The Captain and the Foam

The Navy is misleading a Maryland
community on PFAS dangers

By Pat Elder
June  7, 2021

Patuxent River NAS Commanding Officer Captain John Brabazon  says the Navy’s  PFAS firefighting  foam is safe.

Patuxent River NAS Commanding Officer Captain John Brabazon
says the Navy’s  PFAS firefighting  foam is safe.

The Patuxent River Naval Air Station says the PFAS foam it sent down the drain on May 16 to the wastewater treatment plant operated by the St. Mary’s County Metropolitan Commission (METCOM) is safe.

It’s not true. The foams are toxic and have been released into the environment. 

Captain John Brabazon, Patuxent River NAS Commanding Officer said in a press statement, “We understand the public’s concern when it comes to issues like PFAS, which is why we have transitioned to the replacement AFFF like the Ansulite.” 

The Navy says the new Ansulite firefighting foam does not contain detectable levels of PFOS or PFOA.  Few seem concerned by the 2,500 gallon release. St. Mary’s Commissioner Todd Morgan commented, “The base says the foam isn’t toxic.”

Captain Brabazon is not telling us the whole truth. 

The Navy claims to have "mitigated the release" of approximately 2,500 gallons of AFFF with community partner METCOM. The reality is, however, that METCOM  delivers wastewater “to a number of different treatment facilities for proper treatment and disposal." This means that the 2,500 gallons made its way to a wastewater treatment plant (WWTP). It is a well-established fact  that the WWTP process does not remove PFAS from discharge effluent and/or sewage sludge/biosolids.

METCOM Director George Erichsen would not confirm the release of the toxins.

The Navy did not mitigate the release. Instead, their actions have exacerbated the impact of the release by providing a nearly direct route to surface waters and possibly to groundwater through land application of WWTP biosolids.  

Denise Trabbic-Pointer, a former Dupont chemist working with the Sierra Club’s Michigan Chapter explained, “Although the Navy says the Ansulite 3% AFFF(AFC-3MS) contains less than 25 ppb of PFOS and PFOA, that doesn't mean that it does not contain or cannot transform to harmful PFAS. The "MS" in the product name means that it meets US Department of Defense Military Specifications. Those specs, as they apply to PFAS, mean that they cannot contain PFOA or PFOS above 800 ppb, respectively. The MS-regulated AFFF can, however, contain any blend of short chain or C-6 PFAS compounds.”

In the case of the Ansulite foam at Pax River, the safety data sheet (SDS) published by Occupational Safety and Health Administration indicates that it contains "polyfluorinated alkyl polyamide",  from 1 to 5%. These dangerous PFAS chemicals transform in the environment to PFBA, PFPeA, PFHxA, PFHpA, and PFOA. Chesapeake Blue Crab has high concentrations of PFBA while PFHxA, PFHpA, and PFOA were found in St. Inigoes Creek, near the Webster Field Annex of the Patuxent River NAS facility, just a few miles from the Chesapeake Bay.

The Ansulite SDS indicates that, under California's responsible environmental laws, this product contains PFOA.  

Polyfluorinated alkyl polyamide is a generic name for a group of PFAS compounds. It is listed by the Toxic Substances Control Act  as requiring export notification because many countries around the world have banned their use. The United States still does not regulate these deadly chemicals, although the Europeans are in the process of banning all PFAS. They’re particularly alarmed by the fetal abnormalities, childhood diseases, and  cancers caused  by several of these chemicals. They’re also taking steps to limit the ingestion of these toxins in food, (especially seafood), which is the number one way PFAS is consumed. They especially want to stop PFAS from entering waterways.

The U.S. government has done none of this. Maryland is also negligent, and just about everyone else seems to be clueless or in denial.

Trabbic-Pointer continued, “The EPA has warnings about the chemicals in the foam that the Navy says are safe. From the EPA: "Based on analogy to other perfluorinated chemicals including perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), and perfluorohexane sulfonate (PFHS), the EPA has concerns that the PMN [premanufacturing notice] substances and/or degradation products will persist in the environment, could bioaccumulate or biomagnify, and be toxic to people, wild mammals and birds." 

PFHxS is a by-product of PFOS degradation in the environment. The Patuxent River, the Chesapeake Bay and the St. Mary’s River are loaded with the Navy’s slowly degrading PFOS. PFHxS has been reported in osprey eggs.

Not enough is known about the chemical substances that result from the degradation of legacy chemical PFOS and PFOA or the Navy’s replacement substances, while they are believed to result in significant health and ecological concerns if released to the environment.

 Trabbic-Pointer, the Sierra Club environmentalist, explained, “If, as Captain Brabazon states, the Navy "understand[s] the public’s concern when it comes to issues like PFAS" they would not experiment with these newer, short-chain versions of the same "forever chemicals" and they would convert all of their firefighting systems to fluorine-free AFFF. The fact is that it is more difficult to treat groundwater and drinking water supplies that are impacted by the new generation short-chain PFAS. The smaller molecules tend to break through conventional treatment technologies like granulated activated carbon (GAC) quickly. If not properly maintained and changed out, GAC systems will allow PFAS compounds to continue on into the drinking water source. Frequent change-out of GAC filters can also become quite expensive for either the water treatment plant or the homeowner.”

Trabbic-Pointer identifies the threat to drinking water posed by these chemicals, although public health is also threatened from the PFAS-contaminated food people consume. The chemicals are flooding our rivers and bays and poisoning seafood, while PFAS-tainted sewer sludge is spread on fields that grow contaminated crops.

What’s in your blood?

Captain Brabazon said the danger was “mitigated.”  He explained, “The AFFF discharged after maintenance to the fire suppression system, but METCOM was quick to let us know when it hit a holding tank, and we were able to respond and de-foam it efficiently.”

This incident, like many others over the years, occurred while the overhead fire-fighting foam suppression system was being maintained. The Navy had to immediately defoam the substance or it would have quickly expanded and overwhelmed the treatment facility. It’s not a matter of working with “a community partner to mitigate AFFF release.” It was a serious crisis. METCOM’s system is not built to handle the expanding foam. Defoaming doesn’t lessen PFAS levels.

Elevated BOD (biological oxygen demand) in AFFF foams is quite high and, depending on the amount discharged and the capacity of the receiving WWTP, discharging it could be cause for mass killing of the beneficial "bugs" at the WWTP.  Finally, defoamers have their own hazards and should not be discharged to surface water or treatment plants.

Captain Brabazon explained, “Ease of communications with MetCom and regulatory partners in the state of Maryland helped us to respond and address the issue with minimal impact.”

Nonsense. “Foaming” the system with 2,500 gallons of AFFF was averted, but toxins were allowed to contaminate the environment. There is no excuse for sending the 2,500 gallons of defoamed AFFF to a WWTP, knowing that it will simply pass through and go back to surface or groundwater.

The captain referred to “regulatory partners in the state of Maryland.” He’s referring to the Maryland Departments of Health and Environment, regulatory agencies that allow the Navy to do whatever it wants.  

Sarah Caspar, a chemist and a biologist, worked for US EPA Region 3 in Superfund (CERCLA) and Waste Management (RCRA). She says she is concerned that  the state of Maryland’s Department of the Environment is unaware of the these releases of PFAS into the waters and tributaries of the Chesapeake may have on the fish, wild life and the citizens in the area. High levels have been found in the blue crabs which are a major tourist attraction as well as the source of income of the fishermen. 

As an EPA regulator, At the request of Mr. Tennant, Parkersburg West Virginia, Caspar investigated the death of more than a hundred of Mr. Tennant’s cattle. The source of contamination was the offsite DuPont  Washington Works facility landfill. The DuPont biologist who monitored the waste that went to the offsite landfill from DuPont’s facility in Washington Bottom, confirmed that PFAS known as C8 was sent to the landfill from the DuPont facility. The story was popularized in the movie,  Dark Waters.

Caspar said, “DuPont previously disposed of the facility wastes onsite which consequently contaminated the local public drinking water and wells off site. Federal action closed the onsite impoundments. DuPont transferred it's wastes to an offsite landfill that was then under state regulation. DuPont stated that offsite landfill contained non-hazardous materials. “It was clear from the study I did that the releases from Dupont landfill was the source of the death of Mr. Tennant’s cattle and was not non-hazardous material”, said Caspar.

It’s the same here in Maryland. I reported high levels of PFAS in St. Inigoes Creek 1,800 feet from a Navy hangar across the creek where PFAS was found at concentrations of 87,000 parts per trillion in the groundwater.  The newspapers quoted the state's top superfund official, and he said, after questioning the legitimacy of the test results,  that the PFAS in the water may have originated from a firehouse or a landfill. The closest firehouse is 5 miles away, nowhere near the river, and the closest landfill is 11 miles away, situated on an entirely different watershed. 

To briefly recap, the Navy is poisoning us, but says the foams are safe. METCOM is silent. The county says the Navy says the foams are safe. The EPA and the state of Maryland know how deadly these foams are, but they’re on the sidelines. Most folks are clueless because the mass media won’t cover the story in any meaningful way.  This is big.

The Ansulite foam mentioned by Captain Brabazon is deadly and some of its chemicals may already be in your body if you live close to the base in Southern Maryland. All Americans have PFAS in their blood and 55-gallon drums like the one pictured above are the source for much of it.

Orders of magnitude

We’ll assume that 5% of the 3% Ansulite water mix is PFAS. The exact percentage is proprietary corporate information. We’re not entitled to know, although the stuff is likely in our blood.

·        3% = 30,000 parts per million.

·        30,000 parts per million x  0.05 (5%) = 1,500 parts per million of PFAS.

·        1,500 parts per million of PFAS = 1,500,000 parts per billion of PFAS.

·        1,500,000 parts per billion  = 1,500,000,000 parts per trillion.

2,500 gallons with a potential PFAS concentration of 1.5 billion parts per trillion were sent to the county’s wastewater treatment plant. The substances become part of the environment, most likely being emptied into the bay or its tributaries. Just 1-2 parts per trillion of PFAS can start the bioaccumulation process in fish, crabs, and oysters that humans consume. The substances don’t easily break down if they ever do.

These releases keep happening at Patuxent River NAS and the contamination becomes exponentially worse over time.

During system testing, Navy technicians usually have to drain each stand-pipe and in the past, likely just dumped it and flushed it to a drain or outside onto the ground. This, along with the frequent accidents, explains why almost all of America’s airports and military bases - and the groundwater and surface waters around them - are severely contaminated.

The thing people don’t seem to grasp is that these chemicals can’t be burned and can’t be buried because both actions ultimately threaten human health. We don’t know what to do with them. The EPA’s interim guidance on PFAS  tells us they’re not sure how to manage PFAS. They’re uncertain about how to handle wastewater saturated with PFAS. They don’t know very much about incineration and how bad it likely is. They don’t know the extent of PFAS-tainted leachate that seeps from landfills, and the EPA is not sure about the contamination caused by spreading PFAS-contaminated sewer sludge on farm fields. They just don’t know what to do, so they’ve decided not to regulate the stuff in any meaningful way, while agreeing to study it more. It’s been their playbook since way before the Trump disaster. 

The DOD dictates environmental policy in the United States of America.

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Interview with George Erichsen, Director, St. Mary’s County (MD) Metropolitan Commission

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The Twin Beaches PFAS Contamination Coalition