Subject: Actions taken by the 111th Attack Wing (ATKW) to address PFOS/PFOA water contamination issues
Background: The 111th ATKW has been actively working to address water contamination issues at Biddle Air National Guard Base since they were first discovered and confirmed between 2012 and 2014. The 111th has partnered with local communities, Navy, Air National Guard (ANG) and the U.S. Air Force (USAF) to address drinking water quality, and storm water run-off from the base.
- Presently, Biddle ANG Base/111th ATKW is in compliance with the Environmental Protection Agency's lifetime health advisory (HA) level for PFOS and PFOA. Where Department of Defense (DoD) is the known source of PFAS, no one - on or off-base - is drinking water above these levels.
- The DoD, USAF, ANG and Biddle ANG Base/111th ATKW are attempting to move forward in a systematic, enterprise-wide approach in their response to PFAS. This approach requires extensive coordination with all parties to ensure consistency across all DoD installations.
Key Actions Taken at Biddle ANG Base/111th Attack Wing:
- All water and sewer infrastructure on base was replaced from 2014-2017. This project replaced all the water and sewer lines on base, rehabilitated the drinking water supply wells, and constructed a new drinking water plant. The project, which was completed in 2017, was done in partnership with MCCA and the Horsham Township Water and Sewer Authority. Cost of the project was $6.3M (construction).
- Biddle ANG Base built a system to treat surface water for PFOS and PFOA in September 2017. The current interim system was constructed through a Cooperative Agreement with Warminster Township. The treated water from this current system (i.e. treated effluent) is subject to a temporary discharge request with limits of 70ppt combined for PFOS and PFOA.
- A larger capacity surface water treatment system is being constructed through a Cooperative Agreement with Warminster Township and the estimated completion date is July 2021. This system is designed to reduce PFOS and PFOA to below 70 ppt at the outfall with a drainage basin to accommodate larger rainfall events.
Next Steps: The Biddle ANG Base/111th ATKW will continue to work with our partners to monitor and assess the PFOS/PFOA situation at the base. The 111th ATKW and the ANG work closely with our installation partners, the Navy, in the PFOS and PFOA mitigation effort, as both entities have complex situations that require systematic, coordinated responses to ensure compliance with the intent of the law and in the best interests of the community.
Update on NPDES Permit: The Air Force's appeal of the Biddle ANGB NPDES permit is based on the process PADEP used in developing the limits that are to be set on the outfalls from Biddle ANGB for PFOS and PFOA. PADEP does not presently have a promulgated surface water standard for PFOS and PFOA therefore the ANG is unable to concur with this written limit. However, the permit is in effect while the appeal proceeds and Biddle ANG Base is complying with the terms of the permit which requires monitoring only through the end of December 2021. Biddle and the ANG are committed to working with PADEP to develop a permit that both parties can agree upon, based on current and properly promulgated standards.