Escanaba Defense Fuel Supply Point (Escanaba, Delta County)

• Between 2015 and 2016, EGLE approved work plans for site assessment activities, coordinated local communications, and reviewed the completed site assessment. 

• In 2015 soil and groundwater samples were collected.  From 2015 to 2016, seven residential wells were sampled. 
• All seven residential wells were non-detect.
• Surface water and sediment samples were collected in 2017. Surface water sample results were above water quality standards for PFOS and the LHA for drinking water for combined PFOS and PFOA.
• According to a December 2, 2017 article in the Escanaba Daily Press, the Hannahville Native American Nation purchased the property and is considering redevelopment of the property.  The Hannahville Native American Nation is aware of the PFAS contamination at the site according to EGLE Remediation and Redevelopment Division district staff. 
• Dave Anthony is the Governmental Affairs Representative for the Hannahville Native American Nation.

• On February 14, 2019, a Base Closure Team Meeting was held between EGLE and the USAF.
• On April 11, 2019, there was a Base Closure Team Meeting held between EGLE and Air Force.
• EGLE has received the Air Force’s May 17, 2019, Draft Final, Second Five-Year Review Report. The Air Force has again stated that they will not consider Michigan criteria for PFOA and PFOS. as part of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Five-Year Review process protectiveness analysis.
• On July 9, 2019, there was a Base Closure Team Meeting held between EGLE and the Air Force.
• On September 6, 2019, EGLE sent the Air Force a letter regarding the five-year review required by CERCLA and the fact that the Air Force did not consider PFAS contamination in the review. The Air Force responded on October 9, 2019 stating that in the five-year review they would not take into consideration whether the current remedy was protective of human health. 
• In an October 9, 2019 letter, the Air Force informed EGLE that they would not evaluate the protectiveness of the current remedy for PFAS contamination in the five-year review they just completed despite exceedances of Michigan health-based Part 201 criteria for both PFOS and PFOA.  Because there are exceedances of PFOS GSI criteria in groundwater and Ambient Water Quality Standards in surface water, human exposure to high level PFAS contamination is possible through fish consumption, as the area is heavily fished. DHHS and EGLE are working out logistics for fish sampling.
• On October 17, 2019, a joint site inspection was held by the Air Force and EGLE staff to ensure deed restrictions on the site were being followed.
• On October 17, 2019, a land use control inspection was completed to ensure deed restrictions on the site were being followed.  There was a discussion of the fact that citizens were fishing the PFAS impacted surface water just off the site and off the pier at the site. There is concern that fishing is a possible route of human exposure to PFAS from the site.  Department of Health and Human Services (DHHS) and EGLE are working out logistics for fish sampling.

• On May 14, 2020, the Air Force issued a Final Five-Year Review Report that does not appropriately address the comments provided by EGLE on the draft Report.  The Air Force failed to account for the potential risks to human health, welfare and the environment associated with PFAS contamination released into the groundwater and the surface water.
• On July 7, 2020, EGLE sent notice to the Air Force that the Final Second Five-Year Review was not done correctly and that the remedy at the site was not protective of human health and the environment.

• Type of Sample	Date Sampled	# of Samples	# of Results Received	# of Non-detects	# Between Non-detect and standard*	#>Standard
  Drinking Water (Residential)	Jul 19, 2018 - Jul 19, 2018	7	7	7	0	0
  Groundwater	Jul 19, 2018 - Jul 19, 2018	6	6	0	0	6
  Surface Water	Jul 19, 2018 - Jul 19, 2018	5	5	0	0	5
  Cumulative		18	18	7	0	11

  *Residential well results are compared to EGLE Part 201 Criteria of 70 ppt and the EPA Lifetime Advisory Level of 70 ppt.
  *Groundwater results are compared to EGLE Part 201 Criteria of 70 ppt.
  *Surface water results are compared to Rule 57 surface water quality values of 12 ppt for PFOS and 12,000 ppt for PFOA. 

  • Sample notes:
    • Surface water samples are from Little Bay de Noc.
    • Groundwater monitoring well results are from on-base wells.
• On September 4, 2020, the Air Force reissued the Final Second Five-Year Review Report that addressed most of EGLE’S concerns with the original Final Second Five-Year Review Report.
• On September 15, 2020, EGLE replied to the Air Force regarding the reissued Final Second Five-Year Review Report stating that EGLE could not concur with the conclusion of the report which stated that the current remedy was protective of human health in the short term. The Air Force did not address the potential for human health risks potentially associated with consumption of fish in Little Bay de Noc contaminated with PFOS from the site.

Sampling: PFOS and PFOA Only

*Residential well results are compared to Part 201 Criteria of PFOS 16 ppt and PFOA 8 ppt. *Groundwater results are compared to EGLE Part 201 Criteria of PFOS 16 ppt and PFOA 8 ppt. *Surface water samples are compared to Rule 57 non-drinking water values of 12 ppt for PFOS and 12,000 ppt for PFOA. 

Sampling notes

• On August 3, 2020, new Part 201 Criteria went into effect.  Historical sampling data compared to Part 201 Criteria >70 is captured in the historical timeline below.
• Other PFAS analytes were detected in samples. There are no federal or state standards for these analytes.