Moody AFB and Lowndes County on U.S. PFAS contamination map 2019-05-06

Should we be proud? Lowndes County and Moody Air Force Base again made it onto a national map of PFAS firefighting foam contamination, as did the Florida State Fire College, Ocala Florida.

[U.S.]
U.S.

The report EWG references for Moody AFB says other Air Force Bases did test off-base wells, unlike Moody AFB.

[Page 01]
Page 01

It says Peterson AFB in Colorado applied for further funds and did further testing and continues mitigation work “on private and public drinking water wells.”

[Southeast U.S.]
Southeast U.S.

The report’s Conclusion includes: “We are addressing DoD’s cleanup responsibility”. Well, that’s refreshing news! I look forward to Moody AFB being the community leader it always is.

[Moody Air Force Base]
Moody Air Force Base

Some of the details on this EWG map are a bit odd, such as Date of discovery: 2018”, when Moody AFB reported on this in 2016. Also firefighting foam at the base is not just a “Suspected source”; the base confirmed it. Presumably that’s all just due to EWG handling data about many cases in forms trying to fit them all.

PFOS/PFOA Contimation Site

DETAILS

Contamination site: Moody Air Force Base

Location: Lowndes County, Georgia

Date of discovery: 2018

Results (PFOS/ PFOA) or Range above EPA LHAs: Highest on-base groundwater detections: -PFOS+PFOA: 590-375,000 ppt (2016)

Other Results PFAS or Range above EPA LHAs: Highest on-base groundwater detections: -PFBS: 290,000 ppt (2016)

Suspected source: Firefighting foam used at Moody Air Force Base

Source: EWG from Department of Defense

KEY FINDINGS

  1. PFAS compounds are a class of non-stick, waterproof, stain-resistant compounds used in consumer products and industry. Best known are PFOS, formerly used to make DuPont’s Teflon, and PFOA, formerly in 3M’s Scotchgard.
  2. Very low exposure to some PFAS chemicals has been linked to cancer, thyroid disease, weakened childhood immunity and many other health problems.
  3. Tests of tap water, military bases and industrial sites have found PFAS contamination in more than 600 locations in 43 states. Drinking water for up to 110 million Americans may be contaminated with PFAS.

The report EWG links to is Addressing Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA), by Maureen Sullivan, Deputy Assistant Secretary of Defense (Environment, Safety & Occupational Health), March 2018. It says it is an “Official Response to House Report 115-200.”

This is interesting news in slide 8:

[Page 08]
Page 08

Drinking Water off DoD Installations

  • The Components also sampled private drinking water wells if there was a suspected or known release that migrated off-base
  • DoD is working with the Communities and private individuals to break the exposure pathway
  • DoD off-base testing as of August 2017:
    • 2,445 off-base Public and Private drinking water systems tested
    • 564 public or private drinking water systems tested above the EPA LHA level

And slide 9:

[Page 09]
Page 09

Groundwater Sampling

  • DoD follows a comprehensive approach to identify installations where
    • DoD stored and/or used AFFF and suspect a release is impacting drinking water — As of August 2017, DoD identified 401 active and BRAC installations in the United States with at least one area where there is a known or suspected release of PFOS/PFOA
  • DoD is following the CERCLA process to address these suspected releases
    • First step is to identify the source(s) of a known or suspected release
    • Then identify if there is an exposure through drinking water
    • If there is exposure, DoD priority is to cut off drinking water exposure
    • Once exposure pathway is broken, the site is prioritized and will follow the CERCLA process to fully investigate the release and determine the appropriate cleanup actions based on risk
  • The DoD Components are conducting additional investigations, which include sampling groundwater

And look at slide 14 (in DoD’s boldface):

[Page 14]
Page 14

Conclusion

  • DoD’s priority is to address PFOS/PFOA to protect personnel living and working on our installations and the surrounding communities that we have impacted
  • Military Departments have made great strides to ensure safe drinking water for our installations
  • We are addressing DoD’s cleanup responsibility
  • Initiated removal of AFFF with PFOS from the supply chain

The report does kick the can down the road, saying it needs states and EPA to legislate and pass rules so DoD will know what to do. So that will take EPA at least a year, if it ever decides to do anything. At least Geogia did pass a bill to do some minimal regulation: nobody will be able to use PFAS in firefighting rehearsals without a contained facility.

But it turns out DoD can do something now. On page 49, let’s compare two Air Force Bases:

[Page 49]
Page 49

On-base Groundwater Monitoring Wells Off-base Groundwater Monitoring Wells
DoD
Component
Installation State/
Territory
Total Number
Sampled
Number that
Tested above
the EPA
LHAs1
Range of
Results above
EPA/LHAs (ppt)
Total Number
Sampled
Number that
Tested above
the EPA
LHAs1
Range of
Results above
EPA/LHAs (ppt)
Actions Taken as of August 31, 2017 2 Key Actions Planned for FY 2018 to Reduce PFOS/PFOA Below LHA
Air Force-Active Moody AFB Georgia 34 22 590–375,000 ppt 0 Completed the base-wide Preliminary Assessment and received regulatory concurrence on the findings. Initiated a base-wide Site Inspection for PFOS and PFOA. Continue following the CERCLA process through investigation, cleanup, and long-term monitoring. Perform mitigation activities when impacts to human health are determined.
Air Force-Active Peterson AFB Colorado 28 28 71–4,300,000 ppt 10 2 130–980 ppt
PFOS+PFOA
Summitted request for Expanded SI funds. Conducted mitigation efforts, as reported in Drinking Water Data Call Expanded SI Field work and continued mitigation on private and public drinking water wells

So Moody AFB says it will “Continue following the CERCLA process through investigation, cleanup, and long-term monitoring. Perform mitigation activities when impacts to human health are determined.” Yet, unlike Peterson AFB in Colorado, Moody AFB did not sample any off-base groundwater monitoring wells. Also unlike Peterson AFB, Moody AFB did not ask for “Expanded SI funds” nor do “Data Call Expanded SI Field work and continued mitigation on private and public drinking water wells”.

[Figure 26 Waste Water Treatment Plant (AFFF Area 8) PFBS, PFOA, and PFOS in Groundwater and Surface Water]
Figure 26 Waste Water Treatment Plant (AFFF Area 8) PFBS, PFOA, and PFOS in Groundwater and Surface Water

According to Moody AFB’s own report of 2016, PFAS contamination did go off the base, for example into Beatty Branch and Cat Creek, and underground. Maybe Moody AFB is just getting to those parts of its process. I look forward to Moody AFB being the community leader it always is.

Thanks to WWALS Science Committee Chair Tom Potter for noticing we made it onto this updated national map.

EWG has more about the map: EWG: PFAS Chemicals Must Be Regulated as a Class, Not One by One, Monica Amarelo, EWG, 6 May 2019.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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