More lessons for Brunswick
By Pat Elder
September 9, 2024
Ansulite 3% AFFF and Chemguard 3% AFFF are the two types of aqueous film-forming foam (AFFF) concentrate that were released from Hangar 4 at the Brunswick Executive Airport on August 19, 2024. 1,450 gallons of the concentrate mixed with 50,000 gallons of water to create the foam mixture.
The Maine Department of Environmental Protection (DEP) published the results of samples taken of PFAS concentrate on Monday, August 19, Brunswick’s day of reckoning. They explained these initial samples were taken “to provide a baseline for comparison to best inform site response progress.”
We are grateful for the release of this invaluable data.
It’s rare we can peak into Pandora’s box. The industry keeps these chemicals and their composition a secret. They claim these ingredients are propietary information. It’s understandable - though not defensible - because many of these dangerous toxins are regulalry found in water, food, air, and human blood. Connecting these dots is creating a firestorm of indignation and litigation.
We’ve never known exactly what was in the concentrate, aside from Jon Mitchell’s reporting from Japan. Mitchell reported that U.S. Air Force testing of fire suppression systems in 2016 showed the concentrate contained PFOS at 9.5 billion parts per trillion, (ppt) with PFOA reaching 99 million ppt. These are the highest concentrations ever reported. Brunswick is second. (in ppt.)
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We’ll examine the results below. (in ppt.)
The crime is inherent in allowing the chemicals to be manufactured and marketed in the first place.
Parts per million, billion or trillion?
Rather than reporting the concentrations in parts per trillion as is customary worldwide, the Maine Department of Environmental Protection described the levels in parts per million. For instance, the Maine DEP reported, “The sample from the inlet of the surface water pond showed PFOS at 1.04 ppm, and the sample from the outlet of the surface water pond showed PFOS at 0.000701 ppm.”
Saying the sample from the outlet of the pond showed PFOS at .000701 parts per million doesn’t sound too bad.
.000701 parts per million is the same as
.701 parts per billion, which is the same as
701 parts per trillion.
The EPA says PFOS can bio accumulate in fish up to 4,000 times. the levels in the water. If the water contains 701 ppt of PFOS we may expect to see fish containing hundreds of thousands or even millions of parts per trillion of PFOS in their filet. The other compounds may also bioaccumulate in the unregulated fish. Often, the concentrations of the other compounds exceeds that of PFOS in seafood.
Meanwhile, the U.S. EPA is enforcing a limit of 4 parts per trillion for both PFOS and PFOA in drinking water. They are also regulating PFNA, PFHxS, and HFPO-DA (GenX Chemicals), at 10 parts per trillion. These chemicals are incredibly powerful and they are killing us.
The Maine DEP knows the military has poisoned the fish. Why haven’t they acted to safeguard human health? Could it be the 800-pound gorilla in the room? Like the Navy, the Air Force also wants to keep it quiet.
Ten years ago the Maine Department of Environmental Protection reported catching a Brook Trout near Loring Air Force Base with 1,080,000 parts per trillion of PFOS in its fillet.
Who knew?
Who cares? Apparently, nobody that matters.
Women who are pregnant or may become pregnant should not eat this fish. The carcinogens cut through the placenta and all babies are impacted.
Let’s look at the results provided by Alpha Analytical from Brunswick. “Concentrate” is the PFAS from the manufacturer. “Concentrate + Water” is the foam.
Results are in parts per trillion.
PFOS was reported at 3.78 billion parts per trillion. Foam levels are about 2% the strength of the concentrate. PFOS is 77.24% of the total concentrate and 74.33% of the foam.
PFOS is a ghastly chemical the DOD has held onto despite production being phased out 20 years ago.
PFOS is with us forever. It bioaccumulates in fish and it is making us sick.
History of PFAS at Brunswick
It’s important to know the history of the Brunswick Naval Air Station and its use of aqueous film-forming foam, (AFFF). The Navy has been poisoning this town for two generations.
Segments of the following report are taken directly from the PFAS Investigation Summary Report from the Former NAS Brunswick, Maine dated September, 2020. The massive report prepared by Resolution Consultants spans 11,334 pages and may be found here.
The use of aqueous film-forming foam (AFFF) at Brunswick NAS
The former base was active from 1951 to 2011. At Brunswick, the use of AFFF was phased in sometime in the late 1970s.
The Navy received a patent for AFFF in 1966 and 3M began manufacturing it for the military in the mid-1960s. 3M had evidence in the 1970’s of the compounds’ effects on the immune system. At the same time, studies conducted by the Department of Defense showed that AFFF was toxic.
They knew they were poisoning us.
Accidental releases from the AFFF fire suppression systems frequently occurred at Brunswick and just about everywhere else the systems were installed.
According to the former deputy fire chief at Brunswick, approximately two to three accidental releases from each building’s AFFF fire suppression system occurred.
AFFF fire suppression systems were located at the following buildings:
• Building 81
• Building 653
• Building 555
• Hangar 4
• Hangar 5
• Hangar 6
The fire suppression systems in Building 81 and Building 653 were removed prior to the lease of the property but the long-lasting damage had been done.
Causes of the accidental releases from the fire suppression systems were triggered by various methods, such as a lightning strike (Building 653), motion of a computer screen saver (Hangar 4), and inadvertently leaving the AFFF valve open during fire suppression system testing (Hangar 5).
Historically, only one real fire occurred at the former NAS Brunswick base that was doused with AFFF. The fire occurred on April 28, 1998 when the cockpit of an airplane on the tarmac caught fire. 110 gallons of AFFF diluted in 3,000 gallons of water was used and discharged to the stormwater drainage system. (3.66% mixture).
The fire could have easily been doused with an environmentally safe fluorine-free mixture.
A 2021 study from the University of Maryland surveyed the release of AFFF in civilian and military hangars. 242 of 245 incidents of foam discharges that occurred over a 17-year period occurred despite no fire being present. The discharges without a fire, i.e., “accidental discharges” comprised 98.8% of the total number.
All of this had been swirling around in Congress for many, many years where the chemical industry holds sway. There’s a lot of money in PFAS. This may explain why Federal Aviation Administration regulations have historically been tied to outdated military standards that restricted civilian airports from moving to PFAS-free foam.
But this has all changed.
In December 2022, Congress directed the FAA to develop a plan to ensure the orderly transition from the carcinogenic foams to fluorine-free foams. On January 6, 2023, the DoD published a new fluorine-free foam military specification.
There is no excuse for the most recent accident involving these catastrophic chemicals. The AFFF foams should have disappeared long ago. Maine’s recent laws limiting the use of PFAS-containing firefighting foam failed to prevent the massive spill. Military and corporate interests are more concerned with power and money than public health. Or maybe it’s just stupidity, and a lack of responsibility.
Routine use of defoamers
Due to the number of accidental discharges of AFFF to the sanitary sewer, treatment of the sanitary drain line was implemented by the Navy as a corrective measure of sorts prior to discharge from the former NAS Brunswick base. The foam disrupts the mechanical operation of treatment plants. It removes the oxygen, killing microorganisms used to treat sewage.
The Navy built a shack prior to 1997 where a defoaming chemical was injected into the sanitary sewer system prior to discharge to the Brunswick Sewer District.
According to the former deputy fire chief, when an accidental discharge of AFFF to the sanitary system occurred someone would be sent to the “neutralization shack” to turn on a pump to inject chemicals to “neutralize” the foaming action of the AFFF.
These de-foaming agents may have environmental consequences of their own. While the defoamer reduces the amount of foam, the agent dissolves the foam, but does not break down the chemical compounds that produce the foam. The Brunswick Sewer District would also add a defoaming agent to their system if foam levels increased as part of the WWTP processes occurred.
Other AFFF releases
The oil water separators in the drains in buildings on base captured AFFF, petroleum products, and excessive sludge. The navy says water and sludge were disposed of as nonhazardous, oil-contaminated liquid and solids.
Where were they sent and how were they “disposed” of? Theses toxins may be causing sickness, suffering, and death, so it’s important to know.
These chemicals don’t go away. They are synonymous with Brunswick forever. This is a pivotal moment for this community.
The release of AFFF at Brunswick was not limited to the overhead suppression systems. They also included:
· routine fire training activities.
· discharge of AFFF from tanks on fire vehicles.
· incidental releases or spills of AFFF.
The routine fire training activities likely released more PFAS than the overhead suppression systems. Before the most recent disaster, the highest levels of PFOA at 7,000 ppt were detected in groundwater near the former fire training area. The EPA has set a mandatory limit of 4 ppt of PFOA in drinking water and groundwater and many scientists feel this is not protective of health. They say we shouldn’t be consuming any amount of these carcinogens.
Fire training exercises involved placing waste liquids (e.g., fuels, oils, degreasing solvents, and whatever was available) onto the ground surface where they were ignited, and fire training activities occurred. They would see how long it took them to extinguish the flames with the AFFF. A stainless-steel aircraft mock-up was later added to enhance fire-fighting training activities.
It’s distressing that these chemicals have also been used - and continue to be used - in industrial applications and a host of products at the former base and by current tenants.
See the August, 2023 DOD publication on critical PFAS uses to gain a sense of what we’re likely dealing with here. The DOD was worried that individual states were banning the presence of PFAS in a host of consumer items and applications, so they published this document to carve out exceptions for its continued use.
Many of the same applications and products identified by the DOD are also used in various industries.
Testing surface water for PFAS
In October of 2021, I teamed up with Ed Friedman, Barbara West, and Martha Spiess of Friends of Merrymeeting Bay to test areas around the base for PFAS. We reported 1,661 ppt of total PFAS in the Pond 3 Outlet Stream. Of that total, 886.4 ppt was comprised of 6:2-fluorotelomersulfonic acid (6:2 FTS). This compound has replaced PFOS in chrome plating applications.
In 2012, after the base closed, the EPA finalized a rule to phase out the use of PFOS in chromium electroplating tanks. This suggests that current tenants at the Brunswick Executive Airport may be responsible for the contamination.
As a surfactant, 6:2 FTS lowers the surface tension (adhesion of materials) by creating a thin, foamy layer on the surface of the chrome bath for mist suppression. This mist-suppressant reduces the formation of deadly airborne chromium hexavalent aerosols during the plating process.
Michigan has derived health-based standards for 6:2 FTS in outdoor air. Maine has not. 6:2 FTS has also been detected in drinking water and fish. Short-term studies in rodents have shown that 6:2 FTS can cause damage to the kidneys and liver. More studies must be done. 6:2 FTS is persistent in the environment and can accumulate in people.
Hexavalent chromium and compounds have been detected at 26.0 parts per billion (ppb) in freshwater sediment at the former air base. The carcinogen may be inhaled. Ask Erin Brockovich about “hex chrome” and ask the Navy if they’ve cleaned it up or if the danger remains.
The public learned about contamination caused by the military from the disaster at Camp Lejeune. The Navy identified trichloroethylene, tetrachloroethylene, and vinyl chloride as the three deadliest chemicals in Camp Lejeune’s drinking water. The Navy reported these levels in drinking water:
Trichloroethylene 1,400 ppb
Tetrachloroethylene 215 ppb
Vinyl Chloride 22 ppb
The Navy has reported these levels of the same three chemicals in the groundwater at the former Brunswick NAS:
Trichloroethylene 7,100,000 ppb
Vinyl chloride 180,000 ppb
Tetrachloroethylene 44,000 ppb
Data released by the DOD. See ProPublica – Bombs in your backyard
You’ll have to ask the Navy if they’ve “cleaned up” this contamination and then you’ll have to independently verify it if they will allow it.
This week, (9/9/24-) Maine’s Department of Environmental Protection personnel will go door-to-door to speak with 45 homeowners who live close to the base and have wells. They say they will discuss sampling of their drinking water well for PFAS.
People should be told not to drink from their wells. They ought to be provided with bottled water immediately. The state should also be testing for other deadly chemicals, like those discussed above.
It has often been said that PFAS has taken all of the oxygen out of the contamination room so it’s important to be mindful of the entire suite of chemicals that are poisoning Brunswick.
Let’s examine the historic levels of PFAS in surface water and groundwater at the former Brunswick NAS. The data produced by Navy contractors is not presented in a way most people can understand so let’s try to make sense of it. Let’s start with the surface water.
Appendix G4 Surface Water Sample Analytical Results
Building 653 SW-55-051818 5/18/2018
The sample was collected in a ditch south of Former Building 653.
Building 653 has historically shown the highest PFOS concentrations basewide. In 2015 PFOS was detected at 24,000 ppt in groundwater.
We ought to be concerned about these concentrations in a ditch because they are symptomatic of contamination elsewhere. This is just one snapshot. Think of the subsurface soils like a giant sponge filled with carcinogens. They are recharged, so to speak, when it rains. The toxins seep into surficial and deep aquifers, the underground streams that carry water. They may contaminate wells and run into streams and rivers to contaminate aquatic life and us.
Let’s look at stormwater samples.
7,100 ppt of PFOS is catastrophic. When there’s a torrential downfall of rain, the contaminants run off or they sink into the ground.
The state of Minnesota has placed limits on PFOS in some of its lakes at .05 ppt. They do this because they understand the chemical aggressively bioaccumulates in fish and is harmful to people.
Minnesota is home to 3M, so it knows a lot about PFAS.
Minnesota says concentrations of PFOS can be more than 7,000 times higher in fish tissue than the water. The EPA says up to 4,000 times.
This science - this reality - should dictate environmental policy worldwide! We are regulating tiny amounts in drinking water while allowing astronomical concentrations to be consumed in the seafood. Admit it, Maine, some of your lobsters are poisoned with PFAS.
Environmental officials in the UK, Germany, Japan, and the US understand all of this, but the poisons prevail, with little governmental resolve to restrain it.
Fate and Transport of PFAS
Once PFAS are released to soils from leaks of AFFF, a variety of processes may occur that cause them to be mobilized to another environmental medium, for instance, from the soil to the air.
PFAS gets around! The fate and transport of PFAS at the former Brunswick base may involve sorption, precipitation, deposition, advection, recharge, dispersion, diffusion, and leaching. Let’s look at each one, briefly.
• Sorption is a phenomenon that describes the interactions or mass transfer at the interface of two different phases (gas, liquid, or solid) leading to changes in their composition by physical or chemical processes.
• Precipitation is one of the ways that per- and polyfluoroalkyl substances (PFAS) spread across the environment and contaminate air, soil, and surface water.
• Deposition is the laying down of sediment carried by wind, flowing water, the sea, or ice. PFAS coats sediment.
• Advection is the horizontal movement of a mass of fluid (such as air or an ocean current). We are breathing it.
• Recharge occurs when water seeps into the ground to replenish underground aquifers.
• Dispersion describes a heterogeneous mixture of at least two substances that do not or hardly dissolve in each other or combine chemically.
• Diffusion is the movement of molecules in a fluid from areas of high concentration to areas of low concentration.
• Leaching is the process of extracting a soluble substance from a solid material by dissolving it in a liquid.
Per-and poly fluoroalkyl substances interact in all of these ways. It is important to study them.
We have created chemical technology we can’t control, although the American Chemistry Council would like you to believe otherwise. They’ve spent $25 million lobbying Congress in the last two years.
These chemicals may last forever, and we don’t know how to dispose of them. This is what people just can’t seem to get their heads around. We can’t burn it, we can’t bury it, and it never goes away. And it’s killing us.
Airborne PFAS
Airborne PFAS can result from various sources:
• Releases of AFFF.
• Industrial emissions
• Incineration of PFAS-containing materials
• The release of PFAS particles from contaminated water bodies.
Many PFAS compounds can be transported as dust from soil erosion caused by wind and runoff. Studies have shown that PFAS exposure through air can contribute to respiratory problems, such as decreased lung function and an increased risk of asthma.
As the majority of AFFF releases are to the ground surface, leaching of PFAS from the surface soil to groundwater or to nearby surface water is one of the primary drivers from PFAS migration at AFFF sites.
In saltwater bodies, sorption of PFAS increases, which results in a greater frequency of sorption to sediment. The head of Harpswell Cove is a large salt marsh with a significant drainage stream, Mare Brook. Included in the drainage is about half of the city of Brunswick and the majority of the Brunswick Naval Air Station. We can expect the food chain to be poisoned here, maybe forever.
Brunswick is not unique in the world in this regard, but its leadership and citizenry are up to the challenge. This will be an epic fight for the Navy.
Oct. 9, 2022 - “I can't help but feel anger. I can no longer trust the U.S. military.”
Yokosuka Mayor Katsuaki Kamiji, commenting after high levels of PFAS, 172 times the Japanese government criteria, were detected in wastewater from a U.S. naval base in the city. Like Lejeune, Honolulu, Chatan, and Yokosuka, too many understand the issue to let it go away. The Navy’s worn out talking points won’t work in Brunswick, either.
The Navy’s Project Screening Levels
The navy says concentrations equal to or below their project screening levels do not pose an unacceptable human health risk/hazard and do not require further risk evaluation.
For the values in this 2020 report, the navy established a project screening level of 1.08 ug/L (1,080 ppt) for PFOS and PFOA in surface water bodies. PFBS was set at 1,080 ug/L (1,080,000 ppt).
If the EPA says PFOS may bio accumulate in fish up to 4,000 times greater than the levels in the water this means the navy is not concerned if fish may contain more than a million parts per trillion of PFOS.
The navy changed its project screening levels for Brunswick earlier this year:
Navy screening levels for 7 PFAS compounds fail to protect public health.
The Navy’s project screening level is currently 203 ppt for PFOS in surface water in Brunswick. This level will result in poisoning of fish and people. They’re not paying attention to us. They’re on a mission and our health is not part of it.
The Navy has established a project screening level of 57,400 ppt of PFBA in surface water. How does the Navy defend this screening level for PFBA? Show us the science. People are breathing this chemical.
A Danish study found that people with elevated levels of PFBA were more than twice as likely to develop a severe form of Covid-19. The research involved 323 patients infected with the coronavirus.
PFBA was developed by 3M. It is used in firefighting foams. It passes through the blood quickly, but it builds up in the lungs, which are threatened by Covid and other diseases. Harvard’s Philippe Grandjean, the principal author of the study, sounded a warning about PFBA, “It’s probably what’s in the lungs that counts because that’s where the big Covid battle is fought,” he said.
According to the EPA, PFBA has been found to accumulate in agricultural crops and has been detected in household dust, soils, food products, and surface, ground, and drinking water. Exposure is possible via inhalation of indoor or outdoor air, ingestion of drinking water and food, and dermal contact with PFBA-containing products.
According to the NIH, PFBA exposure is associated with higher incidences of COVID-19, Liver Injury, Fatty Liver, Fibrosis, Hepatomegaly, Hyperplasia, Hypertrophy, Kidney Diseases, Necrosis, and Skin Diseases.
Groundwater PSL’s
When the navy published this report in 2020, they established a project screening level of .07 ug/L or 70 ppt. for both PFOS and PFOA in groundwater. That matched the EPA’s health advisory at the time. The highest PFOS concentration in groundwater was 22,000 ppt, way over the project screening level. It makes a mockery of the entire charade. There’s no enforcement! Where has the Maine Department of Environmental Protection been?
The EPA now enforces a limit of 4 ppt in drinking water and groundwater for PFOS and PFOA.
In 2018 the Maine Department of Environmental Protection reported PFBS concentrations of 87,500 ppt, the highest for any compound on the former base. The level of PFBS actually exceeded the Project Screening Level of 40,000 ppt! The Navy doesn’t think 40,000 ppt of PFBS in your groundwater is a threat to your health and the Maine DEP doesn’t seem to mind, either.
See the associated diseases and disorders for PFBS on the NIH’s brilliant Pub Chem website:
Low Birth Weight
Diabetes, Gestational
Dyslipidemias
Hepatomegaly
Hypertension, Pregnancy-Induced
Pre-Eclampsia
Monitoring well MW-EP-343 located west of Picnic Pond, was sampled in 2018 and results indicate that PFOA was present at 15,000 ppt. This PFOA concentration is the highest detected concentration basewide. PFOA is known to bioaccumulate in crustaceans.
PFOA is a killer, probably the worst of all PFAS because of its power to inflict harm.
Air
From the Navy’s 2020 report: “Potential exposure to airborne particles in outdoor air is not included in this risk evaluation because EPA toxicity values for the inhalation exposure route are not available for PFAS; therefore, quantitative assessment of the inhalation exposure pathway cannot be performed.”
They don’t want to tell us what’s in the air.
Routes of Exposure
PFAS has been measured in indoor air, outdoor air, dust, food, water, and various consumer products. Potential routes of PFAS exposure include ingestion, dermal, and inhalation. - Illinois EPA
PFOS can be present in air due to its potential to volatize from contaminated soil, meaning it can evaporate directly from the soil particles and enter the atmosphere, thus contributing to airborne PFOS concentrations; this is particularly concerning because PFOS is a persistent contaminant that can pose health risks when inhaled. PFOA is worse in this regard.
From the Executive Summary
FINAL PER AND POLYFLUOROALKYL SUBSTANCES INVESTIGATION SUMMARY REPORT NAS BRUNSWICK ME 09/01/2020 RESOLUTION CONSULTANTS - “PFAS are considered emerging contaminants which are chemicals that may present potential unacceptable human health effects, do not have regulatory cleanup standards, and regulatory standards are evolving due to new science. PFAS have been used in chemical formulations of aqueous film-forming foam (AFFF) for fire-fighting operations.”
They knew back in the 1970’s that these chemicals were making us sick.
In 2020 I reported the following information on Brunswick.
NAS Brunswick - Maine PFAS Data (in parts per trillion, ppt) The Maine DEP link has since been disabled.
Surface Water 8/3/17
PFHXS 1,250
PFBS 129
PFOA 1,330
PFOS 2,660
PFHPA 524
PFNA 271
Groundwater 8/8/17
PFHPA 2,010
PFNA 361
PFHXS 21,200
PFBS 2,970
PFOA 2,420
PFOS 12,900
PFAS is a major part of things in this town. Brunswick is not a place to raise a family. When governing structures fail, citizens must protect themselves. There are plenty of places in Maine that haven’t been so terribly poisoned by the Navy. The state ought to be tougher on the Navy. The Brunswick Town Council is doing its best to advocate for people in Brunswick. It’s sad to watch.
The Downs Law Group helps to make this work possible. Their support allows us to research and write about military contamination around the world. They’ve helped us buy hundreds of PFAS kits and they’ve helped pay for flights and hotels. The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to a host of contaminants.
The Downs Law Group employs attorneys accredited by the Department of Veterans Affairs to assist those who have served in obtaining VA Compensation and Pension Benefits they are rightly owed.
If you spent time in the military and you think you or your dependents may be sick as a result of your service, think about joining this group to learn from others with similar issues.
Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination? Contact James Bussey at busride1969@hotmail.com
Consider joining the Veterans & Civilians Clean Water Alliance Facebook group. 2,700 members and growing.