Last spring, the Wisconsin Department of Natural Resources warned Truax Air National Guard base in Madison it could face enforcement action if it didn’t move swiftly to clean up toxic chemicals that were showing up in municipal drinking water.
But Truax personnel never responded to letters spelling out statutory requirements for a prompt and thorough cleanup, and by the end of May all the demands were wiped away by a DNR promise to “work cooperatively with Air National Guard staff to develop an agreeable project timeline for addressing the known contaminant release.”
Nearly nine months later, there is still no timetable for Truax to take the first steps toward a cleanup by mapping each source of contamination and the spread of pollutants through groundwater that is the city’s source of drinking water.
Air National Guard spokesmen didn’t respond to repeated questions about when work would begin at Truax. A U.S. Air Force spokeswoman said the pace of cleanups is dictated by budget constraints.
Madison and Dane County likely share at least some responsibility with the military for two probable sources of pollutants — burn pits where toxic firefighting foam was sprayed on soil just outside the base — but local leaders have agreed to wait for National Guard funding to materialize rather than paying for their own testing of those sites.
The delays and uncertainty come as Truax awaits a final decision on whether the Air Force will choose it as a home for an 18-plane squadron of $90 million F-35 fighter jets that politicians and the Greater Madison Chamber of Commerce view as key to avoiding a shutdown of the base and preserving local economic benefits.
Public support for the jets and the cost of operating the base — including the eventual expense of cleaning up toxic PFAS contamination — are important factors in the selection process, but chamber president Zach Brandon said he isn’t worried.
“We do not anticipate that the PFAS issue will have any effect on Truax Field securing the F-35A jets,” Brandon said. “In regards to the PFAS readings, it is productive that a collaborative approach is being taken to ensure our water is clean and safe. As a community, we expect nothing less.”
Air Force spokeswoman Ann Stefanek said she wasn’t aware of a case where a base designated as a preferred F-35 site — as Truax was in December 2017 — didn’t eventually receive the warplanes. A final decision is due after a public comment period that will be part of a study of the F-35’s expected environmental impact.
Madison City Council leaders in early May called on the military to evaluate the spread of PFAS and other pollutants from the base as part of the draft environmental impact study expected to be released early next month.
Maria Powell of Madison, whose Midwest Environmental Justice Organization has taken the lead in bringing to light the water contamination around Truax, said delays mean toxic materials are continuing to spread unseen and unmeasured, increasing the risk to human health through drinking water and fish that people eat from downstream waters like Lake Monona.
Serious health hazards have been linked to PFAS for decades. The material was sprayed on the ground and washed into storm drains and sanitary sewers at the base since at least the 1970s, according to several government reports.
But federal, state and local governments have been unwilling to begin what will likely be a costly cleanup that could include other nearby polluted sites that may not have been fully remedied in the past, Powell said.
“It’s appalling to the citizens that they put their financial interests before public and environmental health,” Powell said. “If (local leaders) keep putting it off to the Defense Department, it’s going to take forever.”
Madison and Dane County officials have emphasized that PFAS levels in Madison drinking water have been below a controversial federal health advisory.
On Feb. 14 after the Wisconsin State Journal raised questions, representatives from local, state and federal agencies met at the base to discuss the two contaminated burn pits.
The Madison Water Utility later issued a statement saying the Wisconsin Air National Guard was gathering information for a possible “statement of work” about the pits, and the Guard should know by Sept. 30 whether the Department of Defense would pay for an investigation.
Accommodating the military
Wisconsin law requires polluters to meet cleanup deadlines of 30, 60 and 90 days, but it also allows the DNR to develop alternative timelines, said spokesman Andrew Savagian.
Congress hasn’t appropriated enough money for the Department of Defense to clean up all of its bases that are polluted by PFAS and other harmful substances, so the military is working first on places that are the worst threats to human health or the environment.
“The DNR acknowledges this priority plan in place with the DoD,” Savagian said.
The acknowledgment is in the form of a Defense State Memorandum of Agreement, which ended the DNR program manager’s efforts to push for a prompt, thorough action by the Air National Guard when it was signed by a DNR executive on May 28.
The first such agreement between the military and the DNR was signed in 1992, when George Meyer was administrator of the DNR’s enforcement division.
The agreements generally acknowledge that inadequate funding from Congress will determine what the military cleans up and when, said Meyer, who served as DNR secretary from 1993 to 2001.
“Many members of Congress would rather spend more money on building a new aircraft carrier, so the cleanup program is underfunded,” Meyer said. “And the local people can’t do anything about it.”
Meyer said that if a private company had allowed pollutants to remain in groundwater as long as Truax has, the DNR would probably be close to referring it to the state Department of Justice for financial penalties as part of enforcement action.
The state and federal governments jointly fund the Wisconsin Air National Guard, so the state Legislature could allocate money to speed up the process. But Meyer said state lawmakers have been slow to pay for cleaning up sources of pollution.
States have little choice but to sign the agreements, which make them eligible for payments from the military to cover agency costs of overseeing cleanups, Meyer said.
Under the latest two-year agreement signed by the Wisconsin DNR, the military is to pay up to $148,567, less than almost any time in the last decade, for several cleanup sites, said Judy Fassbender, policy manager in the DNR hazardous spills division. In 2010-2012, $642,239 was budgeted because more work was being done at other bases in the state, she said.
Serious health problems
The federal government says PFAS compounds are associated with increased risk of slowed development in children, lower fertility, hormonal disruptions, high cholesterol, immune system deficiencies and several kinds of cancer.
In addition to firefighting foam, PFAS compounds have been used in nonstick pans, grease-resistant paper and stain-proof fabric for decades. In the early 2000s, the U.S. Environmental Protection Agency began encouraging manufacturers to stop making the most widely used types of PFAS compounds, but imports are still available. Thousands of new PFAS compounds have been synthesized.
For decades, the Wisconsin Air National Guard sprayed PFAS-based firefighting foam during training exercises at one burn pit outside the base perimeter, and for a shorter period at another. Meanwhile, on the base itself, fire-suppressing foam drained into sewer lines or soil, according to accounts from Truax personnel in a 2015 Air National Guard report.
PFAS wasn’t measured in soil or groundwater under the base until November 2017. Test results were compiled in a March 27 report sent to DNR in April. The report said: “Given that groundwater flow is to the east/southeast and that samples at the Base boundary (exceed a federal health advisory), groundwater with (PFAS) concentrations above applicable screening criteria is very likely present off-Base to the south and east.”
The highest PFAS measurement was nearly 40,000 parts per trillion, more than 500 times the 2016 EPA drinking water advisory limit of 70 parts per trillion.
Two months before the military sampled groundwater at the base, PFAS was found by Madison Water Utility about a mile southeast of the base in drinking water drawn by Madison’s Well 15. The latest tests show a total PFAS concentration of 42 parts per trillion.
Public Health Madison and Dane County has emphasized that the levels are below the 2016 EPA advisory. But last year the federal government’s leading toxicology agency said a limit of 14-21 parts per trillion was needed to protect infants and fetuses.
The military hasn’t tested beyond the base boundaries, so it’s not known if or when heavier concentrations will reach Well 15.
A spokesman for the Truax base, Wisconsin National Guard Capt. Joe Trovato, emphasized that after decades of use the base has greatly limited use of the firefighting foam that was the most likely source of PFAS contamination.
Truax has taken steps aimed at preventing further environmental releases and switched in 2016 to a foam that is formulated differently from the one most closely linked to health problems, Trovato said.
Powell and others have said there is no guarantee the relatively untested new firefighting foam will prove safer than the old one.
Delayed cleanups carry costs
“The longer contamination is left in the environment, the farther it can spread,” the DNR said in an April 26 letter to leaders of the Truax Field installation. “Quick action may lessen damage to your property and neighboring properties and reduce your costs.”
The DNR warned of possible enforcement action if Truax didn’t meet deadlines of 30, 60 and 90 days for the cleanup effort’s first steps, detailed mapping of toxic plume’s dimensions, its direction of movement, and its sources on the base.
Two weeks later, the DNR program manager assigned to the site pointed out six shortcomings in a work plan Truax had submitted. The military needed to add testing of multiple contamination sources, sample shallow and deep groundwater under the base and install monitoring wells beyond the base boundaries, especially to the southeast where a municipal well was contaminated.
The DNR program manager, Michael Schmoller, invited Truax to discuss the changes.
Schmoller told the Wisconsin State Journal he never heard any response.
However, Schmoller soon learned that all the DNR’s deadlines and demands had evaporated with the signing of the Defense State Memorandum of Agreement on May 28.
In Washington, U.S. Sen. Tammy Baldwin has pushed successfully for an additional $189 million to clean up PFAS water contamination from military bases, replace and dispose of PFAS-based firefighting foam and continue a nationwide health assessment in this year’s budget.
Baldwin’s office said she plans to use her position on the Senate Appropriations Committee and Defense Department subcommittee to do more. However, the Madison Democrat is one of 31 members of the committee, and one of 10 members of the subcommittee.