Tuesday's postcard, and how the threat of the Spokane Airport's groundwater contamination is coming into focus
September 10, 2024
“September Blue,” rapids on the river west of Spokane’s T.J. Meenach Bridge
New field notes from the West Plains’ “forever chemicals” saga
Mike Hermanson was right to be concerned. It wasn’t just what his hydrogeologic work for Spokane County was telling him about the mercurial nature of groundwater pathways in the basalt aquifers west of Spokane. It was what he could see on his commute, heading across the West Plains toward his office in Spokane.
“I was driving to work every day on Old Trails Road,” he remembers, “and I’m watching new houses go in and people drilling wells.”
He was frustrated at the time, suspecting that a grant request to fund a vital, deeper investigation into the spread of PFAS “forever chemical” pollution was being blocked for fear it would implicate the Spokane International Airport (SIA) as a source along with Fairchild Air Force Base. Fairchild had already gone public (in the spring of 2017) with the news that PFAS contaminated groundwater had migrated off the base. SIA—jointly owned by the county and City of Spokane—was conspicuously quiet though.(Hermanson left his position with the county in early 2022, to take a job in the private sector.)
The PFAS contamination saga on the West Plains has periodic eruptions and it was a year after Hermanson’s poignant resignation that it erupted again. This time it was the news from the Washington Department of Ecology that—on the basis of SIA well test results provided to Ecology by a private citizen—the agency was moving to declare and list SIA as a liable party under the state’s Model Toxics Control Act.
As I reported at the time, SIA’s response was open hostility—challenging the accuracy of the evidence the agency acted upon and sternly requesting Ecology to remove the airport from its listing of toxic sites within the state’s jurisdiction. The stand-off lasted nearly a year, and delayed what, in retrospect, was a long-overdue investigation of the airport’s PFAS releases.
That said, the first substantive document delivery of the SIA enforcement action—the initial Site Assessment Report—was made public by Ecology last week. I’ve begun reviewing it and, at first glance, it has some important information to add to the record, including acknowledged data gaps that warrant further investigation.
Tarmac at SIA, looking north
An obvious starting point in such assessments is what investigators often refer to as the “source term”—basically how much of a given toxic substance was used, created, and released to the environment via different processes and release points. It’s crucial in being able to assess exposures from, say, short-lived radionuclides (i.e. iodine-131 from early Hanford operations) that can inflict harm but then vanish by decay. That’s not the case with long-lived PFAS—they are unfortunately stable—but it’s still important to ascertain the parameters of inventory and known releases. The SIA Site Assessment Report begins to cover that ground.
All we knew, prior to last week was in a memo that SIA’s public relations director Todd Woodard created in late 2017 (among the documents obtained via a public records request last year) reporting: “Over the last twenty years, the Airport’s aircraft Rescue firefighting Department expended less than 30 gallons of AFFF (Aqueous Film-Forming Foam Concentrates) during their FAA-required biannual equipment calibration sessions…We do not possess specific information that provides a timeline for the types of AFFF that have been used at Spokane International Airport other than what we know from the past several years.” (emphasis added)
The Site Assessment Report, dated August 13, 2024, begins to fill the PFAS gap. It reports (Table 4.2, p. 13) that the airport’s cumulative site inventory for the most dangerous PFAS—the so-called “C-8” version containing the longer chain PFAS molecules—was nearly 5,000 gallons. While the report doesn’t provide estimates of how much of the PFAS-laden, C-8 foam was released to the environment, it does disclose at least some known instances of how releases may have occurred, including mandatory National Guard fire-training exercises through 1999 and biannual mobile unit certifications until 2016. (See pages 14 & 15). The report also identifies (see Table 8.1, p. 24) ten areas as “Potential or Known PFAS Areas of Concern.”
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The report corroborates the earlier documents from 2017 and 2019 of high levels of PFAS in some of the airports groundwater monitoring wells, including a well near the airport’s Fire Pit Training area where PFAS variants were as high as 5,200 parts per trillion, more than a thousand times higher than the EPA’s new federal drinking standard of 4 parts per trillion. A dozen other wells also tested above the new standard. (See Table 7.2, page 23)
The document—created under contract with SIA by Olympia-based GSI Environmental Inc.—notes that its authors looked at data from 2 public drinking water systems using groundwater within a mile of the airport and that neither system reported positive test results for PFAS in September 2023 tests.
Map showing levels on PFAS on drinking water wells north and east of the Spokane International Airport from sampling done in late spring of this year. (Source, Washington Department of Ecology).
There are, nevertheless, several other indications that PFAS tainted groundwater from SIA may have contaminated nearby private wells and springs. Well testing conducted by the U.S. Environmental Protection Agency in coordination with Washington state agencies earlier this year found (see above map) that most (236) of the 411 private wells tested in an area north and east of SIA had levels of PFAS in excess of drinking water standards. (I should note that the EPA/ECY effort was tailored to well owners outside the zone to the west where the Department of Defense is providing assistance to well owners whose contamination is presumed to come from Fairchild.) The Department of Ecology is currently supplying clean water to those whose well water exceeds actions levels for PFAS.
New Department of Defense memo’s implication for addressing Fairchild’s PFAS contamination
The years-long awaited issuance of the U.S. Environmental Protections Agency’s final rule for PFAS in drinking water ended this spring as EPA set 4 parts per trillion (ppt) as the maximum legally acceptable level for PFAS, and 10 ppt for PFHxS a common variant present in the firefighting foams implicated both at Fairchild and SIA.
The ruling left a large question looming over Fairchild and other federal military installations where releases of PFAS from the use of fire-fighting foams have contaminated groundwater. Since Fairchild initiated its response in 2017, it has been using 70 ppt (an interim health advisory standard issued by EPA) as the action level to provide filtration assistance to more than 100 off-site groundwater users. But, since April, the question has been how the Department of Defense (DoD) would alter its programs to comply with the more stringent final rule by EPA.
According to a September 3rd memo circulated from the Office of the Assistant Secretary of Defense, the DoD plan is to use 12 ppt as its action level to provide clean drinking water (including filtration systems like those used in Fairchild’s orbit) to homeowners whose wells have been contaminated with PFAS emanating from military bases.
On its face, if and when the 12 ppt standard is implemented it would have the effect of making at least dozens of more homeowners on the West Plains eligible for federal government assistance to deal with their contamination. Yet, it also raises the as yet-unanswered question of why the action level is 12 ppt, rather than EPA’s new rule at 4 ppt.
You can read the Environmental Working Group’s analysis and sharp reaction to the Pentagon memo here.
Your can read the Pentagon memo here.
—tjc
