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Richard Kidd, Deputy Assistant Secretary of Defense for Environment and Energy Resilience, and Dr. Herb Nelson, Director, DOD's Strategic Environmental Research and Development Program and Environmental Security Technology Certification Program Public Remarks on PFAS

MODERATOR:  Good afternoon ladies and gentlemen. Thank you for joining us today for our second Department of Defense PFAS discussion, hosted by Mr. Richard Kidd, Deputy Assistant Secretary of Defense for Environment and Energy Resilience.  And we'll be joined today by Dr. Herb Nelson, Director of DOD's Strategic Environmental Research and Development Program, and Environmental Security Technology Certification Program.

Thank you again for taking your time out of your busy schedules to meet with us this afternoon.  Before we begin, just a few quick ground rules. We are recording this session, and we will post a transcript to our website, defense.gov after the event.

One change based on some feedback from our first event back in July is that we will take questions during the presentations.  What we ask is that you raise your hand using the zoom function and wait for the end of that slide before you look to ask your question.  And bear with me, hoping that we won't have technical difficulties, but I'm in a separate room from Mr. Kidd and Dr. Nelson.  So, we'll have to work together here to get those questions.  So, I appreciate your patience in advance.

And just as a reminder, for the session today, if you have an installation specific question, or a service specific question, we won't be able to address those here.  We will, however, take those questions in writing and reply to you after the event.

Also, when it is time for you to ask a question, please state your name and the organization that you are representing.  And as time allows, we hope to allow every individual to ask a question and receive a response.  And if we do have more time, we'll go back around to the start.

And one last thing at the end of today's session, I'll be sending an e-mail to everyone seeking your feedback, ways that we can improve things you liked or didn't like about today's session so that we can ensure our future opportunities meet everyone’s shared interests.  So, thank you again for joining us today.  And I'll now turn it over to Mr. Kidd.

MR. KIDD:  Good afternoon. Peter, thanks so much for the kind remarks.

Good afternoon, everyone.  It's good to be here again.  This is, as Peter said, this is our second of what will be a continuous effort, at public engagement around all issues of PFAS.  So today I'm going to give just a quick summary a little bit of update of where some of the things have changed from where we were in July, as well as -- and then turn it over to Dr. Nelson who will talk about our efforts to find an AFFF replacement.

So next slide.  I would also like to say that, you know, on the line today we have representatives from the White House, the Environmental Protection Agency and all the military services and that the interagency efforts around PFAS are expanding significantly.  And you'll see some announcements as early as next week from some of our fellow agencies on the topic.  So, I welcome those reps here today for this event.

So, this slide, just basically is a little bit of reminder of how we structure ourselves in the Department of Defense when it comes to the issue of PFAS.  So, in 2019, the Secretary of Defense Mark Esper created a PFAS Task Force.  It has senior level representation from the military departments, the key elements inside the Office of the Secretary of Defense, the Guard Bureau and the Department of Defense Health Affairs.

So, this administration re-chartered that, or continued the charter for the PFAS Task Force and expanded the areas that we're going to look at.  So, the four areas that the task force addresses are mitigating and eliminating the use of the current AFFF firefighting foam, fulfilling our cleanup responsibilities, understand the impacts of PFAS on human health, and expanding our PFAS related public outreach.

So, I'm going to actually start with number four.  So next slide, please.  So, following this event in July, we asked for your feedback.  And everyone on our team and myself read the comments that everyone provided us.  And I appreciate that.  And I learned a lot in reading those comments.  And today we're trying to do our best to address some of the things that we heard.  So, first of all, all the slides, the transcript and the written responses to the question from the July session have been posted on our website.

I recognize that some of you would have liked the answers to the questions or the responses to the questions posted faster.  But I would just say that many of the questions we received were installation specific, and we had to send the questions down through the respective service to the installation and to give that garrison team adequate time to respond.

We shifted the timing of the event.  We're going later in the day which is what most people wanted.  We can't go much later than this due to the constraints of the facilities.  But we heard you and we're trying to do, trying to respond as best we can.

We've expanded the invitee list.  We are open to taking questions during the presentation.  And our next session will be in July, probably -- or correction January 14th, and that's our target date, we'll just stick with the 14th.  And the intent there is to have the Deputy Assistant Secretaries from all the military departments join me and be able to answer more department and/or site-specific questions at that venue.  And we have updated our website with the results of our cleanup activities as they progress.

Next slide.  So, in terms of cleanup, I'll start there.  So again, this is a slide that most of you have seen, if you were here in July.  This is a quick summary of the CERCLA process, and the department follows the CERCLA process when we address PFAS response.  The first step is that preliminary assessment site inspection phase.  Right now, all the known sites in the department are in that phase or have moved past that phase.  All right.

The CERCLA process takes time to complete particularly for groundwater cleanup, but it does have significant flexibility to act quickly when PFOS or PFOA are identified in drinking water levels that are above EPA's lifetime advisory.  When this occurs, we the department have provided a fairly fast immediate response - bottled water, point of use filters, while we determine a more appropriate long-term solution.  As of now we have taken such short-term actions at 50 installations, 50 off-base sites around our installations.

Next slide.  Right, so this slide again you've seen before, but this has been updated with the results of the past three months.  So, the department has identified 699 installations, up one from July, where we believe PFAS may have been used or potentially released.  The PA/SI is completed or underway for all of these installations.  And we plan to complete, fully complete all of the PA/SIs by the end of fiscal year 2023.

Of the 699 installations where we have started the investigations, we have completed work at 171 of them.  This is up from 129 in July.  So essentially, we completed 42 PA/SIs in the last quarter.  We believe that the rate of completion will increase as we move throughout calendar -- or throughout fiscal year '22.  529 sites are still under investigation.  Of the 171 that being completed 73 have been identified as requiring no other action.  So, this is an increase of 10 from the 63 that we had briefed in July.

Thus, the total number of installations under any kind of active review by the department has actually gone down to 626. Of the 171 installations that have completed the PA/SI, 98, up 32 from 66 in July, are proceeding to the next phase of the CERCLA process.  As we move through the CERCLA process, we will get a much better understanding of the engineering requirements at each site.  And we'll use that information to prepare our out year budget requests.  Right now, we anticipate the future cleanup costs to be about $2 billion.  But as we progress, this number will likely increase over time.

Next slide.  So, I'd like to just take a few minutes and talk about state and federal standards.  I have met with state regulators over the last couple of months, both in small groups and large groups and both paying close attention to this issue.

As you are aware the CERCLA process involves many steps and takes some time to complete.  But it also provides a consistent approach that applies to everyone and includes environmental regulator coordination, and the opportunity for stakeholder input.  For example, as DOD moves through the CERCLA process, it works in collaboration with regulatory agencies, communities and other stakeholders to ensure open and transparent information sharing.

DOD follows CERCLA, investigates the off-base migration of PFAS, including at private drinking water wells.  Under the CERCLA process risk-based toxicity information is used nationwide to determine if a response is required.  Federal and State cleanup standards are evaluated as required by CERCLA and its regulations to see if they will be incorporated in final cleanup levels to be attained at a specific site.

This process is called applicable or relevant and appropriate requirements process.  The process applies to both state drinking water and groundwater cleanup standards.  And state drinking water standards can be used to set final cleanup levels at private wells under the ARARs process.

DOD recently made a decision that clarifies where and how we can take quick action under CERCLA and expedites when state standards can be evaluated and brought into the process.  DOD uses the -- let me just sort of describe this, sort of the portions of this.  DOD uses the EPA drinking water Health Advisory levels for PFOS and PFOA to trigger short-term cleanup actions to address drinking water removals.

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.

Once the need for this cleanup action has been made, the drinking water can be treated down to state level standards that qualify under the ARARs process.  Even in this early short-term removal action phase.  Right now, we are in the process of documenting this decision and making an official DOD policy.

I just highlight this as it is part of, you know, the ongoing efforts by the department to seek ways that we can work responsibly and -- as responsibly as possible within the authorities and guidelines that are provided by CERCLA.  So, when I first came -- when I first met with many of you months ago, I said look, we're going to take every opportunity to make incremental improvement in every step of the process.  I think we've found a way to do that, in this instance, and it's just an indicator of our commitment to continuous improvement.

Next slide.

MODERATOR:  Sir, this is Peter, just to interrupt before we get to the next slide.  John Reeder from Environmental Working Group had a question.  He sent it to me in chat.  So, I think we'll try this and see how this works.  His question is, will DOD conduct remedial investigations if the detections at a site are below EPA's Health Advisory levels?

MR. KIDD:  So as indicated, the EPA Health Advisory level is the trigger.

Q:  Mr. Kidd?

MR. KIDD:  Yes.

Q:  This is John Reeder from Environmental Working Group.

MR. KIDD:  Hey, John.

Q:  Thank you for hosting, by the way, this is terrific.  I just wanted to get clarification on one point, I think it was on slide five.  And I apologize, I didn't know how to ask the question.  So, I did send it into Peter.  But you'd mentioned that 98 are proceeding through the process.  And I guess my question goes to, does that mean they all had, you know, they all hit that trigger of 70 or the EPA Health Advisory level?  And can you talk a little bit about what it means if they haven't been triggered into the RI/FS?  And you know, is this a matter of priorities or are you cutting them out from further action if they haven't hit the trigger?

MR. KIDD:  And that's a good question.  So let me clarify.  So, we use the value of 40 parts per trillion for PFOS or PFOA individually to determine whether to proceed to the RI, all right.  So that's the trigger value on those individuals or the 70 parts per trillion, either one will trigger the next step.

Q:  Okay, so if they haven't -- even if you hadn't done a comprehensive look or testing to really get a comprehensive look at the potential fate or transport within brown water, it may not see additional action for some time or what happens.

MR. KIDD:  Yes --

Q:  Yeah, go ahead, sorry.

MR. KIDD:  No, no, John.  So, look, you've done a lifetime of CERCLA work.  And I respect that.  So, I think you're going to rapidly exceed my detailed knowledge on the individual inputs and takes on the CERCLA process.  So, I think the main takeaway is, we follow, you know, we follow CERCLA, we follow the laws and the guidance that EPA has given us.  And we're seeking maximum flexibility within those laws to be as responsive as we possibly can.

Q:  Okay, well, we can dig into that question later.  That's fine.  But thank you.

MR. KIDD:  All right.  Great.  So, I've got us on slide six.  No, yes.

MODERATOR:  Yes.

MR. KIDD:  No, I got us on the next slide, my slide -- next slide, please.  There we go.  So, also part of our cleanup responsibility is to identify new technologies that can speed up our work.  So, I've spoken in the past that, you know, the time for cleanup is bounded by the physical properties of our -- of the world that we work in, the chemistry, the physics, the engineering, and so the department has a very large R&D effort designed to push the boundaries of what we can achieve.  And we have, as you see there, we've invested $90 million through this year, and we plan another $70 million through F.Y. 2025, on a range of technologies related to detection, to in-situ destruction, remediation, and a variety of other issues and aspects related to PFAS.  And we do this work in concert with other agencies, as well as with leading academic institutions.

And this, in the yellow there, we just highlight to you, you know, an example, last month working closely with the EPA, we got the first EPA validated laboratory analytic method to test for per- and poly-fluoroalkyl substances in eight different mediums.  So, what does this mean?  It means we have a better job of defining the problem, the faster and more precise we can define the problem, the faster we can put in place a response.

So, this is just one indicator of many of the efforts and anticipate more will come in the future.  And one of which, of course, has to do -- next slide, with finding a solution, or finding an effective PFAS free firefighting solution, and that's what Dr. Herb Nelson is going to talk to you about next.  So, we've been working on this problem for some time.  We made significant investments, we started with 20 possible solutions, we're now down to a smaller number than that.  The short answer is we are optimistic in what we have seen.  We believe that many of these solutions are adequate when it comes to addressing jet fuel related fires, which is a primary concern of the department, but perhaps not as good at addressing gasoline related fires.

So, with that, as a quick summary, I'm going to turn to Dr. Herb Nelson -- turn the floor over to Dr. Herb Nelson, who will be able to show you some science and engineering.  So, thanks, everyone.

DIRECTOR HERB NELSON:  Thank you very much.  I’ll bend down so you can hear me saying the next thing.  I'm, as Mr. Kidd said, my name is Herb Nelson, and I'm very pleased to be with you today.  I don't know whether my slides have been switched to me or not.  I think that's happening.

MODERATOR:  Yes, sir.  I've given you host.  So, you should be able to share now.

DR. NELSON:  Yeah, problem is knowing how to do that.  Hang on a sec.  Peter, I'm afraid that my slides don't appear to be up here.  Am I sharing the desktop?

MODERATOR:  I will get some assistance in there to you right away, sir.

DR. NELSON:  Sorry about that.  I'll talk to you about what's on the first couple of slides so we can -- don't just have to sit here in quiet air.  So, we are really two programs.  Peter said them when he introduced me early on at the start.  The first is the Strategic Environmental Research and Development Program.  This was established by Congress in 1991, as a partnership among the EPA, the Department of Energy and the Department of Defense.  It's headquartered out of Department of Defense so I'm a DOD employee.  But we're coordinated with those other three agencies.

SERDP primarily supports research at the laboratory scale.  So, it's a research and development program, we're developing things there.  But it extends all the way to what the DOD calls advanced development.  And that might be a test plot out in the backyard of the research institute or at a university.  It might be at a test plot out at the research station if it's a land grant university, something like that.  So that's where SERDP goes.

ESTCP -- here comes some help.  Hang on just a second.  Sorry about that.  Yeah, there we go.  Okay, we're almost there.  Hang on a sec.  There we go.  Okay, bingo.  So, I've already told you all this stuff.  But what I didn't tell you as I started, I'm joined today by my colleague, Dr. Andrea Leeson, who manages all of our PFAS cleanup research and development.  So, when I talk a little bit about that, I've got Andrea here as a backstop.

So, I've told you there were two programs, I've told you all about SERDP.  And I'm just getting ready to tell you that the Environmental Security Technology Certification Program, which is a little hidden behind our logo here, sorry about that, was established by the department five or six years after SERDP started and the department realized then that sometimes these R&D programs come to the end of their program, they have a nice little report, and nothing happens.

So, then we need an intermediate program to move things from the R&D stage out to the implementation stage.  And what we do is a lot of these four bullets at the very bottom is built to transition technology, excuse me, out of the lab, that's what I do for a living, I should be able to pronounce that.  It is, we work hard to establish cost and performance in the real world.  Everybody's a genius in their laboratory.  A lot of people stop being a genius when you get out in the real world.  And you see all the things that go on there.

While we do this, we always partner with the regulators and end users.  Because when we get done with this, we want these technologies out of the laboratory out of ESTCP - out to being used.  And of course, we do technology transfer.  So, as you can see, as it just popped up, it's a real-world program, under real-world conditions.

So now I'm going to talk to you a little bit about the PFAS problem writ large at SERDP, before I focus in on AFFF.  So, we got started on this in 2009, when the EPA published its provisional Health Advisory for PFOS and PFOA.  Andrea and her team got right to work.  We started soliciting proposals, we wrote a solicitation, we got proposals in, we judged them, we got the contracts going.  And in the beginning, we started three projects on in-situ remediation.

So, we quickly learned two things when we, as those projects started.  Number one, this is a hard problem, maybe harder than we realized when we got into it.  All of this, of course, seems simple now in 2021, but we learned it a long time ago.  And the second thing we learned is it's not just a PFOS and PFOA issue.  PFAS is a whole class of compounds.  And we've got to broaden our scope.  And look at all of those.

So, we started another group of projects in 2014.  And then you can see in 2015, we started some ESTCP demonstrations.  And that's really how it normally goes, it takes three to five years for a technology to get mature and be ready for demonstration in the field.  So, as I fill this thing in, you'll see this SERDP work and then it just flows in the ESTCP work.  So, I'll start filling this in.  It's a zillion clicks here.  So, I'll click some.

So, you can see how we're doing and cleanup technologies, the SERDP work at the top is getting to be more and more complex systems, and the ESTCP at the bottom is following them all.

In 2017, we started our first project looking for next -- what we called at the time next generation AFFF.  By that you should read PFAS-free substitutes -- alternatives to AFFF.  We were a little disappointed that we didn't get many good proposals to that call.  And then we realized these things have been in use since 1970.  So, there's not a lot of people that have been working on it.  It's not a very active research field.  So that's why we didn't get so many proposals.  So, what we did the next year was put out a call again.  But this time after only one-year proof of concept proposals.  That way we could have a wider band of what we accepted, and we could try to grow the investigator base.  So, in those days, we weren't really limited by money, we were limited by people that have the know-how to make progress on this thing.

I hope I will convince you at the end we've really grown those and now we're not limited anymore by the investigator.  So, we continued along working of course on our PFAS cleanup stuff while we were doing the AFFF replacement work.  We started doing some demonstration validations, some measurements in the field on PFAS, AFFF and you see we got smarter now, we're calling it PFAS-free AFFF.

And so, this is the map up until about fiscal '20.  And then, when we started doing these demonstrations on, out in the field, these are the kinds of things we were looking at on PFAS-free AFFF.  So clearly the first one is fire extinguishment performance.  These are firefighting agents.  So, if they don't put fires out, they're not much good to anybody.  But then things that pass that gate, then we have to look at, can they keep the fire out?  Do they have an adverse impact on human health and environment?  Are they usable in existing equipment?  That's a very important thing.  The DOD owns something like 2,700 crash trucks, 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.

Shelf life, they are only used in emergency, you don't use these things all the time.  So, they've had, maybe sit in the truck for two years before something happens, we have to make sure they don't turn into Jell-O, and then all these other things we want to look at.

So, then in F.Y. '20, the landscape changed a little bit for us, because the National Defense Authorization Act of that year, put some new requirements on the Department of Defense.  And the most important one, or the most relevant one to this discussion is, DOD must phase out use of AFFF containing PFAS by October the first 2014 -- 2024, I mean, excuse me, which is of course the first day of fiscal '25.

So now we've got a deadline we're working toward.  So, this of course focuses the mind, we put out some more calls and you see something else, now we're doing development and demonstration in parallel. We don't really have the luxury of doing them sequentially, like we would normally do, because we have a deadline we're working toward.  And then we've continued to put out more and more calls on clean up, more and more calls on enhanced agents to put out fire.  So, we're working this problem in both SERDP and ESTCP working toward this deadline.

So, of course, now we're going to shift back out of the PFAS, the large world of PFAS.  So, we're going to focus from now on, on the PFAS free alternatives to AFFF.  And so, you can see all the calls and those little numbers that you might not be able to see very well, are the number of projects that we supported out of those.

Up at the very top of this slide is a very small print URL of where you can find a hyperlink version of our website.  And the very last slide, I'm going to show you a much easier way, that eyes that are even younger eyes than me probably can't see that.  So, I'll show you a way that you can get to that URL quicker at the end of the talk.

Okay, so if you've been following along, you probably know what's going to go on in these two slides.  So, what’s SERDP doing, we're looking at new developing new agents, we're looking at developing additives that might improve the performance of the existing agents.  And we're also looking at new technologies that don't even include foam.  So, any way we can think of to meet the requirement without involving PFAS.

ESTCP on the other hand, I told you it's a demonstration validation real world problem.  That's where we're doing real fire tests.  We're looking at both commercially available and developmental species.  And we're doing all sorts of tests at varying fuels, varying application rates, et cetera.  And I'm going to show you a few examples of those as we go along.

So, we don't do this in a vacuum though.  So, here's back to a picture of all of our projects, but it's not like we do these without anybody else being around.  We consult with lots of other federal agencies, other scientists, users, you can see the third bullet is State Fire Marshals and DOD Fire Chiefs, people from industry, we have work, we have international colleagues working on this.  So, this is both an all of government problem, and an all of the world problem.  And we're involving all those people.

One way we do that is over the past three years, we've had a workshop once per year, where we bring all the experts that are listed in that box on the left together, and we talk about our progress.  We make sure we're asking the right questions.  And lots of times as you get smarter you understand you didn't really ask the right question the first time.  And we put out plans for what we should be doing in the next couple of years.

So, in addition to involving a lot of people, we're spending a significant amount of money on this problem.  Mr. Kidd already showed you the amount that we're spending on cleanup.  If we look at just a PFAS free alternatives, by the time all those projects that are on the screen up there are completed we’ll have spent about $70 million on that.  That's a lot of money for a program the size of SERDP and ESTCP.  So, we're taking this very seriously and committing serious resources to it.

We're also doing it all around the country.  You can see this is a map of all the work we do, and this has got both the cleanup research and the AFFF alternatives in it.  But we've got people at universities, government labs, private industry, you can see down the bottom left, we've got some people in Australia working on this.  So, we're trying to get the best minds in the country and in the world working on this problem.

So, I'm going to talk just today about the PFAS alternatives stuff.  We have a lot of work going on at the Naval Research Lab, Chesapeake Beach Division, which is just down here, South of Washington.  In the bottom right of that photo, you can see that the smoke coming out of the fire test facility, that's where they do their tests there.

We have some equivalent work to that going on at Tyndall Air Force Base in Florida.  We've had some big scale test, and I'm going to show you a video of it soon going on at the Naval Weapons Station in China, Lake California.  And SERDP is not supporting this, but we're closely tied to scientists and engineers at the FAA technical center in New Jersey.  We have a monthly call with our demonstrators, our scientists, and the people in FAA, where we talk about plans, share successes, share failures.  So, we're trying to involve everybody that's got a stake in this, in this, in this problem.

So back to the -- back to what we're doing, all of the people that are doing it, now here comes the unhappy conclusion so far, there is currently no PFAS free alternative that meets the military requirements.  So now I'm going to explain to you all the things we're doing to understand that and to move to the next stage.

So, first step is map out what every available PFAS free compound can do.  So, we did a survey, we've got -- I forget the number 35, 40, something like that.  PFAS free compounds that are either commercially available or developmental.  So only some gallons are available.  We want to test all of those for all those characteristics that I talked to you about over here, and then later in that box.  Most of them went on to the fire test, a few of them are so thick, they remind you of Jell-O®, so they're just not really usable.  A couple of them are only available in like one gallon.  So, there's not even enough to do a fire test.  But almost all of them went through this fire testing.

And you can see in the bottom right of this, this is a 28 square foot pan fire with gasoline as the fuel.  That's the qualification test under the current MilSpec.  So, we look at the performance of all of those agents up in the top left at that test.  And we find that five of the PFAS free compounds really get superior performance, stand head and shoulders, I shouldn't say head and shoulders, stand shoulders or stand heads or whatever the right way to say that is, above the rest.

So, we really are focused in on these five for our further testing.  But I told you they don't meet the MilSpec requirements.  And here's an example of that.  So that fire, a gasoline fire needs to go out in 30 seconds.  According to the military specification, PFAS containing AFFF, the current AFFF can do that, you can see that the -- all of the PFAS free, things take between one and a half and two times longer.  So, they are definitely take longer to put the fire out.

So, here's an example of a fire.  I hope it's not as loud for you as it is for me, I'll speak up a little bit.  This is a big scale test at China Lake.  It started at 47 seconds because before that they were lighting the fire and letting it come up and start burning.  So, this is a PFAS free agent putting this fire out.  And you can see they're making progress here, beating the fire back.  We're going to see how nimble I am because I have to do something slick in the middle of this, it may or may not work.

Working their way back on the fire, in just a few seconds, they're going to have to pause though.  Right about now, they pause, and they see that there's some flash back up over on the left, they have to stop their progress and put out the little flashbacks on the left.  And so, oops, it didn't work, sorry.  Okay, well, I was supposed to stop that there.  Let me figure out how to go up, I don't know.  That ain’t good.  So, I'll just tell you, we -- I'm going to play it again.  And we're going to talk while I play.  So, I was going to stop that 38 second in, and tell you that traditional AFFF can put that fire out in 38 seconds.

This PFAS free agent can take about 57 seconds to put this fire out.  So 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 20 sec.  So, the other thing you're going to see is I've already showed you one time where they have to stop and put out the little flickers on the left.

At the end of the video, which we're not going to get to, they click it done at 57 seconds.  And then they notice there's some more burn back on their left and they have to go back and attack it again.  So that's really a characteristic of these PFAS free foams, they don't make as good a foam, they don't seal as well.  So, it's much more of a problem with this burn or flash back in PFAS free foams.

So now that you've seen that, I'm going to show you some of the other things that we've done, some of the other tests we've done on these and I'm going to illustrate it.  We've done it on many of them, but I'm able to try it with these five best performers.  So, you've already seen that they did the five -- you've seen that data on the left-hand side of that plot.  It takes them longer to put out a gasoline fire.  All of these products put out jet fuel fires more quickly, it still takes the PFAS free ones longer than it takes AFFF.  But now we're down into the times getting into the 30 seconds for jet fuel fires.

So, one obvious conclusion of this is jet fuel is easier to put out from gasoline.  I'm a physical chemist, a lot of really cool physical chemistry reasons for that, but you don't want to know - but anybody that calls me up, I'll talk to you about it for hours.

The other thing, and this, of course, won't surprise you, if you spray this stuff on faster, the fire goes out faster.  So that's not like rocket science to figure that out.  But we did that test, and you can see, you get some improvement by spraying it faster.  That sounds like a good thing.  We put the fire out faster.  But there's a downside to that.  Oh, I'm sorry, it also happens for jet fuel.  So, the same way, for gasoline and jet fuel.

Here's the downside though.  Spraying it faster, may require more trucks, these trucks cost up toward a million dollars.  So, there may be a significant capital investment required if you if you have to apply faster.  The other thing we looked at was nozzles.  On the left is the standard DOD firefighting nozzle.  You can see if we go to an alternative nozzle on the right, we can put the fire out faster.  That's a good thing.

MODERATOR:  Dr. Nelson, if I could interrupt very briefly before you get too much further.

DR. NELSON:  Sure.

MODERATOR:  Jared Hayes from Environmental Working Group has a question for you.

DR. NELSON:  Oh, great.  Oh, now I see your hand up.  I'm sorry.  I did not see that earlier.  Okay, Jared, what can I do for you?

Q:  No worries.  Thank you so much for the presentation today.  I really appreciate it.  My name is Jared Hayes, Environmental Working Group.  So just a quick question for you before we move on. We understood that the DOD was considering the option of establishing separate MilSpecs for firefighting foam application, including for non-PFAS foam for land use versus sea use.  Is that still being considered?  And what would be the timing and process for that evaluation?

DR. NELSON:  Well, yeah, okay, I'm sorry, I did not make myself clear.  So that -- so once we know that no PFAS free foam can meet the current military specification, then clearly the NDAA required us a specification for PFAS free foams.  And so, we're mapping out the -- all foams available, what they can do, and then that will be input to the people, the weapon system designers and fire protection engineers who will make the decision on what needs to be the requirements of the new foams.  So, I'm gathering all the data that they're going to use to make that decision.

Q:  Thank you for that.

DR. NELSON:  Cool, sorry about that, I didn't make that clear, I should have.

Q:  Okay.

DR. NELSON:  So, we'll -- so now that we're on alternative nozzles, you can see the one in the bottom, which is the bottom right, which puts the fire out faster, it makes a wider spray pattern.  So that's how come you get better foam, the fire goes out.  That can be a problem though because that means it doesn't throw the foam as far.  So, if it's a very large fire, you may not be able to get into the inside.  So, it may be a problem in a big fire and a smaller fire, it's definitely a good thing, because you put the fire out faster.  So, these are all the kinds of decisions that are going to have to be made by the people that understand what kind of risks they can bear, what kind of fire performance we need.

So, as I told you, we did this at several scales, you saw the 28 square foot fire, several of those, that's the standard qualification test.  We also did these in a larger outdoor fire - 400 square feet.  And then you've seen the video of the very large fire, that very large fire is 400 gallons of jet fuel spilled on the ramp, and then lit and put out.  So, the goal of this is we'd like to find that the 28 square foot fire performance is predictive of those bigger fires, so that we can use the 28 square foot fire for quick retest.  And we're very fortunate, it is predictive.  The ratios of times 28 square foot fire carry through to this bigger fire.

So, we're sort of at the end of my presentation here.  I just want to remind you that we've -- and actually Jared's question really brings me back to what I want to say, we're gathering data.  And you can see it on this slide also, we're gathering a lot of data that will feed into the development of the final requirements for PFAS free alternatives.  So, everything we've done will go off to people to be able to do that.

You've also seen that there's a lot of factors, it's just not as easy as finding something off the shelf and do it - some trade-offs might have to be made.  We are hoping to be able to find an agent that can drop into the existing equipment, remember I told you, to do that early on.  But if we can't, then that may require adjustments to the existing equipment or purchase of new equipment.  And that of course, would slow down the full implementation of a new agent.

But I am perfectly happy to say all though this is a little bit weasel worded, but I'm perfectly happy to say that after seeing all the stuff that we've done, I'm cautiously optimistic that we'll find and deploy a PFAS free alternative within the timeframe that is required by the NDAA.

Now here's that last slide I told you, I'd show you. It's a lot easier to find that stuff on the projects if you just go to our website, which is here in big type, so you can see it more easily.  The first thing under featured initiative is PFAS and AFFF.  So, you can find that there.  And you'll find a much more usable version of that timeline where you can see projects, final reports, project plans, et cetera.

So, as we close, I'd like to thank my colleagues who turned my boring old scientist slides into these slick public slides I was able to use today.  Thank you all for your attention and I think we're on to more questions now for both either for Mr. Kidd or for me.

MODERATOR:  Yes, sir.  Looks like our first questions from Kristen Mello.  Kristen, go ahead.

Q:  Hi, thank you so much.  I am actually a chemist in my, you know, educational field, and I have a lot of chemistry questions.  So, if it's possible, like, would you take them by e-mail or, I mean, you can take them now if you want.

DR. NELSON:  Yeah, I think that's the best way.  So, I spent most of my life being what I -- what is called molecular dynamics to sort of how compounds fell apart.  So, I can talk about the destruction of these things forever.  But --

Q:  Right.  Yeah, I have a lot of questions about the engineering and optimization of, you know, things like nozzles and dispersion.  I have questions.

DR. NELSON:  Okay.  So, yeah, so I may not know, you know, the deep, deep, deep details, but we'll work that, just as Mr. Kidd said, we can work this out.

Q:  Sure.  So, could we, would you please share an e-mail for us?  And thank you.

DR. NELSON:  Yeah.

MODERATOR:  Sir.  I'll interject there.  Kristen, and for anyone else, please send your e-mails to me.  And I'll ensure that they that get to Dr. Nelson, the working group, Mr. Kidd, whoever is the best source for that response.

Q:  Thank you so much.

DR. NELSON:  Great, great.  Looking forward to them.  It looks like Andrea has her hand up.

Q:  Hi, thank you so much for the question.  Andrea Amico from Portsmouth, New Hampshire.  I just want to ask, how are you making sure that the replacement foams are truly PFAS free?  Is DOD doing any of their own testing to be sure that there isn't any PFAS?  And I'd love to know, you know, who's creating these replacement foams?  And, like what's actually in them if it's not PFAS?  Thank you.

DR. NELSON:  Yeah, so that's obviously a multi part question.  So, you are correct, of course, it is difficult to ascertain that there's no PFAS in these foams, it's difficult to measure PFAS.  You know, as well as I do, every manufacturer will have something slapped on the side of the thing that has PFAS free.  So, it is particularly difficult to the levels that we have to have the NDAA specifies foams at less than one part per billion PFAS.

Now, you all know enough that it's not so hard to measure one part per billion in groundwater or in drinking water.  But it's really hard to measure that in these foams, because these foams are made up of hydrocarbon surfactants, siloxane surfactants, lots of things that interfere with the measurements.  So, there's a group at the Naval Research Lab here in Washington that is working on developing a method to be able to measure one part per billion PFAS in these foams, so that's the intention.

Q:  Okay, and what are they using to replace the PFAS?

DR. NELSON:  Well, there you can see they make foam, so you have to use surfactants, what's called surfactants, you know, Dawn® detergent is a surfactant.  In fact, it turns out that Dawn® detergent is not the worst fire suppression thing on Earth.  The people that do these things have this little watchword if something new comes in and it's worse than Dawn® they stop working on it.  So, you need to do things that make surfactants.  There are some hydrocarbon-based surfactants, these are head and tail molecules, you probably read about these when you read about these things.  So, the tail can -- doesn't have to be fluorinated, it can be hydrocarbon, or it can be made of other compounds such as siloxanes.  Those are the two primary now that we're seeing.

Q:  Okay, thanks.  I'll just follow up with one comment, one part per billion doesn't seem you know that's equivalent to 1000 parts per trillion and so if we're looking at part per trillion in the drinking water and, you know, I don't know I think one part per trillion doesn't seem sensitive enough in my non-chemist brain but that seems like there could still be a lot of PFAS or, you know, in the foams if we're not looking lower than the part per billion range.

DR. NELSON:  Well, I -- you act as if that's going to be a piece of cake, the one part per billion in the foams.  It's -- that is a very difficult scientific challenge.  So, no one will stop, if you've been following this and I know all of you have - the analytical techniques get better by the year and go down by year.  Nobody's interested in -- everybody wants zero PFAS in these PFAS free AFFFs.  And the manufacturers are all quite careful, they segregate their lines in their factories so that they don't inadvertently get some PFAS just floating around from some other line in there.  Everybody takes the best precautions they can take.

So, Peter, do I choose, or I guess at the top?

MODERATOR:  Yes, sir, it looks like Mark Henry with the next question from Wurtsmith.

Q:  Well, I have a simple question that you may have already tried.  But in my life, there's many things that people haven't tried.  Most of the AFFF that I've seen used in the equipment that's used to generate the foam relies on atmospheric air to create the foam.  What if you used a companion gas like CO2 to create the foam from the concentrated mixture, and thus encapsulate a bunch of CO2 over the fire?

DR. NELSON:  Well, so that would be referred to in the business as compressed air foams.  So, you want to particularly -- you're suggesting a particular version of those that use CO2 as a compressed air.  But the group -- I talked about some of the other places that are working on.  The group at Tyndall is working hard on these compressed air foams.  So, I'll talk to them about CO2.  I think they're primarily using either compressed air or compressed nitrogen, but I'll talk to them about CO2.  In some cases, though, we have done some work on how best to make foams and CO2 is not always the best foam generator.

Q:  Thank you.

DR. NELSON:  Roy?

Q:  Yes, I'm Roy Herzig, with Mass Development in Massachusetts.  And I had a question on some earlier discussions about what could trigger an earlier removal action.

DR. NELSON:  Okay, so you’re way over my head, I'm going to move over and let Mr. Kidd, come back up here, because --

Q:  Okay.

DR. NELSON:  You don’t want to be asking a scientist that question.  Well, you might want to, but you're not going to like the answer.  So, I'll sit off to the side, and then if we need some more from me, we can do it.

Q:  Okay, the question is essentially, what happens if a site is between a state standard that might be 20 parts per trillion and the EPA trigger of 70 parts per trillion.  Is it still possible to take early action to address that contamination since the state would require treatment for that particular water district or entity here or private well?

MR. KIDD:  So, are you talking about groundwater or drinking water?

Q:  I'm talking about groundwater.  Yes.

MR. KIDD:  Okay.  So, the trigger -- the two triggers I mentioned earlier, were the EPA 70 parts per trillion, or the individual measures of the particular PFOA or PFOS.

Q:  Yes.

MR. KIDD:  And what is significant about the sort of revised approach would have actually happens to be in Massachusetts, which I think you're aware of.

Q:  The joint base, yeah.

MR. KIDD:  Yeah, if we get one trigger, then we will address the entire likely spread of the plume, so --

Q:  Does that trigger in an actual production well, or could it be a sampling well?

MR. KIDD:  A drinking water -- that would have to be in a drinking water well.

Q:  Okay, actually in a production well.

MR. KIDD:  Yeah.

Q:  Okay.  Thank you.

MODERATOR:  Sir, it doesn't appear that there's another hand up, but we did receive a question via chat.  And that is from Pamela Miller, with the Alaska Community Action on Toxics.  Pamela, did you want to ask your question, or would you like me read it?

I'll just go ahead and read it, sir.  The question is, are you avoiding other problematic chemicals such as siloxanes?  How are you avoiding the regrettable substitution problem?  And that's in quotes.  Have you looked at the green screen program developed by clean production action?

MR. KIDD:  Great, so hey, we're going to do musical chairs.  I'm going to turn that back over to my scientist friend here.  Just coincidentally though, I will be in and out of Juneau Alaska next week with extended layover so I'm not sure where you're located.  But if you wanted to spring me from the airport for a cup of coffee, we could happily have a chat if you're in Juneau.

DR. NELSON:  So, I might hear, I might hear the phrase, substitution regret around here as much as maybe you use it, so people are very alive to that issue.  DOD itself is looking at the top performers in the -- after the fire thing -- for measuring their acute human health and ecological health properties.  We are working in conjunction with the human health agencies to look further than that.

Yes, we are aware of green screen.  And I think that -- I don't know the status of the discussions on that, because I'm not constructing the military specification.  But definitely nobody wants to play this game again in five years or 10 years.  That's definitely on the top of everybody's mind.  I hope that answered the question.  I can't see the questioner, so I can't see whether she's nodding.

MODERATOR:  All right, thank you, Dr. Nelson.  Let me see here.  I think we've got some others.  And actually, these were submitted questions from Tony Spaniola who couldn't make it today.  So, Andrea submitted those in writing, they were pre-submitted.  So, I know we have seen these questions.  The first, based on a statement, DOD has declined to accept responsibility for PFAS contamination, caused by its use of AFFF to fight non-military fires in host communities.  In Oscoda, the Air Force has claimed that it is shielded from liability in these instances, under the terms of one or more mutual aid agreements with the local municipality.  However, the Air Force has not produced copies of any of the agreements upon which it is relying.

So, two questions based on that.  One, will DOD produce those agreements?  And two, more broadly, why is DOD attempting to saddle local communities with the burden of cleaning up the contamination that DOD cost?

MR. KIDD:  So yeah, I wish Tony was here.  Because my first answer -- I sort of asked the question, when was the incident?  When did the incident occur?  Because I believe that this incident is, you know, many decades old.  You know, look, I was up in Tinton Falls, New Jersey this weekend.  And there's a little fire station down there.  And they're an hour and a half from New York City.  They got two fire bays and I said, wood -- or not wood, it's a metal shed building.  It's not fancy.  And they've got, you know, they've got two twisted pylons to recognize that they drove an hour and a half across state lines to help respond to a call for assistance from the New York City Fire Department on September 11, 2001.

So, you know, that's what fire departments do.  They respond to requests for assistance from other fire departments.  And -- and that's sort of the facts of the case.  So civilian agency asked for our help, and we provided it.  That's sort of, if not a, you know, legally sufficient mutual aid agreement in place, it's certainly a moral agreement to help one another.  So, I would hate to see anything that would sort of erode that sort of rapport between fire departments.

What I will do to, you know, in response to Tony's question is we'll do a formal task to the air force, we'll go back.  We'll see if we can, in fact, find a mutual aid agreement, or not, from decades ago.  But frankly, I don't think the presence of a mutual aid agreement should be taken as either a lack of department's commitment to addressing AFFF or a lack of good faith in our work with others.

MODERATOR:  Okay, sir.  There was one other question submitted, again, it's the other main question that Tony pre-submitted.

MR. KIDD:  Yeah, no, yeah.  So, I've got him in front of me.  I guess the group wants to read, let's go ahead.

MODERATOR:  Okay, sure.  I'll read it out.

DR. NELSON:  Yeah.

MODERATOR:  In a March 31, 2021, letter to Defense Secretary Austin, Michigan's governor invoked section 332 of the 2020 National Defense Authorization Act, Section 332, calling for the amendment of DOD's cooperative agreement with the state of Michigan to require that DOD's PFAS cleanup activities comply with Michigan standards?  What is the DOD's anticipated timeline for completing the required amendment?  Will it be completed prior to the one-year reporting period specified in Section 332?  Has DOD held discussions with the state of Michigan about the terms of the required amendment?  And if not, when does DOD expect to do so?

MR. KIDD:  Yeah, so this one like the first one is very site specific and so we'll just take it and respond in writing.

MODERATOR:  All right, thank you, sir.  Kristin Mello submitted a question in writing as well.  And she says during the earlier presentation, Mr. Kidd mentioned that DOD is in the process of writing up the updates to the ARAR situation.  Can you share an estimate of the timeline on that documentation?  Thank you.

MR. KIDD:  Yeah.  That was -- all right, so I cannot right now, I mean, we certainly can.  Oh, I'm getting help from the back.  Look at this, one month, that's pretty clear.  So, one month.  So, let's say sometime in November.  Thanks team.

MODERATOR:  And Ms. Amico, we've got your hand up, go ahead.

Q:  Thank you.  Question for Mr. Kidd.  And maybe this is what the one month will bring.  But I'm still a bit unclear where DOD stands on following state drinking water standards when they've impacted private wells?  I asked this question at the last meeting.  And I recall your answer was that the DOD would comply with state drinking water standards.  But then I believe that that was not the case.  And then I'm not quite clear based on your presentation today.  So where does DOD stand on adhering to state guidelines for drinking water?

MR. KIDD:  All right.  Yes, so I think I quickly, I took your question and what I thought was the context of pure drinking water.  So, when DOD is the drinking water supplier, we are required to comply with state and federal drinking water standards.  When we are doing cleanup off base, we incorporate state standards for final cleanup levels under the CERCLA ARAR process.

Q:  Okay, so if DOD was the source of contamination at a private well-off base, and the levels are above a state advisory, but below the EPA 70 part per trillion, what does DOD do?

MR. KIDD:  We incorporate the standards from the CERCLA process.  So, we go for the EPA trigger, or the lower triggers and we follow the CERCLA process.  As I've said repeatedly, we are bound by and follow federal law.

MODERATOR:  Okay, sir.  And just for everyone, we are right at about an hour.  But we do have one more question from John Reeder with Environmental Working Group.  His question is the NDAA required notification to agricultural operations of sites with PFAS.  Has DOD conducted the notifications for these sites?  Are there more notifications to be done?

MR. KIDD:  All right, John, I've got the -- thanks for that, let me find here on my notes, because I do have the exact numbers for you.

John, you asked so many questions.  It's hard to sort through them all.  Okay, here we go.  So, at the end of March, the Department has sent 2143 notifications to agricultural operations downgradient of 97 installations, all right, or National Guard facilities.  So, there are a number of reasons why the number of notifications is less than the total number, right?  So not all installations have agricultural lands nearby or downgradient.  Or we may not have detected ground, any PFAS in the groundwater, that could be affecting those agricultural operations.

I suspect that, you know, going forward as we continue the PA/SI phase, we will learn more at different sites.  And we'll probably have some incremental number of increased notifications.  So as soon as we find evidence, we provide the notification.  Does that answer your question, John?

Q:  I think so.  Jared, did you want to have a follow up on that, or are you…?

Q:  Yeah, that'd be great.  Just a quick follow up, was that there are various bases that have high levels of PFAS that are completely surrounded by farmland and have high level PFAS in their groundwater.  But they were not on the March 2021 notification list in the report released earlier this year.  So, the notifications are ongoing, is that correct?

MR. KIDD:  Yes, notifications continue to be ongoing when it's warranted.  Maybe if you've got specific installations that you think, you know, were not on the list that should be, I'll be happy to follow up on that, you know, be happy to follow up with that if you want to send us the list of what you've got, we can do a comparison and get back to you.

Q:  Sure, yeah, we listed a few in noted questions that we sent in.

MR. KIDD:  All 17 of them.

Q:  Yes.  Thank you.

Q:  So, Mr. Kidd, what about the quality of the questions, though?  It's not just volume?

MR. KIDD:  Yeah, well --

Q:  No comment?

MR. KIDD:  No, they're very good questions, right?  And as I continue to learn, you know, I learned from all of you and the questions that you sent all 17 of them, were very well done.  And, you know, working through the answers, and the responses, and my asking questions of our team was very helpful.  So no, thank you.

Q:  Thank you.

MODERATOR:  All right, sir we're over an hour now.  I think we ought to take yours and/or Dr. Nelson's closing comments, and then I'll just have a few wrap up logistics comments for everyone.

MR. KIDD:  No, I don't have any, you know, closing comments, I -- this is just what we're going to do from now on, we're going to hold these sessions every three months as a minimum.  And we're going to listen to stakeholders, and we're going to try to improve our response where we can and provide information where we can and be as transparent as possible.  You know, where we can I think Dr. Nelson gave a great summary of the science today.  We've got a statutory requirement to provide, come up with an alternative to AFFF.  But there are some -- there are still some significant engineering and scientific and chemical challenges that are going to have to be solved between now and then.  And he shared those with you in a candid manner.  So that's what we're going to do.

Next January, I hope to have representatives from all the services with me, and we'll go in the big room.  And it'll primarily be at that point, we'll have a short summary from each service.  And it will primarily be to take questions from all of you going forward.

I would just like to say inside Washington here, there's a significant amount of interagency work.  So, our senior leadership will be over at the White House next week to talk with the interagency on all issues, PFAS.  We're standing up technical teams also coordinated from the White House, and I'm in communication with my counterparts from the EPA's PFAS Council.

So, I would just say that the whole of government effort is, and momentum is starting to build around this issue on this -- around this issue.  And I think there'll be, you know, more announcements and more events in the coming weeks, months.

And with that, I would like to say thanks to the team here.  Although we had some technical challenges at the beginning, Peter will be doing push ups afterwards.  And we'll try to make sure those don't happen again.  But I appreciate everyone's support, and everyone on our team who helped prepare me for this.  So, thanks.

MODERATOR:  All right, sir.  Thanks again.  Just a couple quick notes for everyone.  Again, check your e-mail, I'll be sending out a request with some questions for feedback on today's session.  And also, I'd encourage you if there any questions you have based on today's information that you would like addressed by Mr. Kidd and the team, please send them to me as well and we will consolidate them for posting later on defense.gov.

Thank you again and it's been a while since I've done pushups, but I'm all for it, apologies, thank you for your patience with my technical challenges, and we look forward to hearing from you again soon.