EGLE office does not support Camp Grayling expansion due to PFAS issues

An area Michigan Department of Environment, Great Lakes, and Energy (EGLE) Remediation and Redevelopment Division office recently sent correspondence to the Army National Guard Cleanup and Restoration Branch expressing concerns about the state of the ongoing PFAS water contamination situation in Crawford County and opposing a proposed expansion of Camp Grayling until more progress is made with regard to the PFAS issue.

A letter to 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 Gaylord District Office, dated December 22 (recently sent to the Crawford County Avalanche via the Camp Grayling Restoration Advisory Board), says the PFAS “investigation needs to be assessed as part of any Camp Grayling expansion proposal.”

“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. The State of Michigan continues to supply point of use filters to impacted residents five years after project initiation. The Department of Defense has implemented a similar interim response at Eielson Air Force Base extending public water six miles. Grayling Township is currently modifying an existing feasibility study to accomodate Camp Grayling and completing work (Army National Guard) needs to conduct. Please cite (Department of Defense) policy and CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act) on why this measure cannot be implemented,” according to the EGLE Remediation and Redevelopment Division Gaylord District Office.

The Grayling Charter Township Board of Trustees – during a regular meeting on Wednesday, December 21 – approved allocation of $18,000 of the township’s American Rescue Plan Act money for a feasibility study with regard to providing municipal water “to residents with contaminated well water” near Camp Grayling and the Grayling Army Airfield.

Rothe’s letter also challenged the planned “pause” of “Redmedial Investigation” at MATES (Camp Grayling’s Maneuver Area Training Equipment Site), a military facility located on North Down River Road.

“This week we were told the (Army National Guard) intends to pause the Redmedial Investigation at MATES until 2024 or, possibly, 2025. 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,” according to the EGLE Remediation and Redevelopment Division Gaylord District Office.

The letter questions the scope of the Army National Guard investigation and says the Army National Guard “continues to minimize known impacts in public facing documents,” comparing figures offered during a recent Camp Grayling Restoration Advisory Board meeting to “existing EGLE dataset.”

“(Army National Guard) expects EGLE to prove beyond a reasonable doubt that (Army National Guard) PFAS impact exists offsite before pursuing those areas themselves. Investigations to prove impact by (Army National Guard) activities are causing enormous expense to the State of Michigan. Many times, EGLE has been told that policy and procedures are limiting (Army National Guard) investigations without cited documentation. Examples where the State has had to open investigations first include: drinking water well investigation downgradient of (Grayling Army Airfield); Lake Margrethe area and Borchers Way drinking water impact; Grayling resampling efforts by the Department of Health and Human Services; Lake Margrethe discharges of PFAS impacted water from spring water downgradient of cantonment (aqueous film forming foam) releases and wastewater treatment plant; Lake Margrethe surface water impact and foam; City of Grayling sanitary sewer investigation and wastewater treatment plant; AuSable River discharges and surface water; Lake Margrethe outflow at Portage Creek; fish sampling in the AuSable and Lake Margrethe,” according to EGLE.

The EGLE letter says the Army National Guard PFAS investigation contains “numerous data gaps” and offers a long list “deficiencies” in the process with regard to the Camp Grayling cantonment area, Lake Margrethe, Grayling Army Airfield, City of Grayling sanitary sewers, and the AuSable River.

According to EGLE, the 2018 Preliminary Assessment is insufficient for some areas and “additional Preliminary Assessment is needed for many base areas.” 

“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,” according to EGLE.

The EGLE letter says “additional interviews helped find additional release areas (of Military Specification aqueous film forming foam) at cantonment this summer that were previously unknown” and more interviews and investigation should be conducted, but “many contacts are unwilling to speak or only speak anonymously for fear of reprimand/reprisal.”

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

“In last five years, insufficient and minimal mitigation and remediation has taken place. Only 17 drinking water wells have been given access to less impacted through extension of City of Grayling water supply and installation of whole home filters. City of Grayling water has had periodic detections of PFHxS due to migrating PFAS contamination from (Grayling Army Airfield) that (Army National Guard) has not sampled. Whole home filters have shown detections of breakthrough in testing required by (Department of Health and Human Services). We continue to recommend point of use filtration after whole home filtration,” according to Rothe’s letter.

(The Michigan Department of Health and Human Services – during a recent meeting of the Camp Grayling Restoration Advisory Board – also recommended that affected homeowners use both types of filters.)

According to EGLE, “only two remedial pilot studies have been conducted at Camp Grayling” and “this is insufficient as interim remedial actions are necessary to prevent further migration of PFAS.” “Other remedial options need to be piloted at Camp Grayling for analysis in a feasibility study. Pump and treat options are feasible,” according to EGLE.

“The deficiencies in this document should not be treated as an exhaustive list. Despite the deficiencies listed, (Army National Guard) expects to reach the Risk Assessment and Feasibility Study phases of investigation at (Grayling Army Airfield). This is unacceptable given the number of data gaps and additional Remedial Investigation needed. EGLE expects further investigation while interim remedial measures are implemented to protect public health and the environment,” according to the EGLE Remediation and Redevelopment Division Gaylord District Office.

Toward the end of the document, Rothe states that the “EGLE Gaylord (Remediation and Redevelopment Division) does not support the expansion of Camp Grayling based on the inability to take timely action to investigate, mitigate, and remediate significant areas of contamination at Camp Grayling. It is EGLE Gaylord (Remediation and Redevelopment Division’s) recommendation to the Michigan DNR not to accept an expansion of Camp Grayling until significant progress and timely action is taken.”

According to an online document provided by the Michigan Department of Natural Resources, “The U.S. military has transitioned from training for counter insurgency to training for large-scale combat operations in response to new and emerging global threats. The resultant military readiness training now requires immersive, multi-domain exercises which integrate land, air, maritime, cyber and space domains over greater distances than those afforded with Camp Grayling’s current size. The newly proposed training areas, if approved, would be used for periodic, low impact activities such as drone operation, cyber, electronic warfare, space and communication system installation and operation. If the proposal is approved the Michigan Department of Natural Resources (DNR) will maintain ownership (and) the DNR will continue to manage the land and resources including game, fish, forestry, minerals, fire and all other interests.”

“Low impact or light maneuver training consists of foot traffic, tents, bivouacking and porta-johns. Vehicle travel will be restricted to current state forest roads and trails,” according to Camp Grayling via the DNR document. “Electronic Warfare is the use of electronic signals to jam, disrupt or spoof communications in electronic systems. Soldiers need to be trained in how to respond when (Electronic Warfare) effects target their equipment (radios, GPS, drones, etc.) and develop techniques and procedures to overcome those effects. Greater distances better replicate when effects by an adversary could be used in scenarios. Additional land use will also allow for separation between (Electronic Warfare) effects and other troop training maneuvers when used.”

According to the DNR/Camp Grayling document, the proposal will “benefit the community” with increased “federal resources for conservation, invasive species management, sensitive habitats, river health and fire prevention” and “enhanced pride and patriotism having one of the largest and most capable four-season training centers in the nation that places equal emphasis on protecting the precious lands which we all enjoy.”

Effects on “land use, ecosystems and award-winning rivers” will – according to the online document – include: “These lands will remain open to hunting and no military training will occur on these lands during Regular Firearms Deer Season (November 15-30). Hunting, camping, fishing and ORV trails will remain open. No permanent fencing will be erected on these lands. Public advisories will be broadcasted on the radio and posted on social media when troops are training in these areas. There will be no military training activity within 1,500 feet of rivers.”

According to a different Michigan DNR page that offers a link to an updated FAQ site for the proposed Camp Grayling expansion, the “Michigan National Guard has proposed leasing about 162,000 acres of state forest land” for the “low impact Electronic Warfare” training. According to military officials, the current size of Camp Grayling is approximately 148,000 acres.

The online page – dated August 12, 2022 – says “DNR Director Dan Eichinger is expected to decide this year whether to move to the next stage in the leasing process, which would include environmental and parcel reviews,” but in December, Governor Gretchen Whitmer’s administration announced a change in DNR leadership.

A press release dated December 2, 2022 (“Gov. Whitmer Announces Cabinet, Agency Leadership to Begin Second Term”), announced that “Dan Eichinger will serve as the acting director of EGLE. Dan is currently the director at the Department of Natural Resources, where he has served since 2019.”

“Shannon Lott will serve as acting director at DNR, where she has worked for over 25 years, most recently as natural resources deputy,” according to the December 2 press release. “Before that, Lott served as assistant chief of the Forest Resources Division and held a variety of jobs in the department’s Wildlife Division. Lott has worked with a broad range of conservation groups and legislators, as well as the Michigan Natural Resource Commission, to guide policies and programs related to outdoor recreation and natural resource management in the state. She has led DNR teams on critical issues such as renewable energy, climate change mitigation and the use of mass timber in construction.”

The Camp Grayling Restoration Advisory Board – during its most recent gathering on Monday, November 21, at Kirtland Community College (and online via Zoom) – tenatively scheduled the next meeting for March of 2023; however, the Restoration Advisory Board last week issued a public notice that it would be meeting on January 17 from 6 p.m. to 7:30 p.m. at Kirtland Community College (Community Room A).

According to the notice, the Restoration Advisory Board meeting will deal with PFAS issues and not the proposed Camp Grayling expansion.

“The agenda for this meeting will include a discussion with the community about recent events pertaining to Camp Grayling and the ongoing PFAS investigations. This meeting will address PFAS issues only and not Camp Grayling’s ongoing request to access Michigan Department of Natural Resources land. National Guard Bureau, Department of Military and Veterans Affairs, the Department of Environment, Great Lakes, and Energy, and Michigan Department of Health and Human Services will be present to speak with the RAB and members of the public regarding PFAS-related issues,” according to the public meeting notice. 

“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).”