Why aren’t you testing for all of the possible varieties of PFAS?
Currently there is no analytical method to test for all PFAS. We use the USEPA validated analytical method, which currently can detect 18 compounds.
Does the Navy plan to perform PFAS testing in fish and shellfish tissue? If so, when? If not, why not?
In the near term there are no plans to sample fish and shellfish tissue for PFAS because there is no USEPA validated analytical method to do so. If and when the USEPA publishes an analytical method for tissue, the Navy and its regulatory partners will revisit the issue.
In light of the heavy contamination at both St. Mary's County Naval installations, specifically groundwater contamination, what steps are being planned or currently undertaken to mitigate the contamination? Are there plans for removal?
It is too early in the CERCLA process to determine whether or not response actions are needed. We are initiating remedial investigations at all of the Areas of Interest. The data from these investigations will be used by the Navy and its regulatory partners, MDE and EPA, to determine of cleanup is needed.
Please list all of the ways PFAS is used on base and how much you use.
Aqueous firefighting foam, which contain PFAS, is not used on a day-to-day basis. It is only used for fire suppression and only in an emergency response.
As an aside, what other products is PFAS found in?
Many, many products: nonstick cookware, water resistant clothing, and cosmetics to name only a few.
What happens to the contaminated media on base? Is it landfilled? Is it shipped to be incinerated? Or is it left in place?
It is too early in the CERCLA process to determine the disposition of PFAS-impacted media.
Laboratories can now test for 42 PFAS compounds - Will you be testing for additional compounds and which ones?
It is true that some laboratories have proprietary analytical methods and claim that they can detect up to 42 PFAS. However, those methods have not been put through inter-laboratory comparisons to ensure that they yield the same results. That’s why the Navy only uses the USEPA validated analytical method. If the USEPA method increases the number of reportable compounds, the Navy will include them in future sampling events.
When will the contamination extent at Webster Field be determined?
The nature and extent of PFAS impacts will be determined during the Remedial Investigation
When will the Navy begin to clean up the Webster Field firehouse site?
It is too early in the CERCLA process to determine whether or not response actions are needed.
What is the long term strategy for ensuring PFAS does not leave the site via groundwater, storm water, or sedimentation?
The Navy must complete the Remedial Investigation to determine the nature and extent of PFAS impacts, prior to determining what if any, actions are needed.
Will the Navy pursue testing of potable water wells? Off-site? Private wells?
At this time, there is no evidence to suggest that PFAS originating from NAS Patuxent River or Webster Field has impacted private drinking water wells. Therefore, at this time there plan to test private wells
What are the adverse health implications for the residents near the Webster Field site? Please include contact concerns such as swimming and breathing the air, consumption of seafood, and drinking water.
At this time, there is no evidence to suggest that residents living near NAS Patuxent River or Webster Field are at risk at risk from PFAS releases on the bases. This includes swimming. breathing, consumption of seafood, and drinking water.
Have all METCOM public wells should be tested for PFAS/PFOA and related compound contamination. When will this happen?
In response to the USEPA’s Unregulated Contaminant Monitoring Rule 3, METCOM’s drinking water wells were sampled for PFAS. There were no detections.
Does the Navy plan to expand the sites tested to include Naval Support Facility Indian Head, Joint Base Andrews, the Naval Academy, Joint Base Anacostia Bolling, and other nearby facilities where PFAS or related chemicals were used or disposed?
The Navy speak for Andrews or Bolling, they’re under the control of the Air Force but yes, Indian Head, the Naval Academy and all of the other Navy and Marine Corps bases in Maryland, the District of Columbia, and Northern Virginia, where PFAS may have been released, have ongoing Preliminary Assessments and/or Site Inspections.
And Pax River is something of the ‘tip of the spear’ with its assessment, correct?
That’s correct, we funded and completed our Preliminary Assessment ahead of many, many other bases. This also allowed us to expedite the Site Inspections and now move forward with our Remedial Investigations.
Would the Navy agree to fund epidemiological studies in a multi-county area centered on Southern Maryland, to identify potential hot spots of cancers and other diseases linked to PFAS and related chemicals?
At this time, there is no evidence to suggest that PFAS originating from NAS Patuxent River or Webster Field presents a human health risk to people living and working at the cases or in the communities surrounding them. There is, however, a DoD-wide effort to conduct blood tests on current and former firefighters to determine possible PFAS exposure.
Have the causes been identified and controlled, or eliminated through substitution?
Legacy AFFF was recently replaced with reduced fluorine content AFFF. Additionally, training and equipment checks using AFFF have been discontinued. Again, AFFF may need to be used in the event of an emergency response.
What do you do if your municipal airport has PFOA + PFOS of over 62,000 ppt in the groundwater 3 meters down?
This website and Q&A is focused on the Navy’s efforts regarding PFAS investigations.
Joint Strike Fighter Aircraft Hangar 2133 shown in slide 41 shows a maximum concentration of PFOS at 135.83 ppt and a maximum concentration of PFOA at 1138.18 ppt. There have been multiple releases of aqueous film-forming foam (AFFF) in 2002, 2005, and 2010 from the suppression system in the hangar. In at least one incident the entire system inadvertently went off. Are the levels reported at Pax River commensurate with groundwater results for PFAS found where these frequent mishaps have occurred at other military facilities?
There are many complex factors pertaining to the nature of the release(s) and conditions of the local geology and groundwater, which affect the concentrations of PFAS measured at a given site. Because of this complexity and variability between locations, comparing groundwater sampling results of one facility to another would not yield information of value.
With consideration for the 2016 reports of PFAS contamination on the Indian Head Base, has the Department of Navy performed any PFAS water tests of water near or around the Indian Head Base located that may be used or accessed by the general public?
The Navy completed PFAS testing for the on-base drinking water for Naval Support Facility Indian Head (NSFIH), which comes from deep-well groundwater, in December 2020. The official results will be provided to the public when the Consumer Confidence Report is finalized and released (provide a time – such as seasonal timeline “fall of 2021” and where they can find it online). Based on the preliminary results, PFOA and PFOS were not detected in the drinking water supply for Indian Head.
Further environmental assessment for possible PFAS impacts is ongoing. The investigation will continue on sites where possible PFAS releases may have occurred. As with all of Navy CERCLA investigations, finalized investigations documents will be included in the official administrative record for Naval Support Facility Indian Head. Additionally, the PFAS investigation plans and results will be discussed as part of the routine Naval Support Facility Indian Head Restoration Advisory Board (RAB) meeting. The next RAB meeting is scheduled for October 14, 2021 and is open to the public. The Administrative Record and information about the RAB is included on the environmental restoration public website at https://www.navfac.navy.mil/Business-Lines/Environmental/Products-and-Services/Environmental-Restoration/Washington/Patuxent-River-NAS/.
When will the Department of Navy hold a public meeting for the Indian Head Base?
The next Indian Head Restoration Advisory Board (RAB) meeting is scheduled for 14 October 2021. The public is welcome to attend this meeting. Information about the RAB is included on the environmental restoration public website at https://www.navfac.navy.mil/Business-Lines/Environmental/Products-and-Services/Environmental-Restoration/Washington/Patuxent-River-NAS/.
How can you assert that there are no known concerns in off base drinking water? Have you tested the private wells of residents or do you know it's safe?
The Navy conducted a comprehensive groundwater flow evaluation. Shallow groundwater at NAS Patuxent River flows towards and discharges to either the Patuxent River, Chesapeake Bay, or smaller tributaries such as Pine Hill Run. Shallow groundwater at Webster Field flows towards and discharges to the St. Mary’s River. Based on the Navy policy, private drinking water wells will not be sampled since known groundwater flows away from these private properties.
Is the contact information for the community co-chair available?
Yes our co-chair is Ms. Heather Moritz with her contact information below:
Heather Moritz, LEHS
Director, Environmental Health Division
St. Mary’s Health Department
301.475.4321
heather.moritz@maryland.gov
What if anything have you done to provide your Southern Maryland neighbors with this information?
The Navy’s PFAS policy is forward leaning. There are no regulatory requirements to sample, however we are taking responsibility for our past actions and we are concerned for our neighbors outside the base fence line. We routinely provide information to the community through the specific installation Environmental Restoration website (https://go.usa.gov/xnBga) and through our Restoration Advisory Board meetings which are open to the public. These meetings provide project overviews and cleanup project status. The public can attend these meetings to learn more.
What are you doing in regards to Public Health and Safety?
The Navy is leaning forward on the PFAS investigations at their installations. Along with the partnering agencies including state and federal regulators, the Navy develops coordinated plans to address public health and safety issues.
Is it safe to consume seafood caught near Webster Field?
At this time, there is no reason to suspect that consuming seafood caught near Webster Field is not safe.
There were high concentrations of PFOS and PFOA in the area of Fire Station 3 at Webster Field. Do you plan to test groundwater radiating out from the fire station, to see what the concentrations do moving away from the fire station?
Sampling groundwater around Fire Station 3 will be a component of the remedial investigation as part of the CERCLA process. This process is coordinated with our state and federal regulators and is a thorough and complete process that takes time.
Have you done a nine target water analysis? This method is available at the office of water at the EPA in NC- this would tell you how many PFAS are in your water? Why is this not being done? And can the EPA step up and do this testing?
In accordance with Navy and DoD policy and guidance, as part of its CERCLA investigation, we are using DoD ELAP accredited laboratories that have been certified for analysis of drinking water in accordance with EPA Method 537.1. This policy also provides guidance on laboratory accreditation processes for the analysis of environmental media other than drinking water (e.g., surface water) in accordance with the requirements contained in Table B-15 of the DoD/DOE Quality Systems Manual for Environmental Laboratories (DoD/DOE QSM, current version 5.3). To our knowledge the referenced analytical method is an internal EPA ORD method. The validation status of this method is unknown, although internal methods such as this typically have not undergone formal single laboratory or multi-laboratory validation. Because of this and the fact that internal EPA methods are not published and commercially available, a method such as this would not be used typically as part of CERCLA investigative efforts. However, the USEPA themselves can take split field samples during the Navy’s investigative efforts if they so choose, and perform analysis using methods that may be experimental in nature performed by their own laboratories.
Are crabs and fish and safe to consume since they are found to 15,000 parts per trillion of PFOS?
Sampling for PFOS and PFOA is extremely sensitive and requires specific laboratory capabilities to test samples. No EPA guidelines have been developed as yet for crab and fish tissue sampling. However, at this time, there is no reason to suspect that consuming seafood caught near Webster Field is unsafe.
What have you done in regards to upcoming federal and local legislation regarding PFAS?
The Navy is not involved with proposed legislation. As the Navy investigates PFAS sites, we will work with our state and federal regulatory partners to develop restoration plans and provide information to the public.
Would you eat crabs or oysters caught near Webster Field?
At this time, there is no reason to suspect that consuming seafood caught near Webster Field is not safe.
Why is the Navy sending PFAS-contaminated materials to be incinerated?
Currently, it is a standard operating procedure to incinerate standard military waste products.
Why is this moving so slowly? It is a fairly circumscribed area at this point.
The CERCLA process is very thorough and requires significant coordination between the Navy and its regulatory partners. As such, it takes time and can be a long process. The Navy is committed to expediting the process where we can to address impacts from PFOS and PFOA.
I am waiting for answer to my question please, and when acceptable levels are given, then I would like the review of the areas that exceed these, since that was not really mentioned—i.e., the slides showed what levels were PRESENT, but not what the acceptable levels WERE for the area of interest or the different compounds,
It’s not clear what “acceptable levels” the statement refers to. However, results for the Site Inspection (SI) sampling results for Webster Field can be reviewed in the report on the public website (https://www.navfac.navy.mil/Business-Lines/Environmental/Products-and-Services/Environmental-Restoration/Washington/Patuxent-River-NAS/). Due to the large number of areas of interest, the SI report for NAS Patuxent River will be published in phases, the first of which will posted on the website in the near future.
The speaker indicated that the EPA does not have an appropriate test for fish or marine life testing. EPA approved SW-846 method appears to be approved for such task. Can it be used to ensure consumption of seafood is safe?
Currently, the US EPA does not have a draft or final method published under SW846 that has been single or multi-laboratory validated for the analysis of PFAS in solid materials, which includes the analysis of biological tissue in fish and crabs. While method development is occurring in conjunction with US EPA, it has not yet been published as a draft method in accordance with SW846.
I noticed that there is drainage ditch or gut behind Fire Station 3 at Webster Field. Do you think this could transport PFAS either in surface or groundwaters to the St. Mary's River? The concentration of PFAS in the groundwater was very high around the fire station. Looking at the concentration of PFAS in biota or in sediment in the shallow waters adjacent to the drainage ditch could provide additional information. A passive water sampler could also be used, to assess the concentration in this nearshore area over time. Passive water samplers are fairly cheap.
It is possible that the drainage ditch acts as a conveyance for PFAS. The remedial investigation (RI) will evaluate all possible migration routes. Similarly, various types of samplers will be evaluated prior for use during the RI.
We know PFAS travels - we know DOD is one of the biggest polluters. PFAS is forever - we know that it has traveled into local water ways- these water ways and private well water that is close to the sites should be tested- Asap. There is so much information from other DOD superfund sites- please consider this. This is a state of energy. This chemical is deadly- and we need to act NOW.
The Navy is committed to investigating and if warranted, remediating PFAS at NAS Patuxent River and Webster Field. The ongoing Remedial Investigations are thorough and once complete will define the location, type and amount of PFAS impacts and include human health and ecological risk assessments.
Is the Navy aware that the screening under the unregulated contaminant rule [UCMR] was very limited and included only a few PFAS compounds and had detection levels too high to detect levels of concern. It is not scientifically sound to rely on this and EPA has recognized this.
The Navy sampled its drinking water wells as required by UCMR 3. The number of analytes was defined in the rule. As noted in one of the EPA’s responses “EPA has proposed…UCMR 5 to collect new data on the 29 PFAS that are found in the nation’s drinking water systems.” The Navy will continue to address PFAS investigations using approved EPA methodologies.
How would you clean up the groundwater?
If one or more sites require restoration, the method of cleanup will be determined during a feasibility study, following the Remedial Investigation. Our partnering team including state and federal regulators will be part of the decision making process for future restoration activities.
Would you anticipate that all Naval Air Stations where AFFF were used will/should be tested?
The Navy is investigating the potential for PFAS at all Navy bases, including all Naval Air Stations as directed by Navy policy.
Who is the point of contact for Indian Head Base?
Alex Scott (alex.e.scott@navy.mil)
Is it safe for children to play in the sea foam?
There is no reason to suspect that the sea foam is related to fire-fighting foam and PFAS.
Method 537.1 is only for drinking water. Is SW-846 being considered for the fish and crabs? SW-846 is EPA approved.
Currently, the EPA does not have a draft or final method published under SW846 that has been single or multi-laboratory validated for the analysis of PFAS in solid materials, which includes the analysis of biological tissue from fish crabs. While method development is occurring in conjunction with EPA, it has not yet been published as a draft method in accordance with SW846.
Materials containing PFAS have been shipped from Pax River to an impoverished community in Cohoes, NY to be incinerated. Will you commit to ending this practice?
NAS Patuxent River has not shipped any PFAS-containing wastes to Cohoes, New York.
What do you doing in regards to the federal legislation and The Earth Bill?
The Navy is not involved in proposed legislation.
Is it safe for children to play in the sea foam where Pfos or Pfas are present? Please explain. And what is being done to test and warn and solve this problem
Sea foam naturally occurs where wind stirs up the water and creates the foam. There is no reason to suspect that the sea foam is related to fire-fighting foam with PFAS.
Can we safely eat oysters raised in St. Inigoes Creek?
At this time, there is no reason to suspect that oysters harvested from St. Inigoes Creek are unsafe to eat.
Why wasn’t Patuxent River NAS included in the DOD’s report, “Addressing Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA) Maureen Sullivan Deputy Assistant Secretary of Defense (Environment, Safety & Occupational Health) March 2018?”
At that time, other than the UCMR3 well sampling, no PFAS sampling had yet occurred at NAS Patuxent River or Webster Field.
The methods you are using will systematically under estimate the extent of the contamination.
The Navy uses the USEPA validated sampling method. Further sampling will be conducted under the CERCLA process to understand more about where PFOS and PFOA have moved.
What are the demographics of the community living in the area around Webster Field ?
We do not have demographic information pertaining to the community near Webster Field; however, Section 3.2 of the 2019 Community Involvement Plan has a demographic profile of St. Mary’s County. The plan is available on the public website (https://www.navfac.navy.mil/Business-Lines/Environmental/Products-and-Services/Environmental-Restoration/Washington/Patuxent-River-NAS/).
How can we get involved in the RAB?
All NAS Patuxent River RAB meetings are open to the public. Additionally, the Navy will be conducting community outreach in the near future to identify people interested in becoming an official community RAB member. In the meantime, we suggest that you continue to follow updates on the website and to routinely attend the RAB meetings – the next meeting will be (time).
POC for Indian Head... please send information to Teresa Ball ejc.ccnaacp@gmail.com.
This information was provided to Mr. Scott.
MDE Opening Statement: My management at the Maryland Department of the Environment (MDE) requested that I give you all a brief update on the PFAS related work that has been conducted by the State since the last PAX River RAB was held in March 2020.
Understanding and managing PFAS risk is a high priority for the MDE. In coordination with many others, we are implementing a multifaceted, science-based strategy to reduce potential risks posed by PFAS in drinking water, surface water, groundwater, and other potential exposure routes, such as the consumption of oysters and fish in Maryland. MDE’s PFAS strategy initially focused on drinking water in public water systems and on a pilot study of the occurrence of PFAS in oysters and surface water in the Saint Mary's River. The oyster tissue results were assessed by MDE’s staff toxicologist, who determined that PFOA and PFOS levels in oysters were well below levels of concern. Recently, MDE has expanded our efforts to include collecting data on the occurrence of PFAS in fish and directing water utilities with levels of concern to take specific actions, that reduce risk and increase public awareness.
MDE is working in close coordination with the U.S. Environmental Protection Agency or EPA to ensure that responsible parties at military installations with PFAS contamination fully investigate and take appropriate actions to protect public health and the environment. MDE has reviewed the soil and groundwater data obtained by the Navy at Pax River and Webster field. While no impacts to on-base drinking water have been found, MDE is concerned about the high levels of PFAS in shallow groundwater and the potential for this shallow groundwater contamination to migrate to surface water and into the deeper aquifer.
Late last year, after the Navy verbally informed MDE of the preliminary results from the SI sampling at Webster Field, MDE requested the Navy take additional, immediate steps to further assess PFAS impacts. These steps include:
increased sampling to ensure that shallow groundwater levels are not impacting off-site drinking water sources or surface water;
more frequent sampling of on-base drinking water wells;
identifying interim measures to prevent the further spread of PFAS while additional assessment and remediation are completed;
developing plans to minimize future releases of PFAS at the base;
and providing an expedited schedule for this work.
MDE strongly urges the Navy to take these steps now. MDE will continue to work with the Navy, and our federal regulatory partner, the EPA, to ensure necessary follow-up occurs to keep Marylanders informed and protected. Thank you.
What are the implications of Webster field PFAS contamination for the St. Mary’s River and St. Inigoes Creek, in particular, what are the expected impacts on fish oysters and crabs?
MDE A- In July and August 2020 the MDE working in conjunction with the Department of Natural Resources (DNR), conducted a pilot study of the occurrence of PFAS compounds in surface water and oysters in the St. Mary’s River. MDE obtained 28 surface water samples and 12 oyster samples from St. Inigoes Creek, St. Mary’s River and Smith Creek. The samples were analyzed for 14-36 different PFAS analytes. Measured PFAS concentrations observed in surface water were between 2 parts per trillion or ppt and 13 ppt and, based on MDE risk-based screening criteria, pose low risk to recreational swimmers who may accidently ingest water while swimming. The results of the oyster tissue and liquor sampling were below MDE-developed risk-based screening criteria for PFOA and PFOS.
Given the elevated PFAS concentrations detected during the SI, the MDE has requested, both verbally and in writing, that the Navy conduct additional sampling in nearby surface waters and on an expedited time frame. To date the Navy has not committed to do this work.
The St Mary’s River pilot study report is posted on the MDE website. If anyone has specific questions regarding the MDE pilot study, please submit them to me in writing via email. I can work with the MDE staff members who conducted the work and wrote the report to get you more specific answers.
Based on the extremely high levels of PFAS found in our local fish and shellfish do you consider them safe to eat?
Although I am aware of reports of elevated levels of PFAS in individual samples of fish and shellfish, I am not aware of any larger-scale studies of PFAS in fish tissue conducted in the vicinity of these bases. However, MDE started last fall to include PFAS analytes in its fish tissue sampling program. MDE is also working with the DNR this year to modify MDE’s existing fish tissue sampling program to assure that we are collecting popular species of fish from locations where higher levels of recreational fishing occur. MDE expects to post the results of fish tissue sampling on its website when these data are available Risk assessment work will be conducted to provide PFAS-related fish consumption guidance to the public, if necessary.
Last summer MDE did collect oyster tissue and liquor samples during the St. Mary’s River Pilot Study of PFAS Occurrence. These results were assessed by our staff toxicologist who determined that the PFOA and PFOS levels in oysters were well below human health levels of concern.
As part of the Remedial Investigation (RI) process at both bases, MDE wants the Navy to conduct both ecological and human health risk assessments, which should include the collection of aquatic organisms like fish tissue samples for PFAS analysis.
Will the Navy be testing wild animals on and near Webster field? For what compounds and at what levels of detection?
At this time MDE does not anticipate requiring the Navy to test terrestrial wild animals such as deer for PFAS analytes. The shallow PFAS impacted groundwater on both bases is brackish and would be an unlikely drinking water source for wildlife. An ecological risk assessment will be conducted during the Remedial Investigation. I, if any unacceptable risk to terrestrial wildlife is identified, MDE will require the Navy to investigate further.
What is the long-term monitoring plan after clean up?
Per the CERCLA process, if any hazardous chemical is left on-site at concentrations which restrict the future use of the property, meaning at concentrations above a maximum contaminant level (MCL) or State Action level, then 5 five- year reviews are conducted to evaluate the protectiveness of the remedy. The five- year review process would continue in perpetuity, until concentrations of contaminants are below levels that warrant site use restrictions, which in most cases are residential risk based standards.
Are crabs safe to eat?
Data on blue crabs and accumulation of fluorinated compounds is limited. We have no data that indicates consumption of blue crabs is not safe. The Department continues to look into this question and is supporting the Chesapeake Bay Program's decision to convene a scientific workshop on PFAS and the Bay---we expect the issue of occurrence of PFAS in blue crabs to be a topic. MDE will provide updates as they are developed.
For updates on MDE's sampling efforts please go to MDE's PFAS Landing Page:
https://mde.maryland.gov/PublicHealth/Pages/PFAS-Landing-Page.aspx