Navy’s Dog and Pony Show on Poison PFAS in Groundwater Falls Flat in St. Mary’s County, MD

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St. Mary's County Commissioners - Back row - Eric Colvin, John O'Connor, Mike Hewitt. Front row - Todd Morgan, Randy Guy
St. Mary's County Commissioners - Back row - Eric Colvin, John O'Connor, Mike Hewitt. Front row - Todd Morgan, Randy Guy

This lengthy piece examines in detail  PFAS contamination by the navy in one county in Maryland. It’s important for communities across the country to understand the psychological campaign being waged by the Department of Defense to evade liability associated with its continued use of PFAS chemicals.

On December 8, 2020 David Steckler, the Remedial Project Manager of the Naval Facilities Engineering Systems Command (NAVFAC) addressed (42:55-)  the St. Mary’s County MD Commissioners on the presence of per and poly fluoroalkyl substances (PFAS) at the Patuxent River Naval Air Station and in the adjacent St. Mary’s County community.

Mr. Steckler’s presentation was an insult to the people of St. Mary’s County because of numerous misstatements of fact. Even the title of his presentation was misleading, “Potential for PFAS in Environmental Media NAS Patuxent River and OLF Webster Field.” Last year, the Naval command was forced to publicly admit to the presence of PFAS on base.
In St Mary’s County, like so many communities across the country, the public is largely clueless regarding the serious threat posed by the Navy’s continued use of these chemicals.  It is imperative for the people of St. Mary’s County and elsewhere to understand the history and the dynamics behind this meeting between the navy and representatives of this rural Maryland community.


Steckler set himself up for derision by attempting to defend a five-year lag in reporting PFAS test results by explaining that the results and data analysis require six weeks to complete. Commissioner Todd Morgan called him out on it. Steckler said he didn’t want to “get into specifics” as he went through his highly scripted and often repeated talking points.

The Navy is under pressure here. The command cancelled the “public” hearing on PFAS it had planned for October. This would have been the first time since 300 concerned citizens crowded into the Lexington Park Library that people outside of the naval command would have had an opportunity to hear the Navy defend its continued use of toxic PFAS chemicals. 


Comments by Project Manager Steckler, Commissioner Todd Morgan, District 4; Commissioner Mike Hewitt, District 2; Commissioner Eric Colvin, District 1, and Commissioner President James Randy Guy are followed by analysis.Steckler – The RAB (Restoration Advisory Board) meeting –  is our mechanism to reach out to the public to tell them about our work with the environmental restoration program.. We decided this time to postpone. We wanted to wait for all of the PFAS data to come in. We are currently targeting mid-March.

Military Poisons – The RAB is a carefully scripted and largely one-way exchange of information that is poorly promoted in the community, and often attended by more active Navy personnel and contractors than members of the public.  The Navy must be compelled to hold truly open meetings – the kind where anyone is allowed to approach a microphone and ask a direct question. This is a democracy and this is our Navy. The naval command must answer to us. Steckler says the Navy is committed to transparency. Having open meetings would be a great way for the Navy to demonstrate its commitment to transparency. 


St. Mary’s is the mother county of Maryland.Morgan – (46:45)  Obviously, there’s quite a number of people concerned about the PFAS contamination levels throughout the county… So, I’m wondering, you say you’ve got the data. So, are we waiting till March to get this data released?  They’re kind of edgy in some areas of the county, particularly some of the watermen, some of the residents.  I was at the last briefing a couple of months ago and obviously, it was a little contentious. I don’t see… when some better answers may be available for the residents to try to help them with their concerns.

Steckler  We are certainly very aware of the public concerns and, in fact, in my next slide, I address a little bit of that, so if we can move on and look at this slide and go through it.

Morgan  (Interrupting..) Can you tell us when you started the investigations?

Steckler 2018 is when we completed the preliminary assessment (PA) … We initiated the PA at Pax River in 2016.

Morgan So we started in ’16. We did something new in ’18 and then we did more studies in ’20 and maybe we’ll get a report in ’21. I’ve got that right in my head?

Steckler – That’s correct. The CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act)  process is not the fastest process. We work very closely with our regulatory partners. We have to address all of their concerns before we go out to the public and because of that, it tends to take time..

Military Poisons – Nonsense.  We tested the water and had several scientists examine the results and the process took two weeks. PEER (Public Employees for Environmental Responsibility) tested seafood, had scientists look at the data, and their process took three weeks.

The DOD is driving this train. The DOD is facing massive liability for its reckless behavior so it’s in no hurry, while the EPA and the MDE are complacent and largely subservient. The same story is being played out across the country. When communities have attempted to sue the DOD for damages caused by PFAS, the military claims “sovereign immunity.” In other words, they reserve the right to poison us.

Steckler – We do the field work, we send the results to the lab. The lab takes 28 days to analyze it, then we have another two weeks to have the data validated by a third party and then we begin to look at it and that takes time.

Morgan –   From the time you collect it and do the data that is 6 weeks. If I just did my math correct, we’re still looking at five years.. 6 weeksI’m just asking questions that the residents and the watermen ask me, so I’m just bringing it up.

Military Poisons – Great question from Commissioner Morgan.


There’s a lot of untold history. Pax River apparently missed an early deadline for submitting its PFAS test results to the DOD, particularly regarding groundwater. The poisons run through groundwater and surface water to empty into the bay, according to engineer’s reports commissioned by the Navy.  (See NAVFAC – 1.3.4 – Human Receptors)No results from Pax RiverA DOD report published in March of 2018 omitted results from Pax River. The report, Addressing Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA) – Maureen Sullivan Deputy Assistant Secretary of Defense was intended to provide PFAS totals found in drinking water and groundwater. Naval installations across the country submitted their findings, but not Pax River.

Nine months before the DOD report, in June, 2017,  the Navy found 1,137.8 ppt of PFOS/PFOA  in the groundwater not far from the intersection of Hermanville Rd. and Rt. 235.

Few outside of the command or the engineering contractors knew about the contamination until Military Poisons reported it in June of 2019.  Local and regional press outlets didn’t see it as newsworthy. A CNBC film crew finally aired the story. 
CNBC was intrigued that Pax River had missed the DOD deadline and had not tested the wells of residents who live in the predominately African American community close to the boundary. CNBC reported on the State Health Department’s concurrence with the Navy that private wells didn’t need to be tested.

The Navy’s report cited above says the groundwater cannot reach residents who live outside the base. They say the toxic plumes and streams that originate on the base stay within the station boundaries before emptying into the Chesapeake Bay or the Patuxent River

The base command says, “There is no current complete exposure pathway to people from releases of PFAS to on or off base receptors.”  The Navy defines “human receptors” as “any users of drinking water on or off the base with ingestion considered the major exposure pathway.”  They don’t mention contaminated seafood, even though this is the most prevalent way people ingest the toxins.

But this is only part of the story.

Steckler is correct that the “preliminary assessment” was initiated in 2016. They just failed to tell anyone the results. And that could be because the results are astronomical. Pax River belatedly reported 1,137 ppt on a far corner of the base. They found a discarded container that may have contained the foam.  ​


A firetruck sprays AFFF foam containing PFAS during a training exercise at the Jacksonville NAS a few years ago.Here’s a snapshot of a few Naval installations of somewhat comparable size to Pax River that were included in the DOD report:   
​                         
(PFOS/PFOA – in groundwater in ppt.) Although there are 6,000+ varieties of PFAS, the Navy often limits its reporting to these compounds.

China Lake, CA                8,000,000 ppt
Dallas, TX                         1,247,000 (BRAC)*
Jacksonville                     1,397,120
Oceana, VA                        493,600
Port Hueneme, CA        1,080,000
Tustin, CA                          770,000

*The Dallas NAS closed in 1998, but these are forever chemicals. Mountain Creek Lake near the base is severely contaminated and consuming fishing is prohibited.

=======

In MD, the Navy has reported these levels:
Chesapeake Beach           241,000
Annapolis                             70,000
=======


Site 14 is an epicenter of PFAS contamination in St. Mary’s County, MD.Naval installations across the country have reported massive quantities of AFFF containing PFAS at the burn pits and outside of the hangars that are outfitted with overhead suppression systems. Not Pax River. We still don’t have the results Commissioner Morgan was referring to.

The Site 14 burn pit is located in the middle of the airfield immediately adjacent to Echo South Taxiway in the east-central portion of the base. Petroleum fuels were ignited on the burn pad and extinguished with AFFF foam to practice fire training. 

Site 41 also contains a burn pit that is known to contain AFFF, although we don’t know how bad it is because they’re not telling us. Building 1669, Hangar 110 Hangar 2905, Hangar 2133, and Hangar 2385 have all had massive releases of AFFF. These would be excellent places to look for PFAS in groundwater.  Perhaps the Navy could invite independent scientists on base to test these areas. Even after sinking new wells, they ought to be able to have the results back to us in a few weeks. We could raise the funds if that’s the problem.

Building 1669 sent 500 gallons of the toxic foam into Metcom’s system. In April 2015, the contents of a 2,200-gallon tank of AFFF concentrate for the suppression system was released from Hangar 110 due to mechanical failure. It went into the ground.

Hangar 2133 has had many releases of AFFF. In 2002, 2005, and 2010 there were releases of the foam from the overhead suppression system in the hangar. In at least one incident (date unknown) the entire system, containing thousands of gallons of AFFF,  inadvertently went off.


Hangar 2835: AFFF concentrate storage tanksHangar 2835 has had several releases of AFFF foam  in 2012-2015 due to spills, mechanical rupture in cold weather, and inadvertent activation of the system. Hundreds, if not thousands of gallons are also believed to have emptied into Metcom’s sewer system. In 2010 METCOM had to shut off sewage flow and deal with massive amounts of AFFF in all the aeration basins. This incapacitated the treatment facility and potentially contaminated the system for years. These are, after all, “forever chemicals.”  

And now, we understand, the Navy is looking for The St. Mary’s Metropolitan Commission  to take over its sewer system. Across the country, the Navy is eager to “privatize” its sewer systems.  

The town of  Oak Hill, Washington recently ceased negotiating the purchase of the sewer system  at the Naval Air Station Whidbey Island, a base heavily contaminated with PFAS. A town official familiar with the deal said,  “The Navy wants to get out of the water and sewer business.” Taking over Pax River’s sewer system would mean assuming its liability.
One drop of this stuff in a drinking reservoir the size of an Olympic-sized pool would poison the water. Tiny amounts contaminate sea life and crops that are grown in soils where toxic sewer sludge is spread.  

Back to the commissioner’s meeting..


The water part is misleading. The oyster part is untrue.Steckler – I certainly understand your concerns. Again, it is a relatively slow process.. We are doing our best to fast track things…. Next slide.. So this gets to a little bit of the public concerns…Based on the meeting in March, the Maryland Department of the Environment announced they would be doing a pilot study for surface water and oyster sampling around both Pax River and Webster Field. PFAS was detected in surface water at very, very low concentrations. PFAS was not detected at all in oyster tissue. 

Military Poisons –  The water –   Steckler says “very, very low PFAS concentrations”  were detected by the MDE in surface water, and this is true, but he fails to explain how the chemicals bioaccumulate in marine life. According to the MDE, the surface water in the St. Mary’s River contained 13.45 ng/l (ppt) of PFAS contamination.  The St. Mary’s River has more than a hundred times the pollution of the .13 ng/l limit established by the European Union.  The Wisconsin Department of Natural Resources says that surface water levels throughout the state that exceed 2 ppt pose a threat to human health. 

The high levels of PFAS in the water ensure that all aquatic life are saturated with the toxins.  It only takes 1 or 2 part per trillion of these chemicals in seawater to trigger an exponential increase of the contamination in aquatic life.  
It helps to explain why and how tests performed by Eurofins Scientific, a fully licensed, certified, and terribly expensive lab found crab backfin  containing 6,650 ppt, an oyster with 2,070 ppt, and a rockfish with 23,100 ppt. of various PFAS chemicals.  All were caught within close proximity of the Webster Field Annex. The tests were performed on behalf of the Public Employees for Environmental Responsibility, (PEER).  

The oysters   –   The PFAS Pilot Study,  commissioned by the Maryland Department of the Environment, concluded that although PFAS is present in tidal waters of the St. Mary’s River, the concentrations are “significantly below risk based recreational use screening criteria and oyster consumption site-specific screening criteria.” Experts in the field say they don’t know what this means. While the report makes these broad conclusions, the analytical methods and basis for the screening criteria used by MDE are questionable, resulting in a misleading of the public, and providing a deceptive and false sense of safety. The MDE’s conclusion over-reaches the reasonable findings based on the actual data collected and falls short of acceptable scientific and industry standards on several fronts. 

The tests performed by Alpha Analytical Laboratory for the MDE had a detection limit for oysters at one microgram per kilogram (1 µg/kg) which is equivalent to 1 part per billion, or 1,000 parts per trillion. (ppt.)  Consequently, as each  PFAS compound is detected individually, the analytical method employed was unable to detect any one PFAS present at an amount of less than 1,000 parts per trillion.  The presence of PFAS is additive; thus, the amounts of each compound are appropriately added to arrive at the total PFAS present in a sample.

Let’s put it a different way. Let’s say you found 800 ppt, 456 ppt, 654 ppt, 378 ppt, 399 ppt, 832 ppt, of six different types of PFAS.  You’d add them up and say there’s a total of PFAS at 3,519 parts per trillion. MDE/Alpha Analytical adds them up and says “No Detect.”

See: this article, Report Deceives Public.  I shared a byline with one of the nation’s leading experts to offer a critique of the bogus report.  St. Mary’s is attracting national attention in scientific circles.

Alpha Analytical, it should be noted, was fined $700,000 by the state of Massachusetts for reportedly mislabeling containers of hazardous waste and failing to take required safety precautions. Only a tiny number of the hundreds of testing labs across the country have been found guilty in civil proceedings.

NAVFAC’s Steckler also referred to the testing of water performed by Eurofins on behalf of the St. Mary’s River Watershed Association.  He said the levels were “very, very low” in the water, but he did not reference the association’s results for the oysters.  The water test results showed the bivalves at Church Point contained more than 1,000 ppt of PFAS.  As stated above, the oyster tested on the north shore of St. Inigoes Creek by Eurofins/PEER contained 2,070 ppt, but that location is 2,600 feet across from Webster Field, while the Church Point oyster was 2.5 miles north of Webster Field.

Back to the meeting. 


Colvin – When we talk about the remedial investigations, is that determining how the problem will be fixed or is that actually cleaning up the PFAS?

Steckler – (After several minutes of confusing talk employing a heavy dose of Naval jargon) The short answer is No. It’s not looking at cleanup. It’s looking at really understanding what the levels of contamination are and what are the risks at the site.

Military Poisons – Colvin’s question is brilliant, not only because it addresses the indeterminable timeline, but because it also addresses “cleanup” –  a word the Navy would prefer not to address or even utter. Steckler’s answer to Colvin is ridiculous because the Navy has known the levels of contamination for 5 years.

Colvin – Maybe you mentioned this, and I just missed it, but what’s the timeline of the remedial investigation?

Military Poisons – Colvin doesn’t miss much.

Steckler – (after several minutes of convoluted discourse) CERCLA is a complicate process, etc.

Colvin – So, optimistically, a year from now, Would the RI’s be complete – or would that be too optimistic?

Steckler – Based on historical experience, I would say that would be too optimistic.

Military Poisons –  The Navy isn’t planning on cleaning up much in St. Mary’s County.  The entire notion of cleaning up the dizzying variety of PFAS chemicals is overwhelming. It’s simple enough, though expensive, to filter the stuff out of drinking water, but most of the PFAS in our bodies comes from eating seafood from contaminated waters. (See EFSA and Christenson, et. al.)  It is contemptible that the Navy continues to focus on drinking water while refusing to address the greater threat to public health posed by the seafood it has contaminated.  

Scientists don’t have an answer to the problem. These chemicals don’t break down in nature.  They can be compared to the half-life of nuclear radiation in this regard. PFAS is part of the environment. It is deeply ingrained in the soil, in the sediment and it is part of the water for our lifetimes and perhaps for a thousand generations. Our focus now must be to stop using them, especially considering that we don’t need them.  We can hope for the science to catch up, but until then we are like Daedalus of old.

Hewitt – I assume you’re not using PFAS any more for fire suppression at the base. Do you have an alternative?

Steckler – PFAS is still used in emergency responses only.  AFFF foams are a life changing technology. They can’t be phased out until another product comes along that meets the same life-saving standards. DOD is working on fluorine-free alternatives.

Military Poisons – This is a great question from Commissioner Hewitt. First, we must be mindful of the thousands of gallons of AFFF accidentally discharged into the soil and sewers of St. Mary’s County. Claims data over the past decade analyzed by insurance provider Global Aerospace indicated that there was not one instance of an intentional discharge of an overhead suppression system in response to an actual fire. But, the Navy’s F-35’s are valued at somewhere near $100 million each, so decision makers figure it’s worth the risk to the public and the environment.

Most of the world follows the lead of the International Civil Aviation Organization (ICAO) to manage the administration and governance of international air travel. The ICAO has approved several fluorine-free firefighting foams (known as F3) that they say have matched the performance of AFFF used by the U.S. military. F3 foams are widely used at major airports worldwide, including major international hubs such as Dubai, Dortmund, Stuttgart, London Heathrow, Manchester, Copenhagen, and Auckland Koln, and Bonn. All of the 27 major airports in Australia have transitioned to F3 foams. Private sector companies using F3 foams include BP and ExxonMobil.  They were concerned about the environment and the health of people in their communities.The world is moving away from PFAS firefighting foams.An expert panel convened by International Pollutants Elimination Network, (IPEN), gathered in Rome in 2018 to celebrate the end of the use of PFAS foam in many corners of the earth outside of the US. See their report:  Flourine-Free Firefighting Foams (3F) Viable Alternatives to AFFF. They’re pretty tough on the Americans.

Back to the meeting..

Hewitt – OK, the reality is that we’ll continue to use PFAS until we come up with something new and if you have Navy bases or aircraft around, then that’s probably going to be a reality. Isn’t that true?

Steckler – If there was an emergency response, yes. But training with AFFF was discontinued a number of years ago. It will only be used in an emergency response.

Hewitt – OK; absolutely. I agree with that.

Military Poisons – Hopefully, you’ll change your mind, Commissioner Hewitt. 

Commissioner President James Randy Guy  – Thank you, sir, very much for your briefing. I hope you get your studies done rather quickly.

Military Poisons – Communities across the country have been victimized by this same sort of dog and pony show the St. Mary’s County Commissioners were subjected to. It is encouraging the commissioners are willing to demand transparency and accountability. Human health is in the balance.

Women of St. Mary’s County who are pregnant or may become pregnant should not consume food or water containing these chemicals.  ​ 
PFAS prenatal exposure linked to miscarriage in second trimester..
PFAS prenatal exposure linked to low birth weight.
PFAS prenatal exposure linked to Cerebral Palsy
PFAS prenatal exposure linked to bronchitis and ear/throat infections in children
PFAS prenatal exposure linked to frequency of childhood diseases
PFAS prenatal exposure linked to neuropsychological development in girls at 4 years of age.

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