Letter to Dr. Catharine Varley, BRAC Environmental Coordinator - Kildee, Peters, Stabenow Urge Air Force to Comprehensively Address PFAS Contamination, Meet Michigan Standards Near Former Wurtsmith Air Force Base


Date: Sept. 2, 2021
Location: Flint, MI
Issues: Environment

Dear Dr. Varley,
As lifelong residents of Michigan and members of its congressional delegation, we write to
submit our comments for the record with regards to the United States Air Force's proposed
Interim Remedial Action (IRA) plan for Van Etten Lake near the former Wurtsmith Air Force
base (Wurtsmith).
As you are aware, the residents of Oscoda have been subjected to harmful per- and
polyfluoroalkyl substances (PFAS) in their groundwater and waterways--including at Van Etten
Lake--for many years. The contamination is a result of the use of firefighting foam containing
PFAS used by the Air Force at Wurtsmith. While we acknowledge the Air Force's work to
initiate remediation and prepare the proposed IRA, it is insufficient to address PFAS
contamination coming from Wurtsmith and abate the imminent and substantial threats to human
health and the environment from PFAS contamination in the Van Etten Lake area.
Multiple stakeholders have shared concerns that the Air Force plume maps and plans do not
accurately represent how much contamination is actually entering Van Etten Lake, and we urge
the Air Force to work with the State of Michigan to ensure adequate testing and sampling. For
example, the proposed IRA currently calls for 12 extraction wells across what is considered the
worst plume entering Van Etten Lake, yet it only covers part of that plume versus the entirety of
the plume in question. While this should dramatically reduce the contaminants entering the
southern end of the lake, contaminated areas around Wurtsmith will continue bleeding PFAS into
the lake and thus lead to continued toxic surfactant foaming and attendant threats to human
By choosing to focus on one part of one plume area in the proposed IRA, we are concerned that
this and adjacent PFAS plumes will continue to spread unabated. We urge the Air Force to
ensure the number, location, and length and depth of extraction wells accurately capture the
entire PFAS contamination entering Van Etten Lake. Doing so will help ensure that the
continued imminent threats to human health, fish, wildlife, and the environment from PFAS
contamination are addressed.
We additionally wish to register our continued frustration at the Air Force's unwillingness to
utilize the surface water discharge criteria established by the State of Michigan as Applicable or Relevant and Appropriate Requirements (ARAR). The Air Force has stated that the discharge
system included in the proposed IRA "uses best available technology that produces a discharge
with at or near non-detectable levels entering Van Etten Lake." As we noted in a previous letter
sent this spring regarding the proposed IRA for Clark's Marsh, rather than risk doing less now
than what will ultimately be required, the Air Force should instead prioritize human health and
meet Michigan's state standards for addressing PFAS contamination from the start of the
remediation process. This would also have the added benefit of preventing unnecessary
expenditures of taxpayer money on enhancing treatment down the line.
Finally, in light of the recently released Department of Defense (DoD) Inspector General report
evaluating DoD's use of PFAS at military sites around the country and the exposure of both
military personnel and civilians living near military sites, we were pleased to see that the Air
Force engaged in a more transparent rollout surrounding the Van Etten Lake proposed IRA than
had occurred for the Clark's Marsh proposed IRA this spring. We urge you to continue with
meaningful and substantive community engagement with Oscoda stakeholders.