Take Action: Make PFAS cleanup in Newburgh a priority

Photo © Lauren Berg

It has been five years since the City of Newburgh stopped using Washington Lake due to PFAS contamination, and switched to its backup reservoir, Browns Pond, and New York City’s Catskill Aqueduct as its sources of drinking water. Stewart Air National Guard Base, the primary source of PFAS affecting Newburgh’s Washington Lake reservoir, is undergoing a Relative Risk Site Evaluation (RRSE), which is used to prioritize remediation actions. Five years after the Department of Defense’s investigation began, PFAS continues to flow off the base. PFAS has contaminated Washington Lake, public and private wells in the Town of New Windsor, and both the water and fish in Silver Stream and Moodna Creek.

The U.S. military is the world’s largest polluter, and it is responsible for causing PFAS (per- and polyfluoroalkyl substances) contamination at hundreds of sites in the U.S., primarily due to its use of firefighting foams. At Stewart Air National Guard Base, too, multiple sites of contamination are identified. The RRSE is meant to prioritize cleanup of the “worst first.”

Send a message today to ensure that Stewart is prioritized among other polluted military sites, and that specific contaminated sites at Stewart are appropriately prioritized for cleanup. The RRSE process is flawed in significant ways that could undermine the thorough and comprehensive cleanup that is needed at Stewart. Personalize the letter by describing the way PFAS contamination has affected you or your family, community or business.

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Recipients

William Myer, Restoration Program Manager, National Guard Bureau

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Message

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Dear: [Decision Maker],

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I am writing with concerns about the Relative Risk Site Evaluation (RRSE) for Stewart Air National Guard Base (Stewart). Stewart Air National Guard Base, the primary source of PFAS affecting drinking water sources and waterways in the Newburgh area,  is undergoing a RRSE, which will be used to prioritize remediation activities at military sites nationwide, and which may also influence which remedial activities are prioritized at Stewart. This contamination has had significant public health, economic, ecological and social effects on Newburgh, New Windsor and neighboring communities.

The RRSE is used by the Department of Defense to prioritize cleanup of the "worst first," ensuring that contamination posing the greatest risks is remediated first. The RRSE for Stewart has several flaws that could de-prioritize cleanup activities for PFAS (per- and polyfluoroalkyl substances) at potential release locations (PRLs) identified in the RRSE. These flaws include:

The RRSE does not evaluate all pathways or receptors. 
The RRSE completely fails to mention wells serving the public drinking water supply for the Town of New Windsor, which also have been  contaminated with PFAS, requiring filtration. These include the Kroll well, which may be impacted by groundwater from the base, and the Butterhill wells, which are impacted by PFAS in Moodna Creek. Contaminated fish in Silver Stream and Moodna Creek pose a risk to subsistence anglers, as well as to the ecosystem--risks the RRSE ignores. These receptors, and the contamination pathways that impact them, must be thoroughly evaluated in the RRSE. Failing to do so will result in a flawed prioritization that would jeopardize the effectiveness of remediation at Stewart.

The RRSE considers only three types of PFAS. 
At least six types of PFAS have been detected at the base, in Newburgh's drinking water, and in the blood of Newburgh area residents. Firefighting foams used at the base include multiple PFAS. New York State, Department of Defense and City of Newburgh have sampled at some locations for as many as 28 different PFAS, 12 different PFAS have been detected in Washington Lake, and 18 different PFAS have been detected in some water samples associated with firefighting foam releases in the Newburgh area. Elsewhere in New York State, the Department of Defense is screening for at least 21 PFAS at other polluted installations. Scientists who study these chemicals state that the entire class of 9,000 chemicals should be regulated due to similar properties of toxicity, persistence and affinity for water. Certified methods exist to easily test for a wide range of PFAS and there is no reason testing should be limited at Stewart.

The RRSE does not evaluate surface water, stormwater or sediment contamination.
By evaluating only groundwater and soil contamination, the RRSE ignores some of the most important contamination sources, pathways and receptors at Stewart. Available data on PFAS concentrations in surface water, stormwater and stormwater infrastructure, and sediment, is ignored. This results in lower risk assigned to several areas of Stewart, including four hangars (PRLs 4, 5, 6 and 7), a building (PRL 10) and two outfalls (PRL 12 and 13). Surface water and sediment are listed within the Department of Defense 1997 RRSE Primer as media to be evaluated, and the RRSE does not provide any explanation why omission of these media was needed for "consistency across all the Installations."

Risk from contaminated soil is not properly evaluated. 
The RRSE focuses on risk from direct exposure to soil, resulting in a determination of "low" risk. Yet, soil is likely to be an important source of PFAS that contributes to groundwater and stormwater pollution, which present high risks.

The RRSE does not adequately evaluate Recreation Pond, outfalls discharging to Recreation Pond, or sources of contamination contributing to discharges via those outfalls. Recreation Pond and its outfall are not identified as being part of the installation, despite being recognized as the most important point of discharge from Stewart to off-base surface waters, including Washington Lake, Silver Stream and Moodna Creek. Only two of four stormwater outfalls that discharge to Recreation Pond were evaluated (PRL 12 and PRL 13). At these two evaluated outfalls, only groundwater was evaluated, not the actual discharges, where measurements have shown PFAS at concentrations hundreds of times the New York State drinking water standards. And, because neither stormwater nor soil as a source of PFAS were evaluated, the RRSE does not adequately prioritize the sources of contamination that result in PFAS discharges via those outfalls. These source areas include but may not be limited to four hangars (PRLs 4, 5, 6 and 7) and the 75-acre "apron" (PRL 11), wich generates stormwater contributing to PFAS discharges.

The RRSE does not evaluate several identified PRLs.
Two PRLs are identified but not evaluated. These include one building (PRL 9) and one outfall (PRL 14). Further, PRL 10 is evaluated, but incompletely, without being assigned an overall site risk. Without these PRLs, the RRSE is incomplete, and no conclusions can be drawn from it.

The PFAS contamination from Stewart has had a profound impact on the City of Newburgh, Town of New Windsor and the surrounding area. The RRSE must be revised to ensure that a comprehensive remediation protects people and the environment from further harm.

Sincerely,
[Your Name]
[Your Address]
[City, State ZIP]