The next stage?

A significant amount of water in Crawford County is contaminated with PFAS, and years after the first positive tests, many questions remain.

What is the extent of the contamination? What are the levels of PFAS in the water? What can be done about it, and when? Who pays for the solutions?

Some homes near the Camp Grayling National Guard base at Lake Margrethe and the Grayling Army Airfield use whole-home filters or point-of-use filters to clean the PFAS out of their drinking water. Multiple studies and documents available through the Michigan PFAS Action Response Team and Camp Grayling Restoration Advisory Board websites cite use of firefighting material (aqueous film forming foam) at military facilities as a significant source of the PFAS water contamination while acknowledging that there could be other sources.

Are the filters sufficient to clean the water? Officials have recently been reporting breakthroughs.

During a meeting of the Camp Grayling Restoration Advisory Board on Monday, November 21, 2022, Sesha Kallakuri, Michigan Department of Health and Human Services Toxicologist, said testing has shown “some detects” for PFAS water that has gone through the whole-house filters but “none of those detections were of concern” because they were at low levels. Kallakuri said testing has shown “levels down to no-detect with point of use” filters, and using both types of filters offers more protection.

Grayling resident Marcia Koppa, a member of the community portion of the Camp Grayling Restoration Advisory Board, lives in the Grayling Army Airfield area and has been using point-of-use filters provided by the Health Department for several years. 

Koppa said she is seeing PFAS breakthrough in her home’s point-of-use filters. Koppa said she’s not sure why the breakthrough is happening, whether it is because the PFAS concentrations are too high or if the filters just aren’t working well enough. She said it’s “not good” but she worries more about the health of neighbors and other community members affected by the PFAS contamination.

“I just feel bad for people raising families with young kids,” Koppa said.

Chet Wheeler and his wife and children, until recently, lived in a home in a subdivision affected by the Grayling Army Airfield PFAS contamination. Prior to that, they lived in a different home in the same subdivision, he said.

Wheeler said a member of his family has a medical issue consistent with one of the negative effects believed to be caused by PFAS exposure (as listed by the Michigan Department of Health and Human Services) but he can’t be sure if it was caused by contaminated water.

Wheeler said using the point-of-use filter was “sufficient” but “tiring.” He had a point-of-use filter (provided by the Health Department) at the kitchen sink for consumable water.

“Anything and everything is supposed to be done from there. Anything you ingest needs to be done from there,” Wheeler said. “Every day you have to sit there and wait for it to fill up. That’s the only hassle is that it’s slow.”

“It’s slow but you adapt to it,” Koppa said.

“It affects the way we live but this is the only town I’ve ever lived in. This is our home,” Wheeler said.

Wheeler said he remembers many years ago going to the first local PFAS town hall meeting, an event that had large attendance, and at the time he thought action would be taken swiftly to remedy the problem based on what the crowd was told. Now?

“I have zero interest in going to another public meeting on PFAS,” Wheeler said. “There’s no action. They just continue to test and test and test. Six years in and we’re still in an investigative stage.”

“At what point do we get to the next stage? You can not eliminate PFAS – it’s a forever chemical – but we can dig deeper wells or we can obtain water from an alternate source,” Wheeler said. “We are not alone in this. PFAS is a national problem. There are solutions.”

Koppa said funding is one of the primary issues with regard to PFAS investigation and remediation, and as the list of known sites with PFAS (and other types of contamination) grows, “high demand” for those dollars may make it difficult to make progress.

“The financial pie is only so big, so it’s going to be tough,” Koppa said.

Koppa said she believes the Camp Grayling Restoration Advisory Board is “on the right track” and offering at least some communication between the parties involved in the investigation. The RAB has a “pretty good group” and offers a lot of documents online via its webmaster through Kirtland Community College, Koppa said.

“I think it provides an opportunity to get things done,” Koppa said.

Grayling Charter Township Supervisor Lacey Stephan III, who’s on the Camp Grayling Restoration Advisory Board on the regulatory side as an elected official, said representatives from the military and state agencies who regularly attend the RAB meetings are working to help the community.

“They’re on our side,” Stephan said.

Koppa said she’s currently trying to approach state and federal legislators for assistance with the Crawford County PFAS issue.

“I don’t know what to say other than ‘I’m trying,’” Koppa said.

 

Legislative Support?

 

In May of 2022, US Senator Gary Peters (Michigan), Chairman of the Committee on Homeland Security and Governmental Affairs, sent a letter to the US Department of Defense asking for answers to a number of questions with regard to the “Army’s ongoing PFAS-related efforts required under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)” at Camp Grayling.

“The public health threat PFAS poses to the community surrounding Camp Grayling demands additional action and continued communication with residents,” according to the Peters letter. “In May 2017, Camp Grayling installation officials identified PFAS in groundwater above the EPA Lifetime Health Advisory levels of 70 parts per trillion (ppt). Since then, the Michigan Department of Environment, Great Lakes, and Energy (EGLE) and Michigan Army National Guard have identified 138 residential well and 259 groundwater monitoring well samples above EGLE’s PFAS criteria of 16 ppt for PFOS and 8 ppt for PFOA in the surrounding area. Due to the high levels of contamination, Camp Grayling was included as part of a July 2021 (Department of Defense) Office of Inspector General report on the Department’s efforts to control PFAS contamination effects. The report found that officials discovered PFAS contamination in an unexpected location, resulting from an unknown source. The report concluded that, as a result, people and the environment may be exposed to preventable risks from PFAS-containing materials other than aqueous film forming foam (AFFF), which is striking, considering DoD’s primary focus on AFFF for PFAS containment.”

“Given the continuing contamination surrounding Camp Grayling, I believe it is critical that Congress, my constituents, and local stakeholders better understand how (Department of Defense) implemented the CERCLA and other DoD policies in the areas surrounding Camp Grayling and what additional actions DoD plans to take,” according to the Peters letter. 

On February 13, 2023, Peters and US Senator Debbie Stabenow (Michigan) announced that “the U.S. Environmental Protection Agency (EPA) is making $37,348,000 in federal grants available to Michigan to address PFAS in drinking water.”

“People in communities across Michigan have experienced the fear and frustration of finding out that contaminants like PFAS now threaten their home, community, and health of their families. This funding is critical for the clean up of these contaminants. It will help communities who don’t have the resources to address the problem on their own, clean up the contaminants so that residents have safe drinking water that we all take for granted,” Senator Stabenow said.

“PFAS contamination and exposure has harmed communities across Michigan, and is not only an environmental threat but a danger to public health and local economies,” Senator Peters said. “I’ll work closely with state and local leaders to make sure this funding is implemented effectively.”

 

The Camp Grayling Expansion

 

The Michigan National Guard’s request to lease from the Michigan Department of Natural Resources “approximately 162,000 acres of land around” Camp Grayling “for periodic, low impact activities such as drone operation, cyber, electronic warfare, space and communication system installation and operation,” according to the DNR, has brought attention to the PFAS issue through opposition to the proposal.

In January, during a regular meeting in which the Crawford County Board of Commissioners passed its “Resolution Opposing The Expansion Of Camp Grayling,” several citizens spoke in opposition of the proposal during the meeting’s public comment periods. One of them was Wheeler.

“I’m strongly against this expansion,” Wheeler said during the meeting. “In our county and in our townships our water isn’t safe. They don’t need more land. They need to fix the problems they have caused.”

“They haven’t taken care of the land they’ve had. Why should they get one single acre more?” Wheeler said during a recent interview.

Some opponents of the training area expansion refer to the PFAS contamination as one of their reasons for opposing the Camp Grayling proposal.

“The National Guard usages of our public land has already created massive contamination of the area’s ground water and has already been poisoning citizens for years without giving the community a plan for clean up,” according to Beaver Creek’s Resolution In Opposition To Camp Grayling Lease Expansion and Military Air Space Expansion.

“This expansion poses risks to our public health and waterways. Camp Grayling and military bases here and across the country have a history of contaminating our land and the water that not only many people rely on for drinking and recreation, but also many species rely on for habitat,” according to the Sierra Club Michigan Chapter.

“The Guard has not cleaned up the PFAS mess it has created. The Guard is not living up to promises to clean up after itself,” according to Anglers of the Au Sable.

 

EGLE

 

A December 22, 2022 letter from Randall L. Rothe, District Supervisor of the EGLE Remediation and Redevelopment Division Gaylord District Office, to Dr. Bonnie Packer, Army National Guard Cleanup and Restoration Branch Acting PFAS Program Manager, says the PFAS “investigation needs to be assessed as part of any Camp Grayling expansion proposal.”

“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 the letter.

The Rothe letter says the Army National Guard “continues to minimize known impacts in public facing documents,” and its PFAS investigation contains “numerous data gaps” and “deficiencies.” Rothe’s letter says the process is moving too slow and costing the state too much money.

“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. In (the) last five years, insufficient and minimal mitigation and remediation has taken place,” according to Rothe’s letter.

The December 22 letter was not the first from EGLE with regard to PFAS issues at Camp Grayling facilities.

A letter from Brian Zuber, Senior Environmental Quality Analyst Emerging Pollutants Section Water Resources Division, to the Michigan Department of Military and Veterans Affairs dated July 25, 2022 (available to view via the Michigan PFAS Action Response Team website), has “Per- and Polyfluoroalkyl Substances (PFAS) Violation Notice” in its subject line.

“On December 7, 2021, the Department of Environment, Great Lakes, and Energy, Water Resources Division, received the results of the Short-Term Storm Water Characterization Study conducted between June 24 and October 8, 2021, at (Camp Grayling),” according to the Zuber letter. “The objective of the (Short-Term Storm Water Characterization Study) was to evaluate concentrations of PFAS, specifically Perfluorooctanesulfonic Acid (PFOS) and Perfluorooctanoic Acid (PFOA), and other pollutants of concern in storm water discharges from all discharge points (outfalls and points of discharge) at the facility to determine compliance. Based on a review of the data provided by the facility, including the (Short-Term Storm Water Characterization Study) results, it appears that the discharge exceeds the Water Quality Value developed in accordance with the (Water Quality Standards) to protect waters of the state.”

“The Permit authorizes the (Department of Military and Veterans Affairs) to discharge storm water associated with industrial activity to Lake Margrethe if it meets the criteria established in the Permit. The Permit does not authorize discharges that may cause or contribute to a violation of a (Water Quality Value). Therefore, the discharge of storm water contaminated with PFOS above the (Water Quality Value) is a violation,” according to the letter.

 

PFAS Litigation Project

 

The attorney general for Michigan recently announced a “landmark settlement” with regard to PFAS investigation and clean-up at a downstate site.

In a press release dated January 30, 2023, “Michigan Attorney General Dana Nessel announced that a settlement has been reached in a lawsuit filed against Asahi Kasei Plastics North America, Inc. to address releases of PFAS at Asahi’s former facility near Brighton, Michigan.  The settlement requires Asahi to investigate PFAS in soil, groundwater, and surface water discharged from their former facility, and to undertake response actions to address levels that exceed state criteria. The Consent Decree (as signed by both parties) requires Asahi to investigate PFAS released into soil, groundwater, and surface water from its former facility on Whitmore Lake Road. If concentrations that exceed state criteria are found, additional steps are required to cut off harmful exposures. Asahi’s investigation and proposed work plans must be submitted to and approved by the Michigan Department of Environment, Great Lakes, and Energy. In addition, the Consent Decree provides that work plans that are of significant public interest can be made available for public comment prior to their approval.”

“In addition to the required investigation and response actions to address exceedances of PFAS criteria, the settlement requires Asahi to pay the State’s past and future oversight costs and costs of litigation, including the attorney fees of the (Special Assistant Attorneys General) for this matter, which means that these costs will not be shifted to taxpayers,” according to the January 30 press release. “Asahi was one of the 17 PFAS defendants named in Attorney General Nessel’s first lawsuit against PFAS manufacturers filed in 2020 under a state-approved contract with Special Assistant Attorneys General retained specifically to assist with complex PFAS litigation. The case against Asahi was separated out from the larger suit and moved to Livingston County Circuit Court.”

“I started the PFAS Litigation project in 2020 to bring relief to communities impacted by PFAS contamination, and this settlement is another step in the right direction,” said Attorney General Nessel via the January 30 press release. “I am pleased with this resolution, and I look forward to seeing the important investigation and work get underway. The agreed-upon framework for compliance at this site requires work under an enforceable schedule and is a favorable outcome for Michigan. This settlement reflects my promise to protect the public and the environment from the harmful impacts of PFAS and hold companies responsible for contamination. My office and I will continue to pursue that goal, in court or cooperatively.”

Could the office of the Michigan Attorney General pursue similar litigation or settlement with regard to the military and the Crawford County PFAS issues? The Crawford County Avalanche, on February 7 and February 14, contacted the Attorney General’s office via email, asking if the Department of Defense/Michigan Army National Guard/Camp Grayling could possibly be included in the “PFAS Litigation project.” As of Monday, February 20, the Avalanche had not received a response other than an automated message saying, in part, “Thank you for emailing the Michigan Department of Attorney General.”

 

Solutions?

 

The December 22 letter from Rothe to the Army National Guard Cleanup and Restoration Branch said EGLE was informed that “the (Army National Guard) does not intend to extend drinking water from Beaver Creek Township to Grayling as part of an interim remedial action.” Dr. Packer, during a meeting of the Camp Grayling Restoration Advisory Board on Tuesday, January 17, said discussions with regard to Grayling Charter Township and Beaver Creek Township extending their Four Mile Road municipal water system into PFAS-affected areas in Grayling are “still ongoing despite what’s in the (Rothe) letter.”

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.

Stephan said he has had regular communication with Dr. Packer with regard to the possible extension of the Four Mile Road municipal water system.

“That is going to be the solution, to extend the municipal water,” Stephan said. “It’s being worked on as fast as possible. They are trying.”

Stephan said other options are limited. Digging deeper wells in contaminated areas could spread PFAS into other water sources, Stephan said, and filters are experiencing breakthrough.

“Filters are not working,” Stephan said. “Whole house filters do not take out every bit of the contaminant.”

Stephan said if the project to extend the water system proceeds, people would not be forced to hook up to it. Public meetings would be held “to see if enough people would hook up,” Stephan said. 

Stephan said a similar municipal water system extension project was completed in Alaska following water contamination from an Air Force base. Stephan said the Four Mile Road municipal water system extension project needs to happen.

“This is life and death here. It matters,” Stephan said. “I’m all in.”

 

What is PFAS?

 

“PFAS” is an acronym for “perfluoroalkyl and polyfluoroalkyl substances.”

“PFAS are a family of human-made chemicals that have been used in manufacturing and commercial products since the 1940s. Practical uses of PFAS include creating nonstick surfaces on cooking pans and food wrappers, waterproofing chemicals, foams used to fight fires, and in industries to keep fumes down for worker safety,” according to the Michigan Department of Health and Human Services.

PFAS types include “perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS),” according to the Michigan PFAS Action Response Team.

“PFAS have been used globally during the past century in manufacturing, firefighting, and thousands of common household and other consumer products. These chemicals are persistent in the environment and in the human body – meaning they don’t break down and they can accumulate over time,” according to the Michigan PFAS Action Response Team.

What are the effects of PFAS exposure?

According to the Michigan Department of Health and Human Services, “Research is ongoing to understand the effects PFAS might have on health. Having PFAS exposure or PFAS in your body does not mean you will necessarily have health problems now or in the future. Most people in health studies do not have health effects, even when exposed to high amounts of PFAS.”

“Some health studies have found health effects linked to some PFAS such as: decreased chance of a woman getting pregnant; increased chance of high blood pressure in pregnant women; increased chance of thyroid disease; changed immune response; increased cholesterol levels; increased chance of cancer, especially kidney and testicular cancers,” according to the Michigan Department of Health and Human Services.

 

Contamination Sources

 

Multiple documents available through the Michigan PFAS Action Response Team website and the Camp Grayling Restoration Advisory Board website suggest that PFAS water contamination has been caused by use of aqueous film forming foam at local military training sites, but other sources are possible.

“During interviews, Camp Grayling firefighters reported that fire truck tanks were washed out into Lake Margrethe as regular practice during routine maintenance. The frequency and quantity of tank washout is not known. Since (aqueous film forming foam) was regularly used as ‘wet water’ in truck tanks during the 1970s and 1980s, PFAS may have been directly washed into the lake,” according to a Site Inspection Quality Assurance Project Plan Addendum Camp Grayling Cantonment and Lake Margrethe, MI document from April 2019, prepared by AECOM for Army National Guard and US Army Corps of Engineers. “Camp Grayling firefighters performed nozzle checks on equipment as part of routine maintenance activities. The process involved pumping an undefined quantity of tank contents through hose lines and nozzles to observe performance and flush the lines. Interviews and photographs confirmed that this activity predominantly occurred in the western area of the cantonment on Lake Road along the shore of Lake Margrethe. Hoses and nozzles were discharged into or towards the lake between 7th Street North and 8th Street North.”

The document from AECOM also lists a variety of fire sites and demonstration sites at the Camp Grayling main cantonment area that featured discharges of aqueous film forming foam.

According to Rothe’s letter and reports from officials during Camp Grayling Restoration Advisory Board meetings, more sites where aqueous film forming foam was used have recently been found, and there are probably more that need to be identified.

“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 the Rothe letter.

 

Warnings

 

Signs at Lake Margrethe warn users about foam that could contain high concentrations of PFAS, and the 2022 Eat Safe Fish Guide from the Michigan Department of Health and Human Services recommends limited consumption of fish from the lake.

“Foam can form on any waterbody, and sometimes foam can have harmful chemicals in it. This can include high levels of per- and polyfluoroalkyl substances (PFAS). PFAS-containing foam tends to be bright white in color, lightweight, and may pile up along shores or blow onto beaches. An MDHHS evaluation suggests young children who come into contact with PFAS-containing foam for a few hours a day may be more at risk of negative health effects,” according to the Michigan Department of Health and Human Services. “Natural foam without PFAS is usually off-white and/or brown in color, often has an earthy or fishy scent, and tends to pile up in bays, eddies, or at river barriers such as dams.”

“If you do come in contact with foam, MDHHS recommends that you rinse off or bathe as soon as possible. This is especially true if the waterbody has suspected PFAS contamination. Coming into contact with foam without rinsing off or bathing can lead to accidentally swallowing foam or foam residue,” according to the Michigan Department of Health and Human Services.