The Defense Department held its second virtual PFAS public engagement recently, the first being in July. Attendees were primarily from communities around military installations where PFAS, or per- and polyfluoroalkyl substances, have been identified in groundwater. Representatives from the White House and the Environmental Protection Agency also attended.
Richard Kidd, deputy assistant secretary of defense for environment and energy resilience, and Herb Nelson, director of the Defense Department's Strategic Environmental Research and Development Program and Environmental Security Technology Certification Program, spoke.
PFAS are found in many consumer products, as well as in a certain firefighting foam called aqueous film-forming foam, or AFFF. The foam is used by the department, civilian firefighting organizations and many industries to rapidly extinguish fuel fires and protect against catastrophic loss of life and property.
Kidd said that the four areas that the PFAS Task Force addresses are:
1
Mitigating and eliminating the use of the current AFFF;
2
Fulfilling PFAS cleanup responsibilities;
3
Understanding the impacts of PFAS on human health;
4
Expanding PFAS-related public outreach.
As for cleanup, the department follows the federal cleanup law, known as the Comprehensive Environmental Response Compensation and Liability Act, or CERCLA, Kidd said.
The first step is the preliminary assessment and site inspection phase. When PFOS, perfluorooctane sulfonate, or PFOA, perfluorooctanoic acid, are identified in drinking water levels that are above EPA's health advisory of 70 parts per trillion, the department has provided a fast and immediate response — bottled water and point-of-use filters — while determining an appropriate long-term solution, he said.
"As of now we have taken such short term actions at 50 off-base sites around our installations," he said.
The department has identified 699 installations, up one from July, where it believes PFAS may have been used or potentially released, Kidd said. The preliminary assessment/site inspection phase, or PA/Sis, have been completed or are underway for all of these installations and the goal is to fully complete them all by the end of fiscal year 2023. Currently, 171 have been completed, up from 129 in July.
"We believe that the rate of completion will increase as we move throughout fiscal year 22," he said. "As we move through the CERCLA process we will get a much better understanding of the engineering requirements."
That knowledge will also inform future budget requests, he said, noting that current estimates of future cleanup costs are $2 billion, but that figure will likely increase over time.
The CERCLA process involves many steps and takes some time to complete, but it also provides a consistent approach that includes environmental regulator coordination and the opportunity for stakeholder input, Kidd said.
In following the CERCLA process, DOD investigates the off-base migration of PFAS, including at private drinking water wells, he mentioned
DOD uses the EPA drinking water health advisory levels to trigger short-term cleanup actions to address PFAS in drinking water. But as long as the health advisory levels are exceeded in one location, short-term cleanup actions can now be taken at all other portions of the same impacted groundwater where drinking water levels are currently below the health advisory level, but are reasonably expected to be above the health advisory level at some future point, absent action, Kidd explained.
The department is working to develop new technologies that can speed up the cleanup effort, he said. To that end, the department has invested $90 million in research and development through the end of this year.
Plans are to invest another $70 million through FY25, on a range of technologies related to detection, on-site destruction, remediation and other aspects related to PFAS, he said.
This cleanup effort is done in concert with the EPA and other agencies, as well as with leading academic institutions, he added.
As for mitigating and eliminating the use of the current AFFF, Nelson said the department has two programs related to finding alternative substances to PFAS that are safe and effective in putting out fires.
The first is SERDP, the program established by Congress in 1991. It is a partnership among the department, the EPA, the Department of Energy and academia that supports laboratory research, Nelson said.
The ESTCP, the second program, was established by the department in the middle 1990s. This program moves technology and solutions from the research and development stage in the lab to the implementation stage in the field, he said.
Finding a suitable replacement is a hard problem, "maybe harder than we realized when we got into it," Nelson said. A viable alternative to AFFF must meet military specifications in terms of the time a fire must be put out, it must meet EPA standards for human health and environmental standards, it must be usable in existing equipment and it must not degrade over time in storage.
"The DOD owns something like 2,700 crash trucks and civilian airports own more than that. So, there's a huge investment in hardware that we want to make sure we can use these things in that equipment," he said.
The military specification requirement is that a gasoline fire in a 28-square-foot pan must be extinguished within 30 seconds or less. AFF foam containing PFAS can currently do that, he said.
All of the other PFAS-free foams took between one-and-a-half to two times longer in the test facility, which is at the Naval Research Laboratory, Chesapeake Beach, Maryland, and at Naval Weapons Station, China Lake, California.
One PFAS-free agent took 57 seconds to extinguish the fire, he said. "That doesn't sound like a lot of difference, but if you're in the airplane that just crashed, that's going to seem like an awful long time."
Another problem with the foam that took 57 seconds was that there was a burn back once the fire seemed to be extinguished, he noted. That's a big problem.
Yet another problem is that it is very difficult to measure the amount of PFAS that are in commercial substitute foams, because these foams are made up of a number of different types of surfactants that interfere with the measurements, he said.
There is a group of researchers at the Naval Research Laboratory in Washington D.C. that is working on developing a method to be able to measure the amount of PFAS in these foams, he said.
Nelson admitted that his team was a little disappointed in 2017 when they started, that there were not many proposals from industry for an AFFF alternative.
Since AFFF has been in use since 1970, there has not been a lot of researchers working on substitutes, he said, so his team cast a wider net in search for alternatives.
"Based on the results we have seen so far, I am cautiously optimistic that we will find and deploy a PFAS-free alternative within the timeframe currently required by the NDAA [National Defense Authorization Act]," Nelson said.
Congress has mandated that the current AFFF containing PFAS must be phased out by the end of FY24, so the department is doubling down on its efforts to find alternatives, working with Navy and Federal Aviation Administration laboratories, other government agencies, fire chiefs from around the country, industry and with foreign partners, he said, adding that Congress has provided for requests for extensions until FY26.
The next PFAS public engagement is scheduled for January and plans are for more to follow.