For information on the SUBASE New London PFAS private drinking water well investigation, please contact the SUBASE Public Affairs Office at:
(860) 694-5980 or firstname.lastname@example.org
New Update as of 31 October 2019
As of this date, the Navy has received validated test results from the sampling described in the background section below. As depicted in the chart, of the 3 samples collected, PFOS/PFOA were not detected above the EPA’s Lifetime Health Advisory (LHA) of 70 parts per trillion (ppt). The private drinking water well owners were notified of their individual results by phone and mail.
SUBASE New London Private Drinking Water Well Sampling Status as of Thursday October 31, 2019
Initial Parcels Requested for Sampling
Number of Potential Wells Identified Within Sampling Area
Preliminary Results Received
Validated Results Received
Preliminary Results Received above the Lifetime Health Advisory
Validated Results Received above the Lifetime Health Advisory
What does this mean?
PFOS/PFOA was not detected above the EPA’s Lifetime Health Advisory in the private drinking water wells.
The Navy responded to potential/known releases of PFOS/PFOA-containing substances at two potential PFAS source areas by testing nearby (within one mile down-gradient) private drinking water wells to:
determine whether wells were impacted by any PFOS/PFOA that exceeded relevant concentration standards; and
determine whether expanding the area of private drinking water well testing was necessary.
Alternate sources of drinking water are not needed.
Per Navy Policy, the Navy was prepared to provide alternate drinking water for any affected drinking water wells above the EPA lifetime health advisory (LHA). Since no well exceeded the LHA, alternate sources of drinking water are not needed.
Expanding the designated sampling area is not needed at this time.
Had the Navy detected concentrations above the EPA health advisory of PFOS/PFOA in the nearby drinking water wells, the Navy would have reevaluated the scope of private drinking water wells that it would seek to test. The levels observed (i.e., low detections below the health advisory or not detected) mean that the Navy will not expand the scope of its private drinking water well sampling footprint at this time.
Respond to any promulgated state standards
Navy policy is to provide alternate drinking water to property owners of any drinking water wells impacted by Navy releases of PFOS/PFOA when those drinking water wells contain concentrations above the EPA lifetime health advisory. The Navy will reevaluate whether to provide alternate drinking water in light of any promulgated state standards. Should Connecticut promulgate a standard, the Navy will reevaluate whether to provide an alternate drinking water source in light of that standard.
The Navy is preparing to investigate the potential PFAS areas of concerns at SUBASE New London identified in the Preliminary Assessment report (Resolution Consultants. March 2020. Per- and Polyfluoroalkyl Substances Preliminary Assessment, Naval Submarine Base New London). A Sampling and Analysis Plan for Basewide PFAS Site Inspection is currently in development. Field work is expected to begin as early as Fall 2020, following approval by the Connecticut Department of Energy and Environmental Protection (CTDEEP), and U.S. Environmental Protection Agency (EPA).
Naval Submarine Base New London
SUBASE New London is a 687-acre facility located in southeastern Connecticut in the Towns of Ledyard and Groton, New London County. SUBASE New London is situated on the eastern bank of the Thames River, approximately 6 miles north of Long Island Sound (Figure 1). SUBASE New London is bordered to the east by Connecticut Route 12, to the south by Crystal Lake Road, and to the west by the Thames River. The northern border is a low ridge that trends approximately east-southeast from the Thames River to Baldwin Hill.
SUBASE New London has been an active Navy facility since 1867, with submarine base operations since 1916. Today, SUBASE New London provides base operations support for Navy submarine forces and other naval organizations and tenants. SUBASE New London accommodates submarine training facilities, military offices, medical facilities, and facilities for submarine maintenance, repair, and overhaul. SUBASE New London also provides housing and support services for Navy personnel.
Areas for PFAS Drinking Water Well Sampling
The Navy is requesting permission to sample private drinking water wells within designated areas near SUBASE New London 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 U.S. EPA has issued a 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 fire-fighting foam (specifically aqueous film forming foam or AFFF) for testing, training, firefighting, and other life-saving emergency responses. PFAS compounds may be present in the soil and/or groundwater at SUBASE New London as a result of historical firefighting training and response activities using the AFFF firefighting foam. Because of this historical use, there is potential for PFOS, PFOA, and other PFAS to be in the groundwater on base, and also be present in nearby private drinking water wells that are located in the direction that the groundwater flows away from the base. The designated sampling area, as shown in Figure 2, was selected because of the proximity to SUBASE New London and the general groundwater flow direction.
Records indicate the majority of residents in the sampling area purchase their drinking water from Groton Utilities, but a limited number of properties use or may be using a private well for their drinking water. The Navy is not requesting to sample water from residents in the designated off-base sampling areas who receive their drinking water from Groton Utilities as your water is tested prior to distribution. Homeowners should contact Groton Utilities with any questions regarding treatment and testing of your drinking water.
The U.S. EPA’s health advisories provide information on contaminants that can cause human health effects and are known or anticipated to occur in drinking water. U.S. EPA's health advisories are non-enforceable and non-regulatory and provide technical information to states agencies and other public health officials on health effects, analytical methodologies, and treatment technologies associated with drinking water contamination. The U.S. EPA lifetime health advisory level is 70 parts per trillion (ppt) in drinking water for the combined value of PFOS and PFOA.
SUBASE New London Actions Based on Drinking Water Sampling Results
If PFOS/PFOA are found at or below the U.S. EPA lifetime health advisory level of 70 ppt in a drinking water sample, then no further action is needed at this time. The Navy will evaluate all results, and additional sampling may be requested in the future.
If PFOS/PFOA are found in a private drinking water well sample above the U.S. 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.
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 fire-fighting 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 U.S. EPA is currently studying PFAS to determine if national regulation is needed. Studies by the U.S. 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 world-wide, the most common historical Navy use has been in fire-fighting foam (specifically aqueous film forming foam or AFFF) used for testing, training, firefighting, and other life-saving emergency responses. The Navy is working on identifying a new formulation for fire-fighting foam that does not contain PFOS and PFOA but will still meet critical fire-suppression and ultimately life-saving 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 SUBASE New London
The Navy first evaluated the need for an off-base drinking water investigation at SUBASE New London 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 1-mile in the direction of the groundwater flow away from known or potential releases of PFAS. Off-base drinking water evaluations were conducted starting in October 2017 for sites meeting this criterion. No known sites on SUBASE New London met the policy criterion in initial review. However, the Navy did not stop with 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 (PA/SI), and their purpose is to verify, validate, and update the inventory of PFAS release sites for further investigation and cleanup.
The recent base-wide review for SUBASE New London identified the following 15 areas where PFAS-related releases occurred, or potentially occurred, and additional investigation is needed. These are listed below with locations shown on Figure 3.
Known/Suspected Releases at SUBASE New London
|Former Equipment Storage (Building 355 – DRMO)
|Central Paint Accumulation Area (Building 174)
|Pave Storage Area (Alpha Lot)
|Hazardous Materials Storage (Building 561)
|Hazardous Waste Storage (Building 562)
|Machine Shop (Building 40)
Potential Releases at SUBASE New London
|Potential Former Fire Training Location (Building 88)
|SUBASE New London Fire Station 1 (Building 107)
|Vehicle Accident Fire Response (Late 1980’s)
|Former Fuel Storage Building (Building 548)
|Damage Control Center (Building 465)
|Former Sewage Treatment Plant
|Location of Two Controlled Burns – Jackson Drive
|SUBASE New London Fire Station 2
Only two of these known/suspected and potential releases are believed to have potentially impacted the local drinking water aquifer: Location of Two Controlled Burns – Jackson Drive (#14) and SUBASE New London Fire Department – Station 2 (#15). The rest of these releases are located on-base, where drinking water is provided by Groton Utilities, and groundwater flow is towards the Thames River (and a way from residential areas with drinking water wells).
The Navy’s priority with PFAS investigations is to identify and eliminate drinking water exposures above the U.S. EPA’s lifetime health advisory level. To protect our neighbors, the Navy is not waiting until all on-base investigations under CERCLA are complete at SUBASE New London to confirm if a release occurred. We are conducting the off-base drinking water investigation first, based on newly identified locations where a potential PFAS release may have occurred. The designated sampling area selected near SUBASE New London lies in the direction that the groundwater flows off-base, away from these 15 areas where additional investigation is needed. The Navy has identified private drinking water wells for sampling within the designated area, shown on Figure 2.
PFAS Regulatory History
PFOA Stewardship Program
In 2006, U.S. 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, and then transitioned to alternative chemicals. On 21 January 2015, U.S. EPA 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 U.S. EPA 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 monitoring, between 2013 and 2015, for 30 substances at all large public water systems (PWSs) serving more than 10,000 people and 800 representative PWSs serving 10,000 or fewer people. Six PFAS compounds were included in the UCMR3 contaminant list. Of these 6 PFAS, EPA issued health advisory levels for only two, perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). The UCMR3 results found these two chemicals were present in less than 1% of the nearly 5,000 public water systems that sampled per UCMR3.
In December 2016, the EPA 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 – 2020. There are no PFAS included on the UCMR4 list of contaminants that require sampling and analysis.
* The 1996 Safe Drinking Water Act (SDWA) amendments require that once every five years U.S. 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 U.S. EPA Office of Water issued a drinking water lifetime health advisory for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). Health advisories are not enforceable, 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.
PFAS Navy Policy
Department of the Navy, Office of the Assistant Secretary (Environment) [DASN (E)] Policy Memo, 21 October 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. 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 were also required to sample their finished drinking water by December 2015.
Chief of Naval Operations (CNO) Policy Memo, 14 September 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 then current U.S. EPA health advisory (i.e., 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 U.S. EPA health advisories.
Office of the Assistance Secretary of Defense (ASD) Policy Memo, 10 June 2016
This Department of Defense (DoD) policy memo specified that decisions regarding drinking water should be based on the lifetime health advisories issued by U.S. EPA's Office of Water in May 2016, rather than the now outdated provisional short-term health advisories issued in 2009.
DASN (E) Policy Memo, 14 June 2016
This policy expanded the sampling PFOA and PFOS at all Navy installations where such sampling was not previously completed under U.S. EPA’s UCMR3 or the Navy’s October 2014 policy. This memo also specified that for instances where an installation’s drinking water is purchased from a public water system, but wasn't tested under UCMR3, that the installation must sample the finished drinking water and provide alternative water if the PFOA and/or PFOS levels in drinking water exceed the U.S. EPA lifetime health advisory levels. Additionally, this policy included reporting requirements to the DASN (E) office for all PFOA and/or PFOS 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 DoD’s performance 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 Navy 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 FY2017 (30 September 2017), 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 June 2016
This policy required Navy to identify and prioritize sites for investigation if drinking water resources, on- or off-installation, are thought to be vulnerable to PFOA/PFOS contamination from past Navy/Marine Corps PFAS releases. The primary mechanism to identify potential PFAS release sites was review of existing Navy environmental restoration databases. 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 be completed by 30 September 30 2017.
SUBASE New London Drinking Water Investigation Documents