The Former Plattsburgh Air Force Base is contaminating the Lake Champlain Basin with massive amounts of PFAS
Astronomical levels of the toxins make Plattsburgh one of the most severely contaminated locations nationwide.
April 20, 2021
By Pat Elder
Although Plattsburgh AFB closed in 1995, it continues to contaminate the Lake Champlain Basin with per-and poly fluoroalkyl substances (PFAS).
Between the 1950s and 1989, firefighting training activities at the Plattsburgh Air Force Base were conducted at the fire training area located approximately 500 ft. west of the runway and 500 ft. from the western installation boundary.
(Final Site Inspection Report for Aqueous Film Forming Foam Areas Prepared for Air Force Civil Engineer Center Joint Base San Antonio - Lackland, Texas by Wood Environment & Infrastructure Solutions, Inc. Former Plattsburgh Air Force Base December 2018 - Inspection Report - p. 20 of 674)
The Fire Training Area consisted of four fire training pits located within an approximately 8-acre area. (Inspection Report - Table 4.0-1)
Aqueous film-forming foam (AFFF) was used in training exercises at these locations (Inspection Report - P. ES - 1) (since 1970) and at a total of 11 areas throughout the base. (Inspection Report - P. ES -. 2)
The waters are contaminated with per-and poly fluoroalkyl substances (PFAS) from use of the foams. (Inspection Report - P. 62 of 674)
Groundwater and Surface water on the base flow east toward Lake Champlain.
As far back as the 1970s, studies conducted by the Department of Defense showed that the AFFF used on military bases and ships that contained PFAS were toxic.
(Environmental Working Group and Fountain Valley Clean Water Coalition, 2018.
We’ll examine the groundwater analytical results contained in the inspection report released by the Air Force in 2018.
PFOS + PFOA Contamination in Groundwater - Plattsburgh Air Force Base
Table 3.0-3 Summary of Groundwater Analytical Results Site Inspection Report for Aqueous Film Forming Foam Areas at Former Plattsburgh Air Force Base, Plattsburgh, New York (Final Site Inspection Report for Aqueous Film Forming Foam Areas Prepared for Air Force Civil Engineer Center Joint Base San Antonio - Lackland, Texas by Wood Environment & Infrastructure Solutions, Inc. Former Plattsburgh Air Force Base December 2018
The numbers above tell us that the shuttered base continues to contaminate the Lake Champlain Basin with PFAS, making the region one of the most contaminated areas in the country. The 1,045 ug/l total for Perfluorooctanesulfonic acid (PFOS) + Perfluorooctanoic acid (PFOA) makes Plattsburgh the 12th-most severely contaminated location in the country.
Highest Levels of PFAS Contamination in Groundwater at U.S. Military Installations, Environmental Working Group Source: Department of Defense reports, Freedom of Information Act requests and information collected by the Social Science Environmental Health Research Institute at Northeastern University. https://www.ewg.org/sites/default/files/u352/Top%20100%20PFAS.pdf?_ga=2.207224979.1669899313.1618881249-199159179.1600816316
Ug/l (micrograms per liter) is the same as parts per billion. PFAS is normally examined in parts per trillion which in ppb x 1,000.
Understanding Units of Measurement Center for Hazardous Substance Researchhttps://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/display.files/fileid/14285
Human epidemiological studies found associations between PFOA exposure and high cholesterol, increased liver enzymes, decreased vaccination response, thyroid disorders, pregnancy-induced hypertension and preeclampsia, and cancer (testicular and kidney) Human epidemiological studies found associations between PFOS exposure and high cholesterol and adverse reproductive and developmental effects.
The US Environmental Protection Agency Technical Fact Sheet –Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA) November 2017 https://19january2021snapshot.epa.gov/sites/static/files/2017-12/documents/ffrrofactsheet_contaminants_pfos_pfoa_11-20-17_508_0.pdf
We’ll look at the chart above, starting at the top. Analyte simply means the chemical that is being analyzed. In this case the chemicals, Per fluoro octane sulfonic acid (PFOS) and Per fluoro octanoic acid (PFOA) are the two analytes being examined. They are both toxic varieties of per and poly fluoroalkyl substances (PFAS). There are more than 8,000 varieties of PFAS known to exist.
The Scientific Basis for Managing PFAS as a Chemical Class June 30, 2020 Anna Reade Natural Resources Defense Council https://www.nrdc.org/experts/anna-reade/scientific-basis-managing-pfas-chemical-class
The health advisory of .07 ug/l is .07 micrograms per liter, or .07 parts per billion, (ppb). This is the same as 70 parts per trillion (ppt).
The EPA has issued a Lifetime Health Advisory (LHA) of 70 ppt for PFOS and PFOA together.
EPA Drinking Water Health Advisories for PFOA and PFOS https://www.epa.gov/ground-water-and-drinking-water/drinking-water-health-advisories-pfoa-and-pfos
The LHA is non-enforceable and non-regulatory advice to the nation’s water providers and public health community. Health advisories simply provide information on contaminants that are known to cause human health effects and are present in drinking water.
Health professionals nationwide have called out the EPA for refusing to strenuously regulate the substances and for setting the bar too high. They claim drinking water with more than 1 part per trillion of any variety of PFAS may endanger public health.
EWG Proposes PFAS Standards That Fully Protect Children’s Health May 6, 2019 https://www.ewg.org/research/ewg-proposes-pfas-standards-fully-protect-childrens-health
Studies show that the safety threshold for PFOA in drinking water should be as low as .1 part per trillion. (point one ppt).
Teflon Toxin Safety Level Should be 700 times lower than current EPA Guideline. Sharon Lerner, The Intercept June 18,2019 https://theintercept.com/2019/06/18/pfoa-pfas-teflon-epa-limit/
Let’s look at the Air Force graphic again.
Moving to the next row, “Regional Screening Level Tap Water” refers to the state of New York’s maximum contaminant levels (MCL’s) for PFOS & PFOA. The toxins are shown as “NA” because the Air Force study on Plattsburgh’s PFAS was published in 2018, two years before New York instituted maximum contaminant levels of 10 parts per trillion (ppt) for PFOA and 10 ppt for PFOS.
State-by-State Regulation of PFAS Substances in Drinking Water JD Supra January 25, 2021https://www.jdsupra.com/legalnews/state-by-state-regulation-of-pfas-2721756/
New York has not set contaminant levels in groundwater.
PFAS Update: Current State-by-State Groundwater Regulations JD Supra March 1, 2021 https://www.jdsupra.com/legalnews/pfas-update-current-state-by-state-5284550/
New York may follow the lead of the EPA and other states by setting an MCL in groundwater that matches drinking water limits. If that’s the case, the Air Force may simply claim it is not required to abide by the newly promulgated levels as it has in Michigan.
Air Force claims federal law bars compliance with Michigan PFAS rules M Live Apr 09, 2021 https://www.mlive.com/public-interest/2021/04/air-force-claims-federal-law-bars-compliance-with-michigan-pfas-rules.html
Let’s go back to the chart.
MW-02-008 is the location of “AFFF Area FT002”. That is the Aqueous Film-Forming Foam Fire Training Area 002. MW-02-008 is the epicenter of PFAS contamination in the Lake Champlain Basin.
Waters from the lake flow north to the Richelieu River and on to the St. Lawrence River and the Atlantic Ocean.
A Few Secrets of the Lake Champlain Region Suzanne May https://www.lakechamplainregion.com/story/2014/10/secrets-facts-lake-champlain
The red X is the location of Fire Training Area #2 where PFOS and PFOA were found at 1,045,000 ppt in groundwater. Lake Champlain is to the east.
Let’s further examine the row beginning with MW-02-008. The testing was done on October 3, 2014. The groundwater was sampled to a depth of 45.5’. The 1,045,000 parts per trillion is 14,928 times above the EPA’s 70 ppt advisory.
The surface water not far from FT-002 contained 2,482 ppt for the two types of PFAS. Rivers across the country with a fraction of the concentration of these chemicals have been home to fish with high levels of the toxins due to the propensity of some of these chemicals to bioaccumulate in fish.
Bioaccumulation Factors Stakeholder Group Meeting PFOS & PFOA Surface Water Criteria 23 March 2020 Meghan Williams Environmental Toxicologist Water Quality Bureau https://dnr.wi.gov/topic/Contaminants/documents/pfas/PresentationBioaccumulation20200323.pdf
The surface water from the fire training area empties into sewers and streams that ultimately discharge into the Saranac River to the north, the Salmon River to the south and Lake Champlain to the east. All surface water eventually drains into Lake Champlain.
Table 4.0-1 Conceptual Site Model: Installation-Wide Summary Site Inspection Report for Aqueous Film Forming Foam Areas Final Site Inspection Report for Aqueous Film Forming Foam Areas Prepared for Air Force Civil Engineer Center Joint Base San Antonio - Lackland, Texas by Wood Environment & Infrastructure Solutions, Inc. Former Plattsburgh Air Force Base December 2018
The Salmon River is known as a top spot for Brook Trout, Water Trout, and Brown Trout. Lake Champlain is renowned for Lake Trout, Landlocked Salmon, Smallmouth Bass, Largemouth Bass, and Northern Pike. The fishing industry attracts millions of tourist dollars to the region.
New York’s Adirondack Region Fish Advisories for Lake Champlain do not include PFAS as a contaminant. Several species, however, have “Do not eat” advisories for mercury and polychlorinated biphenyl (PCB) contamination.
Adirondack Region Fish Advisories Adirondack Region Advisory https://www.health.ny.gov/environmental/outdoors/fish/health_advisories/regional/adirondack.htm#table
Sewer sludge removed from the base’s treatment plant, which may contain residual PFOS, PFOA or PFBS, was spread within an estimated 50- to 100-ft. area around the treatment plant.
Inspection Report P. 22 of 674
Lowland flooding in the former munitions’ maintenance area in the southwestern portion of the former base may have spread PFAS-contaminated effluent from the FT002 Groundwater Treatment Plant.
Inspection Report P. 22 of 674
How does the PFAS contamination at the decommissioned Plattsburgh Air Force Base (PFAB) in New York affect others? This April, the Vermont Military Poisons Coalition members are advocating for changes in a proposed piece of legislation: S.20, which includes imposing 9 restrictions on the use, manufacture, sale, and distribution of class B 10 firefighting foam containing PFAS. The Coalition wants to see the proposed legislation completely ban all PFAS and mandate the use of fluorine-free alternatives, including at military sites in Vermont. The coalition would also like to see the remediation of all Vermont soils, water, and groundwater by the U.S. Government.
The PFAS contamination in Plattsburgh flows into Lake Champlain from Plattsburgh Air Force Base and the Au Sable and Salmon Rivers. The PFAS contamination from the Vermont Air National Guard Base flows into Lake Champlain from the Winooski River. PFAS crosses state and country boundaries. Part of Lake Champlain, like Lake Memphremagog in Newport, VT, is in Canada. We are interconnected and all PFAS affects each of us no matter where we live. Laws across countries and states should be consistent and the only logical choice is the banning of all PFAS, everywhere. And the military must not be exempt from these laws. After all, the military is supposed to protect us from harm, not jeopardize our health and our communities by poisoning us.