The Department of Navy is requesting permission to sample private drinking water wells within a designated area near MCOLF Atlantic
for certain per- and polyfluoroalkyl substances, commonly known as PFAS.
Property owners in Atlantic, N.C. whose drinking water has not been tested
may request sampling by calling 1-877-MCOLF17 (1-877-626-5317)
Marine Corps Outlying Landing Field (MCOLF) Atlantic
Marine Corps Outlying Landing Field (MCOLF) Atlantic, located in Atlantic, North Carolina, has been in operation since 1942 and is an active outlying landing field that supports training operations for MCAS Cherry Point. Current operations at the facility include rotary-wing operations in support of nearby target ranges and training activities (including tactical, air-to-ground, electronic warfare and low altitude exercises) (USMC, 2009). The facility is also used for Forward Arming and Refueling Point (FARP) training by MCAS Cherry Point and other Navy and Army facilities. There is a contingent of military and civilian personnel regularly onsite to support operations of MCOLF Atlantic.
Areas for PFAS Drinking Water Well Sampling
The Navy has sampled over 200 private drinking water wells within a designated area near MCOLF Atlantic for certain per- and polyfluoroalkyl substances, commonly known as PFAS. PFAS are a family of thousands of different chemicals which have been widely used in industrial and consumer products since the 1950s. The Navy developed a policy to address past releases of PFAS at installations nationwide, as several PFAS are now of emerging public health concern to the Navy, U.S. Environmental Protection Agency (EPA), state regulatory agencies, and the general public. The EPA has issued a drinking water lifetime health advisory for two commonly used and studied PFAS, perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA).
The most common Navy activity that could have resulted in the historical release of PFOS, PFOA, and other PFAS to the environment is the use of firefighting foam (specifically certain types of aqueous film-forming foam, or AFFF) for testing, training, firefighting, and other lifesaving emergency responses. Because of this historical use, there is potential for PFOS, PFOA, and other PFAS to be in the groundwater at the air field, and also be present in nearby private drinking water wells that are located in the direction that the groundwater flows away from the air field. The designated sampling area, as shown in Figure 1, was selected because of the proximity to MCOLF Atlantic and the general groundwater flow direction.
Figure 1. Designated Sampling Area near MCOLF Atlantic
MCOLF Atlantic Actions Based on Drinking Water Sampling Results
Due to the historical operations at MCOLF that included the use of AFFF, the Navy has conducted drinking water sampling for certain PFAS in drinking water wells in the vicinity of MCOLF since November 2017. If PFOS/PFOA are found at or below the EPA lifetime health advisory level of 70 ppt in a drinking water sample, then no additional action will be taken at that time. The Navy will evaluate all results, and additional sampling may be requested. If PFOS/PFOA are found in a private drinking water well sample above the EPA lifetime health advisory level of 70 ppt, the Navy will provide alternate water (likely bottled water) for drinking and cooking until a long-term solution can be put in place. Table 1 summarizes the drinking water sampling results to date.
|Table 1. MCOLF Atlantic – Drinking Water Results as of April 2021
Number of drinking water wells identified for testing based on voluntary owner requests
Number of drinking water wells tested
Number of drinking water wells above the lifetime health advisory*
Number of drinking water wells below the lifetime health advisory
* Exceedances of the lifetime health advisory were previously reported in two wells; however, only one well was determined to be a drinking water well.
Per- and Polyfluoroalkyl Substances
PFAS are chemicals used in many consumer products to prevent stains, and repel water, oil and grease. Commercial and consumer products containing or degrading to these compounds were first introduced in the 1950s. They were used in a variety of products such as for the treatment of upholstered furniture fabric and carpets, in nonstick cookware, floor wax, the lining of food containers/packaging and firefighting foam. PFAS are now present virtually everywhere in the world because of the large amounts that have been manufactured and used by international consumers and industry. Once these compounds are released to the environment, they break down very slowly.
PFAS are chemicals of emerging concern, which have no Safe Drinking Water Act regulatory standards or routine water quality testing requirements. The EPA is currently studying PFAS to determine if national regulation is needed. Studies by the EPA, the Agency for Toxic Substances and Disease Registry (ATSDR), and others indicate that exposure to PFAS may cause elevated serum cholesterol levels and developmental effects to fetuses during pregnancy (e.g., low birth weight, accelerated puberty, skeletal variations) or to breastfed infants. Individual states are also conducting their own evaluations and may establish their own drinking water standards or environmental cleanup requirements.
Navy use of PFAS
While PFAS have been used in a variety of products and substances worldwide, the most common historical Navy use has been in firefighting foam (specifically aqueous film forming foam or AFFF) used for testing, training, firefighting, and other life-saving emergency responses. The Navy is working to identify a new formulation for firefighting foam that does not contain PFOS and PFOA but will still meet critical fire suppression, and ultimately lifesaving, properties. Until this formulation is approved, and products are available, the Navy has taken steps to prevent or minimize additional release of fire-fighting foam to the environment. These specific actions and others implemented by the Navy to PFAS concerns are explained in the Navy Policy section.
Identification of PFAS at MCOLF Atlantic
The Navy first evaluated the need for an off-base drinking water investigation at MCOLF Atlantic in summer 2016 in response to a new Navy policy (DASN (E), 20 June 2016). This policy required a review of existing environmental restoration database information to identify sites with drinking water sources within one mile in the direction of the groundwater flow away from known or potential releases of PFAS. The Navy determined MCOLF Atlantic met this criterion, and as a result, private drinking water well sampling commenced in November 2017. The Navy’s priority with PFAS investigations is to identify and eliminate drinking water exposures above the EPA’s lifetime health advisory level.
In addition, across the country, the Navy has been conducting base-wide evaluations to identify additional potential PFAS releases. These evaluations are being conducted under the federal cleanup program which meets the requirements of, the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Following CERCLA, the Navy’s installation-wide assessments are called preliminary assessments/site inspections, and their purpose is to verify, validate, and update the inventory of PFAS release sites aboard the installation for further investigation and cleanup. The preliminary assessment conducted at MCOLF Atlantic identified 11 on-base areas where PFAS-related releases potentially occurred. The Navy completed an investigation of the on-base areas at MCOLF Atlantic in 2019 and found that additional data were necessary to meet the objectives of the investigation. Further sampling at MCOLF Atlantic is planned to provide the data necessary to complete the investigation.
Upon completion of the investigation, the Navy in partnership with federal and state regulatory agencies, will share the results with the public.
PFAS Regulatory History
PFOA Stewardship Program
In 2006, USEPA initiated the 2010/2015 PFOA Stewardship Program in which eight major companies in the United States committed to reduce facility emissions and product contents of PFOA and related chemicals on a global basis by 95 percent no later than 2010, and to work toward eliminating emissions and product content of these chemicals by 2015. All U.S. companies have met the program goals. To meet the program goals, most companies stopped the manufacture and import of long-chained PFAS, and then transitioned to alternative chemicals. On January 21, 2015, USEPA proposed a Significant New Use Rule under the Toxics Substances Control Act to require manufacturers (including importers) of PFOA- and PFOA-related chemicals to notify USEPA at least 90 days before starting or resuming new uses of these chemicals in any process.
Unregulated Contaminant Monitoring Rule (UCMR)
The USEPA issued the Third Unregulated Contaminant Monitoring Rule (UCMR3)* in May 2012. The UCMR3 required all large public water systems (PWSs) serving more than 10,000 people and 800 representative PWSs serving 10,000 or fewer people to sample for 30 chemicals between 2013 and 2015. Six PFAS were included in the UCMR3 contaminant list. Of the six PFAS, USEPA issued health advisory levels for only two, PFOA and PFOS. The UCMR3 results found these two chemicals were present in less than 1 percent of the nearly 5,000 public water systems sampled per UCMR3.
In December 2016, the USEPA issued the Fourth Unregulated Contaminant Monitoring Rule (UCMR4). UCMR4 requires all large PWSs serving more than 10,000 people and 800 representative PWSs serving 10,000 or fewer people to sample for 30 chemicals between 2018 and 2020. There were no PFAS included on the UCMR4 list of contaminants.
USEPA is currently proposing development of a Fifth Unregulated Contaminant Monitoring Rule (UCMR5); the final rule is expected to be released in 2021. It is currently unknown whether PFAS will be included as part of UCMR5; however, several PFAS have been proposed for inclusion.
* The 1996 Safe Drinking Water Act (SDWA) amendments require that once every five years US EPA issue a new list of no more than 30 unregulated contaminants to be monitored by PWSs.
USEPA Lifetime Health Advisories
In May 2016, the USEPA Office of Water issued a drinking water lifetime health advisory for PFOA and PFOS. Health advisories are not enforceable, regulatory levels; rather, they are levels that provide the public, including sensitive populations, with a margin of protection from a lifetime of exposure to PFOA and PFOS in drinking water. The health advisory is 70 ppt for PFOA and 70 ppt for PFOS. When both PFOA and PFOS are found in drinking water, the combined concentrations of PFOA and PFOS are compared with the 70 ppt health advisory level.
Department of the Navy, Office of the Assistant Secretary (Environment) [DASN (E)] Policy Memo, 21 Oct 2014
The Navy issued a policy requiring on-base drinking water sampling for PFOA and PFOS for bases where groundwater was used as drinking water and PFAS could have been released nearby in the past. Navy and Marine Corps installations that were not required to sample finished drinking water under UCMR3 that produce drinking water from on-installation sources and have an identified or suspected PFAS release within approximately a one-mile up-gradient to the drinking water source were also required to sample their finished drinking water by December 2015.
Chief of Naval Operations (CNO) Policy Memo, 14 Sept 2015
Similar to the October 2014 DASN (E) policy memo, this memo related to testing on-base drinking water. However, this memo also specified that if levels of PFOS and/or PFOA in drinking water exceeded the current at the time USEPA health advisory (that is the 2009 provisional short-term health advisories), then alternative drinking water must be supplied until the PFOA and/or PFOS levels were reduced to below the USEPA health advisory.
DASN (E) Policy Memo, 14 Jun 2016
This policy expanded the sampling PFOA and PFOS at all DON installations where such sampling was not previously completed under USEPA’s UCMR 3 or the DON’s October 2014 policy. This memo also specified that for instances where drinking water from an installation is purchased from a public water system, but wasn't tested under UCMR3, that the installation must sample the finished drinking water to comply with this policy. Additionally, this policy included reporting requirements to the DASN (E) office for all PFOA and/or PFOS in drinking water results.
DASN (E) Policy Memo, 17 June 2016
This policy defines the DON’s intention to remove, dispose, and replace legacy AFFF that contains PFOS and/or PFOA once environmentally suitable substitutes are identified and certified to meet MILSPEC requirements. This policy directs the following actions be taken until suitable replacements are certified:
Immediately cease the uncontrolled environmental release of AFFF for shoreside installations, with the exception of emergency responses.
Update and implement Navy and Marine Corps firefighting system requirements, as needed, to ensure fire and emergency service vehicles and equipment at DON installations and facilities are tested and certified in a manner that does not allow the release of AFFF to the environment.
By the end of Fiscal Year 2017 (FY17), remove and dispose of uninstalled PFOS-containing AFFF in drums and cans from local stored supplies for shore installations and ships to prevent future environmental releases.
DASN (E) Policy Memo, 20 Jun 2016
This policy required the Navy and Marine Corps to identify and prioritize sites for investigation if drinking water resources, on- or off-installation, are thought to be vulnerable to PFAS contamination from past Navy and Marine Corps PFAS releases. Sites with drinking water sources within a one-mile down-gradient from known or potential releases of PFAS were assigned the highest priority. This policy directed the sampling of off-base drinking water at these high priority (Priority 1) sites within FY17.
The primary mechanism to identify potential PFAS release sites and areas of concern (AOC), was review of Environmental Restoration records. To ensure all potential PFAS release mechanisms were identified, installations were directed to review installations to identify areas that are not already part of the Environmental Restoration program. We have completed the sampling for all off-base potentially impacted drinking water sources that were identified as a result of this policy and currently known exposures have been addressed.
U.S. Marine Corps Policy
Marine Corps Bulletin 11000, 20 February 2020
This bulletin issues policy and assigns responsibility for a wide range of PFAS-related issues in the USMC, including, but not limited to drinking water sampling, disposal of PFAS contaminated materials, and procurement and management of AFFF stock.
Department of Defense (DoD) Policy
Secretary of Defense Memo, 23 July 2019
This memo established a PFAS task force to ensure a coordinated, aggressive and holistic approach to DoD-wide efforts to proactively address PFAS. The goals of the task force are mitigating and eliminating the use of the current AFFF, understanding the impacts of PFAS on human health, and fulfilling cleanup responsibility related to PFAS. The task force is coordinating and collaborating with other federal agencies to achieve these goals.
ASD Guidance Memo, 15 October 2019
This guidance memo provided clarification of toxicity values for PFOA and PFOS that can be used to estimate screening levels used in the CERCLA program to determine if further investigation is warranted or if a site can proceed to site closeout.
ASD Memo, 23 October 2019
This memo revised quarterly progress reporting requirements for installations with known or suspected PFAS releases.
ASD Guidance Memo, 22 November 2019
This memo established requirements for installation commanders to conduct community engagement with respect to PFAS issues, report on their progress in so doing, and to provide feedback on community questions and concerns.
ASD Guidance Memo, 22 November 2019
This memo established a consistent methodology for analysis of PFAS in media other than drinking water and requires DoD Components to use analytical methods meeting the DoD/DOE Quality Systems Manual for Environmental Laboratories, Appendix B, Table B-15.
ASD Memo, 13 January 2020
This memo established annual reporting requirements for AFFF usage or spills (not associated with use) at all DoD installations.
ASD Policy Memo, 2 March 2020
This memo identifies requirements for PFAS drinking water sampling on DoD installations where DoD is the drinking water purveyor. The requirements include initial and routine monitoring, actions necessary if results exceed the lifetime health advisory, laboratory analysis and record keeping requirements, and notification of results.
MCOLF Atlantic Drinking Water Investigation Documents