The Navy is requesting permission to sample drinking water obtained from private wells within a designated area near the NSA Cutler Fire Station
for certain per- and polyfluoroalkyl substances, commonly known as PFAS.
NSA CUTLER FIRE STATION DRINKING WATER INVESTIGATION
COMMUNITY PARTICIPATION AND COVID-19 CONCERNS
Ordinarily, the Navy would host an Open House public meeting with our partnering agencies* to present information about this drinking water investigation and to interact with the community to address questions and concerns.
Unfortunately, due to COVID-19, the Navy and our partnering agencies agreed that holding a public meeting is not safe at this time. Therefore, we have prepared a virtual open house to provide additional information to the local community; the virtual open house materials are available at https://go.usa.gov/xfGMx. If you have questions about the drinking water investigation, you can also contact the Navy’s Public Affairs Office at NAVFAC_ML_PAO@navy.mil or by calling 1-800-915-4705.
*Partnering agencies include: Maine Department of Environmental Protection, Maine Department of Health and Human Services, and Agency for Toxic Substances and Disease Registry (ATSDR).
The Navy is asking property owners with a private drinking water well within the designated sampling area to call 1-800-915-4705 or email NAVFAC_ML_PAO@navy.mil to schedule a sampling appointment.
Throughout this drinking water investigation, COVID-19 safety protocols will be implemented to protect you and our samplers. Property owners are encouraged to discuss these precautions when scheduling their drinking water sampling appointment.
Naval Support Activity (NSA) Cutler
NSA Cutler is located at 175 Ridge Road near the Town of Cutler, Washington County, Maine and occupies approximately 2,300 acres (Figure 1). In 1957, the Navy began acquiring the NSA Cutler property. Construction of the facility began in 1958 and was completed 2 years later. On June 23, 1961, NSA Cutler was established as a communications facility providing radio signal transmissions with United States ships, planes, and submarines in the North Atlantic and Arctic Oceans and Mediterranean Sea. In 2003, the Navy transferred approximately 80 acres of the Cutler facility to the Cutler Development Corporation, including the living quarters and support facilities for Navy personnel (the Administrative and Housing Area) located north of the main installation. The Navy maintains ownership of the large area with communications towers on the peninsula (NSA Cutler Main Installation), and additional Navy property, including the NSA Cutler Fire Station, to the north of the NSA Cutler Main Installation (see Figure 1).
Figure 1: Location Map of NSA Cutler
Area for PFAS Drinking Water Well Sampling
The Navy is requesting permission to sample private drinking water wells within designated areas near the NSA Cutler Fire Station for certain per- and polyfluoroalkyl substances, commonly known as PFAS. PFAS are a family of thousands of different chemicals that have been widely used in industrial and consumer products since the 1950s. The Navy developed a proactive policy to address past releases of PFAS at installations nationwide, as several PFAS are now of emerging public health concern. The U.S. Environmental Protection Agency (EPA) has issued a drinking water lifetime Health Advisory for two commonly used and studied PFAS, perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS).
The most common Navy activity that could have resulted in the historical release of PFOA, PFOS, 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 life-saving emergency responses. PFAS were recently detected in the groundwater at the NSA Cutler Fire Station, which is approximately 3.5 miles north of the main installation (Figure 1). PFAS may also be present in nearby private drinking water wells that are located in the designated sampling area (Figure 2). There is no public water supply system in the vicinity of the NSA Cutler Fire Station, and therefore it is assumed that residents in the designated sampling area use private wells for drinking water (or community wells owned by non-public entities). The Navy is seeking the public’s assistance to identify drinking water wells located in this area and to obtain permission to sample the drinking water from these wells.
The EPA’s health advisories provide information on contaminants that can cause human health effects and may be present in drinking water. EPA's health advisories are non-enforceable and non-regulatory and provide technical information to state agencies and other public health officials on health effects, analytical methodologies, and treatment technologies associated with drinking water contamination. The EPA lifetime Health Advisory level is 70 parts per trillion (ppt) in drinking water for the combined value of PFOA and PFOS.
Figure 2: NSA Cutler Designated Sampling Area
NSA Cutler Fire Station Off-Base Drinking Water Sampling Results Summary
In September 2020, the Navy requested permission to sample drinking water from private wells within a designated area near the NSA Cutler Fire Station. The table below provides the status of the sampling conducted as of March 22, 2022 including a summary of results. Upon receipt of preliminary results, each well owner was called to let them know if their water contained PFOA/PFOS above or below the lifetime Health Advisory level. Bottled water delivery was also scheduled within 24 hours of the preliminary results phone call for residents whose water exceeded the lifetime Health Advisory level for PFOA/PFOS. After all data were verified, final laboratory results were mailed to each well owner, typically within 3 months of the sampling appointment. Out of respect for residents’ privacy, the Navy will only provide individual results to each well owner.
|NSA Cutler Fire Station Off-Base Drinking Water Sampling Status as of March 22, 2022
|Number of drinking water wells identified for testing based on voluntary owner requests
||Number of drinking water wells tested
||Validated Results Received
||Number of drinking water wells above the lifetime health advisory
||Number of drinking water wells below the lifetime health advisory
NSA Cutler Fire Station Actions Based on Results
If PFOA and/or PFOS are found at or below the EPA lifetime Health Advisory of 70 ppt in a drinking water sample, then no immediate action is needed. This is the case for most of the 59 private drinking water wells sampled in the designated sampling area near the NSA Cutler Fire Station. The Navy has developed a plan to resample some off-base drinking water wells near the NSA Cutler Fire Station that initially detected PFOA and PFOS, but at concentrations less than the EPA lifetime Health Advisory.
The Department of Defense (DoD) follows authorities available in the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), which is a Federal clean-up law. As such, where the DoD is a known source of PFAS to drinking water, CERCLA allows the DoD to provide bottled water, filter systems, and other removal actions to quickly assure no one is drinking water above the EPA lifetime Health Advisory for PFOA and PFOS.
Therefore, for private drinking water wells in the NSA Cutler designated sampling area with PFOA and/or PFOS sample results above the EPA lifetime Health Advisory level of 70 ppt, the Navy provided bottled water for drinking and cooking within 24 hours of receiving preliminary laboratory results. This was an immediate removal action to quickly eliminate exposure to drinking water with PFOA and/or PFOS levels above the EPA lifetime Health Advisory level.
The Navy has developed an intermediate removal action, which is point of entry treatment (POET) systems designed to filter PFOA and PFOS from well water to levels below 70 ppt. As of March 2022, POET systems have been installed on 18 of the 19 wells. The additional well identified as exceeding the EPA lifetime Health Advisory is expected to be fitted with a POET system during Spring of 2022.
The Navy continued providing bottled water for drinking and cooking until the Navy and the Maine Department of Environmental Protection (Maine DEP) agreed that the POET systems are consistently working properly to reduce PFOA and PFOS in the drinking water to levels below the EPA lifetime Health Advisory. Based on review of the results of several rounds of POET performance sampling, on July 28, 2021, the Navy and Maine DEP agreed that the POET systems already installed are working properly. Therefore, residents associated with those POET systems are no longer receiving bottled water from the Navy. Residents were notified by the Navy before the bottled water delivery service stopped.
The Navy is still providing bottled water for drinking and cooking to those residents associated with the four drinking water wells where a POET system was installed in January 2022 and the one drinking water well where a POET system is expected to be installed in Spring of 2022. These five wells service ten residences that are being provided bottled water by the Navy. The Navy and Maine DEP will again review data from several rounds of POET performance sampling before notifying those residents that their bottled water delivery service will be stopped.
NSA Cutler On-Base Drinking Water Sampling Results Summary
The drinking water provided at NSA Cutler is provided by four wells that have been tested per Navy and Department of Defense (DoD) policy requirements. The results were compared to the EPA lifetime Health Advisory for PFOA and PFOS to determine if actions are needed to reduce exposure. The first sampling occurred in autumn 2016, and all results were below the EPA Health Advisory for PFOA and PFOS. The sampling was repeated in the summer of 2020, and the results in three of the four wells continued to be below the EPA Health Advisory level. The water from the fourth well located at the NSA Cutler Fire Station contained PFOA and PFOS above the EPA Health Advisory. The Navy is currently providing bottled water for drinking and cooking to the NSA Cutler Fire Station while long term solutions are being investigated.
The following provides more information on the sampling at all on-base wells and recent actions taken at the NSA Cutler Fire Station:
Fire Station: Drinking water at the Fire Station is derived from a well located near that property, Well #503, and is separate from the drinking water on the main installation. PFOA and PFOS were not detected in Well #503 in 2016. However, total PFOA and PFOS was detected at 121.6 ppt in 2020, which is above the EPA’s lifetime Health Advisory of 70 ppt. Bottled water for drinking and cooking has been provided and this well will be resampled quarterly for the next year to monitor these levels. Personnel at the fire station will continue to receive bottled water for drinking and cooking until a long term solution is in place to ensure on-site drinking water remains below the EPA Health Advisory.
Main Installation: Drinking water at the main installation is derived from three wells. These wells, #100, #103 and #132, were sampled in both 2016 and 2020. PFOA and PFOS were not detected in Wells #103 and #132 during either of these sampling events. Total PFOA and PFOS was detected in Well #100, 24.3 ppt in 2016 and 23.8 ppt in 2020, both results are below EPA’s lifetime Health Advisory of 70 ppt. These wells will be resampled quarterly for the next year to monitor these levels.
High Frequency Area (HFA): Drinking water at the HFA is derived from Well #400. This well was sampled in 2016, and PFOA and PFOS were not detected. It was resampled in 2020, and the PFOA and PFOS results were 0.44J ppt and 0.47J ppt, respectively. These results are well-below the EPA lifetime Health Advisory of 70 ppt. Note that a “J” at the end of a result concentration indicates the value reported is considered estimated because the value is above the laboratory detection limit but above the limit of quantitation.
Per-and Polyfluoroalkyl Substances
PFAS are chemicals used in many consumer products to prevent stains, and to repel water, oil, and grease. Commercial and consumer products containing 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.
DON Use of PFAS
While PFAS have been used in a variety of products and substances world-wide, the most common historical use by DON has been in firefighting foam (specifically aqueous film-forming foam or AFFF) used for testing, training, firefighting, and life-saving emergency responses. The DON is working on identifying formulations for firefighting foam that do not contain PFOA and PFOS, but will still maintain critical fire-suppression and life-saving properties. In the short term, the DON intends to use AFFF with the lowest possible concentrations of PFOA and PFOS.
Since AFFF containing PFOA and PFOS is still in use, the DON has taken steps to prevent or to minimize additional release of firefighting foam to the environment; please refer to DON and DoD policies below.
Identification of PFAS at NSA Cutler
The Navy first evaluated the need for an off-base drinking water investigation at NSA Cutler in 2016 in response to 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 1 mile in the direction of the groundwater flow away from known or potential releases of PFAS. Although Site 1 (Former Fire Training Area) and Site 2 (Former Salvage Yard Area) were identified as known or potential locations of PFAS releases in 2016, no private drinking water wells were located within 1 mile in the direction of groundwater flow. Based on this information, an off-base drinking water investigation was not conducted. The Navy did not stop with the identification of these initial sites. 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 (PAs/SIs), and their purpose is to verify, validate, and update the inventory of PFAS release sites for further investigation and cleanup.
The base-wide review for NSA Cutler was completed in 2019 and identified the following six locations where PFAS-related operations, use, or storage potentially occurred and additional investigation was warranted to determine if a release occurred:
Site 1 (Former Fire Training Area),
Site 2 (Former Salvage Yard Area),
Area of Concern (AOC) 1 (Former Sludge Spreading Area),
AOC 6 (Tank Farm),
AOC 33 (Former Oil and Grease Disposal Area), and
Building 503 – Fire Station (i.e., NSA Cutler Fire Station).
An SI was started at these six sites in March and April 2020. Based on the initial sampling results, PFOA and PFOS concentrations above EPA’s lifetime Health Advisory were detected in shallow groundwater at four of the six sites, requiring additional investigation:
Site 1 – Former Fire Training Area
AOC 1 – Former Sludge Spreading Area
AOC 6 – Tank Farm,
Building 503 – the NSA Cutler Fire Station.
The Navy’s priority with PFAS investigations is to identify and eliminate drinking water exposures above the EPA’s lifetime Health Advisory. To protect our neighbors, the Navy conducts off-base private drinking water well investigations where a potential PFAS release may have occurred and off-base private drinking water wells have been identified within 1 mile in the direction of groundwater flow. No off-base drinking water wells are present within 1 mile of three sites of the four sites on NSA Cutler (Site 1, AOC 1, and AOC 6), so no private drinking water well sampling is needed for these sites. Off-base private drinking water wells were identified within 1 mile from the NSA Cutler Fire Station. Because the groundwater flow in the area near NSA Cutler is not yet well understood, the Navy decided to take a protective approach and request to sample all drinking water wells to the east of Holmes Bay within a mile of the NSA Cutler Fire Station. This designated sampling area is shown on Figure 2.
PFOA Stewardship Program
In 2006, EPA 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% 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 (such as PFOA and PFOS) and then transitioned to alternative chemicals. On January 21, 2015, EPA proposed a Significant New Use Rule under the Toxics Substances Control Act to require manufacturers (including importers) of PFOA- and PFOS-related chemicals to notify EPA at least 90 days before starting or resuming new uses of these chemicals in any process.
Unregulated Contaminant Monitoring Rule (UCMR)
The EPA uses the Unregulated Contaminant Monitoring Rule (UCMR) program to collect data for contaminants suspected to be in the nation’s drinking water, but that do not have health-based standards set under the Safe Drinking Water Act (SDWA). Every 5 years, EPA develops a new list of contaminants that will be monitored by the nation’s large public water systems (PWSs) serving more than 10,000 people and 800 representative small PWSs (i.e., serving 10,000 or fewer people).
The Third Unregulated Contaminant Monitoring Rule (UCMR3)* was issued in May 2012, and the sampling was completed in 2015. Six PFAS compounds were included in the UCMR3 contaminant list, including PFOA and PFOS. The UCMR3 results found these two chemicals were present in fewer than 1% of the nearly 5,000 public water systems that were sampled.
In December 2016, the EPA issued the fourth Unregulated Contaminant Monitoring Rule (UCMR4). There are no PFAS included on the UCMR4 list of contaminants that require analysis. EPA is currently developing the fifth Unregulated Contaminant Monitoring Rule (UCMR5).
* The 1996 Safe Drinking Water Act (SDWA) amendments require that once every five years EPA issue a new list of no more than 30 unregulated contaminants to be monitored by public water systems (PWSs).
EPA Lifetime Health Advisories
In May 2016, the EPA Office of Water issued a drinking water lifetime Health Advisory for PFOA and PFOS. Health advisories are not enforceable, and are not regulatory levels; rather they are levels that provide Americans, 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 parts per trillion (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 should be compared with the 70 ppt Health Advisory level.
State of Maine PFAS Regulatory Actions
The State of Maine recently issued interim drinking water standard and testing requirements for 6 PFAS (i.e., PFOA, PFOS, perfluorohexane sulfonic acid [PFHxS], perfluorononanoic acid [PFNA], perfluoroheptanoic acid [PFHpA], and perfluorodecanoic acid (PFDA) in June 2021**. This requires initial monitoring, potential subsequent monitoring, reporting, and treatment for certain water systems. The comparison level that triggers subsequent monitoring and possible treatment is 20 ppt for the six PFAS listed above, either individually or combined.
DoD follows authorities available in the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), which is a Federal clean-up law. DoD is evaluating its legal authorities, and will engage with its Federal agency partners on how to address state standards in the CERCLA removal process. These state-specific drinking water standards could be considered in the CERCLA process as potential Applicable or Relevant and Appropriate Requirements (ARARs) for final site remedial cleanup goals at the Feasibility Study. The Navy’s actions of providing bottled water and installing POET systems at this stage of the CERCLA process are called Removal Actions. For PFAS Removal Actions, the Navy currently has authority, under the DoD, to take such actions only for PFOA and PFOS and only at the EPA lifetime Health Advisory level of 70 ppt for PFOA and PFOS individually or in combination.
** State of Maine 130th Legislature L.D. 129, S.P. 64, signed by Governor on June 21, 2021.
Department of the Navy, Office of the Assistant Secretary (Environment) [DASN (E)] Policy Memo, 21 Oct 2014
The Navy issued a policy requiring sampling of on-base drinking water systems for PFOA and PFOS for bases where groundwater was used as drinking water and PFAS could have been released nearby in the past. This included installations that were not required to sample finished drinking water under UCMR3, that produce drinking water from on-installation groundwater sources, and have an identified or suspected PFAS release within approximately 1-mile upgradient to the drinking water source. Installations meeting these criteria were required to sample their finished drinking water by December 2015.
Sampling was not conducted at NSA Cutler in response to the October 21, 2014 policy memo because there is no public drinking water system with treated drinking water at NSA Cutler, but rather there are localized water supply wells on the installation that are not considered Public Water Supply wells.
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 PFOA and/or PFOS in drinking water exceeded the current at the time EPA lifetime 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 lifetime Health Advisory.
Sampling was not conducted at NSA Cutler in response to the September 14, 2015 policy memo because no public water supply system with finished water was identified at NSA Cutler.
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.
In response to this memo, all on-base supply wells that are used for drinking water at NSA Cutler were sampled in September 2016 for PFOA and PFOS. All of PFOA and PFOS results of the NSA Cutler on-base supply wells were either non-detect or detected at very low concentrations (less than 25 ppt), well-below EPA’s lifetime Health Advisory level.
DASN (E) Policy Memo, 17 June 2016
This policy defines the DON’s intention to remove, dispose, and replace legacy AFFF that contains PFOA and/or PFOS 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 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 1-mile downgradient 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, Navy (ER,N) records. To ensure that all potential PFAS release mechanisms were identified, installations were directed to review installations to identify areas that are not already part of the ER,N program. The Navy has 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.
Two NSA Cutler sites, the Former Fire Training Area and the Former Salvage Yard, were identified as potential release sites in response to this memo. However, no PFAS drinking water investigation was required because no private drinking water wells were identified within 1 mile in the direction the groundwater flows away from these two sites.
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. PFOS, PFBS that could 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. This memo was superseded by the ASD Guidance Memo of the same name dated 15 September 2021 (see below).
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, to 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 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.
In August 2020, the Navy received results from the resampling of NSA Cutler’s on-base drinking water wells, as required by this DoD policy.
ASD Guidance Memo, 15 September 2021
This guidance memo provides direction on use of toxicity values for PFOA, PFOS, and PFBS 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. It specifically updates the recommended toxicity value for PFBS that was revised by EPA in April 2021, and associated screening levels for PFBS. This memo supersedes the ASD Guidance Memo of 15 October 2019.
NSA Cutler Fire Station Drinking Water Investigation DOcuments