No Excuses

The massive fire fighting foam leak at the former
Brunswick Naval Air Station was entirely preventable.

By Ed Friedman, Friends of Merrymeeting Bay (FOMB)
October 14, 2024

Aqueous film-forming foam is shown here, escaping from Hangar 4 in Brunswick.
- Photo by Ed Friedman

At approximately 5:15 am on August 19, the fire suppression system in Hangar 4 at the former Brunswick Naval Air Station (BNAS) accidently deployed about 51,000 gallons of PFAS-contaminated firefighting foam. Shortly thereafter the entire 90,000 square feet of hangar floor was filled with the aqueous film forming foam (AFFF) 4–5' high or 405,000 cubic feet! This is said to be the sixth largest PFAS release in US history and was a mix of 1,450 gallons of PFAS-laden firefighting concentrate plus 50,000 gallons of water (automatically mixed in when sprayed from the pressurized system).

Within hours, the AFFF had entered surface waters that largely drain southeast through a chain of ponds to Merriconeag Stream, which flows into Mare Brook and out to Harpswell Cove, home to a thriving shellfish industry. The AFFF also entered the sewer system from whence it flowed to the Brunswick Sewer District (BSD) Plant and, untreated for PFAS, directly into the tidal Androscoggin River and Merrymeeting Bay. PFAS foam was all over the Hangar 4 and Pond A vicinity, coming up through the sewer manholes and being vacuumed up on the tarmac by Clean Harbors under DEP supervision. FOMB volunteers were on site by midday, photographing both spill areas we could see and response efforts. Besides cleanup, a focus of the DEP was rapid testing to establish baseline data.

Thanks to member support, FOMB could contribute in a major way, since on our own and in cooperation with the Brunswick Sewer District, Brunswick Area Citizens for a Safe Environment (BACSE), and the Military Poisons Project, we have been monitoring PFAS in and around the former base and in the broader lower watershed for several years.

We met with Chris Hooper, the Maine Department of Environmental Protection’s Director of Spill Response, and helped familiarize him with the lay of the land in and around the base and then emailed him extensive baseline data. His response was appreciative: “It was great to talk with you yesterday. Thanks so much for these results; I’ll forward them on to our Tech Services people who manage our testing and results right away this morning. This will be very helpful.”

Per- and polyfluoroalkyl substances (PFAS) are a large, complex group of synthetic chemicals used in consumer products around the world since the 1950s. They are ingredients in various everyday products. For example, PFAS keep food from sticking to packaging or cookware, make clothes and carpets resistant to stains, and create firefighting foam that is more effective. PFAS molecules have a chain of linked carbon and fluorine atoms. Because the carbon-fluorine bond is one of the strongest, these chemicals do not degrade easily in the environment. (National Institute of Environmental Health Sciences).

These rugged carbon-fluorine chains have earned the name “forever chemicals” and have long half-lives. I like to call them “everywhere chemicals” because of their worldwide presence. There are somewhere between 14,000–16,000 PFAS chemicals and only a very few have been regulated by the Environmental Protection Agency (EPA) or Maine Department of Environmental Protection (DEP). In Maine, only six PFAS compounds are regulated for drinking water and none for surface waters.

Human health effects that we know of include thyroid disease, kidney, breast, and testicular cancers, liver damage, increased cholesterol levels, and delayed mammary gland development. PFAS chemicals are considered persistent organic pollutants and endocrine disrupters.

The Navy still owns Hangar 4 but has already transferred Hangar 6 (closest to the now-contaminated Jordan Avenue Brunswick well field and site of ongoing PFAS leakage) to the Midcoast Regional Redevelopment Authority (MRRA), a legislative-chartered quasi-governmental entity. Since the Hangar 4 spill, the Navy has removed remnant legacy AFFF from Hangar 4. Hangar 6, under MRRA’s authority, remains a ticking, leaking time bomb. Located at the north end of the former base, it will likely continue to influence Brunswick’s water supply and the Androscoggin River.

The EPA has set enforceable limits of 4 parts per trillion for two compounds: PFOS and PFOA. These are known as Maximum Contaminant Levels, or MCL’s. For PFNA, PFHxS, and HFPO-DA (GenX Chemicals), EPA has set MCL’s of 10 parts per trillion (ppt). Maine regulates six PFAS contaminants in drinking water: perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorohexane sulfonic acid (PFHxS), perfluorononanoic acid (PFNA), perfluoroheptanoic acid (PFHpA), and perfluorodecanoic acid (PFDA). An interim standard of 20 ppt for the six PFAS (alone or in combination) is in effect.

For comparison, our July 29 sampling results from Hangar 6 BSD pump station for these chemicals were:

PFOA—303 ppt;
PFOS—20,600 ppt;
PFHxS—57 ppt;
PFNA—49 ppt;
PFHpA—89 ppt; and
PFDA— 82 ppt

for a total of 21,180 ppt.

PFAS levels dilute very quickly in water, so ambient water testing, other than for screening or known hot spots, is of limited value compared to testing in organisms to document real-world bioaccumulations in the environmental food chains. Why, with minimal air traffic and storage at the current Brunswick Executive Airport is PFAS-laden fire suppression foam still present? In 2021 (updated in 2022), the Department of Air Force issued a memo calling for the change from AFFF to fluorine-free dispersal systems in all but special circumstances. The Sunset Order for AFFF was based on study results from Army, Navy, Air Force, and Defense Logistics Agency facilities and was shocking.

The Assistant Secretary of the Air Force for Energy, Installations, and Environment led a joint effort across the Departments of the Air Force (DAF), Army, and Navy along with the Defense Logistics Agency to assess risks with respect to replacing fluorinated Aqueous Film Forming Foam fire suppression systems in Department of Defense Facilities facilities. After reviewing 32 years of historical data and 15 years of safety mishap data, the assessment team did not find a single instance where a hangar fuel related fire resulted in the loss of an aircraft or life. The only aircraft fuel related fire in the past 32 years in the DoD was suppressed by a water deluge system. In contrast, the historical data shows a trend of inadvertent activations of foam systems across the DoD of one in every two months (84 mishaps over past 15 years). The mishap cost associated with these events was in excess of $24.5 million and contact with chemicals in the foam have caused one death, injured 21 people and damaged more than 120 aircraft. Considering the findings of this risk-informed analysis and the high cost of converting, maintaining, and clean-up of accidental discharges of foam systems, effective immediately, all DAF hangars and similar facilities equipped with foam FSS will be categorized as Tier 2 Fire Protection Facilities unless specifically approved for Tier 1 designation. Tier 2 facilities will use an automatic water sprinkler system consistent with the attached guidance in lieu of foam FSS.

Considering that the military is no longer using PFAS-based foam suppression systems, there is simply no excuse for its presence on the former BNAS (or any other former military installation transferred to civilian use).

The Midcoast Regional Redevelopment Authority and the Navy must be held accountable for PFAS and other legacy contamination at Brunswick Landing/Brunswick Executive Airport/BNAS, much of which remains a Superfund site, a fact many tenants are probably not aware of.

“Every American deserves to be able to turn on their water tap or faucet and be able to drink clean water.” —President Joe Biden