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ASD (Sustainment) McMahon and DASD (Environment) Sullivan Update on the DOD PFAS Task Force

Nov. 20, 2019
Assistant Secretary of Defense for Sustainment Robert H. McMahon, Deputy Assistant Secretary of Defense for Environment Maureen Sullivan

ASSISTANT SECRETARY OF DEFENSE ROBERT H. MCMAHON: Let's do this, if you could. And I'm stalling for about two minutes. We'll go to five minutes extra, whatever you want to do, just to make sure everybody's got time. 

But if you would, please – some of you I know, I've had the opportunity to spend time with you before. Some of you are new to me. So if you wouldn't mind introducing yourself, that would be really helpful. 

I'll start right there. 

Q: Right here? Travis Tritten with Bloomberg Government. I'm based here in the building. 

MR. MCMAHON: OK, very good. 

Q: Ariana Figueroa with E&E News.

MR. MCMAHON: Good to see you again. 

Q: Hannah Hagemann with the National Desk at NPR.

MR. MCMAHON: Thank you. 

Q: Tom Bowman with NPR, based here. 

MR. MCMAHON: OK, good. When you say "here," in Washington or in this building? 

Q: Both. 

MR. MCMAHON: Congratulations and condolences, I'm not sure which one. 

Q: Annie Snider with Politico.

MR. MCMAHON: Good to see you again. 

Q: Suzanne Yohannan with Inside EPA.

MR. MCMAHON: Good to see you, (inaudible).

Q: Patricia Kime with Military Times.

MR. MCMAHON: Good to see you. 

Q: Tara Copp with McClatchy.

MR. MCMAHON: Very good. 

Q: David Vergun with OSD PA.

Q: Richard Levine, Army Public Affairs. 


Q: David Nokes, OSD PA.

Q: I was going to say, David is...

MR. MCMAHON: Goes without saying. 


Q: Britney Stevens, Navy Public Affairs.

MR. MCMAHON: Well, very good. All kinds of folks. 

I'm Bob McMahon. I am currently the assistant secretary of defense for sustainment. Among the many things that I have in my portfolio is a concern about something called PFAS [per- and polyfluoroalkyl substances] and PFOA [perfluorooctanoic acid], which is why all of you are here. 

STAFF: I'm sorry, sir. We have two that are online, so...

MR. MCMAHON: That's OK. 

STAFF: ... I'm sorry, ladies, we did – we did introductions and I skipped you, so I ask that you introduce yourselves to the group, please. 

Q: Yes, I'm (inaudible)...


Q This is Sharon Lerner.

Q: ... and I work for The Intercept. 



MR. MCMAHON: Very good. OK, I'm going to assume that – one of two things; somebody's coming through the door, we'll see who it is. And otherwise we'll get going here.

Ah-ha, the world's expert. I'm feeling so much better now. 

I feel so much better, Maureen, now that I see you.


MR. MCMAHON: You're fine. 

So I'm Bob McMahon, assistant secretary of defense for sustainment. Among the many things in the portfolio is a thing called PFAS and PFOA. Obviously, you all are intimately familiar with (inaudible) or you wouldn't be sitting in this room right now. 

I am joined today by who I think is, obviously within the Department of Defense, the premier subject matter expert, and on a given day, I'm beginning to believe, may be the nation's – one of the nation's premier subject matter experts on this, my deputy assistant secretary for environmental issues, Ms. Maureen Sullivan.

MS. SULLIVAN: Thank you, sir, I think.

MR. MCMAHON: Yes, it's good. 

Let me start, if I could, with just some opening comments. What I want to do is share some thoughts with you. Some of you have heard these before, but what I really want then, obviously, is to get into the discussions and the questions that you have for me and (inaudible) for the two of us, and I'm – I'm assuming that if you are here, you probably have some questions for us. And we'll make sure that we've got time for it. 

Ah, Mike, thank you very much. Your timing's perfect. I apologize that I left those on my desk. 

So clearly, over a period of time, we have been focused on doing something very simply, and that is taking care, as the picture indicates up there, of our soldiers, sailors, airmen and Marines. Not only them, but our families, and we have a sensitivity for what occurs outside of those installations where they're housed. 

And when we talk about issues and we talk about families, we are blessed in the military to have tremendously resilient families. And they don't ask a lot of us. One of the things they ask for us, is to make sure we take of them and that we give them a safe place to live. 

They want good medical attention for themselves and their families. They want, as well, good schools for their kids. And finally, that when we move them, we don't break all their stuff. And so that's part of the pact. And it doesn't sound like a lot, and they are tremendously resilient. But part of this, there's an expectation, is we take care of them. 

One of the issues where they're concerned today – and rightly so, as you are, is on the quality of the water that we have on our installations, where a thing called PFAS and PFOA may have been.

It is not a DOD issue, it is a national issue. You all are familiar with the movie, I'm sure, that's coming out Friday? It will talk about this and, I – you know, people say, what do you think about the movie? I'm excited about the movie because it underscores that this truly is a national issue, it's not just a DOD issue. And I think it highlights the challenges that we face and how we move forward with that, and I think that will help educate America a little bit more on some of the challenges that we face. 

But facing challenges in the environmental realm is not new for us. We are dealing today with issues that go back to the Civil War, that we try to deal with. We have – and if I mess this up, correct me, a hundred percent – about a $27 billion liability today for environmental issues. That does not include what the liabilities associated with PFAS and PFOA will be. And that will be on top of that. 

We spend about $1.3 billion annually on being able to pay that – that liability down. But the reality is that, as we become smarter about things we've done in the past, we can't continue to burn that down. It actually continues to build, year after year, because we find new things in new areas that we add to Maureen's portfolio to go deal with. 

And so over the last few years, in particular since about 2014, '15, and really '16, we've been with an emerging issue having to do with PFAS and PFOA. We know that the Congress is interested in it, we know the nation's interested in it, we know that the Department of Defense is interested in it. 

Quite frankly, if you look back and who's been proactive on this, the Department of Defense has been. And I think we've done very well with it, but we can always do better, and we're going to continue to do better. 

The new Secretary of Defense – not so new now – came in. The first thing the secretary did was stand up a PFAS, PFOA Task Force. Literally the first thing he did when he came in. That underscores, I think, from this perspective, of how important this is and that we continue to effectively go deal with it. 

So since 23rd of July, the task force has been stood up. He originally gave us 180 days to work through issues. He's shortened that to 120 to make sure that we were working as aggressively as we could. 

And when you talk about what it is that we're doing with the task force, we're really focused in three areas. Area number one is to mitigate...

Could I have whoever's on the phone that's not on mute to go on mute for me please? Thank you. 

Issue number one is for us to be able to mitigate. And if we can't mitigate, hopefully at some point in time, totally replace the current AFFF [aqueous film forming foam], which is the firefighting foam we use, which is the source of much of the issues that we're facing today on our installations. So that's issue number one. 

Issue two is to fully understand what the impact of PFAS and PFOA are on – on humans. We're obviously focused on our total population with the Department of Defense. In particular, we're concerned about our first responders. And in particular, there are firefighters who have been exposed to this for literally decades. 

And then the third part – thing that we're focused on is this discussion about how we do clean-up. And we could talk about as much as you want about any three of those.

So some of the things that we've been doing, I will tell you that I am not an expert and I'm trying to make myself one on this issue. And so I went down to the Naval Research Lab where they do testing for replacements for AFFF. Ms. Sullivan and part of our team went down there and watched how they test. What this really – when we talk about AFFF as an aqueous film. What does that really mean? Why does that play? What's the science of this?

I learned a new word, and we start talking about hydrophobic and oleophobic, and what does that really mean, and how do you go fight the fire, and how do the chemicals work? So the big thing for us is, can we find a fluorine-free firefighting foam that meets the stringent standards that we have? 

And that sounds easy. We understand there are folks in Europe doing that, but what does it really mean and does it work? This is AFFF. This is what it looks like, and if you went out and looked within a – with one of our crash trucks, that's what you'd find. This is a product that is a supposed potential replacement that’s fluorine free. This is out of 2018. It doesn't matter whose it is; it's one that we've been testing.

Imagine if you were waiting for this to come out of a truck, and the viscosity that you have associated with this. If you just put it in, it probably would have worked. If it sat for some period of time – and this is why we're doing the level of testing that we are, to understand whether our products that can not only today, but in the future meet our requirements. 

I watched AFFF being tested down at the Naval Research Lab and I saw two of the potential products and saw what it took. One of our tests is a very simple test, is in a – how many square feet – 28 square foot container, we pour in – pour in a fuel, light it and then, using the different products we have the – we have in a controlled volume coming out of the hose. We have 30 seconds to put it out. AFFF worked at 30 seconds. The other two products were I think 55 and 70 seconds.

What that means is, that although ultimately they worked, not in the timeframe that we need. Why is that important? That means that there are lives at stake in that period of time. It's one thing to be dealing with, let's say a helicopter that crashed out here. If you're on a ship, what does that really mean, and what do those 70 seconds or 50 seconds extra mean in terms of life to our sailors on the ship? 

Those are the kinds of things that we have to be sensitive to as we go forward and so are we focused on this? The answer is yes. Are we trying to find solutions? The answer is yes. I hosted a summit last Friday where we invited folks across the nation – firefighters, not just Department of Defense firefighters, but firefighters, the state fire marshal from the State of Ohio was there. Academicians, folks who are trying to help us understand how we get to a solution more rapidly than the way that we've been doing this, not just folks who have been looking at firefighting foam. Polymer experts who knew nothing about the business that we were in, but said we invited them and said, OK, help us think differently about this. Help us think differently how we look at this and how we go deal with it.

And so we spent probably about eight hours in the summit talking. We've got follow on meetings set up to continue the conversations, let folks go back and talk to their experts. This is an open tent concept. If you've got a great idea, if you think something is going to work, we want to hear about it. I mean, this is personal for me. I spent 34 and a half years in the United States Air Force. I lived on flight lines. I spent my time, normally every morning as a young officer, going out and watching the fire truck go to the end of the runway and shoot this foam out there because they were practicing, because we didn't know any better back then.

I lived that way. I've been exposed. My family has been exposed. My two kids have been exposed. So for those that suggest that we're not interested in this, it frustrates the heck out of me, quite frankly, because it is personal. It's personal for me and it's personal for hundreds of thousands of others who I have the opportunity to represent today to go find solutions for the things that we're trying to do.

Are we going fast enough? I don't have a solution to this tomorrow and if I can't clean everything up tomorrow, we're not going fast enough. But there's a reality to this that says, how do we go do this and how do we do it better? And so that's what we're trying to do with the task force. When we talk about some of the things that we've done with the task force lately, I think probably one of the biggest things is the collaboration that we're doing. Maureen has had the opportunity in the last month or so to sit down with the National Governor's Association – National League of Cities. A bunch of government agencies, she's part of an integral – intergovernmental agency talking about how we go do this and how do we make sure we take a holistic approach to the things that we're doing.

And we're asking a lot of her to be able to go make that happen. I talked about the summit. We're putting out guidance. You know, can we effectively price how much we're spending each and every year on being able to do cleanup and recovery? Do we know what we're spending each and every year on AFFF; and the reality is, if we're doing this right and we're mitigating properly, what we're seeing is a dramatic reduction in how much we're spending. So I ask that question. I thought it was going to be an easy question to answer. 

The reality is because of the fact that we are so diversified in how we go procure the AFFF, I couldn't look at an accurate number. The Defense Logistics Agency procures a clear amount – the clear preponderance of this, and looking at what they've spent over the last four or five years, it's come down, and I'm wagging now because I didn't do the math, but probably 80% – 80 to 90% reduction in how much is spent. That means the mitigation efforts are working. But is it enough? And is it holistic? 

The answer is no and we've got to understand it better. So giving guidance out there to better understand how much we're spending, where we're spending it, and making sure that that continues.

I talked about what we're doing to try to eliminate, and the efforts that are ongoing, and recreating the sense of urgency to go do that. All of these together get us to where we need to be. I'm going to guess that the first question is going to be, what's this technical document that you put out on the 15th of October? What are the standards to that?

The answer is what we tried to do is, as we talk about RSLs [EPA regional screening levels] and provide that, why do I want 523 different people trying to calculate whatever the right level is for taking the next step after we go through our analysis. Why can't I do it for them? And so, I put that out to provide guidance and try to make it done one time, correctly, as opposed to 523 different times for other people to calculate.

So folks, you know, look, folk – folks, well, why did you do that? The answer: I'm trying to make it easier and we spend less time trying to do calculations, more time trying to make sure that we're moving in the right direction.

So there's a variety of things that we're trying to do in terms of guidance. I'll give you a little peek under the tent. We'll sign out, hopefully, on Friday, a letter that's going out to all of our installation commanders. One of the things we don't – haven't done real well, and – and part of why I've asked to speak with you a second time, is our transparency and our activity in getting the message out. And so part of this is, I want our installation commanders at every installation that we have to go talk to the community. I want them to be able to communicate, first of all, what it is, PFAS, you know, PFAS/PFOA 101; if you – when – when we talk about this, people look at you like you've got three heads unless you're intimately involved in it like you all are.

So go – go understand what that looks like. What does it really mean, and most importantly, how does it affect my community? In many communities, there's a – it's a non-issue. We have, if at all, very, very marginal levels that have – that the bases had get into – get into the ground. And so, part of the message is saying you don't have to worry about this here. At other places, as you all know, that we have levels that are higher, and in some cases where it's gotten into water systems, it's been above the 70 part per trillion lifetime health advisory, and so we've reacted to that. But I want installation commanders to understand that and talk to the communities, and more importantly, get feedback from the communities.

So it – it is this cumulative approach that says, as we move forward, what is it that we can do? And again, three things: mitigate and eliminate, deferred version of AFFF; understand the health impact of that, and we're doing a variety of things not only internal to the Department of Defense, clarifying it for health providers, but partnering with the Veterans Administration in that area; and then finally, what are we doing and how are we moving forward on the clean – clean up and understanding it?

Maureen, anything you want to add that you need to correct, you know, 100%, or just open it up for questions?

MS. SULLIVAN: I think questions are... 

MR. MCMAHON: OK. Let's – let's do that. I'm going to start – I started that way – started it that way. In terms of introductions, I'm going to start this way.

Q: I mean – thank you. So by my calculation, you're pretty much at the 120-day mark. Do you have a report that's due to the secretary, or what are the due outs at this point? And then I have a couple others.

MR. MCMAHON: Absolutely. So question one is, we'll do a – an interim report. We literally reviewed it this morning, and that will hopefully go to the secretary, in a perfect world, before Thanksgiving; and at the end of our full time what we'll do is, hopefully by late December, early January, put a final report out, as well. 

Q: And what can we expect to see in that report?

MR. MCMAHON: In terms of the results, or in terms of what you can see publicly?

Q: Recommendations and...

MR. MCMAHON: I will tell you, I'm – and I – interestingly, even internal to the Department of Defense, this is not about recommendations; this is about actions, and it's – it's to delineate to the secretary what it is that we've done, where we think we've made progress, and what our next steps are. 

And I don't want to get ahead of giving it to the secretary, but I'll give you another peek under the tent. We have talked for – for – for an extended period of time about 401 installations. What we did is as part of this process, we think there's probably more installations than that, and I'm not ready to tell you what that number is, but we found that we undercounted within some of the Guard sites that we have out there. And so part of this is refining what those numbers look like.

I'll tell you up that front – up front that that – that occurred. It wasn't – no one was trying to hide anything. It's just how – how we did the assessment. And so I think what you'll see out of the report is a revised number above 401, and – and I think that's good because it helps us more realistically assess where we are.

Q: OK. Would one of those recommendations be any sort of easing of service connection – presumptions that, you know, service members or their families could take to the V.A. because they were exposed?

MR. MCMAHON: Part – and I'd go back to element number two – and Maureen, jump in at any point in time. I think part of this, and – and you know that we have a whole series of studies being done outside of the Department of Defense by ATSDR [Agency for Toxic Substances and Disease Registry] looking at what the impact on health is, that are looking at eight locations immediately surrounding Department of Defense locations, and then they're looking at another seven...

MS. SULLIVAN: Multi-site, nationwide (inaudible)

MR. MCMAHON: Yeah, and so that they can create the database and – and look and see what kind of variations. Part of this is, I don't think that we as a nation fully understand, and so I don't want to get ahead of the medical providers on that issue. But I think part of this is – is how do we communicate differently to our health providers to make sure, as they listen to conversations, they can help provide a more accurate picture? Anything...

MS. SULLIVAN: So one of the things is establishing the relationship between the department and V.A. to share information, so that's one of the activities. So how are we going to communicate with V.A.? Another is recording the information in databases of what – how we've tested the drinking water, so that information is available to judge exposures. So it feeds into that. Again, it's up to ATSDR in terms of the health aspects, so (inaudible)...

MR. MCMAHON: By the way, before I forget the thought, if you've not seen it, our website went live yesterday. The intent is to be as transparent as we can with the information that we have. And again, that – that becomes part of it to create the – the trust with folks, again, because we know that this is a significant emotional issue. I mean, let me...

Q: OK. Just one – one more.

MR. MCMAHON: All right.

Q: Just one last one. One of the kind of outstanding pieces is the – to what level or (inaudible) you would ever do a cleanup because of the minimum levels; that there's still disagreement on what those minimum levels should be with – should we expect in this report that there would be a, like, clean up to this level, or a willingness, if they – up to a certain level, or...

MR. MCMAHON: Our – our job is to respond to – we don't create levels. That – that is not our job. Our job is to respond to what the nation establishes; and so right now there's a single number out there. It is a lifetime health advisory in drinking water of 70 parts per trillion. That's what we responded to, I think proactively, up to this point in time. There are no – there is no one drinking water above 70 parts per trillion where the Department of Defense is a purveyor of – of the drinking water; and we're very proud of that and – and, you know, if – if the rules change and – and the levels change, then our job is to figure out how to respond to that. 

Go ahead, (inaudible)

Q: So on that note, then, regarding levels and adding new faces or National Guard sites, are we talking ground water contamination? Are we talking drinking water? What – and why – why are you still finding new places, if all the places were tested?

MR. MCMAHON: As – if you go out and look at all of the armories and, you know – we went out and I think we responded very well initially and focused on, if you will, the – the four services. Quite frankly, we probably, when we first responded – and I'll let Maureen comment on it – to that question – I don't think we thought about a National Guard Armory, but we got a responsibility there.

And so this is – is – I mean, this – I think this is good news, because we've – we've looked – it’d be real easy, OK, let’s not talk about that. The answer is just the opposite. Let's make sure that there's not an issue there. You know, what could we have done to have caused an issue there, and let’s add that.

So I think it – it's – it's a better understanding in making sure that we've been more holistic in the way that we're approaching it.

MS. SULLIVAN: So you have to remember, this is the first step of where we have known or suspected releases. So there's something that we actually had a foam there and that there was a potential. That's the first step. So then we'll go on to see if there was a potential release. So this is the first step – we haven't necessarily got to.

So figuring out was there foam there?

Q: Right.

MS. SULLIVAN: And – and so... 

Q: So that – you're saying that the new – the new ones will be that new – you found out there was a release and now you're ongoing ... 

MS. SULLIVAN: Known or suspected.

MR. MCMAHON: Known or suspected, yes.

MS. SULLIVAN: Yeah. And a – and a couple of them, the regulators asked us to go do some more looks in – in – in those circumstances, which we said fine, we'll go look. So... 

Q: Second question (inaudible), is – can you talk a little bit about these – this directive to commanders? Are they going to be holding – is this an order, a directive for them to all hold some kind of town halls or go to city council meetings? What do you envision that looking like now?

MR. MCMAHON: I'll give you my perspective. Each community is different. Many communities, based upon the size, have some sort of RAB [Restoration Advisory Board] out there where it's a perfect place to engage, they've probably already been engaged out there, those conversations have been going.

In some cases, because of the size of the installation an armory – a National Guard Armory, there may not be a relationship today. So part of this is to figure out what fits best for that community to be able to communicate the issue and – and to make sure that community understands what the impact is.

So it is, you know – don't picture this – this is – the directive isn't by gosh, you're going to go do this, it is what makes the most logical sense for where you are? If there is an established organization, you've probably already engaged and just let us know what you've been doing. Where there isn't, let's find what the right is – right – what the – what right looks like there and make sure that we're doing that.

MS. SULLIVAN: And I wouldn't say it's a one-time engagement, it's ongoing.

MR. MCMAHON: And – and that's really the – the hope of this, is – I – I – we – I – quite frankly, I know that national interest on this is going to peak after Friday. People are going to go, oh my gosh, I've got that. Part of this is to make sure, irrespective of the movie, though, is to make sure we're engaged in the communities.

I mean, we – we can't survive without the communities that support us and we have a responsibility to be talking to them. Go ahead.

Q: Oh, sure. Yeah, this refers to your October 15th memo about investigating... 

MR. MCMAHON: It does.

Q: ... PFAS... 

MR. MCMAHON: I know it.

Q: ... for cleanup. So there's some overlap with EPA's draft groundwater cleanup guidance that you're – your Marines are familiar with. So I'm wondering if EPA finalizes that groundwater cleanup guidance of their own, and it differs from your screening level triggers and your – I know your cleanup is – is a little different, it's risk assessment based, but they have a PRG [preliminary remediation goal] – if – so if EPA's differ and it's more – perhaps more stringent, are you going to follow it, or are you going to follow yours?

MR. MCMAHON: So let's answer the first part of that first, and – and that is what did we use in this conversation?

MS. SULLIVAN: So – so we used the current numbers. And – and just to clarify, this is to help once you – the installation finishes the preliminary assessment site inspection, they're supposed to go decide, apply a screening level, whether they go on to the remedial investigation.

And as Mr. McMahon said, instead of each location running that number, we ran it once based on EPA's lifetime health advisory. So it's based on the health advisory. If EPA changes the number, then we will – the – the numbers, then we will update the guidance, but it's based on what is out there right now.

Q: Your trigger level, your screening level?

MS. SULLIVAN: The screening level, to go – to go from the – one step to the next.

Q: But then if you find the chemical and it's alone and not with the other PFAS, it's 400 parts per trillion in yours, but in EPA's draft, their screening level's 40... 

MS. SULLIVAN: Again, it's draft... 


MS. SULLIVAN: ... we will have to – as I said, we'll update based on whatever the final is. But we – because we're making these decisions now, and EPA has not issued a regional screening level – because that's the normal process, the EPA issues a regional screening level – we – we just ran it – the – if they don't, then you run this – run this calculator. We just ran it – the calculator for our staff. That's all this...

Q: So you – they come out with something more stringent...

MR. MCMAHON: We – we adapt.

MS. SULLIVAN: We adapt.

Q: OK.

MR. MCMAHON: That's right.

Q: OK. And have you had discussions with EPA, you know, recently on this matter?

MS. SULLIVAN: This is a – one of the issues in the interagency discussion, where we're all communicating together. We're – we're waiting anxiously to see where they are in the final…

Q: Can you just say who's in the interagency discussion? Not people but the...

MS. SULLIVAN: The organizations?

Q: Yeah.

MS. SULLIVAN: It includes EPA, USDA, Health and Human Services...


MS. SULLIVAN: The National Economic Council, OMB, DOE, Department of Transportation, NASA. I think that's everybody.

Q: How come the National Economic Council – is that Nancy Beck?


Q: OK. 

MS. SULLIVAN: But OMB is really...

Q: OK.


Q: OK. 

MR. MCMAHON: Thank you.

Q: This is Rebecca with The Hill, can I just jump in with a follow up on that?


Q: I'm sorry, I just – I'm having a little trouble hearing over the phone, too. So I think – I just didn't totally understand it. And so the limit you guys are using for tap water, is it 40 or 400? And I was also a little confused by the discussion – like you mentioned there's a calculator, I'm kind of confused why this differs from the 70 parts per trillion.

I apologize, I just can't hear that well, what the – what the discussion was.

MS. SULLIVAN: So the 70 parts per trillion is the drinking water number, and we are fully following the drinking water. So anywhere the drinking water tests at or above 70 parts per trillion, according to the health – EPA's health advisory, we're treating the water to bring it below.

The – the October 15th document is related to how we proceed through the CERCLA [Comprehensive Environmental Response, Compensation, and Liability Act] cleanup process. So when we finish the preliminary assessment site inspection, we have to make a decision if we're going to move to the remedial investigation phase. The process is laid out in the CERCLA regulations. 

Normally, EPA would publish a – a Regional Screening Level, an RSL, that says what that number is. They have not published a number. So as a consequence, the normal process is you use their calculator tool, using the reference dose behind the Lifetime Health Advisory to determine when you go to the next step in the investigation process. So it has nothing to do with drinking water. It has nothing to do with what the cleanup level is. It is simply how you move from one step to the next in the CERCLA cleanup process. 

MR. MCMAHON: And just the only thing I would add to that is, the intent of the letter was to provide common guidance across the Department of Defense to do exactly what Maureen just described. It was nothing new. 

Q: So is that 40 though or 400? I see both numbers and I'm not sure which I should – which one I should use. 

MS. SULLIVAN: 40 is the screening number. And so – and that's where you say, oh, I need to go look further. 

MR. MCMAHON: And that's with PFAS and PFOA.


MR. MCMAHON: OK, go ahead. 

Q: Yes, so Annie Snider of Politico. 

I just want to make sure that I'm clear when you're saying that if EPA tightens or finalizes something you will adapt. Are we talking about a change to the health advisory or were you talking about a final...

MS. SULLIVAN: Either/or. 

Q: So I wanted a little more clarity on why you're not keying off of the groundwater cleanup guidance the EPA has now. I understand it's out in a draft version, but this type of guidance EPA doesn't normally put out for comment into a draft; like it's normally final and relevant the minute that they do it. So why – why wait for them to finalize something when they're already indicating that the screening levels ought to be lower than that 400? 

MS. SULLIVAN: First of all, they got – my understanding is they got multiple comments, hundreds and hundreds, so I don't know when they're going to come final. But in the meantime, we are at that phase, our people need to move into the next step. So we have to move forward under the CERCLA process. 

But the guidance isn't final. I don't know what it is going to be. So I can't suppose the outcome of EPA's action. 

MR. MCMAHON: I would ask you – and the only thing I'll add to that is, if we responded before it was established, I think folks would find fault with us for doing that. Imagine if it were – it came back and it went from 400 – I'm making this up, but if it went from 400 to 800. Then the question would be, well, why did you spend – why are you reacting to something before that? 

We've got to operate on the data that we have, and the decisions that are made up to this point to the best of our ability. And we’ll have the ability to adapt once that guidance is out there. 

Q: So I also wanted to ask about this issue of there being sort of numbers for people – of PFAS and PFBS [perfluorobutane sulfonate], but we know that we're finding PFASes beyond those three, at some DOD installations, I'm thinking particularly of Peterson Air Force Base where PFHxS [perfluorohexane sulfonate], is of concern. 

How are you going to be dealing with that? Are you screening for that? What numbers would you be using? 

MS. SULLIVAN: Until there are numbers that come out of EPA, we're just recording the information. So it’s – we're waiting on EPA. 

Q: And what type of number from EPA? So they're working on toxicity values, would that be sufficient for your purposes? 


Q: Can I ask a follow-up? This is Sharon Lerner, over the phone, hello?


Q: Yes. About the inclusion of PFBS, why is PFBS the one non-PFOA and PFOS [perfluorooctane sulfonate] PFAS that's included? 

MS. SULLIVAN: Because EPA has issued a tox value for that. It's a...

Q: OK. Thank you. 

MS. SULLIVAN: It's a PPRTV, and do not ask me what that acronym stands for, I apologize. [Eds. note: provisional peer-reviewed toxicity values] 

Q: OK. Thank you. 

MR. MCMAHON: Go ahead, sir. 

Q: You mentioned that the interim report will hopefully go to Esper by Thanksgiving; do you expect to release anything out of the interim report, or will you wait until the final report is released before you...


MR. MCMAHON: I think it's important that we share what we can after the secretary has seen it, after we've shared information with Congress that the public has a chance to see some of it as well. 

Q: So hopefully the interim? 

MR. MCMAHON: I would hope that there would be – yes, short answer is yes. 

Q: And also, are there particular places in the country you're most concerned about; I know it's a concern across the board with DOD and Guard facilities. But are there particular sort of hot zones that could be like the larger bases, Hood, or Norfolk, or something like that? Where is this a particular problem with groundwater and everything? 

MR. MCMAHON: Clearly, if you think about AFFF, and what it's used for, that kind of drives you where you expect to have issues. And I think that that's an initial indicator. You know, clearly at a location where there's no aviation activity, that would have a lesser expectation than a base, hypothetically Nellis Air Force Base, or someplace like that that is – has the volume of flying that it has, and things going on. 

Yet, and I may mischaracterize this a little bit, until I talked to the fire marshal from the state of Ohio, I did not realize all of our firefighters have to have the ability to deal with the firefighting foams that we're utilizing. And so the reality is, and again all it is reinforced back to the point that this is a national issue. 

It is – you know, I don't know what every community in the nation has done, but that's why we've got a look at this holistically, is to make sure we understand it. 

Yes, ma'am.

Q: That segues nicely into my line of questioning. So I've been speaking with firefighters, and they're very concerned about their exposure and they're really advocating for medical monitoring. So I know there's some different avenues that that could happen, such as H.R. 1863, an amendment in NDAA. But if that amendment does not pass, will you take it upon yourselves to implement medical monitoring for military firefighters? 

MS. SULLIVAN: You going to let me go with it? 


MR. MCMAHON: Go ahead. 


MS. SULLIVAN: So, one, I can't presuppose the outcome of the NDAA; hopefully we'll know in the next week or so what is in it, and if it has the language we'll be prepared to implement. I would actually point to ATSDR, which doesn't recommend medical monitoring, so, because having the presence of – having the information of what is in your blood doesn't lead you to a diagnosis. 

So we're monitoring what ATSDR recommends at this point. 

Q: Well, NIOSH [National Institute for Occupational Safety and Health] is actually conducting a study on firefighters and PFAS levels in their blood.  

MS. SULLIVAN: Yes, could be. Yes. So but I can tell you one of our bases did test all their firefighters voluntarily, and the levels came out to be exactly consistent with the NHANES [National Health and Nutrition Examination Survey] data, if you're familiar with the NHANES data that ATSDR – CDC maintains.  

Q: Sure. I've also seen that their levels can be three times beyond the average population for firefighters. And so on that line, you know, for a firefighter who was a military firefighter for 40 years and is concerned about his exposure and is now retired, this man is looking to get his blood tested but cannot. So what would you suggest to someone like that who served and wants to know how exposed they – they were?

MR. MCMAHON: Part is, we both alluded to earlier, part of what we're doing today is the conversations between the Department of Defense and Veterans Administration so that there is a commonality there to better understand, and that's part of the process we're trying to put in place today. So that the V.A., for all those that have previously served, have a better understanding of what it is that we're trying to do and the alignment, the information that we have. 

Q: Final, final question. So you know, firefighters still use AFFF, that contains PFAS chemicals and it's an emerging concern for you guys. Are you considering putting out a set of standards or protocols for how these military firefighters should handle AFFF?

MR. MCMAHON: The first – so the first part of this – of the conversation is exactly for the point that you've made, is the fact that there is not a viable replacement yet. It's why we've changed the behaviors for the Department of Defense since 2016, where we're not utilizing it for training, we're utilizing it simply for actual fires, which reduces that exposure.

The part of the conversation we're having is with our fire chiefs, literally as part of this process, to understand what it is that we may have to do or should be doing in terms of how we move forward, in terms of better protecting our firefighters. And that's an integral part of the conversation that we ought to be considering. 

MS. SULLIVAN: And just so you know, I mean, so far I think we've used the foam twice this year; twice, that's it. 

Q: But it is still used to respond to emergency fires?

MR. MCMAHON: Absolutely. Because – because there is no other alternative at this point in time. 

MS. SULLIVAN: I mean – and we have to – we have to – we have to deal with the acute hazards, the fire and the crash.

MR. MCMAHON: So part of the conversation is as well – and we talk about military standard – a mil standard – you know, part of the conversation is, should we bifurcate that standard? Should we look at one standard for ships, which has one set of issues, and have a different for – for ground-based. And as part of the analysis that we've got our experts looking at, to make sure that may give us a different flexibility than perhaps if we just went with a single standard.

Every opportunity that we have to look at doing business differently is the approach we're trying to take. 

Yes, ma'am? 

Q: And kind of just a follow-up to that, is it still being used for practice, the AFFF?



Q: OK. And then I had a quick question about, like, farmers who are around bases and, like, either their livestock has been contaminated, their drinking water from the firefighting foam. How has that factored in? 

MR. MCMAHON: I – only because there is ongoing litigation right now with specifically a situation like that, I want to – I'm not really in a position I could talk about it right now.

Q: But is that – are you taking that into, like, consideration with, you know, your report or no?

MR. MCMAHON: Again, because of the ongoing litigation, I – it's something I've got to stay away from right now in terms of conversation. 

Q: Could I just clarify something really quick? I just want to make sure I understand. So in terms of, like, national-level fire practices, at bases and for military firefighters, there is no standard in terms of handling the foam or in terms of wearing personal protective equipment at this time? Is that correct?

MS. SULLIVAN: No. There is nothing in the material safety data sheets either, so. 

Q: Thank you. 

MR. MCMAHON: You're welcome. 

Q: Could I ask one more question over the phone? 


Q: It's Sharon Lerner. I wanted to follow up on this interagency council I think you mentioned. Is there a press liaison or a press contact who could give me information about membership of this interagency group and perhaps provide any more information about what – what it is doing?

MS. SULLIVAN: I'm not aware that there is a press point of contact. OMB is leading this, so – but this is pretty routine for large policy issues, for the interagency to have a discussion. That's OMB's role. 

Q: Mm-hmm [yes]. And can you say anything about how often the group meets and what its role is exactly as it pertains to the – the process that you're talking about with, specifically the CERCLA?

MR. MCMAHON: What – what I think the intent of the group is, to make sure that there's a clear, consistent administrative – administration policy on the way forward on this discussion. 

MS. SULLIVAN: And overall, it's to make sure we all know what everybody's doing. I mean, it's awareness of – of activities among the federal agencies. 

Q: Hi, yes. So you said that you expect the number of potentially affected installations, 401, to increase. Obviously, there's going to be a lot...

MR. MCMAHON: And when I say installations, imagine something as small as an armory in a local community. Right? And so it – this isn't 80,000 acres necessarily, it could be a very small organization.

Q: Right. So obviously, there's going to be a lot of interest in that. Can you give us some sense at all of how much? Are we talking about a small increase? Going to be maybe a dozen, is it going to be a hundred, is it going to be two hundred? Can you give us some sense of what you're thinking about...

MR. MCMAHON: That's part of what we're going through right now to make sure that we've accurately calculated what that is. I would – I don't want to get ahead of myself or the team as we go through that process. 

Q: OK. And so that increase, is that going to be part of the interim report or part of this final report, just to be clear?

MR. MCMAHON: I would tell you that we are – we're not – because of the sensitivity and the under – sensitive is not the right word. Because we want to be accurate, if we can put it in the interim report and identify what that growth would be, we would do that. If it were – still trying to make sure we've got it accurately identified, we'd defer it to the – to the final report. 

But again, this is making sure that what we know is – is an accurate assessment, an accurate count. 

Q: OK. So it could be in the interim, it could be in the final report?

MR. MCMAHON: That's correct.

Q: And just to be clear, the interim report is going to Esper soon, so you expect that to come out within days or a few weeks?

MR. MCMAHON: I would hope that in the near future, we can get that out as we get it through the coordination process.

Q: Yes. And just so – because you had said, I believe, that the final report could be done by the end of December, early January?


Q: OK. Because that's very close together, so...

MR. MCMAHON: Well, and that's a great point. Again, go back and picture what the original guidance that the secretary gave me. And that was, I want an interim report at 90 days, I want a final report at 180. So it made logical sense, 50 percent of the way through, that we give them an interim report. 

He then said, I want this to go faster. So 180 became 120, so what we want to do is make sure at the interim point, we're giving him an accurate picture of the multitude of things that we're doing, and then he's asked us – and oh, by the way, let me make a point. 

I don't know what will happen after 120 days, whether the task force (inaudible) continues to go, whether it stands down. It's irrelevant to me, because the focus is on doing what's right for our soldiers, sailors, airmen, Marines, their families and the communities. And so we're going to be just as aggressive as we are today, whether or not we define – decide that there has to be a task force. 

If you look at what we've been doing on housing privatization, the battle rhythm for meeting and working those issues is literally just about the same battle rhythm that we're having with regards to PFAS PFOA.

And – and so I – the task force I think was the smart thing to do – I believe strongly was the smart thing to do, but it isn't going to – our behavior isn't going to change whether the task force is up or down. We're going to continue to do exactly what we're doing, we'll continue to communicate with the communities, be transparent, working the interagency process, as well as talk with all of you, because this is helpful to us that we get the story out.

Q: Now I want to ask you about your vials there.


Q: So you said this repeatedly now, that there's no viable alternative that you've found to AFFF.

MR. MCMAHON: And – and that's measured against the – the mil standard that we have today for the testing that we do. Nothing that we have looked at that is a non-fluorine – that is a fluorine-free product has yet met the – the test standards that we have.

Q: Right. So you're coming down to the end of your time. I can't imagine there's much more time for testing. So is that going to be one of your final findings, is that there's no viable alternative?

MR. MCMAHON: No, exactly just the opposite. What – what we'll say is today there isn't, but hopefully tomorrow there will be, or a year from now; and that was the whole idea of the summit that we had, is to bring anybody that had – it – was mildly interested in this into a room together to talk about this, to figure out what it is that we could perhaps do differently – the addition of polymers, can we change why we think about it, is there something magical in a different part of the – the national – international enterprise that could – could apply here?

So the...

Q: So you think it's possible that somebody will invent something by the end of December?

MS. SULLIVAN: Oh, no, no, no, we – we've invested about $22 million and this research will go on for – for several years into the future. So I don't see the – the 120 as the end of research, I see we're going to be going for...


Q: ... the – the task force?

MR. MCMAHON: Oh, absolutely. It – it existed before the task force; they've been looking at this for a number of years, and we'll continue to look at it over an extended period of time until we find a solution. And then once we find a solution, we'll – the next thing will be how can – can I make the solution even better?

MS. SULLIVAN: We just did the call for proposals for fiscal year '21 research projects. So, you know, we've just awarded all of the fiscal year '20 research projects, so they’re just starting. You know, so I see this research going on.

Q: Before (inaudible)...


Q: If I can just finish – but – but – but it's likely, so at the end of all this when you issue a final report, it's going to probably say that you haven't found a viable alternative?

MR. MCMAHON: Yeah and – and the – the operative word there is yet. And we continue to make investments. I'm not sure that there's anyone investing more time and energy or dollars right now to find a solution than what the Department of Defense is.

Q: Can I – I'm sorry.


MR. MCMAHON: One second on the phone, please.

Q: So...

Q: OK.

Q: ... at our previous roundtable, I brought up that the – well there's service-level guidance on PPE [personal protective equipment] and all of the services have pictures out there of sailors on decks squashing with AFFF. And a little deeper digging, they're still calling it AFFF, even though they say it's the swapped out, but there's no checks on that, there's no safety, like – you see...


MS. SULLIVAN: ... but remember, we didn't change the policy for shipboard. So the – the prohibition on using the foam is for land, it's not for ships. So ship practices stay the same.

Q: So they're still using the more dangerous AFFF...

MS. SULLIVAN: Well we're changing out the – the – yeah, it's AFFF, you're right...

Q: Either way.

MS. SULLIVAN: It's either way. So yeah, they're using the quote "newer version" as they procure – they replace the one with PFOA (inaudible) with PFAS, of course the Navy changed the military specification this summer to – to eliminate the requirement for a fluorine chlorinated (inaudible) and set minimum levels.

So as we buy new and replace it, it will be the newer version. It's still AFFF.

Q: Cause you can go on DVIDS right now and see guys without gloves, no masks, no nothing, just sweeping off the deck, covered with foam, unfortunately.

MS. SULLIVAN: Well sometimes – sometimes it's an expansion foam that works really nice versus an AFFF.

Q: And then one last one. So your initial release in response to Congress, you know, where they – everyone got the 401 sites, cause often it's an installation that has more than one site on the same installation, is there any desire to update that? Because those numbers are starting to get a couple of years old now, and maybe go retest some of these wells?

MS. SULLIVAN: So I don't see, unless Congress asks us – updating the report; however, we're following the CERCLA process. So in – all of these reports come – become public documents and are – are part of the administrative record for each – each site. So all of that information and the testing is a part of the whole cleanup process.

So if it's generally – this is a general number, – if it tested around – above 40, we're monitoring it to – and that – that gets all rolled into the administrative record by site.

Q: How are you guys monitoring it, if you don't mind just elaborating...

MS. SULLIVAN: It depends on the local circumstance. So in some cases, it would be more testing.

STAFF: OK, I hate to be the – our lease is up on this space so we...


Q: For the – for the new – the new ones that we're about to hear, you know, that eventually, how – how long does the testing process take? So when you all say there was a release, they're going to want to know what – when am I going to find out what the level...

MS. SULLIVAN: Suspected.

Q: Yeah. Suspected release or actual release, right.

MS. SULLIVAN: That process normally takes two to three years overall, but, you know, some of it is already – some of it's already started, so where they are in the process is going to depend.

Q: OK.

MS. SULLIVAN: But that's the normal – preliminary assessment site inspection takes two to three years.

Q: OK.


STAFF: All right, sir, do you have a 30-second PSA [public service announcement] to lead us out, or is that it?

MR. MCMAHON: At the end of the day, very simply, this issue has the secretary's attention; it has the leadership of the Department of Defense's attention; and it has our attention and will continue to have that. At the end of the day, this is taking care of our soldiers, sailors, airmen, Marines, their families and communities where we reside.

We are serious about it, and we hope to continue to communicate to you all, as well as to our Congress and our communities, where we are and what we're doing. And we appreciate your interest because you help us in the communication process. So thank you all very much.

STAFF: I thank you all for participating. I'm sure you have follow on questions. Send them to me and I'll try to get you some responses. 

MR. MCMAHON: Thank you.