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A few passing clouds. Low 48F. Winds light and variable..
A few passing clouds. Low 48F. Winds light and variable.
CO-CHAIR COMMENTS – Steven Willis is pictured above at far right during the latest quarterly meeting of the Wurtsmith Restoration Advisory Board (RAB), which was his first as co-chair. The program manager/Base Realignment and Closure environmental coordinator with the Air Force Civil Engineer Center is seen speaking with fellow RAB members at the Oscoda United Methodist Church, where the RAB meeting was held in person and also webcast live for virtual participants.
VISUAL AIDS – Among the posters on display at the Wurtsmith Restoration Advisory Board meeting, was the one shown above outlining the interim remedial action (IRA) work for Van Etten Lake, at Ken Ratliff Memorial Park. The meeting featured updates on the progress of this IRA, as well as that for FT-02 at Clark’s Marsh, to expand the capture and treatment of PFAS-contaminated groundwater from these sites in Oscoda Township.
CO-CHAIR COMMENTS – Steven Willis is pictured above at far right during the latest quarterly meeting of the Wurtsmith Restoration Advisory Board (RAB), which was his first as co-chair. The program manager/Base Realignment and Closure environmental coordinator with the Air Force Civil Engineer Center is seen speaking with fellow RAB members at the Oscoda United Methodist Church, where the RAB meeting was held in person and also webcast live for virtual participants.
VISUAL AIDS – Among the posters on display at the Wurtsmith Restoration Advisory Board meeting, was the one shown above outlining the interim remedial action (IRA) work for Van Etten Lake, at Ken Ratliff Memorial Park. The meeting featured updates on the progress of this IRA, as well as that for FT-02 at Clark’s Marsh, to expand the capture and treatment of PFAS-contaminated groundwater from these sites in Oscoda Township.
OSCODA – The following is the first of a two-part story on the Wurtsmith Restoration Advisory Board (RAB) meeting. It will focus on the remedial investigation (RI) and interim remedial action work (IRA) at the former Wurtsmith Air Force Base (WAFB) in Oscoda. Next week’s story will highlight such items as the Military Munitions Response Program RI being planned for WAFB.
It’s been more than a decade since per- and polyfluoroalkyl substances (PFAS) were discovered in groundwater (GW) at WAFB. So when it was revealed that the RI portion of the cleanup process may take about a year longer than expected, this was unsettling to some of the attendees.
“Having been at these meetings now for a number of years – in fact, this process is now in its 13th year – it is very disappointing to hear that we’re losing another year on the RI,” said Van Etten Lake (VEL) property owner Anthony Spaniola.
A breakdown of the RI and IRAs at WAFB was given by Aerostar Senior Program Manager Paula Bond, during the meeting at the Oscoda United Methodist Church. The event was also broadcast live, for remote participants.
The RI is one step in the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) which the Air Force (AF), as well as such project partners as Aerostar, must follow when working on a remedy for the contamination.
Bond said that there was a request to go over this process in more detail, so she also provided a CERCLA summary, the first step of which is site identification and initial sampling. For this, WAFB’s preliminary assessment/site inspection was completed in 2019.
Next is the RI/feasibility study (FS), which entails more detailed studies and investigations, the development of potential cleanup solutions and the evaluation of remedial alternatives.
“And then that’s followed by the feasibility study, where we take the data from the RI and try to develop remedial alternatives that may be appropriate to address the PFAS that we found during that investigation,” Bond said.
The next step is creating a site cleanup plan and, upon looking at the alternatives in the FS, a preferred approach is developed in the proposed plan. This will be agreed to in the record of decision (ROD), “which is signed off and that becomes the actual remedy for the cleanup that you’re addressing,” Bond explained.
This is followed by the development of a remedial design and implementation of the remedial action/site cleanup. Then comes the site cleanup progress evaluations, where the remedial action-operations and long-term management steps take place.
“And then eventually the site is closed out,” Bond said.
WAFB is currently in the RI/FS phase but she reminded meeting goers that in the meantime, time-critical removal actions, IRAs and other such early response measures – which can be implemented at any point as the CERCLA process is ongoing – have been carried out at WAFB.
As previously reported, for example, this included a time-critical removal action last year where PFAS-contaminated soil at the former fire training area (FT-02) was hauled away.
Aside from the main steps in CERCLA, the RI itself also has different stages. The first two, scoping and then developing a Uniform Federal Policy-Quality Assurance Project Plan (UFP-QAPP), are complete. The risk assessment work plan and the collection of field data are currently ongoing. Once the delineation efforts wrap up, to determine the nature and extent of the contamination, there will be an RI report.
RAB Member Arnie Leriche said he believes that the date for the final RI report was originally to be in December 2022, but was bumped back to the spring of 2023. “Is that still on schedule for a final report by next spring, ‘23?”
Bond said no, as it has been “pushed to the right a little bit,” which she would talk about more as she got to the schedule portion of her presentation.
“So it’s delayed a second time,” Leriche said.
Bond shared some background on the RI, for which the fieldwork began in July 2021. Between that time and when the work was paused in December for the winter season, GW samples were collected from 96 existing monitoring wells (MWs); 245 soil borings were completed (1,151 samples); 323 samples were taken from 51 vertical aquifer sampling (VAS) locations; four seep samples were collected; and 13 hydraulic profiling tool locations were completed.
Fieldwork resumed on April 4 this year and has included further VAS sampling to help finish the delineation of the GW plumes. It will also entail the installation of MWs and an update to the conceptual site model.
Bond advised that the fieldwork will proceed this season and continue into next season. “So that is why that has been pushed out and why the schedule for the RI is also going to be pushed out to 2023.”
“We’re not going to finish the RI under this contract,” added RAB Co-Chair Steven Willis, program manager/Base Realignment and Closure (BRAC) environmental coordinator with the AF Civil Engineer Center. He said that there’s simply not enough time in the current contract to finish the RI and write the report since there are still data gaps, additional step-outs which need to be done and biota sampling and risk assessment work to complete.
However, Willis said that funding has already been programmed to finish the RI through a follow-on contract, and that the AF has talked with the Michigan Department of Environment, Great Lakes and Energy about the scoping on that, as it relates to VEL and Van Etten Creek.
As soon as funding is received in the next fiscal year (FY), the contract will be awarded and RI work will continue.
The existing agreement ends in January. “We’re working to extend that contract another six months, but we can’t extend it beyond that time,” said Willis. The follow-on will likely be a three- to five-year contract, as it will consist of finishing the RI, plus doing the FS.
Leriche said he understands that this happens with contracts and, when moving on to another one, there’s a transition in between. “So how much would you estimate has been added to the schedule delay, because of that?”
“Well the good thing is that in the follow-on contract, we’ll be able to use the existing QAPP, as well as the risk assessment work plan and the biota sampling plan,” Willis answered. “So we won’t have to write any of the planning documents upfront; we’ll be able to go right into the fieldwork in that follow-on contract.”
He said that in all likelihood, it will be awarded in the fall/winter time frame, with the fieldwork staring next spring. So it will probably push completion of the RI out by roughly one year.
“Pushing it out an additional year from...” Leriche asked.
“From this contract,” Willis replied.
Leriche said that they would be losing a field season, because now they’re not going to be able to start sampling for that phase until the spring of the following year.
“I wouldn’t say we’re losing a season, because this season we’re going to finish the delineation work,” Bond pointed out, adding that fieldwork will start in April 2023. “So we wouldn’t lose a season, we would keep going.”
Just for comparison, Leriche said that he observed a recent Pease AF Base RAB meeting and that this site is on schedule, with a slight delay.
According to Leriche, the Pease RI contract was signed right around the same time as WAFB, “and they’re going to have their RI report by next spring. And that’s the same time that you’re going to start your sampling for the risk assessment part of the RI.” So, he said he wanted to emphasize that “this is a full year that we’re going to be behind that site.”
Willis said he understood, but that the team wants to ensure they collect all the data needed in order to answer the questions. They don’t want to do a partial RI, have missing data and then have to go back and do it again. So they split it into two contracts to make sure it’s a complete, continuous RI, with all the data gaps addressed.
Since the public is not given an opportunity to comment officially on the RI draft or plan, Leriche asked if the AF could give some briefings over the winter about the draft planning and so forth, so that when sampling does begin, the public can have a comfortable feeling of what the AF is doing and what they’re sampling for.
Willis affirmed this, saying that a presentation can be made at a future RAB meeting on what will get done under the existing contract and what will happen in the next contract.
Spaniola made a similar statement as Leriche, during the public comment period. He acknowledged that with Willis – who was marking his first RAB meeting as co-chair – being new to the site, the history at WAFB is certainly not his responsibility.
Spaniola asked that the RI process be opened up, saying that this was done at Pease. “Pease is actually ahead of us now.”
He commented that the Department of Defense’s (DoD) process for this is a very opaque one to the community and it lends itself to a great deal of distrust. “And I think, given the fact that people in our community have to live with the results of this remedial investigation, it should be opened up.”
Spaniola also said he believes that the process could go a whole lot faster and that there wouldn’t have been “all this horsing around” on the east side of VEL for so many years, if the discussion had been more candid.
As Bond continued her presentation, she described the progress of the IRAs which, as reported, will expand the capture and treatment of PFAS-contaminated GW from FT-02 at Clark’s Marsh, as well as from VEL at Ken Ratliff Memorial Park.
The scoping, proposed plans, interim RODs and remedial designs have all been completed for the IRAs. Bond said that they are now in the interim remedial action phase of implementing the remedies for the two areas noted above.
The FT-02 at Clark’s Marsh IRA site work began in October 2021, with the area being graded and prepared for construction.
“We are doing a building expansion because we’re adding pre-treatment to the existing FT-02 system and it will be handling additional water out there,” Bond said. A tote building, associated with biological treatment, has also been constructed. “And then we built an expansion onto the side of the building.”
Conveyance piping has been put in place too, for the extraction wells which were to start being installed this month.
“And then that system will be hooked up to the extraction wells and we’ll be well on our way to getting that treatment system up and running,” Bond said.
For the VEL IRA at Ken Ratliff Memorial Park, filter press optimization began on March 1 this year, and the building expansion, well control building foundation and structures are complete. Carbon tanks were installed, as well, and other equipment is being put in place as it is received.
Bond explained that the existing central treatment system (CTS) at WAFB is being expanded, and a well control building is also being constructed to handle all of the new extraction wells and the increased water that will be coming to the CTS. “And the extraction wells for this system are planned to be installed in July and August 2022.”
According to Bond, both the Clark’s Marsh and the VEL IRAs are expected to be up and running by late summer this year.
Following the meeting, Willis sent an e-mail to the RAB and other stakeholders, noting that the final interim ROD for the VEL IRA is now available on the Wurtsmith Administrative Record (AR). This can be found at https://ar.afcec-cloud.af.mil, by clicking the circle next to “BRAC,” selecting “Wurtsmith AFB” and entering 617775 in the AR # section.
In related topics, RAB Member David Winn said that in conversations with Congressional representatives, he understands that there were some updates to the 2022 budget released by Congress. He asked if Willis was aware of those or if he could provide any information, and Willis said he had not seen anything on that.
RAB Member Cathy Wusterbarth said she believed that what Winn was referring to, was the National Defense Authorization Act funding.
She said that in their last discussion with Dr. Catharine Varley, the former RAB co-chair, Varley mentioned that not all the funding she requested was coming towards WAFB.
“So we’re particularly interested in knowing that the project is being funded adequately,” Wusterbarth said, to which Willis answered that it is.
“So what you’re asking for, you’re getting 100 percent of it?” Wusterbarth continued.
“What we’ve asked for, we have gotten so far, yes,” Willis confirmed.
Wusterbarth then asked if there is a process for receiving the funding for the next RI contract.
Willis said that they programmed the money and expect that it will be funded next year. “But it would be FY ‘23 funding; not this year’s money, but next year’s money.” He noted that there is a process for budgeting that money and then receiving it and putting it on contract.
“What I can actually spend is based on what Congress allocates to the services,” he added. “So it’s always contingent on the federal process for funding anything. But yes, we have budgeted money for the follow-on work.”
Leriche said that because of the schedule and cycle of the defense budgets, that money may not be actually given to award a contract until after March; not October, which is the beginning of the FY that this money starts to be reviewed or approved. “It usually takes about nine months. So is that going to cause you delays? In other words, should we expect that the [DoD] is going to be looking forward to get money out of ‘22, and raise our priorities to the top of the list for any leftover money in this fiscal year?”
“I don’t expect there’s going to be money left over this year,” Willis said, explaining that there are numerous installations, such as WAFB and Pease, which are much further along in their PFAS RIs than most. So available funding has been put toward getting RIs started at other installations.
“So far, Wurtsmith has not been underfunded on anything we’ve requested, and I would hope that next year we won’t see any difference in that,” he went on, adding that WAFB is a high priority installation and he would anticipate that it will continue to see funding.
Leriche said he wasn’t pointing this at Willis personally, but it appears that because the new contract has not been funded yet and it causes a one-year delay in the RI, that the statement of WAFB being a high priority “and therefore you’ve always gotten the money that you’ve asked for, there’s a disconnect here.”
Willis reiterated that the follow-on is for FY 2023, not for this year.
“Exactly. But what I’m saying is, for contract purposes, that money should be requested by the team and have it ready so there are no contract delays in the future,” Leriche said. “We’ve gone through two types of contract delays at this site in the last four years. And so, your upper management, I think, needs to do a lot more for this site than has happened in the past, especially for add-ons by Congress.”
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