Officials provide PFAS investigation update during RAB meeting

National Guard addresses some aspects of recent EGLE letter that says process is not moving quickly enough and costing the state too much money
During a meeting of the Camp Grayling Restoration Advisory Board at Kirtland Community College on Tuesday night, officials offered PFAS investigation updates and addressed some elements of a recent letter from the Michigan Department of Environment, Great Lakes, and Energy Redevelopment Division Gaylord District Office that said parts of the current process are “unacceptable,” “too slow,” and “(too costly) to the State of Michigan.”
Christiaan Bon, Senior Geologist at the EGLE Redevelopment Division Gaylord District Office, said “there’s going to be a little bit of change in approach from EGLE” because of funding changes. 
Bon said earlier in the investigation process the state had money available specifically for PFAS but that funding is now “competing” with “other contaminants.” Bon said EGLE wants “clean, reliable water” for the community through a “coordinated effort.”
A letter dated December 22, 2022 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 Gaylord District Office, says “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.” 
Rothe’s letter says the Army National Guard’s PFAS investigation contains “numerous data gaps” and it offers a long list “deficiencies” in the process. The letter says 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 the EGLE letter.
“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.
“I think that letter speaks for itself,” Bon said during Tuesday’s meeting. “We want to keep the investigation moving forward. We understand there are going to be hurdles along the way.”
Bon said EGLE was able to do a lot of testing and other work earlier in the investigation but – due to funding issues – the department is now “going to look to our partners to do that work we were doing.” Bon said EGLE will continue to send violation notices if necessary and provide feedback on the National Guard investigation.
“We’re still going to have that input,” Bon said.
Rothe, present during Tuesday’s meeting via audio, said EGLE has spent millions of dollars on the investigation during the last five years.
“There has been significant expense incurred by the state,” Bon said.
According to Dr. Packer’s presentation on Tuesday, the Army National Guard’s “top priority” is “human health” and the military is looking to “move deliberately through Remedial Investigations while taking actions to protect human (health).”
Dr. Packer said a “remedy” can occur after all the CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act) stages but “removal action” can occur “if there is a threat to human health.”
Dr. Packer has said throughout meetings of the Restoration Advisory Board that in order to be included in the military’s “remedy” homes must have their water sampled and tested through the Army National Guard.
“The army guard is doing its own sampling. I know this gets very confusing for the community. The reason the guard needs to take its own sample is because the actual remedy for the community is an army guard remedy. In order to take that action, either with bottled water or whole house filter or the final remedy, those houses that want to be involved in that have to have their houses sampled by the army guard,” Dr. Packer said during a previous Camp Grayling Restoration Advisory Board meeting. “Even if you’ve already been sampled two or three times by the state it’s very important if you’ve got a right of entry from us that you sign it and send it back.”
According to Dr. Packer, the Army National Guard has to conduct its own sampling and testing effort per CERCLA for funding requirements, even though EGLE and the Michigan Department of Health and Human Services also have conducted testing.
“They’re not going to take our results and apply it to their remedy,” Bon said.
Dr. Packer said many residents have still not submitted signed right of entry forms required for the Army National Guard water sampling. Dr. Packer said the Army National Guard will still sample wells of homes with “newly signed” right of entry forms.
John Alef of the community portion of the Camp Grayling Restoration Advisory Board said several people do not want to sign the right of entry form because of language in it that allows for “other things besides sampling” and he asked if the wording could be modified.
During past meetings, officials have acknowledged that some people have been reluctant to sign the forms because of some of the language.
One of the Grayling Army Airfield letters says the right of entry gives the government “an irrevocable and assignable right to enter in, or over and across the land described... for the purpose of conducting remedial investigations, to include water sampling, soil sampling, and the right to install temporary wells as determined by the government for a period not to exceed 24 months, or for a period not less than the duration of the remedial investigative phase, whichever is longer.”
“There are people that would look at that and say no way,” Alef said.
Dr. Packer said the overall language of the right of entry forms can not be changed, but residents can modify the duration listed on them from “24 months” to anything they want, even changing it “to one day.”
“If they’re worried, I hear that they’re worried,” Dr. Packer said. “They have the control. They can cross off 24 months and put whatever it is they want.”
Dr. Packer said talks 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.”
“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,” according to the Rothe letter.
The Remediation and Redevelopment Division Gaylord District Office letter questions the “pause” of “Remedial Investigation” at MATES (Camp Grayling’s Maneuver Area Training Equipment Site, a military facility located on North Down River Road).
“We were told the (Army National Guard) intends to pause the Remedial 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 Remediation and Redevelopment Division Gaylord District Office.
Dr. Packer – during Tuesday’s meeting – said the MATES investigation is “on pause” due to “insufficient funds” and “pending new contract for new Remedial Investigation.” Dr. Packer said investigators are “not seeing impact on homes” in the MATES area.
Sesha Kallakuri, Michigan Department of Health and Human Services Toxicologist, said the department has conducted resampling near MATES and “it isn’t an area of concern compared to Lake Margrethe or the Grayling Army Airfield” because the results were “mostly non-detect.”
Dr. Packer presented a new plume map for the Grayling Army Airfield, but she said a “good plume map” for the Lake Margrethe area is still “one-and-a-half years out.”
Kallakuri said round three sampling letters have been sent to homes in the MATES, Grayling Army Airfield, and Lake Margrethe areas.
When asked how long point of use filters will continue to be provided to affected residents, Kallakuri said a “final recommendation for water” has not been made. The Michigan Department of Health and Human Services will “make a recommendation in the next year or so,” and the determination for people will be based on detectable PFAS levels in the groundwater at homes, neighboring homes, and monitoring wells, Kallakuri said.
“We’re going to look at the overall data and see how they fluctuate over time,” Kallakuri said.
During the beginning of Tuesday’s Camp Grayling Restoration Advisory Board meeting, Jonathan Edgerly, of the Michigan Department of Military and Veterans Affairs and co-chair for the military/regulatory portion of the RAB, said the committee still needs a co-chair for the community portion of the board.
Edgerly said two nominations were received but one withdrew and the other is a local elected official. Some RAB community board members felt that it would be fine to have an elected official serving on the community side, but others felt that elected office holders belong on the regulatory portion of the board.
Edgerly said the community portion of the board could vote on the lone nominee or nominate others or table the issue to try to recruit more nominees or have further discussion. Edgerly said the role of the community co-chair is to “help drive the group as far as discussions” and be a leader for the board.
Edgerly said “if we can’t find a community co-chair this group becomes non-viable.”
“If we don’t have a community co-chair we don’t have an RAB,” Edgerly said.
Edgerly said there is not a defined time limit for finding a new community co-chair.
The board opted to table the matter in order to have more discussion and a possible vote via email.
“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).”

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