NAVFAC NW PFAS Drinking Water Investigations
The Navy is addressing past releases of per- and polyfluoroalkyl substances, commonly known as PFAS, under the Navy Environmental Restoration Program. These substances may be present in the soil and/or groundwater at Navy sites as a result of historical firefighting activities using aqueous film forming foam (AFFF), which is considered the main DoD source of PFAS releases. This foam was also used for firefighting training, equipment testing, and as a component of fire suppression systems. Additionally, plating shops used PFAS formulations to suppress the airborne release of PFAS compounds. Since drinking water sources may have been impacted by the Navy’s past use of PFAS products, the Navy’s first step has been to sample drinking water sources (off or on our installation) that are close to known or suspected releases of AFFF in accordance with Navy Policy.
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.
PFAS Regulatory History
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 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 Jan. 21, 2015, 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 EPA at least 90 days before starting or resuming new uses of these chemicals in any process.
Unregulated Contaminant Monitoring Rule (UCMR)
The EPA 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 the six 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 percent 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).
USEPA 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 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 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 one-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 relates 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 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 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 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 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 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 Sept. 30, 2017.
For more information on the Navy’s work on PFAS see the following website URL: