2018, after review, comment, and incorporation of comments from EGLE and the Michigan Department of Natural Resources. The Army National Guard finalized the (Site Inspection) work plan for the Grayling Airfield in August 2018 after review and comment by EGLE, has sent draft work plans to EGLE for review and comment for every (Site Inspection) at Camp Grayling, and holds technical project planning meetings with EGLE to discuss Army National Guard’s proposed work. Finally, the Army National Guard has established an active restoration advisory board to ensure that the public has an opportunity for meaningful involvement in the Army’s cleanup efforts for Camp Grayling. The Army National Guard will continue to work diligently through the CERCLA process, and closely with EGLE and the public to be fully transparent,” according to the Colonel Hammett letter.

The Rothe letter says the Army National Guard’s PFAS investigation contains “numerous data gaps” and “deficiencies.”

“The Army National Guard is following the CERCLA process, and the (Preliminary Assessment) and (Site Inspections) are not intended to evaluate full nature and extent of releases,” according to the Colonel Hammett letter. “Rather, the purpose is to identify areas where operational history suggests and then sampling confirms there was a PFAS release, and then determine whether the site should move into the (Remedial Investigation) phase. Many of EGLE’s concerns raised about the sufficiency of the (Preliminary Assessment) and (Site Inspections) relate to an evaluation of the nature and extent of releases, which will be conducted in the (Remedial Investigations), including requests for preferential pathway evaluations, if warranted, groundwater to surface water interface investigation, and risk assessments.”

The National Guard Bureau letter also responds to the Rothe letter’s statement about aqueous film-forming foam release areas. 

According to the Rothe letter, “The 2018 (Preliminary Assessment) was completed at a time when much less was understood by (Army National Guard), contractors, EGLE, and interviewees about Camp Grayling site specifics, aqueous film forming foam use, and PFAS contamination and migration. The (Preliminary Assessment) has been shown to be inadequate at cantonment on Lake Margrethe, MATES, and Grayling Army Airfield. Additional release areas were found at all three locations that were not identified in the (Preliminary Assessment). The (Preliminary Assessment) needs to be expanded to all sources of PFAS as (aqueous film forming foam) was the focus.”

“These concerns relate to information obtained by EGLE of possible off-installation releases of PFAS not addressed in the (Preliminary Assessment), including possible use of military specification (aqueous film forming foam) outside of Army National Guard property,” according to the Colonel Hammett letter. “Army National Guard will continue to work closely with EGLE and will consider and evaluate all information provided by EGLE and other stakeholders as the Army National Guard’s (Remedial Investigations) progress. This includes the review of information EGLE provides that demonstrates (Department of Defense) use, storage, or release of PFAS that was not evaluated in the Army National Guard’s (Preliminary Assessment) but should be evaluated to address Army National Guard’s CERCLA PFAS actions associated with Camp Grayling. As to possible use of military specification (aqueous film forming foam) outside of Camp Grayling, it is the understanding of this office that the first (Department of Defense) military specification for (aqueous film forming foam) was published in 1969, requiring military bases to use (aqueous film forming foam) for aviation firefighting purposes, and after this, beginning in the 1970s, many airports adopted the use of (aqueous film forming foam) as well. In 2004 the Federal Aviation Administration required the use of military specification (aqueous film forming foam) at FAA-regulated airports, and today (aqueous film forming foam) may also be used by municipal fire departments. The Army National Guard will address Army National Guard releases of (aqueous film forming foam) and other releases of PFAS from Army National Guard/DoD activities at Camp Grayling.”

“Under CERCLA, the Army National Guard will continue to perform removal actions where appropriate to mitigate immediate threats to human health from PFAS in drinking water,” according to the Colonel Hammett letter. “Additionally, the Army is evaluating whether there are more long-term actions that can be taken through a removal action, such as connection to/expansion of public drinking water systems, and Army National Guard will coordinate as it conducts this analysis. As for final remedial action, the Army National Guard will continue to work with EGLE and other stakeholders, including the public, as we complete the (Remedial Investigation) work and move on to final phases of CERCLA to address PFAS releases attributable to Army National Guard activities at Camp Grayling.”

“Perfluoroalkyl and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that includes PFOA, PFOS, GenX, and many other chemicals. PFAS have been manufactured and used in a variety of industries around the globe, including in the United States since the 1940s. PFOA and PFOS have been the most extensively produced and studied of these chemicals. Both chemicals are very persistent in the environment and in the human body – meaning they don’t break down and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects,” according to District Health Department #10. “The most-studied PFAS chemicals are PFOA and PFOS. Studies indicate that PFOA and PFOS can cause reproductive and developmental, liver and kidney, and immunological effects in laboratory animals. Both chemicals have caused tumors in animals. The most consistent findings are increased cholesterol levels among exposed populations, with more limited findings related to: low infant birth weights, effects on the immune system, cancer (for PFOA), and thyroid hormone disruption (for PFOS).”