MADISON, Wis. — The Wisconsin Department of Military Affairs launched a new website today devoted to informing the public about per- and polyfluoroalkyl substances (PFAS) mitigation efforts at its facilities.
The new website provides timelines and updates on the current status of PFAS mitigation efforts at several Wisconsin National Guard facilities.
The Wisconsin National Guard continues to work closely with partners at the local, state, and federal levels to address PFAS concerns at installations where the military historically used Aqueous Film Forming Foam (AFFF). AFFF is the most efficient means of extinguishing petroleum fires, and is widely used across the firefighting industry, to include all commercial airports and petroleum production and storage facilities to protect people and property, and it is mandated for use by the Federal Aviation Administration. The Wisconsin National Guard adheres to this FAA standard and has always followed required testing procedures.
The military used AFFF, which contained perfluorooctanesulfonic acid (PFOS) and perfluorooctanic acid (PFOA), forms of PFAS, from 1970-2015. In 2016, the Environmental Protection Agency established a lifetime health advisory level for PFOA and PFOS in drinking water, and it is now classified as an emerging contaminant.
The Department of Defense and U.S. Air Force modified their training procedures in 2015 to reduce contamination risks and switched to Phos-Chek 3% AFFF, an environmentally responsible formula. The new products are considered less toxic, are not considered bio accumulative and are PFOS-free and contain only trace amounts of PFOA.
The entire Air Force implemented this switch in 2016, and there are now no buildings in the Wisconsin National Guard that use legacy AFFF. But even this more environmentally responsible formula is only discharged by the trucks in the event of a real fire.
To ensure no AFFF is discharged during required testing procedures, all Wisconsin National Guard facilities now use a closed system – known as an Ecological Test Cart – that is fully contained and keeps any foam from hitting the ground, and in addition, bases conduct their testing on a site that allows for complete collection in the event of an inadvertent AFFF discharge.
At Truax Field, for example, the 115th Fighter Wing’s fire department provides all of the emergency fire services for Dane County Regional Airport and is bound by federal regulations.
The fire department uses the Ecological Test Cart distributed by the Air Force Civil Engineering Center, to adhere to its regulatory requirement to test its firefighting systems. The 115th received instructions from the U.S. Air Force on retrofitting its firefighting vehicles in September 2017 and completed their retrofit later that month, becoming one of the first 8 fire departments out of 63 across the Air National Guard to complete the retro-fit and begin using the new testing procedure. The new system bypasses the tank containing AFFF and, instead, flows water through the extinguishing system and the cart, gathering data readings and discharging water from the vehicle's turret instead of foam.
The Wisconsin National Guard has and will continue to follow all federal laws related to PFAS, and is federally mandated to follow the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) process to address PFAS concerns at its facilities.
CERCLA is an established multi-step federal process. Truax Field and Volk Field Combat Readiness Training Center in Camp Douglas, Wisconsin received authorization and funding from National Guard Bureau to begin step three of the CERCLA process - “Remedial Investigation” this fall. This step involves an evaluation of the nature and extent of contamination at a site, and evaluates potential threats to human health and the environment. The results of the risk assessment determine what, if anything, needs to be cleaned up. If the risk assessment identifies an unacceptable risk to human health, safety, or the environment, a Feasibility Study is conducted. The exact timeline for when the remedial investigation will begin is yet to be determined.
The National Guard Bureau also simultaneously announced this fall that both Truax Field and Volk Field received funding and authorization for an Off Base Drinking Water Study to assess drinking water sources within the vicinity of each installation. As part of that process, contractors working on behalf of the U.S. Army Corps of Engineers will survey and conduct public testing at public drinking water sources in the vicinity of the installation. That effort, in partnership with other named responsible parties – including the City of Madison and Dane County Regional Airport, would immediately result in the federal government addressing the issue at any residence with drinking water that exceeded PFAS readings of 70 parts per trillion or more.
More information about the CERCLA process is available here: https://www.epa.gov/superfund/superfund-cleanup-process.
The CERCLA process is driven by federal law and associated funding is prioritized based on site investigations nationwide. The Wisconsin National Guard will continue to adhere to the CERCLA process and will remain actively engaged with each step and with partners at the local and state level to keep the process moving forward.
The Wisconsin National Guard previously completed steps one and two of the CERCLA process, including the initial site investigation and preliminary assessment.
The new website is available at: https://dma.wi.gov/DMA/pfas