Former Marine Corps Air Station Tustin contaminates the Newport Beach region with PFAS
Fish and people are contaminated
Pat Elder
May 16, 2023 Online here. 2,400 words and 15 images
An abandoned blimp hangar at the Tustin Marine Corps Air Station in Tustin, California
An obscure report by the Navy in 2022 on the Former Marine Corps Air Station Tustin describes high levels of PFAS escaping the base 23 years after its closure in 1999.
The Final Preliminary Assessment/Site Inspection Report on Per- and Polyfluoroalkyl Substances, Former Marine Corps Air Station Tustin, describes the migration of the carcinogens and various pathways to human exposure. The report provides a kind of PFAS roadmap to human ingestion.
Frightening concentrations of PFAS in groundwater and surface water are draining from the area of the old base and creating a public health crisis that few are willing to acknowledge. PFAS levels were reported at 836,600 parts for trillion (ppt) for three compounds tested in the groundwater: PFOA (743,000), PFOS (26,900) ppt, and PFBS (66,700). The EPA says it will set enforceable drinking water limits at 4 ppt for PFOS and PFOA by the end of this year. Commercial labs can test for 55 compounds so there is a lot the U.S. Navy isn’t telling us.
Surface water that drains from the old base into San Diego Creek was reported at 199 ppt for PFOS alone. Although the number seems small compared to the groundwater levels, this is concerning because the compound bioaccumulates in living things like invertebrates that fish consume. Bioaccumulation rates for PFOS in aquatic life may be thousands of times greater than the levels in the water.
Groundwater and the regional aquifer flow southwesterly toward the Pacific Ocean.
The Santa Ana - Santa Fe Channel and Barranca Channel carry surface water flow southeast along the edges of the base’s old boundary. The Santa Ana-Santa Fe Channel discharges into Peters Canyon Channel which merges with San Diego Creek about a third of a mile southwest of the station. Barranca Channel also discharges into San Diego Creek approximately 1 mile southwest of the old base.
San Diego Creek empties into upper Newport Bay approximately 4 miles southwest of the Station.
Fishing is allowed at the Jamboree Bridge, where San Diego Creek opens to the sea. This is a little more than four miles from massive releases of PFAS at the shuttered Tustin base.
San Diego Creek, shown here passing by Marine Corps Air Station Tustin, is the chemical toilet for the base and industrial users.
Where does the PFAS come from on base? Let’s count the ways
Think of the soil under Tustin as a kind of massive subterranean sponge that is rinsed by the occasional downpours. PFAS contamination this severe is never going away, and it cannot be cleaned up, although we can take additional steps to protect human health.
The Navy’s PFAS report examines multiple activities on base that introduced the chemicals into the environment, beginning in the 1970’s. PFAS were released to perennial or ephemeral surface water features, drainage ditches/channels, or adjacent canyons. All of the PFAS used by the Marines are still haunting us.
Fire training exercises at burn pits - Craters were filled with jet fuel, oils, solvents, lacquers, primers, and various chemicals. An estimated 250,000 to 350,000 gallons of liquid wastes were used for firefighting training at the burn pits. We don’t know how many gallons of AFFF they used, although the fuel alone left a toxic legacy.
This drain in a Navy hangar connects to an oil water separator before heading to the sanitary sewer - Oil/water separators were located in buildings for flight line operations. They are designed to target oil, based on the gravity difference between oil and water, allowing for heavier solids (sludge) to settle to the bottom while oil rises to the top, leaving additional wastewater in the middle layer. Sludge can then be scraped away, oil can be skimmed off the top and wastewater can move along for further treatment. None of these processes remove PFAS, however.
Wastewater treatment plants, evaporation ponds, sludge beds, and land application – The wastewater treatment plant was located at the intersection of Armstrong Avenue and Barranca Parkway. The plant likely received wastewater from the oil/water separators or directly from hangar drain systems that may have discharged into the sanitary system. The property where the Wastewater Treatment Plant was located was transferred to the City of Tustin in 2002.
Leachate draining from a landfill - The landfill, known as the Moffett Trench, is on either side of and beneath Jamboree Road, and is adjacent to Peters Canyon Channel. With groundwater and surface water at this location merging into Peters Canyon Channel it can be expected that the leachate, high in PFAS, is continuing to make its way into the channel.
Vapor suppression systems associated with metal plating operations - PFAS was used at MCAS Tustin as a chemical fume suppressant in chrome plating. Military machine parts are often plated with chrome for greater durability. Fume suppressants containing PFAS are commonly used by electroplating facilities for controlling air emissions and reducing worker exposure to hexavalent chromium, a known human carcinogen and inhalation hazard.
The EPA required chrome platers to stop using PFOS-containing fume suppressants in chrome plating tanks in September 2015 due to concerns about human health and environmental impacts. It’s not known if the Navy continues to use PFOS or has substituted this compound with 6:2 FTS or another PFAS-based suppressant.
Wash racks for engine cleaning - Nothing cleans engine parts like PFAS. The wash rack was used for cleaning aircraft and automobile parts. It drained through a 12-inch-diameter pipe below the grill. The pipe was connected to the storm drain and the wastewater was discharged directly into Peters Canyon Channel
Materials known to contain PFAS were also believed to have been released unintentionally, like the accidental discharges from fire suppression systems due to equipment failures or spills. The Navy didn’t address accidents in its report. They often leave these details out, while the Air force Reports them. A single accidental discharge from an overhead suppression system can release tens of thousands of gallons of PFAS foams while a teaspoon of the material may be enough to poison a city’s drinking water reservoir.
Air Emissions - Although the report on PFAS at the Tustin facility fails to address PFAS emissions to the air, shuttered military bases like Tustin continue to contaminate the air in the surrounding communities.
A 2015 CDC public health notice describes how certain PFAS may be carried through soil by groundwater and surface water. (Keep in mind the giant subterranean sponge.) The carcinogens coat the banks of canals and creeks. The compounds dry in the sun when the waters recede and become airborne when lifted by the wind. Long-range atmospheric transport of these contaminants is important to consider.
In most communities, food, especially fish, is the number pathway for the transport of these chemicals into our bodies. Next is the air. The drinking water may be a distant third, followed by a host of consumer goods, like cosmetics, frying pans, food packaging, etc.
The Centers for Disease Control Prevention and the Agency for Toxic Substances and Disease Registry (CDC/ATSDR) have conducted an exposure assessment in the community surrounding the Shepherd Field Air National Guard Base, West Virginia. PFHxS and PFOS had the highest concentrations pouring out of groundwater and surface water on the base. The same compounds also topped the list for concentrations in blood serum among the residents and in dust in the surrounding community. Dust in a home near the base had a concentration of 16.4 million ppt for PFHxS and 13.9 million ppt for PFOS. The Navy failed to report on PFHxS levels escaping Tustin.
This air and mind-blowing fact ought to be marshalling public health officials to warn residents near military bases to take precautions to protect themselves from the airborne pathogens. Air conditioning vents ought to be replaced regularly while changing the vacuum cleaner bag ought to be considered an occupational hazard. This finding should revolutionize the way we clean our homes.
Wastewater Treatment Plants - Taking a grab sample from a wastewater treatment plant. Photo - Los Angeles County Sanitation District.
Wastewater treatment plants can serve as a kind of Grand Central Station for PFAS. The Michelson Wastewater Recycling Facility in Irvine is less than two miles from the closed Tustin Marine Corps base. In July, 2021 the California Water Board reported that the plant was discharging a total of 150.8 ppt of PFAS. We don’t know exactly where these contaminants originated unless they tell us.
PFAS effluent results from the Michelson Wastewater Recycling Facility
Irvine, CA 7/22/2021 (in parts per trillion)
Final Effluent Grab
PFBS 3.5
PFBA 6.5
PFDA 2.9
PFHpA 2.7
PFHxA 41
PFOS 2.2
PFOA 18
PFPeA 74*
Total PFAS 150.8 - California Water Board
* PFPeA is known to collect in vegetables from irrigated water containing the compound.
The Michelson Water Recycling Plant (MWRP) can treat up to 28 million gallons of sewage daily to produce 28 million gallons of tertiary-treated recycled water. The recycled water is used principally for outdoor irrigation as well as industrial and commercial uses. The state says the resulting recycled water meets all state standards for use on freshly edible food crops.
What about the PFAS? If the recycled water contains PFAS it shouldn’t be used for agricultural purposes.
Up to 8 million gallons of recycled water produced at Michelson in a day can be sent to the Orange County Water District. If they cannot take it or they don’t need the recycled water, up to 3 million gallons a day can be disposed through their ocean outfall.
What’s in the fish there? If the recycled water contains PFAS it shouldn’t be dumped into the ocean.
MWRP may be able to achieve targeted reductions through industrial pretreatment programs, but even that will not address the concentrations arriving from countless households.
The California state water board says that over half of the industrial sources in wastewater are potential sources of PFAS, including automatic vehicle washing, fabricated metal products, industrial laundries, electronic manufacturing, airports, landfills, military facilities, fire training centers, paper manufacturing, and textile manufacturers. The highest concentrations of PFAS in wastewater are tied to aqueous firefighting foam (AFFF) and leachate from airports and landfills.
The fish - The Navy’s report on Tustin says “potential ecological receptors” (vulnerable earthly life forms) include terrestrial plants, aquatic plants, invertebrates, birds, reptiles, and mammals. Mammals! That would include us, although the Navy’s report doesn’t make it clear, and they never mention the fish.
PFOS can travel 20 miles in water while many fish depend on aquatic invertebrates for food. (shown here.) Studies show these creepy crawlers are loaded with various compounds of PFAS.
Many Fish depend on aquatic invertebrates like these for food. Some fish eat bloodworms. Some eat krill. Others enjoy the squid, or mosquito larvae. It’s all good, except for the PFAS and a host of other chemicals.
San Diego Creek and Newport Bay are likely to be loaded with contaminants, including PFAS. What’s in the fish people catch at the Jamboree Bridge in the Upper Newport Bay State Marine Conservation Area?
The ocean fish at Newport Beach are contaminated. The state reasons it’s a matter of the degree of contamination that matters. Many fish contain high levels of Polychlorinated biphenyls (PCBs) and Mercury.
PCB’s are highly carcinogenic chemical compounds, formerly used in industrial and consumer products, whose production was banned in the United States by the Toxic Substances Control Act in 1979. Mercury is a killer.
The state is saying it’s OK to consume the poisons, just not too much of them. See the graphic here on eating fish from the California Coast.
California - “Eat the good fish – Eating fish that are low in chemicals may provide health benefits to children and adults.”
It’s also true that eating fish that are high in chemicals may provide health benefits to children and adults. It may also sicken and kill them.
PFOS in fish in the San Francisco Bay, 2018. San Francisco Estuary Institute, Richmond CA. (in parts per trillion) See the California Guide to Eating fish from the San Francisco Bay
California does not regulate PFAS in fish. It’s OK to catch and consume fish with tens of thousands of parts per trillion of PFOS. Some of the fish advisories for mercury, PCB’s, and DDT may disallow the consumption of fish also high in PFAS.
Meanwhile, the state has set a response level for PFOS at 40 ppt. in drinking water. The state advises water systems to take a water source out of service or provide treatment above this level. The EPA promises to establish a nationwide maximum contaminant level for PFOS at 4 parts per trillion in drinking water by the end of the year.
In San Francisco Bay, Staghorn Sculpin are bottom-dwelling fish, and as such, they have a higher exposure to PFOS due to PFOS concentrations in the sediment. River bottoms are caked with PFAS and it’s not going away and we can’t clean it up.
Asked if there is a difference between eating or drinking PFAS contamination, Linda Birnbaum, former director of the National Institute for Environmental Health Sciences, said, “No. Both are routes of ingestion. Whether you eat it or drink it, PFAS go to the same places in the body and do the same thing. We need appropriate fish advisories and regulation of what’s in our food.”
See California’s Office of Environmental Health Hazard Assessment (OEHHA) advice regarding the preparation and consumption of fish for women who are pregnant or may become pregnant.
Following the state’s advice may lessen the carcinogenic punch. The state appears to be more concerned with treating cancer, a profitable enterprise for many, than it is with regulating the consumption of fish that are known to cause it.
Severely limiting the consumption of fish in California will likely cost billions in lost revenue to several economic sectors. It would be a jolt to California’s economy.
The bottom line.
Financial support from the Downs Law Group makes this work possible.
The firm is working to provide legal representation to individuals with a high likelihood of exposure to PFAS and other contaminants.
Interested in joining a multi-base class action law suit pertaining to illnesses stemming from various kinds of environmental contamination?
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