Source: https://mibiz.com, March 17, 2019
By: Matt Gryczan
Michigan needs to buckle up for a long, long ride on the PFAS rollercoaster.
If history is any guide, coming up with workable solutions to PFAS contamination around the state is going to take decades of painstaking work, billions of dollars and many awkward dances of cooperation between companies, government agencies and citizens groups.
The sheer scope of the problem almost guarantees that patience will be a virtue when it comes to dealing with PFAS, short for per- and polyfluoroalkyl substances. PFAS chemicals are found everywhere in modern life, and PFAS pollution is being discovered at landfills, manufacturing sites, airports, waterways and sources of drinking water.
It’s not just the ubiquity of PFAS that makes it a problem. PFAS-detection technology has raced ahead of technology to remove it from the environment. Science is still developing a clear idea of the long-term effects on human health that come with ingesting microscopic amounts of PFAS. Experts also remain uncertain about which of the nearly 4,700 PFAS chemicals should be classified as “emerging contaminants” in need of regulation.
Individuals with firsthand experience of previous massive, messy environmental problems say there aren’t shortcuts to fact-based remediation — or for negotiating liability. Calls for immediate answers are fanciful and sometimes counterproductive, they say.
“When the horses are running as fast as they can, when you whip them, you draw blood but you don’t make them run any faster,” said Kenneth Kornheiser, president of the Kalamazoo River Watershed Council that helps oversee the cleanup of the Southwest Michigan river system. “And right now, I believe that the (Michigan government) agencies are running as fast as they can to try and get caught up with the PFAS problem.”
Kornheiser said the current system of environmental remediation is “very slow, very difficult, and very frustrating,” but it does produce results.
Alan Schwartz, an attorney at the Grand Rapids law firm of Miller, Johnson, Snell & Cummiskey PLC with 30 years experience in environmental law, said the general public often is unaware of the complexity of the problems.
“The public’s reaction is kind of interesting” with regard to expectations, Schwartz said. “People begin to ask: How come this hasn’t been dealt with? How could you let this happen? Why is this taking so long to clean up?
“The problem is that the information and technology and the procedures that you need to clean it up are lagging way behind the introduction of these types of chemicals.”
Through all the turmoil, however, it appears that Michigan and the nation overall are responding quicker and more decisively to environmental issues such as PFAS than they did decades ago when dealing with harsh chemicals like polybrominated biphenyls (PBB) and polychlorinated biphenyls (PCB).
Two cases studies in particular — one involving the Kalamazoo River and the other involving a chemical plant in the St. Louis/Alma area of mid Michigan — offer perspective on what it takes to accomplish cleanups on a grand scale and how far the nation and state have come in response to such emergencies.

Been Here Before

In 1974, news reports started filtering out that a worker at Michigan Chemical Corp. had mislabeled bags of the flame retardant PBB. As a result, more than 500 pounds of the chemical was mistakenly mixed with animal feed used at farms across the state. While the mistake occurred in May 1973, it took nearly a year for farmers to convince company and state officials that something terrible had happened.
After sifting through studies and recommendations from experts, the state legislature passed a law in 1977 that reduced the state’s PBB action level to 20 parts per billion in cattle fat — a fraction of the 1 part per million level used previously to identify contamination. Experts have estimated that millions of people in Michigan ingested PBB through contaminated foods while the tragedy was unfolding.
“We were living in Chicago at the time, and I remember seeing on TV that farmers were shooting their own cows that were contaminated with PBB,” said Edward Lorenz, emeritus professor at Alma College and vice chairman of a citizen’s advisory group that monitors the cleanup of the site where PBB was manufactured. “And I said to myself: Where is that happening, and why?”
More than 30,000 dairy cows, 1.5 million chickens and tons of eggs, cheese and dried milk products were eventually destroyed in Michigan. The incident is still considered one of the largest cases of food contamination in U.S. history.
The PBB incident opened the window on other instances of negligent handling of hazardous chemicals, including the insecticide DDT, at Michigan Chemical Corp., later known as Velsicol Chemical Co.
The Velsicol plant is now listed as a mega site on the U.S Environmental Protection Agency’s list of 65 Superfund sites in the state of Michigan.
About the same time that PBB was contaminating Michigan’s food supply, another Superfund mega site was in the making near the city of Kalamazoo. State officials discovered high concentrations of PCB in the sediment and fish that lived in the 80-mile stretch of the Kalamazoo River and Portage Creek watershed leading to Lake Michigan.
The news didn’t come as a tremendous shock to those familiar with the river. Large stretches of the Kalamazoo River were placed on the condemned list of state waters in 1949. Reports at the time described the waterway as looking like a “milkshake” pouring into Lake Michigan. Paper mills along its banks had long polluted the river with wastes that robbed the water of oxygen, rendering long stretches lifeless of fish. Life Magazine’s “Picture of the Week” for Oct. 5, 1953 showed what it billed as “four acres of carp corpses” floating in nearby Dumont Creek.
But PCBs represented a whole new chapter in the pollution of the Kalamazoo River. The odorless, tasteless and colorless PCB found its way into the watershed starting in 1957 as paper mills recycled carbonless copy paper that used the chemical. Manufacturers stopped using PCB in carbonless copy paper in 1971, but state officials determined that PCB continued to enter the Kalamazoo River watershed after that year from at least five disposal areas.
Now more than 40 years later and with hundreds of millions of dollars spent, work continues at both Superfund sites.
“2035 is probably a good guess at the completion of the project, and we are trying to expedite the work,” said Jim Saric, EPA remedial project manager in charge of the Allied Paper Inc./Portage Creek/Kalamazoo River Superfund site. He added that the price tag on the cleanup project may be about $1 billion, paid primarily by the companies that engaged in releasing PCBs in the watershed or that now own the properties of known PCB sources.
Meanwhile, Tom Alcamo, EPA project manager for the Velsicol site, said he expects construction at the project to continue for at least another decade. The project will probably cost about $500 million to complete, paid for largely by federal tax dollars.

Same Difference

There are important differences between the Velsicol and Kalamazoo River Superfund sites and what is happening now with PFAS.
But there are also some similarities that can help to set rough reasonable expectations as to how to attack the chemicals and what it will take to solve the problems of PFAS at locations such as Wolverine World Wide Inc.’s former tannery site in Rockford.
The contaminants — PBB, PCB and PFAS — belong to the same family of chemicals of halogenated organic compounds. They are prized by industry and consumers alike for their remarkable stability, even in hellish conditions such as chrome plating baths, transformer oils or home cookware.
The normal processes of nature don’t readily break down PBB, PCB and PFAS. When they enter the environment, some halogenated hydrocarbons accumulate in the tissues of animals and then “biomagnify” as they move up the food chain: Fish eat worms or ingest sediment with PCB, humans eat PCB-laden fish and PCB accumulates in their tissues to an unhealthy level.
It took decades from the time PCB and PBB were introduced as industrial products to the time that their manufacture was banned in the United States when evidence of bioaccumulation and potential health risks became clear.
The EPA has started evaluating whether to designate PFAS chemicals known as PFOA (perfluorooctanoic acid) and PFOS (perfluorooctanesulfonic acid) as “hazardous substances” under federal statutes. This could result in placing known PFAS sites under consideration as Superfund sites.
U.S. Sen. Gary Peters, D-Mich., recently supported federal legislation to mandate that the EPA declare PFAS as hazardous substances. The move “would make contaminated sites eligible for cleanup funds and more clearly enable a requirement that polluters undertake or pay for remediation,” according to his office.

Seek and Find

In the cases of the St. Louis and Kalamazoo River Superfund sites, it took years before all stakeholders — companies, agencies and the general public — became fully aware of the scope of contamination problems. Similarly, though it’s been dealing with PFAS for two years, Michigan still is discovering new areas of PFAS contamination.
Michigan is at the forefront of the nation when it comes to aggressively seeking out sites with potential PFAS contamination, according to government and private industry officials. Consequently, new sites are being found in Michigan on an almost daily basis, said Al Taylor, hazardous waste section manager for the Michigan Department of Environmental Quality (MDEQ), who manages a contaminated industrial site in metro Grand Rapids where PFAS has been detected.
“It’s becoming much more of a national issue,” Taylor told citizens attending a February informational meeting about the Lacks Enterprises site. “We (in Michigan) happen to be on the pointy end of the issue because of Wolverine.”
Footwear and apparel maker Wolverine dumped wastes from its Rockford tannery operations at sites in northern Kent County starting in the 1950s. The company became embroiled in legal and environmental issues after it was discovered in late 2016 that the waste has been contaminating widespread areas of surface and groundwater with PFAS.
The response to PFAS contamination appears to be tracking the same path as the PCB and PBB catastrophes, but the state and the nation appear to have learned quite a bit along the way.
After the initial discovery of the problem, citizens and environmental groups generally call for the immediate halt to the use of the emerging contaminants and expedited cleanup of known sources. In practice, it takes years to accomplish that work because of its sheer scope, cost and need for cooperation between parties with conflicting agendas.

Marathon or Sprint

History shows that after the discovery of major contamination events, the next phases of immediate and long-term actions take years to implement.
Applying a triage approach, the state and federal governments concentrate their efforts first into pinching off those points where humans may ingest the chemicals through drinking water or sources of food. Some of the efforts can be dramatic, such as the emergency connection by the city of Parchment to the Kalamazoo City water system last summer after the MDEQ tested high amounts of PFAS in Parchment’s water.
But some remedies still take time, as contamination continues to get discovered. Last year, the Gratiot Area Water Authority completed work on a $45 million project that supplies untainted water from municipal wells to citizens of Alma and St. Louis — more than 30 years after the devastation at the Velsicol site. St. Louis discovered in 2005 that its city wells were contaminated, and it connected to the Alma city water system in 2015.
Protection of public health and remedial action may seem to plod along, but the questions of liability and practical ways of correcting large-scale contamination are difficult to resolve. On both the national and state levels, Michigan and the EPA have evolved their policies to move projects forward faster and keep the public better informed than 40 years ago.
Before Velsicol, department heads at the state level didn’t know who was responsible for environmental issues, and departments didn’t communicate well with each other.
“When the problems with DDT in the Pine River were first brought up, there was no state agency to even deal with it,” said Lorenz, the emeritus professor at Alma College. “In 1935, the Saginaw City Council unanimously passed a resolution asking for the state to shut down the contamination in the Pine River, (and) the state turned it over to the University of Michigan’s water program because it didn’t have an environmental agency.
“Now we have the MDEQ and the EPA. We may have complaints about people dragging their feet, but we are better now.”
During the DDT and PBB debacle in St. Louis, it was clear that state agencies weren’t used to coordinating efforts and communicating with the public.
“It took a couple of years before the state’s department of agriculture and the department of public health and the department of natural resources all talked to each other about the mixup, and that’s understandable,” Lorenz said.
Lorenz and others said the state’s response to PFAS is a marked contrast to its reaction to the Velsicol situation. Under direction of former Gov. Rick Snyder, the state launched the Michigan PFAS Action Response Team (MPART) to coordinate the work of local, state and federal agencies and “to investigate sources and locations of PFAS contamination in the state, take action to protect people’s drinking water, and keep the public informed…”
MPART says it is the first multi-agency action team of its kind in the nation.
Since its inception, MPART has held more than 18 public meetings across the state to inform citizens about PFAS and the actions being taken to protect public health.

Getting to the point

Michael Lunn, utilities director for the city of Grand Rapids, said in dealing with PFAS city officials have ripped pages from the PCB and mercury playbook from years ago: Review known sources of the contaminant, collect data on concentrations, elicit cooperation to reduce emissions, then go after unknown sources with detective work on the city’s sanitary sewer system.
The city met with 18 of the largest PFAS dischargers in January to develop PFAS reduction programs similar to ones instituted for PCB and mercury. Grand Rapids has more PFAS dischargers than the group contacted in January, and the city will systematically test discharges and review and adjust plans proposed by the dischargers to reduce emissions, Lunn said.
“We told them that we’re going to take a best management approach to PFAS, which is also going to take time,” he said. “We generally get good cooperation from our local companies, and they all see this as an issue.”
It is anyone’s guess at this point what the total cost may be in Michigan to assess, control and remediate sites contaminated with PFAS and the price to protect drinking water, but the costs could reach into the billions of dollars.
At the end of February, there were 46 sites with PFAS contamination listed on the MPART website and the number may rise as more sites are being tested for the chemicals. MDEQ is conducting testing in drinking water, groundwater, lakes, streams, soils, sediments and wastewater, and the department said it expected to spend about $1.7 million to test 1,380 water systems and 460 public schools alone. In addition, water systems are requiring companies to conduct internal tests for PFAS to control effluent reaching wastewater systems.
When the sites and concentrations are identified, control and remediation can be expensive and ongoing. After it discovered PFAS, Plainfield Charter Township in June began filtering its drinking water through granular activated carbon (GAC) with help from a $750,000 grant from the state of Michigan. Water customers of the city of Parchment and nearby Cooper Township reportedly will face higher water bills to pay for the more than $500,000 cost of hooking up with the Kalamazoo water system. Wolverine World Wide last year estimated that it would cost about $40 million to “address local groundwater issues potentially connected to its legacy tannery operations.”
Those examples don’t include the costs of controlling PFAS contamination at landfills, military airbases, commercial airports and smaller companies.
Remediation of sites often includes drilled purge wells that suck up water at certain locations near the sources of groundwater contamination and then filtering the water through GAC. When the GAC is filled with PFAS, it can be sent out-of-state to specially designed incinerators to restore its filtering capacity.

Remediation is not beautification

In the cases of the Kalamazoo River and Velsicol Superfund sites, the cost to remove contaminated sediments has reached into the hundreds of millions of dollars, and yet the work may go unnoticed after it’s completed.
Remediation doesn’t elicit the same warm, fuzzy feelings from the public as beautification projects, where public or private funds are spent on improvements that enhance the enjoyment of a property.
After extensive work during the past 20 years that included removing some 450,000 cubic yards of contaminated material, the cleanup of 7 miles along its banks and capping of 82 acres of contaminated sites, one main outcome on the Kalamazoo River is the fish now show less PCB contamination.
“Appearance is not everything, and health is everything” for the Kalamazoo River project, the watershed council’s Kornheiser said. The Superfund work “hasn’t changed the big picture look of the river, but it has produced an actual important health benefit upstream.”
“The important thing about PCBs is that it contaminates fish, and people eat the fish,” Kornheiser said. “Whether people can see it or not, those fish are less contaminated upstream from the site. Upstream 30 miles or so, even though it’s not declared safe to eat, the fish are probably safe to eat. That really has happened.”