Impact of PFAS Contamination at the Burlington Air National Guard Base
By Pat Elder
The former fire training area (red x) is 1,600 feet from the Winooski River. The blue arrows show the groundwater flow. Surface water also runs to the river.
This is the third article in a three-part series on the contamination caused by the use of per-and-poly fluoroalkyl substances (PFAS) at the Burlington, Vermont Air National Guard base. This work is made possible through the generous support from the Women’s International League for Peace and Freedom (WILFP-US Section), the WILPF Burlington Branch, and the Center for Health, Environment, and Justice - a project of the Peoples Action Institute.
The first article explored the history of the burn pit on base and the contamination it has caused to the groundwater and surface water in Burlington. Part two examined PFAS contamination in fish and the processes involved in the development of surface water quality standards. In Part 3, I’ll analyze the contamination of storm water flowing from the base and I’ll look at how the wastewater and the sludge produced at treatment plants in Burlington and across the state create a pathway for human exposure to these toxins. I’ll examine the state’s efforts to establish regulations for PFAS and I’ll report on what the Vermont Air National Guard has to say about the toxic mess it has created.
Contaminated storm water
Three aerial images tell the story of storm drains flooded with PFAS at the Burlington Air National G.
Contaminated water is flowing from the Burlington ANG Base through Outfall NG001- P. The red X shows the location of the storm sewer that pours PFAS-saturated groundwater into the Vermont countryside. The storm sewer flows with contaminated water even when it hasn’t rained.
PFAS chemicals continue to pour out of the giant toxic subterranean sponge lurking under the Burlington base and it is likely to continue for hundreds of years unless the military stops it, and that’s not likely, considering the DOD’s abysmal record in these matters.
The storm sewer on private property just east of National Guard Rd. contained 2,170 ppt of the combined sum of PFHpA, PFHxS, PFNA, PFOA, and PFOS. We don’t know the level of additional PFAS chemicals likely in the mix. The poisonous water finds its way into the groundwater that may find its way into someone’s
drinking well. It also drains into streams and creeks that feed into the rivers. It’s important because these chemicals are amazingly bioaccumulative in fish and it only takes 1 or 2 parts per trillion of PFAS in the water to start the bio accumulative process in fish.
Stormwater samples were collected from the sewer pipe on National Guard
Ave within 12 hours of a storm event on base. The sewer pipe was continuously discharging water, even when no precipitation event had recently occurred. It
is likely that water discharging from this sewer pipe consists of contaminated groundwater that is infiltrating into the stormwater management system. This sort of contamination is occurring at military installations across the country. The poisons find their way into our water and our food. Almost all public attention has been focused on filtering drinking water when most of the PFAS in our bodies comes from the food we eat, especially the seafood.
Contaminated Wastewater
Wastewater is making us sick.
For many, the distinction between storm drain sewers and sanitary sewers is not well understood. A sanitary sewer is a system of underground pipes that carries sewage from bathrooms, sinks, kitchens, and other plumbing components to the wastewater treatment plant. The storm sewer is a system designed to carry rainfall runoff and other drainage, but not sewage. Both systems carry PFAS.
Until a few years ago, shallow groundwater intercepted by the groundwater collection trench on the Burlington ANG base was pumped to the base sewer lift station and ultimately to the Airport Parkway Wastewater Treatment Plant (WWTP) in South Burlington, Vermont (CH2MHill, October 2015).
A water sample collected by the EPA from the groundwater collection trench sump on May 18, 2016, showed PFOS and PFOA concentrations of 38,000 parts per trillion and 9,300 parts per trillion respectively (H&S/Nobis Environmental JV, LLC, June 2016).
Since August 2017, groundwater from the collection trench has been treated for PFAS by routing it through two granular activated carbon (GAC) vessels. Treated groundwater is pumped to infiltration trenches constructed at the site and is no longer pumped to the WWTP (CH2MHill, June 2017). We don’t know how effective these particular filter systems are and we don’t know what they’re doing with the used carbon filters that are presumably caked with the toxins. Are they being sent to the Coventry landfill?
Water filtration system for PFAS in Hudson, MA (Photo by Eric Ryder)
Sewage is pumped from the base’s central lift station to the City of South Burlington’s Airport Parkway Wastewater Treatment Facility. The Agency of Natural Resources (ANR) says it is determined to establish programs to control the PFAS sources entering wastewater treatment plants, although this is a challenge in Burlington. How is Vermont planning to control this source of PFAS contamination when the polluter is the United States of America?
The Vermont Department of Environmental Conservation released data in early 2020 on the level of PFAS in sewer sludge at facilities across the state. The South Burlington Airport Wastewater Treatment Facility had the following totals:
We don’t know how many of these chemicals originated at the Burlington ANG base. Many of these PFAS chemicals have not been studied. The sewage from the base should be continually tested for PFAS, and the Air National Guard should face heavy fines until it removes the toxins.
When you flush the toilet, the materials go through a process called dewatering which decreases septic liquid volume as much as 90 percent. Sludge is put through large centrifuges that work something like a washing machine’s spin cycle. Neither the solids nor the liquids are treated for PFAS before they are released into the environment.
Peter Walke, the Commissioner of the Vermont Department. of Environmental Conservation, joined the five other directors of environmental agencies in New England in a historic letter to incoming EPA chief Michael Regan in early February, 2021. They wrote, “PFAS entering [wastewater treatment] facilities from commercial, industrial, waste, and residential sources is not removed from the effluent.” This is a remarkable statement that should have been met with headlines across the region and nationally, but few understand the enormity of this ongoing environmental disaster.
The environmental chiefs pleaded with the EPA to step up to develop PFAS surface water standards and fish consumption guidance values. They made it clear that wastewater treatment plants are the source of much of the PFAS contamination crisis.
The EPA hasn’t been much help. The EPA’s interim guidance on PFAS tells us they’re not sure how to manage PFAS. They’re uncertain about how to handle wastewater saturated with PFAS. They don’t know very much about incineration and how bad it likely is. They don’t know the extent of PFAS-tainted leachate that seeps from landfills, and the EPA is not sure about the contamination caused by spreading PFAS-contaminated sewer sludge on farm fields. They just don’t know what to do, so they’ve decided not to regulate the stuff in any meaningful way while agreeing to study it more. It’s been their playbook since way before the Trump disaster. We’ll see if the Biden administration gets tougher.
To its credit, Vermont has new rules that require testing soil, groundwater and the sludge that is slathered on farm fields. In 2019 the Vermont DEC sampled the influent and effluent of wastewater treatment facilities. Nearly 400 samples were tested for 24 PFAS chemicals. Detectable PFAS was found in influent, effluent and solid byproducts collected at all facilities, including at WWTFs that do not accept industrial wastewater, indicating that residential materials can also contribute PFAS to wastewater treatment facilities.
Eamon Twohig of the residuals management program within the ANR captured the essence of the PFAS problem when he explained to the Vermont Digger, “We can’t snap our fingers and make it all go away. If we continue to cut down on the management options, there won’t be places to take it,” Twohig said. “We’ve got to think of these systems holistically because if we decide we’re going to ban land application, what are we going to do with this material? We don’t have an incinerator in Vermont. The landfill doesn’t want it; they can’t take it all. So it’s a challenge.”
Protecting human health must inform all decisions regarding PFAS in Vermont’s environment. Right away, the state must ban the importation of septic sludge from other states. What is Vermont thinking? We can no longer allow septic sludge to be spread on farm fields. We cannot allow PFAS to be buried in the landfill, and we cannot incinerate the stuff. We can’t do these things because they’re making people sick, and they’re threatening the unborn for generations to come.
Twohig is right. We snap our fingers and the PFAS is still with us.
We must explore radical solutions. Obviously, eliminating the production and discharge of all PFAS is imperative. No consumer items that contain PFAS should be allowed to be bought, sold, or possessed within the state. Call it draconian. An entirely new state department may have to be developed and adequately funded. The community must be required to pay substantially higher rates for sewer usage to fund programs to deal with the issue.
We must force manufacturers to develop alternatives to PFAS-based products. For instance, we already have suitable environmentally friendly, fluorine-free firefighting foams. Chrome plating, wire coating, and a host of manufacturing processes must be prohibited from using materials containing PFAS. If the federal government isn’t stepping up, Vermont must soften the financial impact of industries hurt the most.
Vermont must take an inventory of everything discarded that contains PFAS and separate it from the waste stream. This is no small undertaking. Items like couches and carpets can no longer be allowed to be sent to the landfill. Consider Table 3 showing the PFAS concentrations found in 3 Mattresses, 2 Box Springs, 2 Couches, and 1 Chair that were discarded at the New England Waste Services of Vermont, Inc. (NEWSVT) Landfill in Coventry, Vermont.
Consumer items like Teflon pans and thermocouple wire in electronics containing these chemicals ought to be removed from retail shelves and from our homes. Cosmetics are loaded with the stuff and are typically disposed of through the drain. They’re all loaded with PFAS. New systems must be developed to safely store these contaminated products and to extract PFAS from them before they are buried in the earth - unless we can devise new ways to reuse the materials. It is a massive undertaking of immense cost. Landfill leachate, sewer sludge, and wastewater must be filtered again and again to protect the earth from this brutal contamination. And there must be an educational component to teach people that they’ve got to consume less and throw away less. Tax policies must be engineered to bring about the necessary changes in human behavior. Waste Not. Heal the earth.
This is not demagoguery. There’s no hyperbole. We’re in trouble with these chemicals and we must deal with them - along with many others.
A crew chief marshals an F-35 on the flight line.
More Contamination from VTANG
The Pentagon has poisoned millions of acres and left Americans to guess at the threat to their health. Its oversight of thousands of toxic sites has been marked by defiance and delay. ProPublica has done a remarkable job of taking DOD data on contamination at military bases and turning it into a user-friendly format through its site, Bombs in Our Backyard.
PFAS are not the only toxic chemicals leaching out of the Vermont Air National Guard base. According to the DOD, groundwater samples collected within the burn pit site of the Vermont Air National Guard base, contained these chemicals in the following concentrations:
1,1-Dichloroethane 220.0 ug/L 1,1,1-Trichloroethane 310.0 ug/L 1,2-Dichloroethylene (Total) 3,100.0 ug/L 1,2-Dichlorobenzene 140.0 ug/L 1,2,4-Trimethylbenzene 270.0 ug/L 1,3-Dimethylbenzene 520.0 ug/L
Acetone 950.0 ug/L Arsenic 57.2 ug/L
Barium 59.3 ug/L Benzene 320.0 ug/L Ethyl benzene 290.0 ug/L Iron 11,500.0 ug/L
Lead 13.7 ug/L
Manganese and compounds 4390 ug/L Naphthalene 96.0 ug/L
o-Xylene 740.0 ug/L
Toluene 840.0 ug/L
Trichloroethylene (TCE) 3.0 ug/L
Vinyl Chloride 110.0 ug/L
Ug/L means micrograms per liter, which is the same as parts per billion. To compare these levels to PFAS, which is measured in parts per trillion, you’ll have to multiply each value by 1,000.
Go to Pub Chem and search for these toxins. These chemicals are monitored because they threaten our health. Napthalene may be expected to contaminate fish, so do several of the others. Trichloroethylene causes kidney cancer. Toluene affects the brain and the nervous system. These chemicals are in our soil and our waters, and our bodies.
Vermont environmentalist James Ehlers sounded a warning on septic sludge that is laden with various chemical and biological pollutants - along with PFAS. Ehlers told the Vermont Digger, “The whole point of wastewater treatment is to keep these things out of the water. But we’re putting it right back on the soil, where it either, through the groundwater or surface runoff, winds right back up in the water.” The state should listen to Mr. Ehlers.
Vermont’s Solid Waste Management Plan highlights the beneficial use and disposal of septage and sludge. As of April 2017, approximately 947 acres of agricultural land is certified and used for the land application of biosolids and septage. The state adheres to all applicable federal regulations set by the EPA’s Part 503 extraordinarily weak rule that lays out requirements for the management of sewer sludge.
All biosolids applied to the land must meet the ceiling concentrations for pollutants, shown here.
The EPA hasn’t updated this list since 1994. There are hundreds of chemicals in wastewater and sludge that aren’t regulated. We may be eating fruits, grains, and vegetables fertilized with sewage sludge containing heavy metals, dangerous viruses, dioxins, PCBs, pesticides and hundreds of other toxic chemicals.
Many of the pathogens cause diseases that sicken, cripple and kill humans including salmonella, shigella, campylobacter, e-coli, enteroviruses (which cause paralysis, meningitis, fever, respiratory illness, diarrhea, encephalitis), giardia, cryptosporidium, roundworm, hookworm, and tapeworm. Sludge pathogens can move through many environmental pathways --direct contact with sludge, evaporation and inhalation, contaminated groundwater, contamination of rodents burrowing in sludge, and uptake through the roots of crops. Lovely.
This is not surprising. Throughout the course of human civilization, mankind has been threatened by exposure to its own excrement. Today, we’ve compounded the problem by flushing a Pandora’s box of pathogens down the civic drain.
Getting a handle on the health threat from the toxins inhabiting sewage sludge is beyond the capabilities of current science. We can no longer collectively shrug our shoulders while claiming there’s little more we can do.
Although environmental and health officials in states across the country focus primarily on treating drinking water with PFAS, the food we consume is often loaded with the toxins. For instance, bread purchased from a supermarket in Cleveland made from wheat grown in contaminated soils contained 14,700 ppt of PFOA. Apples grown in contaminated soil had 2,350 ppt in Decatur, Alabama and ground beef had 1,090 ppt of PFOA in Port St. Lucie, Florida. The cows are believed to have grazed on contaminated fields. The fish are much more contaminated.
What’s in your food, Vermont? What’s in your blood and how did it get there?
What the Air National Guard is saying
The Air Force says the extraordinarily dangerous 8-carbon chain AFFF on the Burlington base “has been removed, properly disposed of, and replaced with short-chain six carbon based (C6) AFFF.” The Air Force claims the C6 PFAS are currently considered lower in toxicity and have significantly reduced bioaccumulation potential compared to 8 carbon chain (C8) PFAS. (See Sec. 1.1)
These dangerous statements are used by the air force to explain away the dangers of PFAS to communities around the world. The old C8 PFAS chemicals (PFOS & PFOA) are pouring out of the base daily. Many of the new C6 and C4 toxins may be more of a threat than their precursors because of their ability to travel more quickly in water and their toxicity relating to specific diseases and fetal abnormalities. It’s all bad.
The Vermont ANG says the toxic foam “has been properly disposed of.” How, exactly are they accomplishing this currently impossible task? The air force says burying the materials in landfills and burning are safe ways to go, but we know this is not the case. They make up their own rules, like a sovereign, illegal nation from within.
The Burlington base adhered to a national script provided by the Pentagon for damage control when PFAS results were published in March, 2020. “This has been a very thorough process to determine potential impacts from the use of PFAS on our base and I am encouraged that we can now move toward the next phase of this critically important work.” said Col. Adam Rice, 158th Fighter Wing Vice Commander. He continued, “We take this issue very seriously and want to reassure our employees and the community that drinking water has not been impacted and there is no threat to human health."
Because of the way the DOD spins the contamination, the press creates headlines stating, “PFAS found in groundwater at Burlington Air Force base, drinking water safe.” We know there’s more to the story.
The military command also stresses that the firefighting foams in question are no longer used. They use the same tactic nationwide and the press dutifully responds. For instance, the lead paragraph of the Vermont Digger’s story on the DOD’s PFAS report is misleading. “The findings come in a draft report released last week by the Guard on the extent of the contamination by the so-called “forever chemicals” — largely from now-banned firefighting foam.” PFOS and PFOA are banned, but they’ve been substituted with other dangerous PFAS chemicals.
Vermont is testing PFAS in waste streams and has promised surface water standards by early 2024. Many states have done nothing at all. Even so, there’s much more work to be done, remediating the damage to the environment and protecting human health from the seafood and agricultural produce that is contaminated with PFAS. The state has also filed lawsuits against companies for the manufacturing and distribution of PFAS chemicals and PFAS-containing products in Vermont.
Vermont, however, has been slow to hold the military accountable, while the press has generally preferred to look the other way regarding the harm done to Vermont’s public health and the environment by military activities. Several states, most recently, New Jersey, have sued the DOD for contaminating groundwater. Vermont must light a fire under the DOD to force them to clean up the mess they’ve made and pay the state for the damage they’ve caused.