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
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 – Results as of Tuesday October 1, 2019|
|Number of Parcels Potentially Impacted*||Number of Drinking Water Wells Permitted to Test||Number of Drinking Water Wells Tested||Number of Drinking Water Wells above the LHA||Number of Drinking Water Wells below the LHA||Estimated Number of Households/ Businesses Potentially Impacted|
* Includes developed and undeveloped/vacant lots
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 recent preliminary assessment conducted at MCOLF Atlantic identified 11 on-base areas where PFAS-related releases potentially occurred, and additional investigation is needed. These are listed below in Table 2.
|Table 2. Potential PFAS Source Areas at MCOLF Atlantic|
|1||Circa 2000-2002 Forest Fire Area #1|
|2||Circa 2000-2002 Forest Fire Area #2|
|4||Historical Crash Crew Staging Area #1|
|5||Historical Crash Crew Staging Area #2|
|6||Historical Crash Crew Staging Area #3|
|7||Historical South Runway FARP Area|
|8||Current FARP Area and Associated Parking Areas|
|9||Prescribed Burn Sites|
|10||M151 Jeep Emergency Response|
|11||CH-46 Helicopter Emergency Response|
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.
MCOLF Drinking Water Investigation Documents
MCOLF Atlantic Drinking Water Investigation Fact Sheet (October 2017)
Sample Invitation Letters to Property Owners (October 2017)
MCOLF Atlantic press release (October 3, 2017)
MCOLF Atlantic Open House Posters (November 8, 2017)
MCOLF Atlantic press release (November 28, 2017)
Sampling Reminder Postcard to Property Owners (November 2017)
Sample Results Letter to Property Owners (February 2018)
MCOLF Atlantic Drinking Water Investigation Fact Sheet (updated February 2018)
Postcard Invitation to Open House (February 2018)
MCOLF Atlantic press release (February 12, 2018)
MCOLF Atlantic Open House Posters (February 21, 2018)
Project Update/Sampling Reminder Postcard to Property Owners (July 2019)
Drinking Water Sampling FAQ
ATSDR Per- and polyfluoroalkyl Substances (PFAS) Frequently Asked Questions
ATSDR Interim Guidance: An Overview of Perfluoroalkyl and Polyfluoroalkyl Substances and Interim Guidance for Clinicians Responding to Patient Exposure Concerns
ATSDR Perfluoroalkyls – ToxFAQs
ATSDR ToxGuide for Perfluoroalkyls
Minnesota Department of Health Summary of Results: Perfluorochemicals in Home and Gardens Study
New York Department of Health: In-home Water Filtration Options for Household Drinking Water
USEPA Fact Sheet: PFOA & PFOS Drinking Water Health Advisories
USEPA’s Per- and Polyfluoroalkyl Substances (PFAS Action Plan)