PFAS Contamination at Fort Leavenworth Army Base, Kansas Drinking WaterOctober 10, 2023
PFAS Contamination at Alameda Naval Base, CaliforniaOctober 10, 2023
Victims of PFAS Contamination at Wright-Patterson are filing lawsuits against the toxic AFFF manufacturing companies. Stephens and Stephens LLP are investigating airforce water contamination cases countywide on a contingency basis. Reach out to us for a free case evaluation.
Per- and poly-fluoroalkyl substances (PFAS) are a group of synthetic chemicals used for different industrial purposes, including the production of AFFF and plastics, among others. Some of the most common PFAS include perfluorooctanoic acid, (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorohexane sulfonic acid (PFHxS), perfluorononanoic acid (PFNA), perfluorodecanoic acid (PFDA), perfluoroundecanoic acid (PFUnA), and N-methyl perfluorooctanesulfonamidoacetic acid (MeFOSAA).
PFAS are known as forever chemicals due to their ability to remain in the environment without breaking down. Human exposure to PFAS is linked to illnesses like cancer, kidney diseases, liver problems, infertility, and congenital disabilities. The human body cannot break down or eliminate these toxins; thus, they will accumulate with continued exposure. Once released into the air, they get into the soil and water, from where they get into the food chain. They can also get into the human body through respiration.
PFAS contained in AFFF are released into the environment where the compound is used often. The Air Force and Air National Guard bases have used PFAS-based aqueous film-forming foam (AFFF) since the 1970s for training and emergency response. In these locations, the foam made its way to the ground, contaminating the soil and groundwater and exposing the residents to high levels of these toxins. PFAS from AFFF released in air force bases also migrates through the air and soil into nearby water supplies and municipal and private wells.
About the WPAFB
Wright-Patterson Air Force Base is an active air force base located in Greene and Montgomery Counties, southwestern Ohio, east of Dayton City and adjacent to Fairborn City. It dates back to World War I in 1917. The 8,200 acre Base is home to 26,000 civilian, military, and contractor personnel. Generally, the Base is used for industrial, research, and development activities. The base operations include defense-related activities such as acquisition and logistics management, research and development, education, and flight operations.
It has two administrative areas (A and B), separated by railroad tracks and State Route 444. Area A is approximately 5,700 acres and surrounds the Patterson USAF active airfield. It has building complexes, flight facilities, and active runways. The WPAFB area A is used for various activities, including aircraft and vehicle fueling, aircraft and vehicle maintenance, runway and aircraft deicing, munitions and explosive ordnance disposal, warehousing and storage, small arms training, steam and electrical generation, general site maintenance, miscellaneous disposal, office operations, and classroom instruction.
Area B is approximately 2,400 acres, and it contains Wright’s inactive airfield, infrequently used for special occasions such as the Air Force Museum aircraft activities. It contains building complexes for research and development, training, and administrative activities.
Groundwater at WPAFB occurs at different elevations and depths due to the region’s aquifer types and surrounding recharge areas. The aquifer types in the region include water table aquifers occurring in coarse-grained deposits frequent in valley locations and hill region till deposits. Groundwater is also found in bedrock and semi-confined aquifers, but bedrock is not viable aquifers. The Base extraction and monitoring wells have different depths ranging from 3ft to 100 ft bgs.
Testing of PFAS Contamination at Wright-Patterson
The Air Force Base Civil Engineer conducted four quarterly sampling of PFAS Contamination at Wright-Patterson under the long-term monitoring program at specific areas, including Area A and IRP sites within OU3 and OU10. Area A well operations continued with the installation of a treatment unit.
WPAFB well water sampling for PFOS/PFOA was conducted in June 2016 as part of the long-term monitoring program. Due to the high levels of these toxins, the Base put up a quarterly PFOS/PFOA sampling program, which continued until November 2017. The program was followed by a USACE PFAS Investigation, which began in 2018. The two programs were conducted from winter 2017 to summer 2019, but the seasonal differences did not establish any concentration deviation.
Between June 2016 and November 2017, the long-term monitoring program involved quarterly groundwater PFAS sampling of 16 FAA-A monitoring wells. According to the initial quarterly results of February 2017, only well CW08-085 had PFOA and PFOS concentrations of 75.2 ng/L (exceeding the HAL of 70 ng/L). Sampling results from the remaining three quarters were below 70 ng/L.
The testing of PFAS Contamination at Wright-Patterson was based on the previous USEPA HAL of 70 ng/L, the set standards at the time. During the long-term monitoring program, PFOS and PFOA concentrations exceeding the HAL of 70 ng/L were detected in the OU3 FTAs 2, 3, 4, and 5, OU5 downgradient of LF5 and OU10 at the fire training exercise areas. In most wells with high PFOA and PFOS, the PFOS concentration was higher than that of PFOA. Wells with higher PFOA concentrations include CW08-085 and GR-421. The concentrations of these two compounds were equal at OU10-MW-21S. High PFOS/PFOA levels were also detected in WPAFB Area A drinking water wells.
The site investigation report detected high PFOS/PFOA concentrations exceeding the USEPA HAL of 70 ng/L in 20 areas. It recommended an expanded site investigation to evaluate areas of potential interest at the AFFF fire training sites in the facility possibly affected by PFOA and PFOS exposure.
Further groundwater testing was conducted to investigate potential PFAS migration over the southwestern WPAFB boundary toward the City of Dayton wellfield. The US Army Corps of Engineers conducted the sampling (USACE) PFAS investigation contract. The investigation occurred in eight FAA-A monitoring wells over six quarters from March 2018 to June 2019. The results revealed PFOS/PFOA levels below the former HAL limit, with the highest PFOA and PFOS concentration being 30 ng/L from samples taken from well CW08- 085.
A summary of events related to the investigation, management, and remediation of Wright-Patterson PFAS contamination:
- In September 2015, the Preliminary Assessment Report (CH2M HILL, 2015) identified 26 areas of potential PFOS/PFOA usage that required further investigation
- In spring 2016, two water wells were sampled for PFOS/PFOA under the EPA’s Unregulated Contaminant Monitoring Rule 3 (UCMR3). The results indicated high PFOA and PFOS levels above the HALs of 70 ppt.
- In June 2016, the long-term monitoring program was initiated with quarterly PFOS and PFOA sampling.
- In the fall of 2016, Site Inspection (SI) was initiated for AFFF-used areas within the facility.
- In February 2017, the AFFF was replaced in fire trucks
- In June 2017, the treatment of Area A drinking water supply wells #8 and #9 using the GAC system was initiated
- Between March 2018 and June 2019, the quarterly PFOS/PFOA sampling in wells at the downgradient perimeter and within the WPAFB boundaries
- In June 2018, the Final Site Inspection Report of Aqueous Film Forming Foam Areas at Wright-Patterson Air Force Base was completed
- In June 2018, the Expanded Site Inspection (ESI) Report of Aqueous Film Forming Foam Areas at Wright-Patterson Air Force Base was completed, and an expanded investigation for PFOA and PFOS in affected areas began.
- In September 2018, AFFF was replaced at nine hangars
- In September 2019, the PFAS destruction pilot studies at WPAFB began
The EPA Drinking Water PFOA and PFOS Advisory
In June 2022, the EPA updated the drinking water Lifetime Health Advisory (LHA) to PFOA levels of 0.004 ppt and PFOS of 0.002 from the 2016 LHA levels of 70 ppt. The new advisory is based on new research considering lifetime exposure, which established that even PFOA and PFOS levels close to zero could have adverse effects.
The Air Force uses the LHA guidelines to determine the safe PFOS/PFOA levels in drinking water (under the Comprehensive Environmental Response, Compensation and Liability Act). However, the LHA levels are not enforceable. The first round of groundwater well sampling to assess the impact of AFFF release under the Air Force-wide PFOA and PFOS initiative occurred in June 2016. Quarterly sampling at select base boundary (sentinel) wells went on, with AFFF Area Site Inspection and Expanded Site Inspection completed in 2017 and 2019, respectively.
Remediation of PFAS Contamination at Wright-Patterson
Remedial Investigation (RI) was carried out at AFFF Sites. It involved collecting data, characterization of site conditions, determining the extent of PFOS/PFOA, identifying potential exposure pathways, and collecting data to support risk assessment for human health and the environment. This investigation involved 16 AFFF sites and was intended to evaluate them for possible remediation. It entailed 100 (75% of the monitoring wells) and 52 soil boring. One hundred forty-six groundwater samples were collected from new and 46 existing wells and sampled twice. Over 372 soil samples, 116 surface water and sediment samples, and 18 lysimeter samples were also sampled four times each.
The Air Force is proactively working toward preventing future PFAS exposure by limiting PFAS-based AFFF to emergency use. They replaced the toxic foam with Phos-Chek 3 percent, six-carbon chain AFFF. Additionally, they prevent foam release by installing auto mechanisms for testing the fire vehicle’s functionality, which doesn’t involve releasing the foam into the environment. They also standardized the hangar systems and replaced those containing the PFAS-based foam. Firefighting training is now carried out in double-lined pits to safeguard against the impacts on the ground, and any uncontained AFFF release is treated as if it were a hazardous material.
PFAS Contamination at Wright-Patterson Attorney
If you or your loved one suffered from PFAS-related illnesses after taking AFFF-contaminated water, you could be eligible for compensation. Contact Hugh at Stephens and Stephens LLP for a free case evaluation. Those eligible include military, contract employees, and civilians who lived in military and airforce bases where AFFF was used, and site inspection reports identify the presence of these toxins in drinking water.
Defendants in these lawsuits include companies producing PFAS-based AFFF, such as 3M, DuPont, Chemguard, Chemours Company, Tyco fire products, and National Foam. Victims of PFAS Contamination at Wright-Patterson cannot file lawsuits against the DoD because the US military is immune from all forms of litigation.