U.S. GOVERNMENT PUBLISHING OFFICE

33–955 PDF WASHINGTON : 2019

S. Hrg. 115–461 

THE FEDERAL ROLE IN THE TOXIC PFAS 

CHEMICAL CRISIS 

HEARING 

BEFORE THE

SUBCOMMITTEE ON FEDERAL SPENDING 

OVERSIGHT AND EMERGENCY MANAGEMENT 

OF THE

COMMITTEE ON 

HOMELAND SECURITY AND 

GOVERNMENTAL AFFAIRS 

UNITED STATES SENATE 

ONE HUNDRED FIFTEENTH CONGRESS 

SECOND SESSION 

SEPTEMBER 26, 2018 

Available via http://www.govinfo.gov 

Printed for the use of the Committee on Homeland Security 

and Governmental Affairs 

( 
(II) 

COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS 

RON JOHNSON, Wisconsin, Chairman 

ROB PORTMAN, Ohio 

RAND PAUL, Kentucky 

JAMES LANKFORD, Oklahoma 

MICHAEL B. ENZI, Wyoming 

JOHN HOEVEN, North Dakota 

STEVE DAINES, Montana 

JON KYL, Arizona 

CLAIRE MCCASKILL, Missouri 

THOMAS R. CARPER, Delaware 

HEIDI HEITKAMP, North Dakota 

GARY C. PETERS, Michigan 

MAGGIE HASSAN, New Hampshire 

KAMALA D. HARRIS, California 

DOUG JONES, Alabama 

CHRISTOPHER R. HIXON, Staff Director 

MARGARET E. DAUM, Minority Staff Director 

LAURA W. KILBRIDE, Chief Clerk 

SUBCOMMITTEE ON FEDERAL SPENDING OVERSIGHT AND EMERGENCY 

MANAGEMENT 

RAND PAUL, Kentucky, Chairman 

JAMES LANKFORD, Oklahoma 

MICHAEL B. ENZI, Wyoming 

JOHN HOEVEN, Montana 

GARY C. PETERS, Michigan 

KAMALA D. HARRIS, California 

DOUG JONES, Alabama 

GREG MCNEILL, Staff Director 

ZACHARY SCHRAM, Minority Staff Director 

KATE KIELCESKI, Chief Clerk 
(III) 

C O N T E N T S 

Opening statement: Page 

Senator Paul ..................................................................................................... 1 

Senator Peters .................................................................................................. 1 

Senator Harris .................................................................................................. 3 

Senator Hassan ................................................................................................. 14 

Senator Shaheen ............................................................................................... 16 

Senator Jones .................................................................................................... 19 

Senator Carper ................................................................................................. 21 

Prepared statement: 

Senator Paul ..................................................................................................... 41 

Senator Peters .................................................................................................. 43 

WITNESSES 

WEDNESDAY, SEPTEMBER 26, 2018 

Peter C. Grevatt, Ph.D., Director, Office of Ground Water and Drinking 

Water, U.S. Environmental Protection Agency ................................................. 4 

Maureen Sullivan, Deputy Assistant Secretary of Defense for Environment, 

Office of the Assistant Secretary of Defense for Energy, Installations and 

Environment, U.S. Department of Defense ....................................................... 6 

Linda S. Birnbaum, Ph.D., D.A.B.T., A.T.S., Director, National Institute of 

Environmental Health Sciences and National Toxicology Program, National 

Institutes of Health, Department of Health and Human Services .................. 7 

Brian J. Lepore, Director, Defense Capabilities and Management, U.S. Government Accountability Office ............................................................................. 9 

Andrea Amico, Co-Founder, Testing for Pease ...................................................... 29 

Arnold Leriche, Community Co-Chair, Wurtsmith Restoration Advisory 

Board ..................................................................................................................... 31 

Timothy Putnam, Vice President, Tidewater Federal Firefighters Local F– 

25, International Association of Fire Fighters ................................................... 32 

ALPHABETICAL LIST OF WITNESSES

Amico, Andrea: 

Testimony .......................................................................................................... 29 

Prepared statement .......................................................................................... 82 

Birnbaum, Linda S., Ph.D., D.A.B.T., A.T.S.: 

Testimony .......................................................................................................... 7 

Prepared statement .......................................................................................... 56 

Grevatt, Peter C., Ph.D.: 

Testimony .......................................................................................................... 4 

Prepared statement .......................................................................................... 45 

Lepore, Brian J.: 

Testimony .......................................................................................................... 9 

Prepared statement .......................................................................................... 69 

Leriche, Arnold: 

Testimony .......................................................................................................... 31 

Prepared statement .......................................................................................... 89 

Putnam, Timothy: 

Testimony .......................................................................................................... 32 

Prepared statement .......................................................................................... 92 

Sullivan, Maureen: 

Testimony .......................................................................................................... 6 

Prepared statement .......................................................................................... 50 
Page

IV 

APPENDIX 

Statements for the Record: 

Scott Markam ................................................................................................... 103 

Michigan League of Conservation Voters ....................................................... 105 

Tess Nelkie ........................................................................................................ 130 

Jane Lauber ...................................................................................................... 131 

Martha Gotllieb ................................................................................................ 133 

Jeri-Lynne Richardson ..................................................................................... 135 

Marcy Harig ...................................................................................................... 136 

Crittenden Family ............................................................................................ 137 

Julie Spahn ....................................................................................................... 138 

Wurtsmith Firefighter ...................................................................................... 139 

Susan Turoski ................................................................................................... 140 

Ken Turczyn ...................................................................................................... 141 

Chris Rogers ...................................................................................................... 142 

Tammy Cooper .................................................................................................. 143 

Danny R. Burns ................................................................................................ 145 

Linda Cole ......................................................................................................... 146 

David Gregory ................................................................................................... 147 

Lisa Whisenant Storey ..................................................................................... 148 

James M. Bussey .............................................................................................. 149 

Jennifer Carney ................................................................................................ 150 

Environment America et al ............................................................................. 152 

Mayor of Dayton ............................................................................................... 155 

Tobyn McNaughton .......................................................................................... 157 

Merrimack Citizens for Clean Water .............................................................. 159 

Pamela Miller et al ........................................................................................... 161 

National Ground Water Association ............................................................... 165 

New Hampshire Department of Envronmental Services .............................. 167 

Oscoda-Wurtsmith Airport Authority ............................................................. 168 

Southern Environmental Law Center ............................................................. 171 

Sierra Club ........................................................................................................ 188 

Eric Tobin .......................................................................................................... 191 

Water Quality Association ............................................................................... 193 

Cathy Wusterbarth ........................................................................................... 195 

Sandy Wynn-Stelt ............................................................................................. 197 

Responses to post-hearing questions for the Record from: 

Mr. Grevatt ....................................................................................................... 199 

Ms. Sullivan ...................................................................................................... 207 

Ms. Birnbaum ................................................................................................... 213 

Mr. Lepore ......................................................................................................... 217 
(1) 

1The prepared statement of Senator Paul appears in the Appendix on page 41. 

2The prepared statement of Senator Peters appears in the Appendix on page 43. 

THE FEDERAL ROLE IN THE TOXIC PFAS 

CHEMICAL CRISIS 

WEDNESDAY, SEPTEMBER 26, 2018 

U.S. SENATE,

SUBCOMMITTEE ON FEDERAL SPENDING,

OVERSIGHT AND EMERGENCY MANAGEMENT, OF THE COMMITTEE ON HOMELAND SECURITY

AND GOVERNMENTAL AFFAIRS, Washington, DC. 

The Subcommittee met, pursuant to notice, at 2:33 p.m., in room 

SD–342, Dirksen Senate Office Building, Hon. Rand Paul, Chairman of the Subcommittee, presiding. 

Present: Senators Paul, Peters, Harris, Jones, and McCaskill (ex 

officio). 

Also present: Senators Shaheen, Carper, and Hassan. 

OPENING STATEMENT OF SENATOR PAUL 

Senator PAUL. I call this hearing on Federal Spending Oversight 

Subcommittee to order. Today we are here to discuss the issue of 

per- and polyfluoroalkyl substances (PFAS), which is a chemical 

grouping that includes approximately 3,000 individual chemical 

chains. Two chains in particular, perfluorooctanic acide (PFOA) 

and perfluorooctane sulfonate (PFOS), are of issue here today. 

This issue was brought to my attention by Ranking Member Peters as numerous Michigan communities have exposure to this 

chemical. Fortunately, my home State of Kentucky seems to have 

little exposure to these chemicals, and since it is such an issue of 

interest in the Ranking Member’s State, I will yield to him for his 

opening statement and submit mine for the record.1

OPENING STATEMENT OF SENATOR PETERS2

Senator PETERS. Thank you, Mr. Chairman. Thank you for working in such a bipartisan way to convene today’s hearing and for 

your support through the entire process. 

In Michigan, we have seen firsthand the devastation a community experiences when it cannot trust the water coming out of the 

tap. In Flint, thousands of families were exposed to dangerous levels of lead in their water, and many residents, unfortunately, still 

use filters and bottled water to ensure that their water is safe. 

Just over 100 miles north of Flint, residents of Oscoda, Michigan, 

have spent years voicing their concerns about another serious envi-
2 

1The information submitted by Senator Peters appears in the Appendix on page 103. 

ronmental and public health threat in their drinking water, this 

time from highly fluorinated chemicals known as PFAS. These 

chemicals are widely used in products like non-stick cookware, 

water-repellent clothing, stain-resistant upholstery, and many firefighting foams. They are extraordinarily persistent, meaning they 

do not break down naturally in the environment. They accumulate 

in the soil, in our water, in our food, and too often in our bodies. 

They are toxic and they are not well regulated. 

I am grateful to Mr. Leriche for being here today to talk about 

the impact of contamination on his community in Oscoda and the 

challenges residents face around the former Wurtsmith Air Force 

Base. 

Unfortunately, Oscoda is not alone. There are contaminated sites 

throughout Michigan and the entire Nation. Sandy Wynn-Stelt of 

Belmont, Michigan, who is here today and I met with earlier, was 

exposed to one of the highest concentrations of these chemicals that 

have been identified in the United States, and now has PFAS levels in her blood that are more than 750 times the national average. 

Tobyn McNaughton is also here. Her 2-year-old son, Jack, this 

beautiful young boy, has what may be the highest documented 

PFAS levels known for children at 484,000 parts per trillion. He is 

just 2 years old. Families in Parchment Township, Michigan, were 

also forced to switch to bottled water earlier this summer, and now 

they fear that their children have been poisoned since their birth. 

As a Senator from the State of Michigan, a State surrounded by 

the Great Lakes, the world’s largest source of fresh water, I am appalled by the number of water crises that we have faced. My constituents and people across the country are facing this crisis and 

are also fed up as well. 

Mr. Chairman, I request the permission to enter into the record 

a few statements from Michiganders who are urging swift action on 

these fluorinated chemicals, without objection.1

I asked for this hearing because I believe that everyone in this 

great country should have access to safe drinking water, and I 

want to do everything I can to ensure that the Federal Government 

is effectively managing this crisis. 

Soon the Senate will approve a Federal Aviation Administration 

(FAA) bill that includes my language to remove Federal mandates 

requiring the use of these chemicals in firefighting foams, and I 

have also worked with my colleagues to urge the Environmental 

Protection Agency (EPA) to swiftly establish national enforceable 

standards to enable longer-term cleanup. 

I look forward to hearing more from the EPA today. These are 

important bipartisan steps that we are taking today, but they are 

certainly just the beginning. I look forward to hearing more today 

about what Federal agencies are doing, what more they can do, and 

what Congress must do to identify contamination, prevent exposure, reduce harm to human health, and to expedite the cleanup 

and assistance to the affected communities. 

Mr. Chairman, before I introduce our panel, I know one of our 

colleagues, Senator Harris, would like to give an opening statement. Without objection, she could take that time, and then I will 
3 

introduce each of the panelists for their statements. Senator Harris. 

OPENING STATEMENT OF SENATOR HARRIS 

Senator HARRIS. Thank you, Senator Peters. I want to thank the 

Committee for having this hearing and for the witnesses’ being 

here today to testify about PFAS contamination. 

I hope we can all agree that everyone deserves the right to 

breathe clean air and drink clean water. The issue of contamination from PFAS chemicals is a critical public health issue, impacting the water supplies of millions of Americans and the consumer 

products of millions more. 

I know we have a number of people impacted by PFAS here and 

in the audience, and I want to thank you for being here and for 

your courage to speak up and to let us recognize you. 

PFAS chemicals can be found in the non-stick cookware that 

families use every day. They are in stain-resistant and water-repellent fabrics that consumers wear. Multiple water systems across 

California have tested positive for PFAS concentrations above recommended levels with our military bases experiencing especially 

high concentrations of PFAS from foams that have been used to 

put out aircraft fires. 

These chemicals can accumulate and stay in the human body for 

long periods of time with potentially devastating impact. Studies 

indicate that chemicals such as PFAS can increase cholesterol levels. They can lead to low infant birth weights, to thyroid hormone 

disruption, and to an increased risk of cancer. 

As we learn more about the toxic nature of these chemicals, it 

is critical that the government take steps to protect public health, 

improve data gathering and transparency, increase public awareness and education, and make decisions based in fact and hard 

science. 

I am very troubled by reports that administration officials sought 

to block publication of a report on this PFAS contamination crisis 

because they feared ‘‘a potential public relations nightmare.’’ Our 

government should not pretend that PFAS contamination is not 

happening, and we should do something about it. 

I am proud that California is leading the way in addressing 

PFAS contamination. Earlier this year, California began the process to consider carpets and rugs containing PFAS chemicals a priority product under the State’s Safer Consumer Products Program, 

and I hope California can be a model for other States. Hearings 

like this, in closing, are important, Mr. Chairman and Mr. Ranking 

Member, to elevate issues impacting public health, and I appreciate 

that all of the witnesses are here and everyone who traveled to 

Washington, D.C., to share your stories. 

Thank you. 

Senator PETERS. Thank you, Senator Harris. 

I am pleased to intorduce our first panel. This hearing will consist of two panels. In the first panel, we are joined by four experts 

in this area. 

First, Dr. Grevatt is the Director of the Office of Groundwater 

and Drinking Water at the Environmental Protection Agency. He 
4 

1The prepared statement of Mr. Grevatt appears in the Appendix on page 45. 

is responsible for safeguarding America’s drinking water and overseeing State drinking water programs. 

Ms. Sullivan is the Deputy Assistant Secretary of Defense for the 

Environment in the Office of the Assistant Secretary of Defense for 

Energy, Installations and Environment. She is responsible for policies and programs related to environmental laws, cleanup of contaminated sites, and emerging contaminants. Her professional career spans 38 years serving in the Office of the Secretary of Defense and the Defense Logistics Agency in Virginia, Michigan, 

Ohio, and Germany. 

Dr. Birnbaum is the Director of the National Institute of Environmental Health Sciences (NIEHS) at the National Institutes of 

Health (NIH) and the National Toxicology Program (NTP). She is 

a renowned expert and board-certified toxicologist. Dr. Birnbaum is 

responsible for researching environmental influences on human 

health. 

Mr. Lepore is the Director of Defense Capabilities and Management at the U.S. Government Accountability Office (GAO), where 

he directs audits on the Department of Defense (DOD) Infrastructure and Facility Programs, Construction, and Environmental Management. Mr. Lepore, I will say, is a frequent flyer with this Committee, and we often rely on his hard work and astute analysis. 

Good afternoon, and again thank you to all four of you for being 

here today to discuss this extremely important topic. Dr. Grevatt, 

we will begin with your testimony. 

TESTIMONY OF PETER C. GREVATT, PH.D.,1 DIRECTOR, OFFICE 

OF GROUND WATER AND DRINKING WATER, U.S. ENVIRONMENTAL PROTECTION AGENCY 

Mr. GREVATT. Thank you. Good afternoon, Chairman Paul, Ranking Member Peters, and Members of the Subcommittee. I am Peter 

Grevatt, Director of the U.S. Environmental Protection Agency’s 

Office of Groundwater and Drinking Water, and I also serve 

as the Chair of EPA’s cross-agency efforts to address per- and 

polyfluoroalkyl substances. Thank you for the opportunity to testify 

today. 

Protecting America’s drinking water is one of EPA’s top priorities. I am here today to share with you the actions the agency is 

taking to address PFAS. 

PFAS are a group of manmade chemicals that have been in use 

since the 1940s. PFAS are, or have been, found in a wide variety 

of consumer products and as an ingredient in firefighting foam. 

PFAS manufacturing and processing facilities, airports, and military installations are some of the contributors of PFAS releases 

into the air, soil, and water. 

Because of their widespread use, most people have been exposed 

to PFAS, and there is evidence that exposure to certain PFAS may 

lead to adverse health effects. 

The EPA has taken steps under its various statutory authorities 

to understand and address these chemicals. For example, under the 

Toxic Substances Control Act (TSCA), the agency has issued various significant new use rules for certain PFAS chemicals to guard 
5 

against their reintroduction or new use without prior EPA review. 

Under the Safe Drinking Water Act (SDWA), which my office oversees, EPA has also monitored for six PFAS to understand the nationwide occurrence of these chemicals in our drinking water systems. 

In 2016, EPA issued drinking water lifetime health advisories 

(LHAs) for two well-known PFAS—PFOA and PFOS—of 70 parts 

per trillion. EPA is also working to move research forward on 

PFAS to better understand their health impacts, options for treatment, and how information on better-known PFAS can be applied 

to inform our knowledge of other PFAS. 

To build on these actions, EPA hosted a PFAS National Leadership Summit in May of this year. The summit provided an opportunity for participants to share information on ongoing efforts, to 

identify specific near-term actions, and to address risk communication challenges with PFAS. 

At the event, EPA committed to work on four significant actions: 

First, to evaluate the need for a maximum contaminant level for 

PFOA and PFOS; 

Second, to begin the necessary steps to consider designating 

PFOA and PFOS as ‘‘hazardous substances;’ 

Third, to develop groundwater cleanup recommendations for 

PFOA and PFOS at contaminated sites; 

And, last, to develop draft toxicity values for two PFAS—GenX 

and perfluorobutane sulfonic acid (PFBS). 

EPA also continues to provide support to States, tribes, and communities who are addressing PFAS issues. As EPA takes these actions, the Agency is also committed to working with our Federal 

partners, including the Department of Defense and the Department 

of Health and Human Services (HHS). We look forward to continuing our interagency dialogue and collaboration. 

Additionally, EPA recognizes the need to hear from citizens. 

Since June, EPA has traveled to five States across the country to 

hear directly from communities. EPA is also planning to travel to 

Michigan next week to hear directly from constituents in the State. 

These experiences are invaluable, and community feedback will 

help shape how we move forward. 

EPA will consider information from the National Leadership 

Summit, community engagements, and the public docket to develop 

a PFAS Management Plan. 

Protecting public health is EPA’s top priority. Acting Administrator Andrew Wheeler has expressed his continued commitment to 

considering actions on PFAS so that EPA can lead efforts that meet 

the needs of impacted communities. 

Once again, Chairman Paul, Ranking Member Peters, and Members of the Subcommittee, thank you for the opportunity to discuss 

PFAS, and I look forward to answering any questions that you may 

have. 

Senator PETERS. Thank you, Dr. Grevatt. Ms. Sullivan. 
6 

1The prepared statement of Ms. Sullivan appears in the Appendix on page 50. 

TESTIMONY OF MAUREEN SULLIVAN,1 DEPUTY ASSISTANT 

SECRETARY OF DEFENSE FOR ENVIRONMENT, OFFICE OF 

THE ASSISTANT SECRETARY OF DEFENSE FOR ENERGY, INSTALLATIONS AND ENVIRONMENT, U.S. DEPARTMENT OF 

DEFENSE 

Ms. SULLIVAN. Chairman Paul, Ranking Member Peters, and distinguished Members of the Subcommittee, I am Maureen Sullivan, 

the Deputy Assistant Secretary of Defense for Environment. My 

portfolio includes oversight of DOD’s programs to comply with environmental laws such as the Safe Drinking Water Act and the Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA). I want to thank Congress for your strong support 

for the Department of Defense, our national security priorities, and 

for the funding we need to protect our Nation. Ensuring the health 

and safety of our servicemembers, the families living on our installations, and the surrounding communities is one of our top priorities. 

I also want to thank this Committee for the opportunity to discuss the establishment of a national approach to per-and 

polyfluoroalkylide substances. We believe DOD has been leading 

the way to address these substances. 

One commercial product that contains PFAS is Aqueous Film 

Forming Foam (AFFF). This highly effective firefighting foam has 

been used by DOD, commercial airports, local fire departments, 

and the oil and gas industry. However, it only accounts for approximately 3 to 6 percent of the PFAS production in the calendar year 

2000, and DOD is just one of many users. 

DOD has committed substantial resources in the last 2 years and 

has taken action to respond to concerns from PFOS PFOA. When 

EPA issued the lifetime health advisories, for PFOS and PFOA in 

May 2016, the Department acted quickly to voluntarily test our 525 

drinking water systems that serve approximately 2 million people 

on our installations worldwide. Twenty-four of these systems tested 

above EPA’s lifetime health advisory level. Although it is only an 

advisory, DOD has followed EPA’s recommendations to include providing bottled water or additional water treatment. 

CERCLA provides a consistent approach across the Nation for 

cleanup. The Department of Defense Environmental Restoration 

Program statute provides authorities to DOD to perform and fund 

actions, and requires they be carried out in accordance with 

CERCLA. The first step is to identify the source of known or suspected releases. DOD has identified 401 active and Base Realignment and Closure installations with at least one area where there 

is a known or suspected release of PFOS or PFOA. 

The Military Departments then determined whether there is exposure through drinking water and, if so, the priority is to cutoff 

human exposure where drinking water exceeds EPA’s lifetime 

health advisory. Once the exposure path is broken, the Military Departments are prioritizing the sites for further action using the 

longstanding CERCLA risk-based process, ‘‘worst first.’’ These 

known or suspected PFOS and PFOA release areas are in various 

stages of assessment, investigation, and cleanup. 
7 

1The prepared statement of Ms. Birnbaum appears in the Appendix on page 56. 

To prevent further releases into the groundwater, DOD issued a 

policy in January 2016 requiring the Military Departments to prevent uncontrolled, land-based AFFF releases during maintenance, 

testing, and training activities. The policy also requires the Military Departments to remove and properly dispose of the supplies 

of AFFF containing PFOS—other than for shipboard use. 

Currently no fluorine-free version of AFFF meets the military’s 

very stringent performance requirements to extinguish petroleum 

fires. However, between fiscal year (FY) 2017 and fiscal year 2019, 

we solicited research projects to identify and test the performance 

of fluorine-free AFFF. These efforts support DOD’s commitment to 

finding an AFFF alternative that meets critical mission requirements while protecting human health and the environment and 

will represent $10 million in research and development (R&D) 

funding. 

In summary, DOD is taking actions to reduce the risks. We are 

committed to mitigating PFOS and PFOA releases to the environment that are a direct result of DOD activities. DOD is making significant investments in research and development for fluorine-free 

AFFF, and these combined efforts reinforce DOD’s commitment to 

meet critical mission requirements while protecting human health 

and the environment. 

We look forward to working with you as you move forward. 

Thank you. 

Senator PETERS. Thank you, Ms. Sullivan. Dr. Birnbaum. 

TESTIMONY OF LINDA S. BIRNBAUM, PH.D., D.A.B.T., A.T.S.,1 DIRECTOR, NATIONAL INSTITUTE OF ENVIRONMENTAL 

HEALTH SCIENCES AND NATIONAL TOXICOLOGY PROGRAM, 

NATIONAL INSTITUTES OF HEALTH, DEPARTMENT OF 

HEALTH AND HUMAN SERVICES 

Ms. BIRNBAUM. Good afternoon, Mr. Chairman, Ranking Member 

Peters, and distinguished Members of the Subcommittee. I am 

Linda Birnbaum, Director of NIH’s National Institute of Environmental Health Sciences. I am also Director of the National Toxicology Program, which develops and coordinates toxicological testing across HHS. 

For more than 39 years, I have personally conducted research in 

toxicology, and I am here today to provide a scientific perspective 

about the large, complex, and ever-expanding class of chemicals 

known as per-and polyfluoroalkyl substances. 

PFAS are some 4,700 manmade chemicals that contain fluorine 

atoms bonded to a carbon chain. The carbon-fluorine bond is one 

of the strongest ever created by man, and it is rarely seen in nature. The chemical composition of PFAS imparts high stability for 

consumer product design but also makes PFAS extremely problematic in the environment because they do not easily degrade. In fact, 

PFAS remain in the environment for so long that scientists are unable to estimate an environmental half-life. 

The use of PFAS is growing, and they are being incorporated into 

more processes and products than ever before. PFAS chemicals are 

making their way into our environment and can undergo long- 
8 

range atmospheric and oceanic transport. PFAS are now ubiquitous 

and have been identified in even the most remote environments. 

NIEHS has sponsored basic research investigating health effects 

associated with human exposure to PFAS for three decades. Our 

understanding of the health effects associated with PFAS and our 

ability to draw conclusions is based on combined data from many 

studies, including epidemiological associations in human cohort 

studies, biological plausibility and pathways studies in animals, 

mechanistic effects seen in human tissue and cell culture systems, 

and rapid high-throughput screening. By combining and carefully 

considering data from all these studies, we can build an understanding of how PFAS chemicals impact human health. 

Research conducted to date reveals statistically significant associations between human PFAS exposures and specific adverse 

human health outcomes. These include potential effects on children’s cognitive and neurobehavioral development, immune system 

dysfunction, endocrine disruption, obesity, diabetes, lipid metabolism, and cancer. While further studies are necessary, mechanistic 

studies in animals support our understanding of the biological 

underpinnings for these associations. NIEHS continues to conduct 

research to understand the biological processes affected by PFAS 

and how this may be harming human health. 

I would like to emphasize four key points. 

First, PFAS are extremely stable and, therefore, persist for a 

very long time in the environment. 

Second, human exposures to PFAS are extremely widespread, 

and humans are exposed to PFAS through many pathways, practices, and products. While ingestion, particularly through drinking 

water, is the predominant human exposure pathway, recent studies 

suggest other routes of exposure, including inhalation and dermal. 

Third, while we have studies that indicate potential adverse 

health effects due to a few PFAS, our findings are limited, and we 

do not have data for thousands of PFAS that have not been well 

studied. Based on what we know so far, we can extrapolate conclusions about structurally similar compounds which we can reasonably expect to act through the same pathways and have similar effects. With so many PFAS compounds, we cannot test our way out 

of this. 

Finally, I want to point out that we are learning about new and 

different PFAS exposures in many communities, even as we learn 

more about the potential hazards to human health. Inevitably 

questions arise about whether PFAS should be used so widely or 

if safer alternatives exist that still provide sufficient product performance. As part of our research portfolio, NIEHS contributes substantively to the fields of alternatives assessment to ensure harmful chemicals are not replaced by equally harmful but less well 

studied compounds. 

To conclude, Mr. Chairman, NIEHS is well positioned to provide 

new and essential scientific knowledge about PFAS consistent with 

our missions under both the Public Health Service Act and 

CERCLA. We are coordinating our efforts with other agencies to 

prevent duplication, and we are sharing our results. 

Thank you for inviting me to participate in this hearing today, 

and I look forward to answering your questions. Thank you. 
9 

1The prepared statement of Mr. Lepore appears in the Appendix on page 69. 

Senator PETERS. Thank you, Dr. Birnbaum. Mr. Lepore. 

TESTIMONY OF BRIAN J. LEPORE,1 DIRECTOR, DEFENSE CAPABILITIES AND MANAGEMENT, U.S. GOVERNMENT ACCOUNTABILITY OFFICE 

Mr. LEPORE. Thank you, Senator. Mr. Chairman, Ranking Member Peters, and Members of the Subcommittee, I am delighted to 

be here today to discuss the Department of Defense’s efforts to 

manage contaminants in its drinking water systems. I am here on 

behalf of myself and my colleague Alfredo Gomez, a Director in our 

Natural Resources and Environment team. Our two teams collaborated on our statement today and the underlying report on which 

our statement is based. 

You asked us to discuss the Federal role in addressing PFAS contamination nationwide. I will make two points. I will discuss the 

actions DOD has taken to address elevated levels of PFAS and 

PFOA in drinking water, and I will describe steps DOD is taking 

to address health and environmental concerns with its firefighting 

foams containing PFAS. But, first, I think it is important to emphasize EPA has not yet issued drinking water regulations for 

PFAS. 

EPA has reported working with States and communities to monitor water systems for six types of PFAS chemicals. This may help 

them to understand the occurrence of these chemicals across the 

country. Such monitoring is part of a larger framework established 

under the Safe Drinking Water Act. Under the framework, EPA is 

to identify unregulated contaminants presenting the greater public 

health concern, establish a program to monitor drinking water for 

them, and decide whether or not to regulate at least five contaminants every 5 years. 

EPA included six PFAS, including PFOS and PFOA, in its unregulated contaminant monitoring rule process, and EPA can issue 

a drinking water regulation if warranted. 

Now, even when EPA does not issue a regulation, it may publish 

drinking water health advisories. These advisories are not enforceable, but they do recommend the amount of contaminants that can 

be present in drinking water at levels that are not expected to 

cause adverse health effects. 

While EPA has not regulated PFAS, in May 2016 EPA issued 

lifetime health advisories for PFAS and PFOA at individual or 

combined concentrations of 70 parts per trillion in drinking water. 

DOD considers these health advisories in deciding on cleanup at its 

installations with PFAS or PFOA contamination, which brings me 

to my first point. 

DOD’s actions to address elevated levels of PFAS and PFOA in 

drinking water. Since issuance of the lifetime health advisory, each 

of the Military Departments have directed their installations to: 

first, identify locations with PFAS or PFOA releases and address 

any consequent risks to human health; second, test for PFAS or 

PFOA and address any contamination above the EPA health advisory level. As you heard earlier, DOD has identified 401 active or 

closed bases with known or suspected PFAS or PFOA released. 
10 

In January 2017, we recommended to DOD that they include the 

cost of PFAS and PFOA cleanup in annual reports to Congress. 

DOD implemented our recommendation in its June 2018 report. 

The estimate at that time was about $200 million. 

DOD has also addressed PFAS and PFOA contamination off the 

installations. DOD has shut down drinking water wells, provided 

alternative sources of drinking water, and installed water treatment systems. DOD has also indicated it may still take several 

years to determine the full cleanup costs for PFOS and PFOA contamination. 

Now I will turn to my second point: steps DOD is taking to address environmental concerns with its firefighting foam. These 

steps include: restricting the use of existing foams containing 

PFAS; testing current foams to determine the amount of PFAS 

they contain; and funding research into PFAS-free replacement 

foams that meet DOD’s performance and compatibility standards. 

DOD’s military specification for firefighting foam requires such 

foam to contain PFAS. At the time of our report, no PFAS-free 

foam was available that met the military specification. Now, the 

Navy authors the military specification, and Navy officials told us 

if a PFAS-free foam that meets the specification becomes available, 

they would change the requirements. However, as of June 2018, 

DOD still reported no commercially PFAS-free foam met the performance requirements of the military specification. DOD-funded 

research efforts are continuing, however. 

Mr. Chairman, Ranking Member Peters, and Members of the 

Subcommittee, I would be delighted to answer any questions that 

you may have. 

Senator PETERS. Thank you to each of you for your testimony 

and highlighting what is indeed a significant problem and a concern for all of us. 

I am going to start my questions with Dr. Birnbaum. Again, 

thank you for being here. A lot of what is known and discussed 

about PFAS chemicals focuses on two specific chemicals, which is 

PFOS and PFOA. But your testimony included the following point, 

and I would like to take a moment to underscore it because I think 

it is very important. 

You said, ‘‘Approaching PFAS as a class for assessing both exposure and biological impact is the best way to protect public health.’’ 

That is a significant statement. I think it has to be taken to heart, 

and I want you to paint a little picture here for us so we understand exactly what we are dealing with. 

Would you please explain just how bad PFAS is relative to other 

more commonly understood contaminants? Basically, if you were to 

compare PFAS to some other contaminant that was eventually regulated as a toxic substance, what would you suggest as a comparison? 

Ms. BIRNBAUM. Senator Peters, thank you for the question. Some 

of the problems with PFOS and PFOA and many other members 

of the class is the fact that they never go away. They will persist 

in the environment certainly as long as any of us are here, and 

many of them, like those two as examples, also persist in our bodies with half-lives on the order of years—in fact, many years. These 

chemicals build up not only in the environment but in our bodies. 
11 

For the compounds that do not last as long in our bodies, they 

still last in the environment so that they will build up, so that ongoing exposure can be a problem as well. 

I think if we look at other persistent bio-accumulative chemicals, 

if we compare it to some things like DDT or DDE, which, although 

it was banned 40-some years ago, is still in every one of us, or polychlorinated biphenyls (PCBs) that were banned by Congress in the 

late 1970s, and we still all carry them in our bodies. I think that 

is a concern for this class of compounds, that they will be with us 

long after they stop being made. 

Senator PETERS. That is disturbing, and, in fact, I have heard 

from one researcher who said basically if you are a geologist at 

some point in the future, however many millions of years, and you 

look at the strata in the rock, you will actually find PFAS chemicals. That is how long-lasting they are. That should be a wake-up 

call to everyone of what we are dealing with. 

I recently spoke with a scientist who also compared the presence 

and use of PFAS in our everyone to the situation we once created 

with lead, as an example. Lead was once used everywhere. It was 

in gasoline, our cars, our pipes and our plumbing, and the paint 

that we used on our walls. As a result of that widespread use, lead 

has created some very serious and some very tragic consequences. 

While we have made progress to reduce lead, we are still struggling 

to replace outdated infrastructure with those lead pipes. 

PFAS chemicals strike me as very similar. They seem to be used 

everywhere. What is known about how people are exposed to 

PFAS? How are the contaminants taken into the body? What sort 

of impact would we expect? 

Ms. BIRNBAUM. PFAS chemicals, we can be exposed to them in 

many ways since they are present in many consumer products, including the clothes that we wear, the carpets that we walk on, the 

paper products that are used for food, as well as, for example, 

being released into drinking water. We can ingest them from all 

those routes. 

Also, especially at production facilities or use facilities, we can 

inhale them. When things are inhaled into our body, they often 

have very different effects than when we ingest them. Some of the 

PFAS can be absorbed through our skin, so young children crawling around on the carpet may have more exposure, for example, 

than adults. 

Senator PETERS. Nationally, communities seem to be focused on 

finding PFAS chemicals, but primarily looking at only a handful of 

those PFAS chemicals. What should we be doing differently going 

forward to better capture the potential risk that you are outlining 

here? 

Ms. BIRNBAUM. Thank you for that question. It is a very difficult 

question because we really do not know very much about the thousands of chemicals that have been produced. There are CAS numbers, which are chemical abstract numbers, for 4,700 of them, but 

there are additional PFAS which are being produced in the environment by breakdown of some of the very long chain, the polymeric forms of PFAS. 

Let us see. I think I am forgetting the question. 
12 

Senator PETERS. What should we be doing differently to deal 

with all these others? 

Ms. BIRNBAUM. Yes, so I think the thing is I had suggested at 

the EPA summit several months ago the possibility of monitoring 

for total organic fluoride. There are essentially no sources of naturally occurring organic fluorides, and we can search for that. There 

are technological ways that we can do that, and we can at least use 

that for a screening approach. Just measure all the organic 

fluorides and determine where we might have a problem and where 

we do not find many. I would say that that is one way for us to 

get a handle on it. 

Senator PETERS. Ms. Sullivan, thank you as well for being here 

and the work that you have been doing on this issue. You and I 

have spoken about Wurtsmith and other sites in Michigan, and I 

know you hear very similar and very sobering concerns about hundreds of other sites across the Nation. Yet residents of Oscoda are 

frustrated, to say the least, and I believe justifiably so, with the 

slow pace of both the State and Federal action in that area. The 

EPA withdrew oversight of Wurtsmith in 2016, leaving the Air 

Force and the State to handle that cleanup. I realize that you are 

not in a position to discuss specifics, as it is currently the subject 

of a dispute resolution process right now with the State. 

But let me ask you this: From a national perspective, would the 

EPA groundwater cleanup recommendation for PFOA and PFAS at 

a contaminated site be helpful for you at the Department of Defense? 

Ms. SULLIVAN. Thank you for the question, sir. We have been requesting that guidance for a number of years. Although we can, in 

fact, use the reference dose behind the lifetime health advisory 

under the CERCLA process to calculate an unacceptable risk, it is 

a site-by-site determination, and it is not a national approach, a 

consistent approach to how to deal with these sites. It creates confusion on the part. 

We are moving forward. As I stated, we have identified where we 

are directly impacting drinking water, and we have short-circuited 

the CERCLA process to cutoff those exposures where the drinking 

water exceeds EPA’s lifetime health advisory. But consistent guidance from EPA would be extremely helpful to not only us but all 

of the entities that have sources of PFAS and PFOA. 

Thank you. 

Senator PETERS. Thank you, Ms. Sullivan. I am out of time. I am 

going to have more questions for the panel but Chairman Paul has 

some questions. 

Senator PAUL. I was just thinking about when Dr. Birnbaum 

said there are no natural sources of organic fluoride compounds. 

When you use the term ‘‘organic fluoride,’’ do you mean fluoride 

hooked up to carbon? Is that why you call it ‘‘organic?’’ 

Ms. BIRNBAUM. Yes, that there are—I should have said ‘‘almost 

no’’—— 

Senator PAUL. OK, because we add fluoride to our water. We add 

fluoride salts, right? 

Ms. BIRNBAUM. We do add fluoride salts to some drinking water. 

Senator PAUL. Fluoride salts do not—is there a possibility they 

can chemically react with alkyl substances that are in the water 
13 

separately and you could be fluorinating things and actually creating PFAS? 

Ms. BIRNBAUM. There is no evidence for that occurring. 

Senator PAUL. But, chemically, does that happen? How hard is 

it to polyfluorinate an alkyl substance? Does it take electricity? 

Does it take some—to get the reaction to work? Or is it something 

that if you mix fluoride with carbon, you can get carbon hooked up 

to fluoride? 

Ms. BIRNBAUM. I do not think it is an easy reaction to cause, but 

I will be glad to provide more information on that. 

Senator PAUL. I am not saying there is a problem with fluoride 

in the water. What I am just saying is that we do put it in there, 

and somebody should have an answer for that. Does anybody else 

have an answer to the question? 

Mr. GREVATT. Not beyond what Dr. Birnbaum stated. We would 

be happy to circle back with you, but I know it is a fairly complicated process to manufacture—— 

Senator PAUL. It is probably scientifically not really possible. If 

somebody would just look it up and get back to us in a written 

form, I think to reassure people about fluoride in the water, that 

fluoride does not react with alkyl substances, I think that would be 

helpful. 

The only other question I had was, we are going to have some 

people, I think, who are going to present, who have very large levels of this in their system. Is there a theory as to why some people 

would get so much of it and then others would not, in that we are 

all sort of exposed to a lot of the same things as far as the drinking 

water and carpets, etc? 

Ms. BIRNBAUM. I think that there is some data that suggests that 

people living near use facilities may have higher levels because 

there is more release into the environment—— 

Senator PAUL. Living near what? 

Ms. BIRNBAUM. Living near a use facility. In other words, a place 

where the PFAS are being used to make products, or by a production facility. There is some data that suggests that very young children have higher levels, for example, than their parents, and much 

of that, again, is related to their behavior. 

Senator PAUL. Then the only other question I have is that when 

you are looking at regulating something like this or trying to prevent it from happening, there are certain things that probably 

would be easier to get into the water—a piece of plastic, a plastic 

bottle, or something—the PFAS from that getting into the drinking 

water is less likely than, say, foam sprayed on a runway and it 

rains and gets into the storm water drainage. Is there an estimate 

of where more of the problem is coming from? Is a lot of it this firefighting foam? Or, are we saying that the problem is more related 

to one entity that makes this as opposed to non-stick cookware? 

Mr. GREVATT. If I may, Dr. Birnbaum. Thank you for the question, it is a really important one, and this really is about the 

sources. As Dr. Birnbaum mentioned, we know that across the population in the United States, through the NHANES Survey, we 

know that there are levels in most of our bodies. But there are 

much higher levels where there are particular sources like near 

sites where firefighting foams have been used—that is not only 
14 

1The letters referenced by Senator Hassan appears in the Appendix on page 103. 

military bases; that can be airports and other fire training areas— 

near manufacturing facilities, and we have seen some instances 

where we actually have visited EPA communities impacted by 

manufacturing facilities. There are particular areas around known 

sources where the concentrations can be quite elevated beyond the 

rest of the population in the country. 

Senator PETERS. Thank you, Chairman Paul. Senator Hassan. 

OPENING STATEMENT OF SENATOR HASSAN 

Senator HASSAN. Thank you very much, Chairman Paul and 

Ranking Member Peters, for holding today’s really important hearing. To all of the witnesses, thank you as well for being here. 

Before I begin with questions, I would also like to thank a lot of 

the advocates from around the country who have really taken this 

on, particularly in my home State of New Hampshire. Thank you 

for taking the time to come meet with me and my colleagues to discuss how the PFAS crisis is affecting communities in New Hampshire and around the country. Mr. Chairman, I have had numerous 

people write in about their experiences with PFAS, and I believe 

these letters provide a resource for those who want to learn more. 

They tell personal stories, and I would like to submit them for the 

record.1

Senator PAUL. Without objection. 

Senator HASSAN. Thank you. 

Dr. Birnbaum, I want to build a little bit on the testimony you 

have already provided to us. We have heard a lot about PFAS exposure around Department of Defense bases, and I think you know, 

and Dr. Grevatt just actually mentioned, it is also important to discuss industrial contamination as well. 

In New Hampshire, a number of communities, including 

Merrimack, have been struggling for 2 years to address PFAStainted water wells around a use facility called ‘‘Saint-Gobain.’’ You 

spoke about the multiple exposure pathways that we should be 

paying attention to. Can you elaborate on how your agency is coordinating between and among the Federal agencies on developing 

toxicological profiles and human health risk assessments for PFAS 

chemicals? 

Ms. BIRNBAUM. Thank you for the question. NIEHS is part of 

NIH, and it conducts biomedical research. We are conducting and 

funding a great amount of research looking at what the potential 

health impacts would be from exposures to this very large class of 

chemicals. Our National Toxicology Program is actually conducting 

rapid studies to try to get a handle of a much larger number than 

just PFOA and PFOS, and we collaborate with our 

Federal partners—the EPA, the Department of Defense, the Centers for Disease Control and Prevention (CDC), the FDA, and others—so that they will have the information they need to make good 

policy choices. 

Senator HASSAN. Thank you. That is very helpful, and we may 

follow up with you a little bit more about where that coordination 

is happening and how we can help support it. 
15 

Dr. Grevatt, PFAS is a national issue, and the need to understand the significance of this chemical class within our impacted 

public drinking water systems is critical. However, much of New 

Hampshire and, frankly, the Northeast, for that matter, is serviced 

by private drinking water wells and systems. Can you please share 

with me what type of technologies exist to effectively, safely, and 

affordably conduct tests at private wells to ensure safe water quality? What is the EPA doing to make these testing technologies 

available to those who believe they have been affected? 

Mr. GREVATT. Yes. Thank you very much for the question, and 

we were very pleased to be able to visit with many of the folks who 

are here in Exeter when we traveled up there for our first community engagement meeting. 

As you stated, this has been an issue both in community water 

systems and in private wells. EPA has studied the Nation’s drinking water systems in terms of occurrence, but also has been supporting sampling of private wells in communities, particularly in 

terms of providing technical assistance on those issues. 

We are currently examining the utility of various treatment technologies, both for community water systems and also for point-ofuse devices for private wells to make sure that we can help to identify strategies to address those concerns that have risen in a number of communities. This has been a very important part of our 

work. 

Senator HASSAN. I thank you for the work. Are there technology 

improvements that are being worked on or lie ahead to improve the 

treatment of drinking water and reduce the cost to private well 

owners? 

Mr. GREVATT. Absolutely, without question, and EPA has an active research program, in collaboration with other Federal partners, to identify technologies for treating these compounds not only 

in drinking water but actually in other sources like a contaminated 

site. This is a very active area of research for us. 

Senator HASSAN. Thank you. 

To Ms. Sullivan, as you mentioned, the CERCLA, establishes liability for remediation and natural resource damages for releases 

of hazardous substances into the environment, but not other pollutants or contaminants. 

What is the position and moral obligation of the Department of 

Defense on responding to releases of PFAS from current and 

former U.S. military installations for which there is no current liability under CERCLA? 

Ms. SULLIVAN. I want to think through that question, ma’am. 

Senator HASSAN. Sure, yes. 

Ms. SULLIVAN. That is a complicated question, to be honest with 

you, because our obligations do stem from CERCLA and from the 

Defense environmental restoration account statute on what our responsibilities are. Once there is enough toxicological information 

about a compound, EPA has established a clear process, a longstanding clear process, of how you enter into the CERCLA process 

when you have enough information. The reference dose behind the 

lifetime health advisory is that trigger to say, yes, there is enough 

information about the toxicology to roll it into the CERCLA risk assessment process. 
16 

Senator HASSAN. I am going to push back a little bit here because we have a process established, and I think for people in New 

Hampshire whose wells have been impacted, whose water systems 

have been impacted, or parents whose children are crawling on carpeting on industrial uses, but when we are talking about DOD base 

exposures, people are very concerned about the harmful nature of 

these chemicals, and they want DOD to be stepping up now to help 

them get clean drinking water and to help reduce their exposure 

for firefighting foam. Waiting for the perfect situation where 

CERCLA would apply under its current parameters may not get 

people the help that they are looking for right now. 

Ms. SULLIVAN. Ma’am, I appreciate what you are talking about. 

That is why we said that our first priority is cutting off drinking 

water exposure—— 

Senator HASSAN. Right. 

Ms. SULLIVAN [continuing]. That is above the lifetime health advisory. We have done that as, in essence, a removal action under 

the CERCLA process. Doing it prior to going through the full 

CERCLA investigation risk assessment process, to work with the 

communities, and as you know, the Air Force has just signed an 

agreement to provide Portsmouth with over $14 million to build a 

treatment facility there. 

Senator HASSAN. Right, and I appreciate that. I think we are 

going to be looking for scaling that kind of response up. 

I see that I am over, but the other part of this question is: What 

is DOD doing with handling waste materials, for instance, that 

contain PFAS? We can follow up on that. 

Ms. SULLIVAN. I would be glad to. 

Senator HASSAN. Thank you. 

Senator PETERS. Thank you, Senator Hassan. Senator Shaheen. 

OPENING STATEMENT OF SENATOR SHAHEEN 

Senator SHAHEEN. Thank you very much, Chairman Paul and 

Ranking Member Peters. I very much appreciate your willingness 

to let me sit in with this Subcommittee as you are holding this 

hearing. Thank you to all of the witnesses. As you could tell from 

my colleague from New Hampshire Senator Hassan, and as many 

of you already know, this is a huge issue for us in New Hampshire. 

I would like to actually begin with you, Dr. Grevatt, because I 

think Senator Peters referenced the report which we learned that 

the Agency for Toxic Substances and Disease Registry (ATSDR), 

had delayed, that indicated the impact of the minimum risk levels 

for PFOA and PFOS should be 10 times lower than what the agency had previously determined. 

Dr. Grevatt, based on those findings, is the EPA considering updating the lifetime health advisories for those chemicals? 

Mr. GREVATT. Thank you very much for the question, and thank 

you also for your support of our work in New Hampshire. We are 

very close collaborators with ATSDR. We work with them on their 

toxicity profile, and they are actually working with us right now on 

toxicity assessments we are doing on additional compounds—PFBS 

and GenX—as is Dr. Birnbaum, the folks at NIEHS, and at the Department of Defense. 
17 

We are not planning currently to update our drinking water 

health advisories for PFOA and PFOS. We recognize, as does 

ATSDR, that the purposes of their toxicity profile differ from our 

health advisories. Theirs is really focused on a screening approach, 

and that is part of the reason why they have lower values than we 

have. We believe that our health advisories are supported by the 

strongest science, and we also appreciate why they took the direction they did in their toxicity profiles. 

Senator SHAHEEN. As you are working with them, do you have 

any kind of timetable whereby you expect to definitively determine 

whether the levels make sense going forward? Or are you telling 

me that, based on the science, you believe that you have set the 

correct levels for human health? 

Mr. GREVATT. Yes, based on the current science, we believe that 

the health advisory value that we have developed is supported, and 

we subjected that to independent external peer review, and we believe that the findings were supported. But in saying so, I am not 

trying in any way to discount the importance of ATSDR’s toxicity 

profile, but really to recognize that the purposes of their profile differ somewhat. It is really a screening tool. If levels are found above 

the values they have established, that is an indicator of the need 

for additional investigation as opposed to our drinking water health 

advisories are really trying to identify a level below which we believe it is safe and above which we believe that action should be 

taken. In fact, that is the way the drinking water health advisory 

has been used. 

Senator SHAHEEN. Are you going to be paying attention to the 

health study that they currently have underway? Will the outcome 

of that have any impact on whether you decide to change the levels 

that you are recommending? 

Mr. GREVATT. We will be paying very careful attention to that 

work, as we are paying very careful attention to the work that Dr. 

Birnbaum has underway at NIEHS and other research organizations as well. As the science continues to develop, we will look back 

at this issue and make sure that we continue to have a value that 

reflects the best science. That is our commitment. 

Senator SHAHEEN. I think there is a great deal of concern among 

people in New Hampshire who have been affected by these chemicals that we really do not know enough yet about the science to be 

able to make definitive determinations, and that is why the health 

study is so important. 

Dr. Birnbaum, in July, the Centers for Disease Control and Prevention issued a report that said New Hampshire had for the period of time between 2003 and 2014 the highest rates of pediatric 

cancer in the country. There is a cluster of pediatric cancer in the 

seacoast, close to where we have seen those elevated levels of PFAS 

chemicals from the closure of Pease Air Force Base. I wonder if you 

could describe the work that you are doing at NIEHS to connect 

PFAS exposure to cancer and how you are working with ATSDR 

as they are looking at this health study? 

Ms. BIRNBAUM. Thank you for your question, Senator Shaheen. 

We are working very closely with and providing consultation to 

ATSDR related to the funding that they have gotten through the 

Department of Defense to deal with eight sites at different places 
18 

1The statement referenced by Senator Shaheen appears in the Appendix on page 159. 

2The statement referenced by Senator Shaheen appears in the Appendix on page 167. 

in the country. The studies are initially going to be looking at exposures so that we really know what people are exposed to at those 

sites, and then the health effects parts will come later. We are 

looking at quite a number of years before we will have a lot of data 

from those studies. 

At the same point, we—— 

Senator SHAHEEN. I am sorry to interrupt, but can you be a little 

more specific when you say ‘‘quite a number of years.’’ Are you 

talking about 5 years, 10 years, or 20 years? 

Ms. BIRNBAUM. I would say we are looking at a 5-year window. 

That would be realistic. These are very difficult studies to conduct, 

especially when you are dealing with people living on or around 

military bases, there is a lot of movement, so it is sometimes hard 

to track people. 

Senator SHAHEEN. Sure. 

Ms. BIRNBAUM. Many of our grantees are actually looking at the 

relationship between this class of chemicals and different kinds of 

cancer. So far there are associations that have been reported by our 

grantees and others that have shown associations with a wide variety of cancers. We are not talking about just one type. But we have 

not seen an increase in pediatric cancers in the studies that have 

been conducted to date. That may in part be because the question 

has not yet been asked, so I think that there is an opportunity to 

investigate this elevated rate that appears to be especially in a specific region of New Hampshire. We would welcome grants in that 

area. 

Senator SHAHEEN. I am not quite clear when you say ‘‘because 

the question has not been asked.’’ What exactly do you mean by 

that? 

Ms. BIRNBAUM. When people design, say, whether it is an animal 

study or a human study, people usually have a hypothesis that 

they are testing. Most of the animal studies which provide the biological plausibility to say what we might see in an epidemiology 

study makes sense have focused on adult animals, not developing 

animals. 

Senator SHAHEEN. As you all know, there were two child-care 

centers that were located on Pease where children drank that 

water almost from birth. I hope that that question will be asked 

as part of the study. 

Thank you all very much. Mr. Chairman, I am out of time, but 

I have a statement here from the Merrimack Citizens for Clean 

Water1 as well as the Commissioner of our Department of Environmental Services in New Hampshire that I would like to ask be introduced for the record.2

Senator PAUL. Without objection. 

Senator PETERS. Without objection. 

Senator SHAHEEN. Thank you. 

Senator PETERS. Thank you, Senator Shaheen. Senator Jones. 
19 

OPENING STATEMENT OF SENATOR JONES 

Senator JONES. Thank you, Senator Peters, and I appreciate the 

opportunity. Thank you all for coming here today. 

Like New Hampshire, I have a different issue in Alabama. We 

have a number of water supplies in Alabama that a bunch of constituents are affected by what appears to be private manufacturers, 

and the water supplies have been contaminated. It is obviously a 

very real concern to those constituents. I know there is some litigation. But I was wondering, Doctor, you stated that you have begun 

the necessary steps to consider designating PFOA and PFOS as 

hazardous substances. Could you walk me through that process 

and give me some kind of estimate—and I know as you sit here 

today, it will not be firm. It is always a moving target. But walk 

me through that process and give me some idea of the timeline for 

a potential designation. 

Mr. GREVATT. Right, certainly. Thank you, Senator. This is a 

very important question and a very important action we are exploring carefully at EPA. The reason why this is so important is that 

designation as a hazardous substance will provide EPA with the 

authority and States that are implementing CERCLA with the authority to both order cleanup actions at contaminated sites and also 

recover costs that are expended by the agency for those actions. 

There are five statutory mechanisms through which these substances could be listed as hazardous substances, and that includes 

a number of statutes in addition to CERCLA. We are looking carefully at the various avenues by which this could be accomplished, 

and we are going to include this as an important component in the 

agency’s management plan that we hope to have completed by the 

end of the calendar year. 

As you point out, such an action is a public notice and rulemaking action, so there would be a proposed rule, regardless of the 

statutory mechanism, a proposed rule, public comment, and then 

consideration, careful consideration and comment to get to a final 

rule. We are talking about years before we could have that completed in all likelihood, just recognizing that if the process started, 

even at the end of the year, we would have to go through the proposal and then the final rule to get there. 

Senator JONES. Right. Given the other testimony we have heard 

about how stable these substances are, I would encourage EPA to 

get that moving as quickly as possible. I have had some experience 

as a Special Master when Anniston—for the PCB cleanup there, I 

did that for a number of years. 

I have another question that is related to that, and I know that 

there will be at some point a public comment, but I am curious as 

to if you are already hearing anything from any of these manufacturers, any kind of pushback or—have any of these manufacturers 

started contacting the EPA with any information or anything like 

that before this comment period starts? 

Mr. GREVATT. Related to the question of listing as a hazardous 

substance, I do not know that we have had discussion with manufacturers on that particular issue, although I will note that we did 

have the manufacturing community present at the National Leadership Summit this past May, and this was a topic of discussion 

there. But, without question, primarily through our TSCA program, 
20 

we have ongoing engagement with the manufacturing community 

on a wide variety of issues, but probably the most prominent ones 

that we have implemented through EPA using TSCA are both the 

voluntary phase-out of PFOA and PFOS, but also the significant 

new use rules that I mentioned that have kind of locked that 

phase-out in place and requires manufacturers to notify EPA 

through TSCA Section 5 before they can take steps to begin to reintroduce those compounds into commerce. There has been quite a 

bit of work with the manufacturing community on those particular 

issues. 

Senator JONES. All right. I hate to belabor the point because it 

is a pretty complicated process that you guys go through. Has there 

been any specific pushback to say do not designate this as a hazardous substance? 

Mr. GREVATT. Not that I am aware of, sir. 

Senator JONES. All right. That is great. Thank you. 

This would be to anyone, but, again, particularly to EPA. Are 

there any steps being taken right now to just kind of raise awareness of the issues so that people are looking at this? What can we 

do particularly for small water systems? That is where my big concern is in a State like Alabama. 

Mr. GREVATT. Yes, thank you for the question. There is a great 

deal underway to raise awareness of this issue and also to engage 

the public and the States and local communities on these challenges, both through the National Leadership Summit and then 

through the community engagement meetings we have had now in 

five States around the country. I cannot emphasize how important 

it has been to meet with local citizens to hear the challenges that 

they are experiencing as we think about the development of the 

National Management Plan, which is going to be a comprehensive 

view of steps that we can take across our statutory authorities in 

collaboration and support of States and local communities to address these issues. 

We are hoping to have that completed by the end of the calendar 

year, and we will continue both through our website presence but 

also reaching out to communities—and I mentioned to Senator Peters we will be in Michigan next week for another engagement with 

constituents there. We are going to continue to talk to communities 

across the country on these issues. Small systems are, without 

question, a challenge, and technical assistance is a priority for us 

to small systems, and I think you know that we fund a number of 

technical assistance activities for small systems. 

Senator JONES. Great. Thank you very much. Let me just say in 

the remaining time I would invite you to north Alabama. There are 

people anxious to talk to you as soon as possible, so I would invite 

you, and my office will be happy to help arrange and facilitate that 

as part of Region IV down in the Atlanta—— 

Mr. GREVATT. We appreciate the invitation. Thank you. 

Senator JONES. All right. Mr. Chairman, I am going to yield the 

remaining part of my time. Thank you. 

Senator PETERS. Thank you, Senator Jones. Senator Carper. 
21 

OPENING STATEMENT OF SENATOR CARPER 

Senator CARPER. I want to thank my friend from Alabama for 

yielding 47 seconds to his colleague. 

Senator JONES. It is the least that I could do. [Laughter.] 

Senator CARPER. Welcome. It is good to see you all again, some 

of you for the first time, others not the first time. This past February, the little town of Blades, Delaware, which is in the southwestern corner of our State, just under 1,500 people, found that the 

drinking water had been contaminated with PFOA, one of 

the PFAS classes of chemicals. Delaware State officials, along 

with—it was really an ‘‘all hands on deck’’ situation. You had the 

fire company, you had the Delaware National Guard, you had the 

Delaware Division of Health, the Department of Natural Resources, 

and our congressional delegation, all descended on this little town 

to try to make sure that they got the help that they needed. They 

got it in the form of bottled water provided to town residents. They 

got it in the form of a filtration system which was added to the 

public water supply system. 

The likely source that was subsequently identified was plating 

companies in the area that used PFOA to coat cookware, and the 

reality of this situation in communities around the country is that 

the discovery of these chemicals is now a fairly frequent occurrence, as we know. By the time the contamination is discovered, 

though, citizens may have been exposed not for just weeks or 

months but actually for years. 

We have a big Air Force base, a big airlift base in Dover. I believe that the Federal agencies such as DOD, which used these 

chemicals in ways that resulted in releases into the environment 

need to take the necessary steps to clean up this contamination 

wherever it is threatening harm. 

I also believe that the companies that made these chemicals need 

to share some of the responsibility for finding solutions to the contamination that their chemicals created. 

A company called ‘‘Chemours,’’ which is an offshoot, if you will, 

of DuPont, a big chemical company—the chemical part of DuPont 

is called ‘‘Chemours.’’ But Chemours, for example, has taken responsibility for past contamination. They have announced future 

plans to reduce air and water process emissions of these chemicals, 

not just by a little bit but by 99 percent or greater, and we commend them for that. 

However, just last week, representatives of a new industry-funded group provided my office with documents that appear to be 

aimed at calling into question the science that shows these chemicals to be dangerous. Specifically, the document states, and I quote, 

‘‘The weight of the scientific evidence does not show that PFOA or 

PFOS cause health effects in humans.’’ 

Let me just repeat that. It says, ‘‘The weight of the scientific evidence does not show that PFOA or PFOS cause health effects in 

humans.’’ 

I would just like to ask all of you—I do not ask a lot of yes or 

no questions, but this is going to be one. Do any of you agree with 

this industry statement that says that neither PFOA nor PFOS 

cause health effects in human? Does anybody agree? If you agree 

with that, raise your hand. 
22 

[No hands raised.] 

Senator CARPER. OK. If you do not agree with that, raise your 

hand? 

[Hands raised.] 

Thank you. All right. It looks like nobody raised their hand the 

first time through, and about two of you on the second, and a couple people reached a little bit, but not a full extension. Let the 

record show that. [Laughter.] 

A question to Dr. Grevatt. Is there enough data for EPA to decide to regulate these chemicals? The industry document that my 

office obtained and that I just mentioned also states that, ‘‘Policies 

and actions must be guided by the best available science rather 

than fear-driven discussions.’’ 

Now, I actually agree with that statement, but unlike the industry group that wrote this document, I do believe that enough study 

has been done to take action, and I would just ask of you, Dr. 

Grevatt, in your opinion, is there enough available science about 

PFOA or PFOS for EPA to decide whether to regulate them? 

Mr. GREVATT. Yes, sir, I believe there is enough information for 

us to make that decision, and I think you are familiar with the criteria under the Safe Drinking Water Act to support that decision. 

Those are issues that the Administrator is looking very carefully at 

right now. 

Senator CARPER. All right. Thank you. 

I am going to ask other questions of the other folks. I am not 

picking on you, but I do have at least one more. I was going to ask: 

What steps is EPA considering and when? There are several ways 

EPA could regulate these chemicals. First, I believe that EPA could 

announce it is setting a drinking water safety standard for these 

chemicals. My question would be: When do you expect EPA might 

announce whether it plans to regulate these chemicals in drinking 

water? How long do you believe it would take EPA to finalize a 

drinking water standard? 

Mr. GREVATT. Thank you. Similar to the question on hazardous 

substance listing, we plan to address this issue in the National 

Management Plan, which we hope to have completed by the end of 

the calendar year. This would also be a public notice and rulemaking action, so we would have to do a proposed rule with public 

comment and a final rule before we could move forward, and that 

would take over a year, certainly, to do that. I would think we 

would be talking about some number of years to complete that action. 

Senator CARPER. All right. Just to follow up, and you may have 

just answered this, but EPA could also list these chemicals as hazardous substances under the Superfund law, which would facilitate 

the cleanup of these chemicals, as you know. Let me just ask this 

question: When will EPA—and if you have already answered this, 

I apologize, but when will EPA announce whether it plans to designate these chemicals as hazardous substances? How long would 

such a designation take to finalize? 

Mr. GREVATT. Thank you. A very similar answer to the last, that 

we will be addressing this issue in our National Management Plan, 

which we hope to have completed by the end of the calendar year. 
23 

It would have to go through a proposal and then a final rule, so 

that will take some number of years to complete. 

Senator CARPER. All right. 

Mr. GREVATT. Those are the two most significant regulatory actions that we are talking about right now, the hazardous substance 

listing and the development of an MCL. There are other things certainly much broader that we are looking at at EPA comprehensively, but those are the two biggest regulatory actions that we are 

currently contemplating. 

Senator CARPER. All right, good. You are just doing so well, I am 

going to just ask you one more. In 2015, EPA proposed regulation 

of some of the uses of some of these chemicals through what I 

think is called a ‘‘significant new use rule’’ under TSCA, which has 

not yet been finalized. Since that time, Congress also gave EPA 

more authority to assess chemical safety under TSCA. 

My question would be: When do you expect that EPA will announce whether it plans to use its TSCA authority to regulate 

these chemicals? Could you give us a sense of the range of options 

that might be under consideration? 

Mr. GREVATT. Certainly. Your statements are exactly correct. We 

did propose a significant new use rule, and then we have the Lautenberg Act with additional authorities to the Agency under TSCA. 

We are currently in the process of developing a supplementary proposal to that rule that reflects the new authorities that we have received from Congress through TSCA, and that work is underway. 

We would be glad to follow up with your office with specific further 

input on that from our TSCA team if that would be helpful to you. 

Senator CARPER. All right. That would be great. 

Ms. Sullivan, I was going to ask you the next question, but we 

are going to let Mr. Grevatt answer it for you. No, I think my time 

has expired, so thank you all. Thanks very much. This is important 

stuff to us in Delaware, and I know it is in other States as well, 

so thank you very much. 

Senator PETERS. Thank you, Senator Carper. 

We do want to get to a second panel, but I think a few of us have 

a couple of other questions that we would like to follow up on, and 

we will try to move that along. Then we will bring on the second 

panel. 

Dr. Grevatt, you have mentioned a couple times now about the 

meeting next week in Michigan. Could you be more specific as to 

when you plan to be there and who will be there as well? 

Mr. GREVATT. Right. Thank you very much, sir. We plan to be 

there on the 5th, Friday the 5th, and also on the 4th, and I know 

our team in our congressional office is working with your staff as 

well as the rest of the Michigan delegation on the specifics of that. 

I do not have a location to announce for you, but we are going to 

be very happy to work with you and the other representatives’ staff 

and the rest of the team from Michigan on setting this event forward. 

We plan to have a roundtable event. We expect to have some opportunity for the public to participate and also for press to participate in that. But we are going to want to bring together key stakeholders from the State reflecting the challenges that you, in fact, 
24 

have addressed from the multiple different areas in the State of 

Michigan. 

Senator PETERS. Right. There is going to be plenty of opportunity 

for people in Michigan to be heard at this meeting. That is the important thing, which I appreciate. 

We heard before, as I ended my questioning with Ms. Sullivan, 

about the importance of having some EPA recommendations for 

contaminated sites to have some standards. My understanding is 

that the EPA is currently developing those recommendations for 

contaminated sites. I am a little clearer on some of the answers 

that you had to some of my colleagues, but that was supposed to 

be done and completed this fall. Are you still on track to have those 

recommendations for contaminated sites? 

Mr. GREVATT. We hope to have those completed this fall. As Ms. 

Sullivan knows, those are currently in interagency review. We just, 

in fact, received comments from the Department of Defense and 

others on the draft, and so we are making progress on that. But 

there are additional discussions that need to be had before we can 

land that document. But we are still hoping to have that completed 

this fall. 

Senator PETERS. In the next couple of months, then? 

Mr. GREVATT. That is what we are hoping for, yes, sir. 

Senator PETERS. Great. Ms. Sullivan, the question that I often 

get is: What water filters is the Department typically providing to 

homeowners that are impacted by PFAS? How confident are you 

that these filters are actually protecting human health? 

Ms. SULLIVAN. That is an interesting question. I am sorry, sir, 

I do not know the specifics, but I am glad to get that for you for 

the record. 

Senator PETERS. Yes, it is critically important that we have that. 

Ms. SULLIVAN. We will do that. 

Senator PETERS. Dr. Birnbaum, do you have a comment on filters? 

Ms. BIRNBAUM. I think there is some evidence that granular activated charcoal filters can remove some of the PFAS, like PFOS and 

PFOA, at least when it is new. But the efficiency of removal decreases over time so you need to replace it. There is not much evidence that it removes some of the newer alternatives that have 

been developed. 

Senator PETERS. That is a major concern. We are going to follow 

up with both of you on that, if we could. 

Mr. Lepore, I know that GAO has recently added the Federal 

Government’s environmental liabilities to the High-Risk List. If 

you could give us some insight as to what the GAO may believe is 

the Federal cost of cleaning up PFAS contamination that you are 

finding? 

Mr. LEPORE. Yes, thank you, Senator, for that question. In 2017, 

for the first time, we added the government’s financial exposure to 

environmental liabilities to our High-Risk List. The numbers I am 

going to give you are 2016 numbers. We do expect to have some 

updates next year when we issue the next high-risk update. But at 

that time, the government’s environmental exposure was $447 billion for environmental remediation. 
25 

Now, this is much more than just water. This is a whole variety 

of different contaminants. The Department of Energy (DOE) had 

the largest share; it was $372 billion. That is about 83 percent of 

the total. The Department of Defense was next at $63 billion, 

which was 14 percent of the total. All the other agencies combined, 

other than DOD and Department of Energy, were $12 billion, or 3 

percent. It is a pretty substantial liability. We will have updated 

numbers next year if we keep them on the High-Risk List. That is 

still under discussion right now. 

Senator PETERS. But that is overall environmental liabilities, not 

PFAS-specific? 

Mr. LEPORE. Correct. 

Senator PETERS. Do you have any specific to PFAS? 

Mr. LEPORE. We do not have a PFAS or PFOA number in there. 

The biggest issue, I think, is the nuclear weapons complex. That 

is why the Department of Energy is such a large component of 

that. 

Presumably, unregulated contaminants in drinking water would 

be a piece of it, although we do not actually have a real number 

for that. We do not have that right now. We could try to get that 

for you, Senator, if that is helpful. 

Senator PETERS. I think it is important that we work on that 

number, especially as you are updating these numbers in the 

months ahead. 

Mr. LEPORE. We are happy to do that. 

Senator PETERS. I appreciate that. 

In the interest of time, I will now defer to Senator Hassan, although I will be providing questions for each of you after the meeting. 

Senator Hassan. 

Senator HASSAN. Thank you, Senator Peters. 

Ms. Sullivan, I wanted to return to the topic we were beginning 

on at the end of my first round. Given that PFAS chemicals are not 

currently listed as a hazardous substance, how is DOD currently 

handling waste materials that contain PFAS chemicals? 

Ms. SULLIVAN. Thank you, ma’am, for that question. Our waste 

materials we are sending to licensed hazardous waste disposal facilities. For the most part, the excess supplies of PFAS and those 

things are going for incineration. Soil-contaminated is going to permitted hazardous waste landfills. 

Senator HASSAN. OK. What is DOD’s timeline for research and 

development of fluorine-free foams? When will DOD stop using 

PFAS-containing foams to the maximum extent practicable? 

Ms. SULLIVAN. We have already stopped using the foams for 

training and testing. 

Senator HASSAN. OK. 

Ms. SULLIVAN. That really limits the exposure to where we are 

fighting actual fires. 

Senator HASSAN. Right. 

Ms. SULLIVAN. As you can appreciate, especially in shipboard 

uses, there are some critical timeframes to be able to fight fires. 

We have invested a significant amount of money to do the research. I am going to say it is going to take 2 to 3 years. We are 

working in partnership with Dr. Birnbaum’s group on dem-
26 

onstrating the foams that are currently available that are fluorinefree to see if they meet our standards and also working with her 

on testing the ones that are currently on the market to figure out 

how much is actually in there. But it is research. It takes time, 2 

to 3 years. 

Senator HASSAN. Are there other countries that use foams that 

do not have these chemicals in them? 

Ms. SULLIVAN. Yes, there are, ma’am. There are foams—for example, in England they are, and we are working closely with them 

to test the efficacy of them to see if they will, in fact, meet our 

standards. We are in close touch and monitoring all of these efforts 

that are going on. 

Senator HASSAN. That is good to know. 

The last thing in this second round, we are hearing, obviously, 

a lot of concerns from firefighters whose protective gear contains 

PFAS. Is there research being done by DOD concerning DOD firefighters and their gear and related exposure to PFAS? 

Ms. SULLIVAN. Ma’am, I am not aware of any research on the 

gear itself, but we are working with our health affairs counterparts 

to begin tracking certain exposure levels for our active-duty members and former members so we have the long-term records of who 

is exposed when. Of course, we work in partnership to share that 

information with the Veterans Administration. 

Senator HASSAN. That is really helpful. I would urge you to continue to research this area. Here we have people putting their lives 

on the line, first responders, firefighters, people in active service for 

us, and the great irony here is that the protective gear may, in 

fact, be causing them long-term devastating health consequences. 

I think this really should be a priority, and I look forward to working with you on it. 

Ms. SULLIVAN. Thank you. 

Senator PETERS. Thank you, Senator, and I would like to thank 

each of the panelists for being here today. This is going to be an 

ongoing issue. We will look forward to working with you in the 

months and years ahead. 

At this time I would like to call up—— 

Senator SHAHEEN. Excuse me, Senator Peters. I have one more 

question, if I could ask that. 

Senator PETERS. Absolutely. Go ahead, Senator Shaheen. 

Senator SHAHEEN. This is for Dr. Grevatt. I know that the EPA 

has been working very hard to try and help address the contamination, but it has been nearly 10 years since EPA established provisional health advisories for PFOA and PFOS. Why after 10 years 

hasn’t the EPA come up with an enforceable drinking standard for 

PFOA and other PFAS chemicals? 

Mr. GREVATT. Thank you very much for the important question. 

There are three criteria in the Safe Drinking Water Act that guide 

this decision on whether to develop an enforceable standard. 

The first is whether a contaminant has an impact on the health 

of persons, and I think we have discussed that issue extensively 

here. 

The second is whether that contaminant occurs at a frequency 

and level of concern in the Nation’s drinking water systems. 
27 

The third is, in the sole judgment of the Administrator, there is 

a meaningful opportunity to reduce public health risk through a 

national drinking water regulation. 

It is really those last two criteria that are the ones that the Administrator is thinking about very carefully now. When we did our 

national survey of the Nation’s drinking water systems for these 

compounds, we sampled nearly 5,000 systems. It was a census of 

every large drinking water system in the United States and a representative sample of the smaller ones. It covered 80 percent of the 

United States population that is served by community water systems. We found in that effort 1.3 percent or 63 of the Nation’s systems had levels of these PFOA and PFOS above our health advisory values. Additional work in the State of Michigan that is underway right now, a comprehensive sample of all the drinking 

water systems in the State of Michigan, results for about 750 

drinking water systems have come back as a part of that effort, 

and thus far one parchment has come back above the health advisory levels. 

These are important considerations about what is the most effective tool to make sure that we can protect local citizens from contamination in drinking water. Is it a national standard that requires all the Nation’s systems to sample on some regular basis 

and has the tools to get treatment in place? Or is it something that 

it will address more locally? Those are the issues that the Administrator is thinking through. I am not trying to signal a direction on 

that, but just to say these are important questions that Acting Administrator Wheeler is thinking about, and we will be including 

this in the National Management Plan that we hope to have done 

at the end of the calendar year. 

Senator SHAHEEN. Thank you. 

Thank you, Mr. Chairman. 

Senator PETERS. Thank you, Senator Shaheen. Actually, that 

raises another question I have for you, but then we will release you 

to the second panel. 

Dr. Grevatt, your testimony talked about the Safe Drinking 

Water Act and support of the establishment of criteria for PFOS 

and PFOA. But certainly many people, including myself, and I 

think folks on this Committee, would urge that the Agency may 

need to think more broadly considering the wide range of substances that we are talking about. 

Has a broader class-based approach ever been utilized before by 

the Agency for other types of contaminants pursuant to the Safe 

Drinking Water Act? 

Mr. GREVATT. Yes, sir, and there are a couple of examples, but 

in particular, the microbial disinfection byproducts rule addresses 

a suite of disinfection byproducts. We have taken a group approach 

in the past, and I would emphasize that while we have been talking—I personally have been talking a lot about PFOA and PFOS, 

EPA has a very active successful effort underway to help us to 

transition to think about the broader group of compounds. We 

think that the work that we are doing on several individual compounds is going to help to inform that shift, also using some of the 

tools that Dr. Birnbaum mentioned, like the computational toxicology tools to look at a broader suite of information, to think about 
28 

hundreds of compounds, or even more, rather than two or three. 

Your point is very well taken. 

Senator PETERS. We will look forward to having that broader approach taken by the EPA. 

Thank you again to our panelists, and we look forward to hearing from our second panel. 

[Pause.] 

Welcome to our second panel. We appreciate your presence here 

to talk about this issue. We are going to introduce our three witnesses, but I think we will start—Senator Hassan, I know you have 

a guest here. If you want to start introducing our first witness, 

then I will immediately introduce the two others. 

Senator HASSAN. Thank you, Mr. Chairman. I know Senator 

Shaheen joins me in welcoming our first witness here today. It is 

my pleasure to introduce Andrea Amico, co-founder of Testing for 

Pease, a community action group that aims to educate and advocate for residents impacted by the water contamination at the 

former Pease Air Force Base in Portsmouth, New Hampshire. 

Andrea was rightfully concerned when media reports began to 

surface that an emergent contaminant called ‘‘PFAS’’ had gotten 

into the water her children drank at their daycare center. Fearing 

for their health and the health of her neighbors, Andrea began to 

research and make calls to State officials to determine what this 

contamination might mean for her community. 

Her efforts to raise public awareness and get blood tests for those 

who had been exposed to the contaminant propelled her cause to 

the mainstream, gaining attention from the Department of Health 

and Human Services as well as the Environmental Protection 

Agency. She also started the Testing for Pease group in 2015, 

which continues to this day to keep the Pease community well informed of the meetings, media, coverage, and latest research on 

PFAS contamination. 

Andrea holds both a B.S. and a Master’s in occupational therapy. 

Those degrees, combined with over a decade of experience in the 

health care field, made her particularly well suited to head up efforts to advocate on behalf of other concerned residents. 

Since beginning her efforts in 2014, Andrea has turned her activism on behalf of the Pease community into a second full-time job. 

As far as PFAS contamination goes, no one is better informed or 

more motivated than Andrea. She exemplifies New Hampshire’s 

‘‘all hands on deck’’ spirit where we roll up our sleeves, we come 

together, and we work together to solve issues facing Granite 

Staters. 

I urge our Federal agencies and this Subcommittee to listen to 

Andrea and carefully consider her priorities so that we can take 

meaningful action to keep communities in New Hampshire and 

across our Nation safe. 

Thank you, Mr. Chairman. 

Senator PETERS. Thank you, Senator Hassan. 

We also have with us today Arnold Leriche, who is a founding 

member and community co-chair of the Wurtsmith Restoration Advisory Board in Oscoda, Michigan, and a board member of the Pine 

River-Van Etten Lake Watershed Coalition. He has worked for 30 

years as an environmental engineer with the EPA and served for 
29 

1The prepared statement of Ms. Amico appears in the Appendix on page 82. 

23 years in the United States Army National Guard and Reserves. 

Mr. Leriche has retired to Oscoda to enjoy fishing on the famous 

Au Sable River, Lake Huron, and surrounding inland lakes and 

streams, which sounds a lot better than being stuck here in a hearing room in Washington. But we are certainly very glad that you 

are here, sir. 

Mr. Putnam is our third witness who began his career 28 years 

ago as a firefighter, a crash fire rescue with the United States Marine Corps, continuing to serve as crew chief as well as an instructor for the American Red Cross. Currently, he is a lieutenant with 

Mid-Atlantic Navy Regional Fire and Emergency Services, a certified firefighter, fire officer, fire inspector, fire instructor, hazmat 

technician, and an emergency medical technician, has decades of 

experience with all manner of firefighting foams. Mr. Putnam is 

also vice president of Tidewater Federal Firefighters Local F–25 of 

the International Association of Fire Fighters (IAFF), representing 

Federal firefighters at Joint Expeditionary Base Fort Story and Little Creek. 

We appreciate all three of you being here with us today. We look 

forward to your testimony, and, Ms. Amico, if you would begin. 

TESTIMONY OF ANDREA AMICO,1 CO-FOUNDER, TESTING FOR 

PEASE 

Ms. AMICO. Thank you to Chairman Paul, Ranking Member Peters, and honorable members of the Subcommittee. Thank you, 

Senator Hassan, for that incredibly kind and heartfelt introduction. 

My name is Andrea Amico, and PFAS water contamination is a 

very personal issue for me. My husband and two small children 

were exposed to highly contaminated drinking water at the former 

Pease Air Force Base while at work and attending daycare at the 

Pease Tradeport. My husband took a job on Pease in 2007, in 2011 

we had our first child, a daughter, and in 2013 we were blessed 

with our second child, a son. We were thrilled to learn of a beautiful new daycare center on Pease that was right next door to my 

husband’s work. Both of my children started daycare at the young 

age of 12 weeks old. 

When looking into child care facilities, we asked many questions 

of the daycare facilities we considered, but never did it cross our 

minds that we had to question the quality of the water. 

You can imagine the devastation I felt when I learned that the 

Pease drinking water was highly contaminated with PFAS from 

AFFF use in May 2014. I live every day with worry that my children, who were exposed to high levels of PFAS in their early life 

and at critical stages of their development, will now suffer adverse 

health effects over their lifetime. 

However, I have channeled those feelings of anxiety and worry 

into my advocacy work by forming a community action group called 

‘‘Testing for Pease’’ with two other mothers, Alayna Davis and 

Michelle Dalton. We have successfully advocated for a blood testing 

program, remediation and filtration of our water, and a health 

study to better understand the health impacts to our family and 

our community. 
30 

We also collaborate with other PFAS community leaders across 

the Nation to share best practices, streamline efforts, and work together toward making positive change at a national level for PFASimpacted communities. With the incredible support of our New 

Hampshire congressional delegation, Senator Hassan and Senator 

Shaheen are leading the way and making Federal policy changes 

related to PFAS contamination that will benefit so many. 

There are many areas of concern related to PFAS exposure. They 

are extremely persistent in the environment; they bio-accumulate 

in the body with very long half-lives; and they are associated with 

multiple adverse health effects that impact multiple systems of the 

body, such as different types of cancer, impaired immune function 

in children, elevated cholesterol, fertility issues, and more. They 

also cross the placenta to unborn children and can be passed to infants through breast milk, which means future unborn generations 

are at risk for the contamination we are facing today. 

The Environmental Working Group estimates PFAS is in the 

drinking water of 110 millions of Americans. As a community leader, I feel strongly that we must help impacted communities that 

are suffering now; we must learn more about the long-term health 

impacts of PFAS; and we must take steps to put in place more protective measures to prevent any other families from being exposed 

to harmful contaminants in drinking water in the future. 

A few of the major challenges and concerns impacted community 

members are facing: 

PFAS are presumed safe until proven toxic and ongoing exposure 

continues. This is evidenced by the EPA only setting lifetime 

health advisories for two of the thousands of PFASs in this class 

of chemicals. With the lack of Federal health advisories for all 

PFAS, millions of Americans continue to be exposed to several 

PFAS in their drinking water today. In the absence of leadership 

and guidance from the Federal Government, States are scrambling 

to find resources and construct their own plan on how to manage 

this growing and widespread issue. We see a fragmented and disjointed effort among States, and it is critical that we have a consistent and coordinated action plan by the Federal Government to 

tackle this nationwide issue. 

Communities need action now. For far too long, our government 

has not taken swift and meaningful action to address PFAS contamination. Although a large amount of contaminated communities 

have been identified in the last few years, the reality is that these 

communities have been exposed to these harmful contaminants for 

decades and are already suffering the consequences of this exposure. We need action now, and we cannot wait any longer. 

Last, communities should not be financially responsible for the 

cost of this contamination. Sadly, impacted communities are facing 

the financial burden of the costs associated with obtaining alternative water supplies, remediation, filtration, blood testing, medical bills, and lost wages due to illness. The financial responsibility 

should fall on the polluters, such as DOD and industry responsible 

for the use and manufacturing of these chemicals. 

Impacted community members cannot even begin to compete 

with the billion-dollar budgets and extensive legal teams of the responsible parties. Instead, we rely heavily on our government agen-
31 

1The prepared statement of Mr. Leriche appears in the Appendix on page 89. 

cies charged with protecting our health and the environment to 

take the action that puts our best interests first. 

In conclusion, we need to stop giving these chemicals the benefit 

of the doubt and instead give public health the benefit of the doubt 

by implementing much stricter standards for all PFAS and eliminating ongoing exposure. We need meaningful action now from our 

Federal Government to help those suffering, and we must make the 

polluters pay for the damage they have done. We cannot lose sight 

that water is the most basic need for all living beings, and if we 

are not prioritizing safe and clean drinking water for our Nation, 

then we are failing at a very basic level. 

Thank you for the opportunity to testify in front of you today, 

and I look forward to any questions you may have. 

Senator PETERS. Thank you, Ms. Amico. I appreciate that testimony. Mr. Leriche. 

TESTIMONY OF ARNOLD LERICHE,1 COMMUNITY CO-CHAIR, 

WURTSMITH RESTORATION ADVISORY BOARD 

Mr. LERICHE. Good afternoon, Chairman Paul, Ranking Member 

Peters, and honorable Members of the Subcommittee. My name is 

Arnold Leriche, and I am a retired environmental engineer from 

the EPA and a Vietnam era veteran. 

I retired to Oscoda, Michigan, mostly because I wanted to go 

fishing on the Au Sable River—which some of you have mentioned—the many beautiful inland lakes, and Lake Huron. 

One thing I quickly learned after moving to Oscoda is that many 

people fill their freezers with the fish they catch and the wildlife 

they hunt. It is second nature to the residents of northern Michigan. 

Oscoda sits next to the former Wurtsmith Air Force Base on the 

banks of the Au Sable River and the shores of Lake Huron. The 

Air Force used firefighting foam at a training site on the base. That 

training site is adjacent to Clark’s Marsh, a beautiful wetland. 

For more than 25 years, PFAS contamination drained into 

Clark’s Marsh and from that marsh into the rivers and lakes of 

northern Michigan. The base closed in 1993, but it was not until 

2010 that our State environmental department started to investigate the site for potential PFAS contamination. 

I learned from news reports in 2012 that they had discovered 

fish in Clark’s Marsh with the highest levels at that time of PFAS 

contamination found anywhere in the world. Then they found very 

high levels of contamination in the adjacent Au Sable River. I 

learned then of the health effects of PFAS contamination. We were 

advised, ‘‘Do not eat the fish.’’ You can imagine how that feels to 

residents of Oscoda who have spent their lives eating contaminated 

fish and serving it to their children. 

We now know that the contamination is in the groundwater and 

drinking water, and it is even spreading into Lake Huron, which 

is a source of drinking water for hundreds of thousands of 

Michiganders. 

I participated in sampling the drinking water around Van Etten 

Lake which adjoins the base. I will never forget the lake resident 
32 

1The prepared statement of Mr. Putnam appears in the Appendix on page 92. 

who asked, ‘‘How long has the contamination been in my well?’’ I 

could see the fear in her eyes as she thought about her grandchildren who had been drinking that water for 20 years. 

The Air Force owned a beach on Van Etten Lake, adjacent to the 

base, which has been given to the township. On this beach, our 

friends fish and have picnics, children play and learn to swim. At 

this beach, on most days you will find a bright white foam washing 

up on shore. The EPA says that PFAS contamination in drinking 

water is safe up to 70 parts per trillion. In this foam, the Air Force 

has found the level at 165,000 parts per trillion. 

Would you want your children and grandchildren playing in that 

water? Would you want them eating the fish? 

The harm extends beyond the residents of Oscoda. We now know 

that there was contamination in the drinking water on Wurtsmith 

when it was an active base. I have personally heard from veterans, 

such as Staff Sergeant Rick Thempto and Airman James Bussey, 

who are to this day suffering from health effects. 

I appreciate that the Air Force has taken some steps to address 

the contamination at Wurtsmith, including recently one step, they 

are looking at a State standard of 12 parts per trillion in groundwater as it enters a water body. That is Rule 57. They are finally 

acknowledging it. 

I listened to the testimony of the government witnesses. I am 

glad that they are beginning to acknowledge this problem and 

think about steps to fix it. 

But the people of Oscoda do not have any more time for delays 

or missteps. We need action now. We want the responsible parties 

and the Federal Government to take this seriously right now. 

We need interim mitigation. They already have enough information to take these actions. For businesses on the former base, we 

need assistance with indemnification and insurance to secure employment and encourage development. We need assistance in providing municipal water to residents who cannot drink their own 

well water. 

I ask this Subcommittee, please do not forget about the people 

of Oscoda-Au Sable Townships and those like us all around the 

country. Thank you for the opportunity to speak on their behalf. I 

look forward to you questions. 

Senator PETERS. Thank you, Mr. Leriche. I appreciate your testimony. Mr. Putnam. 

TESTIMONY OF TIMOTHY PUTNAM,1 VICE–PRESIDENT, TIDEWATER FEDERAL FIREFIGHTERS LOCAL F–25, INTERNATIONAL ASSOCIATION OF FIRE FIGHTERS 

Mr. PUTNAM. Thank you, Chairman Paul, Ranking Member Peters, and distinguished Members of the Subcommittee. My name is 

Timothy Putnam. I am the vice president of Tidewater Federal Fire 

Fighters Local F–25 of the International Fire Fighters Association. 

I appreciate the opportunity to testify today on behalf of General 

President Schaitberger and over 315,000 firefighters and emergency medical personnel who serve this Nation as the first line of 

defense against emergencies and disasters. 
33 

For over 28 years, I have been employed by the Department of 

Defense. After 4 years of military service, I transitioned into a civilian fire fighter position with the Department of the Navy, where 

I currently hold the rank of lieutenant at Joint Expeditionary Base 

Little Creek-Fort Story. As a firefighter, I have witnessed and participated in routine apparatus checks of AFFF which is known to 

contain the toxic chemicals referred to as PFAS. 

While engaged in operations utilizing AFFF, firefighters are regularly exposed to toxic PFAS. I have worked with AFFF on a continuous basis throughout my career. During my 28 years with the 

Department of Defense, the majority of my contact with AFFF is 

without benefit of adequate personal protection equipment. 

During the 1990s the use of firefighting foam agents at military 

bases was virtually unchecked. There was an abundant supply kept 

in the fire station without any limitation on its use or a requirement of protecting oneself with PPE. 

AFFF was thought to be so safe that I recall using it as a substitute for truck soap and station soap. We cleaned vehicles and 

station floors. Firefighters were required to train with and ensure 

the ready availability of such foam. I performed daily checks of my 

ARFF-assigned vehicles by flowing a few gallons of water and 

AFFF. We also conducted training exercises involving hands-on fire 

extinguishment of jet fuel burning pits. While training with 

handlines, firefighters would wade into the flaming fuel pit to practice the technique called ‘‘pushing foam’’ across the burning jet fuel. 

Exposure to AFFF was a regular and common occurrence. 

As awareness of the environmental impact of toxic foam grew, 

base officials limited where firefighters were permitted to release 

AFFF. Additionally, the frequency of the foam discharge occurring 

as part of regular vehicle checks decreased. By 2009, discharges 

dropped off to a monthly basis. Today such discharges are taking 

place on a substantially reduced quarterly or semiannual basis 

under very controlled situations. 

We know that regular exposure to AFFF causes PFAS to present 

in a firefighter’s blood and tissue where it can remain for years and 

build up to concentrations that may cause health effects. Scientific 

studies link PFAS to cancer, thyroid and liver damage, and other 

disorders. It was not until recently that I became educated about 

the potential health impacts of AFFF. Alternate foams such as C6 

or fluorine-free foam provide a less toxic option. Fluorine-free 

foams are gaining acceptance in Europe and Australia where the 

use of mil-spec AFFF is not required. European locations having 

transitioned to a new formulation have reported acceptable firefighting experiences with the foam. As we learn more about the 

toxic impact of PFAS, we must take steps to reduce firefighters’ exposure and protect their health. We, therefore, seek to ultimately 

discontinue the use of toxic foams. Meanwhile, we know that firefighters have been and will continue to be exposed to toxic PFAS. 

Although the EPA and manufacturers have worked to phaseout 

AFFF, PFOS, and PFOA foams may still be used or in stockpiles 

stored in fire stations and warehouses for years to come, continuing 

to expose firefighters and place their health at risk. 

Additionally, in the past PFOA was found in turnout gear as a 

component of such gear as moisture barriers. Although major U.S. 
34 

manufacturers have assured the IAFF that PFOA is no longer 

present within turnout gear, the toxin may persist in the legacy 

gear. To protect firefighters’ health, we support discontinuing the 

use of legacy foams and turnout gear containing PFOA. 

We also believe all firefighters should receive mandatory training 

on the hazards of toxic foam and annual physicals to determine the 

level of PFAS in a firefighter’s bloodstream. Such information will 

allow doctors to take active steps to better protect health and treat 

potential health impacts which may have already occurred. 

In conclusion, we must take immediate steps to limit firefighters’ 

exposure to the toxic formulations of AFFF. Again, I appreciate the 

opportunity to testify, and I am happy to answer any questions at 

this time. 

Senator PETERS. Thank you, Mr. Putnam. 

Mr. Leriche, you certainly spoke in a very heartfelt way about 

the impact that this contamination has had on your community 

and seeing how it is impacting really every family in the area as 

well. As your background was with the EPA and working on many 

technical aspects of environmental cleanup, what specifically would 

you like to see out of the EPA and Federal agencies? Who do you 

believe should be responsible for that remediation? What advice 

would you give us in terms of our dealings with the EPA as they 

move forward? 

Mr. LERICHE. Thank you, Senator, for the question. I must say 

at the outset that is above my pay grade, at least in the EPA, and 

my area of expertise at EPA was not with CERCLA or Superfund 

but other enforcement statutes. 

However, I can address definitely the Department of Defense. As 

the co-chair of the Wurtsmith Restoration Advisory Board, I will 

answer in that area, and I will stay out of trouble. 

Senator PETERS. Please do. 

Mr. LERICHE. The timing of their investigations and how long it 

takes for them to investigate a site, especially under their current 

implementation of CERCLA, has been very frustrating because it 

is linked so significantly to the lifetime health advisory. 

In my calls almost weekly with my counterpart co-chair in the 

Air Force, it is constantly causing problems in trying to get remediation and investigation action happening quickly. That particular 

interpretation of the CERCLA is—and the answer I think over 

here—has caused us so much delay that it is very troublesome. I 

think that is an important thing that needs to be opened up, and 

that is the biggest one, because if they had the money and they 

had the interpretation of the national policy to support real quick 

remediation and investigation, then we would have much more 

done at this point. There have been years of delay on this particular point because they are following national policy. 

Senator PETERS. Obviously, the people of Oscoda cannot wait any 

longer. When you hear talk about this may take 5 or 10 years, that 

is simply unacceptable. 

Mr. LERICHE. That is correct, especially when we know the 

health effects can possibly skip generations, so we are talking 

about grandchildren. We are not going to be here when they have 

the effects. Timing cannot be bought back. We have to do it now. 
35 

Senator PETERS. What would citizens of Oscoda consider adequate remediation? When it is all said and done, what would you 

like to see? 

Mr. LERICHE. Rule 57 I mentioned—and I am sorry I added that 

to my testimony—that is a huge step, because it was based somewhat on health studies by the State in 2014 to control the bio-accumulating effect of PFOS in fish and then humans eat the fish. That 

is why there is ‘‘Do Not Eat the Fish’’ around Wurtsmith. But it 

is an advisory. That statute is an advisory for fish consumption. 

But this standard is an enforceable standard by the State, and it 

must be incorporated into the Department of Defense’s remediation 

plans and action. That is where they have been avoiding putting 

it in their action plans, and now they are thinking about it. 

Senator PETERS. Thank you. 

Mr. Putnam, thank you for your service and your long career 

fighting fires as a professional firefighter. I must say I appreciate 

the support from the International Association of Fire Fighters 

when we worked on removing the Federal mandate that the FAA 

regulations require fluorinated chemicals. We are going to be 

changing that as we move the FAA reauthorization forward as we 

look at alternatives. 

I think you may have heard some testimony of the folks before 

you who claim that the military still believes that these chemicals 

are necessary to fight fires, although in your testimony you talk 

about a number of alternatives. 

Please elaborate on that based on your experience as a professional firefighter. Can we effectively fight fires with alternatives? 

Mr. PUTNAM. Senator Peters, I would first like to thank you for 

your leadership on these fluorine-free foams. It is critical that we 

provide these to our firefighters. The elements that are out there, 

the research is being done now. We are taking a back seat to Europe and Australia at this time. Will they work? Absolutely. Will 

we have to adjust how we train? Yes. Every time we have a new 

tool, we change and we train. With what we are using right now, 

the training is very limited, and it is on a very sporadic basis. A 

new fluorine-free foam would work outstanding for us. 

Senator PETERS. Great. Thank you. Senator Hassan. 

Senator HASSAN. Thank you again, Senator Peters, and thank 

you again to this panel. 

Ms. Amico, I just wanted to thank you again for taking the time 

out of what I know is a very busy schedule and time away from 

your family to come here to D.C. to tell your story. As you mentioned in our meeting earlier, your husband was employed for a 

company on Pease for almost 9 years, and both of your children 

have attended daycare on Pease since they were, what, about 12 

weeks old? 

Ms. AMICO. Yes. 

Senator HASSAN. You have spoken about some of the ways PFAS 

contamination impacted your community and other communities 

across the Nation, but I thought I would just give you this opportunity to expand on that a little bit, and then I want to follow up 

on what we can do to help. 

Ms. AMICO. Thank you for the question. PFAS contamination is 

clearly a widespread issue. It is impacting several communities 
36 

across the country, and it is causing a lot of stress for people. The 

fear of the unknown, having these exposures, in some communities 

having blood testing that shows high levels but not quite knowing 

what those high levels in the blood mean is creating worry and fear 

for people. We are extremely grateful for the health study that will 

be coming down the pike for our community that may will benefit 

from. But we are also seeing that people are having to absorb the 

financial costs of the contamination, which is incredibly wrong. 

Like I said in my testimony, people are having to pay for their own 

filters or for bottled water. If communities are not being offered 

blood testing, some are opting to pay for their own blood testing, 

which is very expensive. There are medical bills and lost work due 

to health effects from PFAS exposure. And like I touched upon, 

there is the emotional toll. 

I think we are seeing communities face emotional, physical, and 

financial impacts because of this contamination. 

Senator HASSAN. Thank you. You noted that without Federal 

leadership, States are left to investigate PFAS contamination and 

provide remedial action to contaminated sites on their own. Do you 

think the government is acting in a timely manner to address 

PFAS contamination across the country? 

Ms. AMICO. I do not. I think we need a more consistent approach 

among the Federal agencies, particularly through ATSDR, EPA, 

NIEHS, and I was happy to hear of some of that collaboration 

today in the testimony from the first panel members, but we need 

more of that. We need a much more consistent approach, because 

we are seeing other States take different steps, different measures, 

and it is leaving us, as community members across this country, 

wondering why is Vermont lowering a standard to 20 parts per trillion for five different PFAS when the EPA is saying 70 parts per 

trillion for two different PFAS. Then we are seeing New Jersey propose lower standards. We are seeing Massachusetts and Connecticut take five different PFAS into consumer for their 70 parts 

per trillion. It is very confusing for community members, and it is 

also very alarming—what are these States seeing, what science are 

they analyzing that they are coming to these different numbers? 

We need a much more consistent and coordinated approach than 

what we have. 

Senator HASSAN. That really leads me to the next question, and 

you have answered it in part. Do you feel that the current EPA 

lifetime health advisories for PFOS and PFOA of 70 parts per trillion are protective enough? 

Ms. AMICO. I do not. I say that based on information that I have 

read in some of the New Jersey data that has come out of their 

Drinking Water Quality Institute and looking at most sensitive 

populations and also in my discussions with other researchers and 

academics across the country. I think that we need to make sure 

EPA is taking into consideration the most sensitive populations 

such as unborn children and infants. Also, I would like to see the 

EPA, ATSDR, and NIEHS look at exposed communities because 

they need to be considered a sensitive population as well. Should 

a community member who drank high levels of PFAS with high 

levels in their blood be allowed to continue to drink 65 parts per 

trillion because it is under 70? No, to me that is a sensitive popu-
37 

lation that we need to be more protective of. As we heard earlier 

in the statements by the government officials, it is a widespread 

issue. It is found in the blood of almost every single American. We 

all have some level of exposure, but we have a large and growing 

amount of community members that we are discovering have a 

very high exposure, and we need to take those folks into consideration as well as we move forward with next steps. 

Senator HASSAN. Thank you for that. I just want to commend 

you again. You and your colleagues Alayna Davis and Michelle Dalton have done incredible work, and you are continuing to do it with 

community groups like Testing for Pease. It has been, obviously, 

really important to the safety of all citizens impacted by dangerous 

contaminants in our drinking water. 

In your opinion, what can we as elected officials do to help important action groups like yours continue to succeed? 

Ms. AMICO. I think a few major things that government can do 

is we can take action now. It is disheartening to hear that meaningful action can take 5 and 10 years when at Pease we are coming 

up on 5 years of discovering our contamination. I do not think that 

we can continue to delay anymore. 

We also need to see meaningful action to the entire class of 

PFAS, so just trying to do one contaminant at a time is not working. We have thousands of them in our environment. We have several of them found in drinking water across the country, and we 

need to regulate it as a class. 

We also need to provide biomonitoring and blood testing for impacted community members, and we also need to provide medical 

monitoring, which is a program that folks can participate in with 

their physicians to better monitor their health in the setting of the 

exposure. I like to point out the difference. The health study, there 

will be a lot of benefits that come from that, but we heard from 

Dr. Birnbaum that could take 5 years to get that information. 

What can I do today? I have two children with high levels in 

their blood. What can I do today with their pediatrician to monitor 

their health? Does that mean check additional labs? Should they be 

seen twice a year instead of once a year? We need some more clear 

guidance to impacted community members. We could not prevent 

this contamination from happening, but what can we do moving 

forward to protect our health? 

Senator HASSAN. Thank you for that. Again, I want to thank 

Senator Peters and Chairman Paul for having this hearing. 

I want to ask a very quick last question to Mr. Putnam just to 

clarify what I think I heard you say to Senator Peters. Earlier Ms. 

Sullivan from the Department of Defense said it would take more 

research before the Defense Department could decide to move to 

PFAS-free foam or protective gear. I take it, given that Europe and, 

I think you said, Australia already have gotten there, that you 

might think that we do not need more research, we just need to 

use their example and get going on a transition. 

Mr. PUTNAM. Thank you for the question. I believe we should use 

it as a tool. 

Senator HASSAN. OK. 

Mr. PUTNAM. We should use it for our own research and moving 

forward and getting what we need here. 
38 

Senator PETERS. OK. Thank you very much, and thank you 

again, Senator Peters. 

Senator PETERS. Thank you, Senator Hassan. Senator Shaheen. 

Senator SHAHEEN. Thank you, Senator Peters. Again, I very 

much appreciate being able to be part of this very important hearing on an issue that, as we heard from the first panel—and you all 

clearly can confirm—this is an issue that affects tens of millions of 

people across the country. The cost of cleanup to address this is 

tens of billions of dollars. We do not even know yet what the longterm health impacts are. 

We have a lot of work to do, and I want to begin with you, Ms. 

Amico. Thank you for all of your advocacy and for the group that 

you started. We affectionately call you all the ‘‘Pease Moms’’ because of all of the work that you have done to make sure that 

something was done at the local, State, and Federal level to address the contamination that has affected you and your family and 

so many people. 

I want to follow up on Senator Hassan’s question about what we 

can do. You laid out some very impressive recommendations for 

what we ought to be thinking about as we are addressing this 

issue. If you could ask Congress to do one thing in the immediate 

term, what would it be? 

Ms. AMICO. Thank you for the question. I would say our top priority would be to stop the ongoing exposure, so we would need to 

strictly regulate PFAS as an entire class to a much lower standard 

than what we have right now to prevent ongoing exposure. That 

would be a top priority, stop the exposure. 

Senator SHAHEEN. Clearly, prevention makes a lot more sense 

than cleanup later on. 

I want to ask you, Mr. Leriche, because it is my understanding 

that you and Andrea have worked together with other groups 

across the country to raise concern about this. Can you talk about 

how you have done that, how you all have worked together? 

Mr. LERICHE. Thank you for the question, Senator Shaheen. 

What has not come out yet is my birth State was New Hampshire. 

Senator SHAHEEN. I knew you looked familiar. [Laughter.] 

Mr. LERICHE. I am surprised you did not pick up on the accent. 

But your question, if you could repeat just quickly? 

Senator SHAHEEN. Just I am interested because we have obviously got—— 

Mr. LERICHE. Oh, how we work together. I am sorry. 

Senator SHAHEEN [continuing]. People in the audience who have 

been affected by this across the country, and I know from talking 

to Andrea that one of the things you all have done very effectively 

is network with groups across the country to see how you could advocate and build on what you are learning in different parts of the 

United States. Can you talk about some of the things that you have 

done? 

Mr. LERICHE. Thank you. When I first started realizing the significance in Oscoda, I started to see that there was a process where 

the Air Force would bring the community in, and it is called the 

‘‘Restoration Advisory Board (RAB).’’ I went back home, and I attended the RAB at Pease, and I linked up with some of the program managers for remediation there from my old agency. That is 
39 

where I first started. I met Alayna there. I did not meet Andrea 

until today, actually, face to face, but I had talked to her, plus 

other groups. I think that that is where the community members, 

such as myself, need to do is we have to become educated on how 

the Federal agencies do their business, because if we do not, then 

we are just listening. We are not able to act and be activists until 

we understand what motivates them and what regulations do they 

have. That was the first exposure. The energy that these three ladies and others have done their business over the last 41⁄2 years 

is outstanding. 

That is where we gain the knowledge, and I would suggest that 

all communities, at least around Department of Defense sites, do 

that, they engage with this group, the PFAS National Coalition 

that holds calls, and that is where I have learned a lot about what 

is going on. We can use all of our expertise to bear on the large 

agencies that may not be acting as fast as we need. 

Senator SHAHEEN. All right. Let me just say how effective you 

have all been, because when I introduced the amendment in the 

defense authorization bill 2 years ago for the health study, we went 

around and talked to people on the committee from all over the 

country. There were a significant number of them who had heard 

from their constituents that this was an issue in their communities 

and in their States. It has made a huge difference, and that advocacy is going to continue to make a difference as we go forward. 

I just want to ask a final question of you, Mr. Putnam, because 

one of the things that Congress did this summer was to pass the 

Firefighters Cancer Registry. Talk about why that is so important, 

especially as we think about an issue like this. 

Mr. PUTNAM. Thank you for the question. As we move forward, 

firefighters have a 60 percent more likely chance to get cancer. 

This is going to give us a basis to lead and help the IAFF lead this 

drive to help find out what is causing it. Whether it may be the 

PFAS or the environmental concerns that we deal with, this is 

going to drive that, and the Cancer Network is a big part of it also. 

Thank you. 

Senator SHAHEEN. Thank you. 

Thank you very much again, Mr. Chairman, for holding this 

hearing. 

Senator PETERS. Thank you, Senator Shaheen. I appreciate both 

my colleagues for being here to the very end on this very important 

topic. I would certainly like to thank everybody here in attendance 

today. This is clearly a significant issue, a significant issue that 

may be impacting tens of millions, perhaps a hundred million 

Americans. It is an issue that we are going to likely be dealing 

with for a long period of time. We have to be focused on it because 

we do not have time. We already have folks, as we heard from our 

witnesses here today, that have been dealing with this for far too 

long, over a decade, and may have been exposed over several decades, which requires action. 

I would also like to let folks know we have been getting not only 

the testimony here but a lot of letters and comments coming in. I 

got additional comments as I was sitting here from folks across 

Michigan. I would encourage anyone else to submit anything they 

would like to be put into the official hearing record. The hearing 
40 

record will remain open for 15 days until October 11 at 5 p.m. for 

the submission of statements as well as questions for the record, 

questions that individuals may want to ask of folks who appeared 

before this Committee. 

With that, thank you again to all of our witnesses, and the hearing is adjourned. 

[Whereupon, at 4:41 p.m., the Subcommittee was adjourned.] 
(41) 

A P P E N D I X 
42 

represented here today. But, is 70 the right number? Some states have set it much lower, while 

others have followed the EPA guidelines, which some say are lower than needed. The fact that 

the appropriate level is being debated begs the question, how were these levels set in the first 

place? 

Some are calling for quick action while others warn moving faster may lead to improper 

or unneeded regulation. The U.S. military seems to be acting by changing procedures for use of 

:'FAS fire fighting foams, including more robust clean ups when it is used and has turned to 

alternative fire retardants. They have also spent over $200 million on testing and remediation 

efforts where contamination has already occurred. More good news is that sampling from the 

Red Cross and the National Health and Nutrition Examination Survey, a CDC activity, have 

shown a dramatic decline in PFOA and PFOS concentrations in blood chemistry over the past 

two decades. It does not mean all is well, but it appears things are moving in a positive direction. 

But the question remains, is this enough, what are the continuing risks, and what will the 

long term cost to the federal government's be? Hopefully the witnesses we have here today will 

be able to help us answer these questions. 

With that, I'll recognize the Ranking Member Peters who brought this issue to my 

attention, to give his opening statement. 
43 

U.S. Senate Homeland Security and Governmental Affairs Committee 

Subcommittee on Federal Spending Oversight and Emergency Management 

"The Federal Role in the Toxic PFAS Chemical Crisis" 

September 26, 2018 

Senator Gary C. Peters, Ranking Member 

Opening Statement 

Thank you Mr. Chairman, for working in a bipartisan way to convene today's hearing. 

In Michigan we've seen firsthand the devastation a community experiences when they can't 

trust the water coming out of the tap. In Flint, thousands of families were exposed to dangerous 

levels oflead in their water. and many residents still use filters and bottled water to ensure their 

water is safe. 

Just over 100 miles north of Flint residents of Oscoda. Michigan have spent years voicing their 

concerns about another serious environmental and public health threat in their drinking waterthis time from highly-l1uorinated chemicals known as PFAS. 

These chemicals are widely used in products like non-stick cookware, water-repellent clothing, 

stain-resistant upholstery, and many firelighting foams. They are extraordinarily persistent, 

meaning they don't break down naturally in the environment. They accumulate in our soil, our 

water, our food. and too often, in our bodies. They are toxic- and they are not well regulated. 

I'm grateti1l to Mr. LeRiche for being here today to talk about the impact of contamination on the 

community in Oscoda and the challenges residents face around the former Wurtsmith Air Force 

Base. 

Unfortunately Oscoda is not alone- there are contaminated sites throughout Michigan and the 

nation. 

Sandy Wynn-Stelt of Belmont, Michigan. who is here today. was exposed to one of the highest 

concentrations of these chemicals that has been identified in the United States- and now has 

PF AS levels in her blood that arc more than 750 times the national average. Tobyn Mc\iaughton 

is also here, also from Belmont. Her two year old son Jack has the highest documented PFAS 

levels known, at 484,000 parts per trillion. He's two years old. 

Families in Parchment Township, Michigan were forced to switch to bottled water earlier this 

summer and now they fear that their children have been poisoned since birth. 

As a Senator from Michigan a state surrounded by the Great Lakes- the world's largest source 

of surface freshwater- I'm appalled by the number of water crises we've faced. l'v!y constituents 

--and people across the country facing this crisis- arc fed up as well. Mr. Chairman, I request 
44 

permission to enter in the record a few statements from Michiganders urging swift actions on 

f1uorinated chemicals. 

J asked for this hearing because I believe that everyone in this great country should have access 

to safe drinking water and I want to do everything I can to ensure the federal government is 

effectively managing this crisis. 

Soon the Senate will approve an FAA bill that includes my language to remove federal mandates 

requiring the usc of these chemicals in flretlghting foams. I've also worked with my colleagues 

to urge EPA to swiftly establish national enforceable standards to enable longer term clean-up 

look forward to hearing more fi·om EPA today. These are important bipartisan steps- but they 

are just the beginning. 

I look forward to hearing more today about what federal agencies are doing and what more 

they can do and what Congress must do- to identify contamination, prevent exposure, reduce 

harm to human health, and to expedite clean-up and assistance for affected communities. 

2 
45 

TESTIMONY OF 

PETER C. GREV ATT, Ph.D. 

DIRECTOR 

OFFICE OF GROUND WATER AND DRINKING WATER 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

BEFORE THE 

SENATE COMMITTEE ON HOMELAND SECURITY AND 

GOVERNMENTAL AFFAIRS 

SUBCOMMITTEE ON FEDERAL SPENDING OVERSIGHT AND 

EMERGENCY MANAGEMENT 

SEPTEMBER 26,2018 

Good afternoon, Chairman Paul, Ranking Member Peters, and members of the Subcommittee. I 

am Peter Grevatt, Director of the U.S. Environmental Protection Agency's Office of Ground 

Water and Drinking Water. I also serve as the chair of the EPA's cross-agency efforts to address 

per- and polyfluoroalkyl substances (PFAS). Thank you for the opportunity to testifY today. 

Protecting America's drinking water is one of the EPA's top priorities. I am here today to share 

with you the actions the agency is taking to provide states, tribes, and communities with the tools 

they need to effectively address PFAS. 

BACKGROUND 

Per- and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that have been 

in use since the 1940s, and are (or have been) found in a wide array of consumer products like 

cookware, food packaging, and stain repellants. PF AS have also been used in aqueous filmforming foams. PFAS manufacturing and processing facilities, airports, and military installations 

that use firefighting foams are some of the contributors ofPFAS releases into the air, soil, and 

water, including sources of drinking water. There are many PFAS chemicals, including the 
46 

chemicals perfluorooctanoic acid (PFOA), perf1uorooctane sulfonate (PFOS), and GenX (HFPO 

dimer acid). 

Because of their widespread use, most people have been exposed to PFAS. Some PFAS can 

accumulate and can stay in the human body for long periods oftime. There is evidence that 

exposure to certain PFAS may lead to adverse health effects. 

EPA'S WORK ON PFAS 

The EPA has taken steps under its statutory authorities to understand and address these 

chemicals. For example, certain PF AS chemicals are no longer manufactured in the United 

States as a result of the EPA's PFOA Stewardship Program in which eight major chemical 

manufacturers agreed to phase out the use ofPFOA and PFOA-related chemicals in their 

products and as emissions from their facilities. All companies met the PFOA Stewardship 

Program goals by 2015. In support of this effort, through the EPA's work under the Toxic 

Substances Control Act, the agency has issued various significant new use rules (SNURs) to 

guard against the unreviewed reintroduction and new use, through domestic production or 

import, of certain PFAS chemicals in the United States. However, the SNUR authority did not 

cover ongoing uses such as low-volume usc of some PFAS in limited industrial applications. 

The EPA has also worked with the states and local communities to monitor for six PFAS under 

the Safe Drinking Water Act to understand the nationwide occurrence of these chemicals in our 

drinking water systems. In 2016, the EPA issued drinking water lifetime health advisories for 

PFOA and PFOS of 70 parts per trillion individually or combined. The health advisories are nonregulatory values that help to provide technical information to state agencies and other public 

2 
47 

health officials on the level ofPFOA and PFOS that would provide Americans, including the 

most sensitive populations, with a margin of protection from a lifetime of exposure to PFOA and 

PFOS from drinking water. The EPA is also working to move research forward on other PF AS to 

better understand their health impacts, options for treatment, and how information on betterknown PFAS (such as PFOA and PFOS) can be applied to inform our knowledge of other PF AS 

chemical classes. 

To build on these actions, the EPA hosted a PF AS National Leadership Summit in May 2018 

that brought together state, tribal, and federal partners, as well as key stakeholders including 

industry, utilities, Congressional staff, and nongovernmental organizations. The Summit 

provided an opportunity to share information on ongoing efforts, to identity specific near-term 

actions, and to address risk communication challenges. 

At the event, the EPA committed to work on four significant actions: 

I. Initiating the steps to evaluate the need for a Safe Drinking Water Act maximum 

contaminant level for PFOA and PFOS. 

2. Beginning the necessary steps to consider designating PFOA and PFOS as "hazardous 

substances" through one of the available statutory mechanisms, including potentially 

CERCLA Section 102. 

3. Considering groundwater cleanup recommendations for PFOA and PFOS at 

con tam ina ted sites. 

4. Working in close collaboration with federal and state partners to develop draft toxicity 

values for GenX (HFPO dimer acid) and for pcrtluorobutane sultonic acid (PFBS). 

3 
48 

The EPA also continues to provide support to states, tribes, and communities who are addressing 

PFAS issues. For example, at the request of the North Carolina Department of Environmental 

Quality, the EPA continues to perform independent laboratory analysis for GenX and several 

other PFAS compounds in water samples collected along the Cape Fear River. In Michigan, the 

EPA is providing technical assistance to the Michigan Department of Environmental Quality as 

the state responds to PFAS contamination in communities such as Parchment. 

As the EPA takes these actions, the agency is also committed to working with our federal 

partners, including the Department of Defense and the Department of Health and Human 

Services, on response actions and continuing research into the health and environmental impacts 

of these substances. For example, the EPA is coordinating with its tederal agency partners as the 

agency develops draft toxicity values for GenX and PFBS. Interagency coordination is key to 

providing a common Federal approach to addressing these substances in order to best support our 

state, local, and tribal partners as well as the public. We look forward to continuing to our 

interagency dialogue and collaboration on PFAS issues. 

COMMUNITY ENGAGEMENT 

The EPA recognizes the need to hear directly from communities that have been and/or continue 

to feel the impact ofPFAS. Since June, the EPA has traveled to Exeter, New Hampshire; 

Horsham, Pennsylvania; Colorado Springs, Colorado; Fayetteville, North Carolina; and 

Leavenworth, Kansas. The EPA also engaged with tribal representatives at the Tribal Lands and 

Environment Forum in Spokane, Washington. At these events, the EPA has engaged with nearly 

a thousand individuals, including more than 150 people who delivered remarks about their 

personal experiences. We listened to these community members to better understand their 

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49 

concerns and to learn from them ways that the agency can best support the work being done at 

the state, local, and tribal levels. The EPA is also seeking recommendations from state and local 

officials through the agency's Local Government Advisory Committee. Hearing directly from 

impacted communities has been invaluable, and community feedback will shape how we move 

forward on this important issue. 

To ensure that everyone who would like to provide input can do so, the EPA has set up a public 

docket that will remain open until September 28, 2018. The EPA will consider information from 

the National Leadership Summit, community engagements, and the public docket to develop a 

PFAS Management Plan. The Management Plan is expected to include actions that the EPA will 

take to provide tools that states, tribes, and communities can usc to address PF AS. 

CONCLUSION 

Protecting public health is the EPA's top priority. Acting Administrator Wheeler has expressed 

his continued commitment to considering actions on PFAS so that the EPA can lead efforts that 

meet the needs of impacted communities. 

Once again, Chairman Paul, Ranking Member Peters, and Members of the Subcommittee, thank 

you for the opportunity to discuss PFAS and the EPA's ongoing commitment to working to find 

solutions to address these chemicals. I look forward to answering any questions you may have. 

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1 

Statement of 

Ms. Maureen Sullivan 

HOLD UNTIL RELEASED 

BY THE COMMITTEE 

Deputy Assistant Secretary Of Defense 

(Environment) 

Before the Committee on Homeland Security and Governmental Affairs 

Subcommittee on Federal Spending and Oversight 

The Federal Role in the Toxic PFAS Chemical Crisis 

September 26,2018 
51 

Federal Spending Oversight Subcommittee 

Committee on Homeland Security and Governmental Affairs 

Hearing: September 26 @ 2:30 pm 

SD-342 Dirksen Senate Office Building 

Chairman Paul, Ranking Member Peters and distinguished members of the 

Subcommittee. Thank you for the opportunity to discuss DoD's actions related to perfluorinatcd 

chemicals. 

Background: 

Perfluoroalkyl substances (PFAS) refers to the entire class of poly- and per-fluoronated 

alkyl substances, of which perfluorooctane sulfonate (PFOS) and perfluorooctanic acid (PFOA) 

are the most well-studied substances. These substances are ubiquitous in many industrial and 

consumer products because they increase a product's resistance to heat, stains, water, and grease. 

As such, they are not uniquely attributable to Department of Defense (DoD) activities. The 

Interstate Technology and Regulatory Council (ITRC) determined three to six percent of the 

perfluorooctanyl chemicals produced were used as firefighting foam. 1 Ofthis percentage, DoD 

is only one of many users of Aqueous Film Forming Foam (AFFF), which also includes 

commercial airports. the oil and gas industry, and local fire departments. The remaining 

perfluorooctanyl chemicals produced were used in the following industrial and consumer 

applications: approximately 41 percent for paper and packaging protectors; 36 percent for 

textiles, leather and carpet treatment, and fabric protection; and 19 percent for industrial 

surfactants, additives, and coatings. Perfluorooctanyl chemicals are used in electroplating and 

etching, household additives, insecticides, and other applications. 

DoD's limited usc ofPFAS started in the 1970s, with the introduction of AFFF for 

aircraft fuel fire-fighting purposes. AFFF may contain PFOS and, in some formulations, PFOA. 

AFFF is mission-critical because it quickly extinguishes petroleum-based fires, which is why the 

Federal Aviation Administration has also adopted its use at airports nationally. AFFF containing 

PFOS, other than in potential trace amounts, is no longer manufactured or available for purchase 

in the United States, although legacy stocks of these AFFF remain. 

On May 19,2016, the EPA issued Safe Drinking Water Act (SDWA)Iifetime health 

advisories (LHA) recommending individual or combined levels of PFOS and PFOA 

concentrations in drinking water be below 70 parts per trillion. While the LHA is non-regulatory 

guidance under the SDWA and not a required or enforceable drinking water standard, DoD 

began proactively taking action to address drinking water impacted by DoD releases. 

Despite the fact that the EPA drinking water LHA for PFOS and PFOA is only an 

advisory, DoD has taken a three-pronged approach: I) DoD has taken quick action to address 

1 The Interstate Technology and Regulatory Council (ITRC) analysis is based on a 3M July 7, 2000 letter to the U.S. 

Environmental Protection Agency Office of Prevention, Pesticides and Toxic Substances on 3M Phase-Out plan for 

perfluorooetanc sulfonyl fluoride (POFS)based products. This analysis does not include PFOA produced by 3M or 

PFOS/PFOA or other PFAS production by other manufacturers 

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52 

PFOS and PFOA in the drinking water it supplies, 2) DoD has taken response action in 

accordance with the Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980 (CERCLA, aka Superfund), and 3) DoD has committed significant funds in research and 

development to identifY and test fluorine-free AFFF. 

Drinking Water: 

DoD provides drinking water to approximately 2 million people on its installations 

worldwide. The Department began testing DoD-operated drinking water systems worldwide in 

June 2016 to identifY drinking water that exceeded EPA's LHA. DoD completed testing of all 

524 DoD-owned drinking water systems worldwide in August 2017. These tests determined that 

twenty-four DoD drinking water systems contained PFOS and PFOA above the LHA. 

Accordingly, though not required by law or regulation, DoD has followed the EPA LHA 

recommendations, to include providing consumers bottled water or additional water treatment. 

In cases where DoD purchases drinking water, the Department identified 12 drinking water 

systems where the results were above the EPA LHA level. These installations are working with 

the drinking water supplier(s) to encourage appropriate actions. 

Remediation Action: 

CERCLA provides a consistent approach across the Nation for cleanup and includes 

environmental regulators and public participation. The Department addresses on-base and offbase migration of its PFOS and PFOA releases to protect human health and appropriately spend 

taxpayer dollars. The Defense Environmental Restoration Program (DERP) (10 USC 2701-

2711) provides authorities to DoD to perform and fund these actions, and requires they be carried 

out in accordance with CERCLA. Our first step is to identify the source of a known or suspected 

release. The Military Departments identified installations where DoD stored or used AFFF 

containing PFOS or PFOA and suspects there was a release. DoD has identified 401 active and 

former (Base Realignment and Closure) installations with at least one area where there is a 

known or suspected release ofPFOS or PFOA. 

The Military Departments then determined whether there is exposure through drinking 

water and, if so, the priority is to address high exposure levels. DoD's actions are consistent 

with EPA's LHA recommended actions, which include treatment of drinking water or closing 

drinking water wells and providing alternative water supplies, such as bottled water or 

connecting private residents to public drinking water systems. Once the exposure pathway is 

broken, the Military Departments are prioritizing sites for further actions using the normal 

CERCLA risk-based process. This longstanding site prioritization process is based on "worst 

first," meaning the Military Departments will address sites that pose a greater potential risk to 

human health and the environment first. 2 

2 Further details for this longstanding CERCLA prioritization process was developed by EPA and state regulators, as 

well as the other stakeholders such as DoD, and documented in recommendations of the Federal Facilities 

Environmental Restoration Dialogue Committee (FERDEC I 999). 

3 
53 

DoD follows the CERCLA process to fully investigate the release and determine the 

appropriate cleanup actions based on risk. These known or suspected PFOS and PFOA release 

areas are in various stages of assessment, investigation, and cleanup. Although the EPA LHA 

level is only guidance under the SOW A and is not an enforceable drinking water standard, DoD 

considers the EPA's LHA toxicity information when assessing risk to human health under 

CERCLA. Under the EPA's longstanding risk assessment and hierarchy of toxicity value 

policies, the LHA toxicity information is used to determine a site-specific risk-based cleanup 

level for groundwater used as drinking water. This calculated risk cleanup level may be higher 

than the EPA LHA, which can cause communication challenges when explaining to the public 

how this groundwater cleanup level is within safe parameters. 

Before Fiscal Year (FY) 2018 when the Department first included such cleanup in the 

President's Budget, DoD had to prioritize funds from other cleanup activities in order to address 

PFOS/PFOA. Now that we have an initial inventory, we arc determining the potential cleanup 

costs as we collect information on the nature and extent of the releases. It will also be necessary 

to understand the regulatory cleanup standards for PFOS and PFOA to adequately plan and 

budget for DoD responsibilities. As DoD moves through the CERCLA process, the Department 

will work in collaboration with regulatory agencies and communities, and will share information 

in an open and transparent manner. 

Research and Development: 

In May 2000, 3M, the sole American manufacturer, began voluntarily phasing out the 

production ofPFOS-related products, including AFFF containing PFOS, in response to proposed 

EPA regulations under the Toxic Substances Control Act. Since PFOS is no longer 

manufactured in the U.S., the U.S. AFFF on the market today should not contain PFOS, although 

legacy stocks of these AFFF remain. However, some formulations still contain trace amounts of 

PFOA. While AFFF containing PFOS (other than potential trace amounts) is no longer 

manufactured for purchase in the U.S., the Military Departments may still have AFFF containing 

PFOS in equipment, such as aircraft hangar fire suppression systems. There is currently no 

fluorine-free formulation of the foam commercially available that meets the critical Military 

Specification (MILSPEC) requirement to suppress aircraft fires effectively, although DOD is 

testing alternative formulations. DoD must maintain the capability to fight fires to protect the 

men and women serving in the military and the communities surrounding their installations. 

To address this challenge, DoD is taking several steps. To prevent further releases into 

the ground water, DoD issued a poliey in January 2016 requiring the Military Departments to 

prevent uncontrolled, land-based AFFF releases during maintenance, testing, and training 

activities. The policy also requires the Military Departments to remove and properly dispose of 

local warehouse supplies of AFFF containing PFOS (other than for shipboard use), where 

practicaL Each Military Department is taking actions to remove this AFFF containing PFOS 

from its inventory. 

The Department is also researching and developing technologies to enhance our 

response to PF AS and to ensure the safe use of AFFF through two key programs: the Strategic 

Environmental Research and Development Program (SERDP), which focuses on basic and 

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54 

applied research, and the Environmental Security Technology Certification Program (ESTCP), 

whose mission is to validate more mature technologies to transition them to widespread use. 

SERDP initiated research into the fate, transport, and remediation ofPFOS and PFOA 

shortly after EPA released the 2009 Provisional Health Advisories for these compounds. 

Follow-on research beginning in 2014 has targeted developing several approaches for treating 

groundwater containing PFOS and PFOA. These efforts have matured from the small seale to 

field demonstrations that began under ESTCP in 2017, with an additional demonstration in 2018. 

In addition to these initial projects on PFOS and PFOA, the SERDP and ESTCP 

Environmental Restoration Program Area has launched an aggressive effort to develop more cost 

effective treatment options for other, newly-identified PFAS. At the conclusion of the ongoing 

projects, the Department will have invested $40M in PF AS-related research and development 

through SERDP and ESTCP. 

In FY 2017 and FY 2018, SERDP solicited research projects to identify and test fluorinefree surfactants for use in next-generation AFFF that can meet the military's stringent 

perfonnance requirements while eliminating PFAS. Two core projects and seven limited-scope, 

quick-look projects have been initiated in this effort. 

In FY 2019, ESTCP will initiate demonstrations of existing replacement AFFF 

formulations at DoD facilities to determine if their performance can meet mission requirements. 

These combined efforts support DoD's commitment to tlnding an AFFF alternative that meets 

critical mission requirements while protecting human health and will represent $1OM in research 

and demonstration funding. 

The Department of the Navy is funding research and development efforts related to AFFF 

alternatives and development of analytical methods to test commercial products for PF AS. 

Recognizing the need to continue to have a foam that fights aircraft fires effectively while also 

looking for options without PFOA, the Navy is working with the manufacturers to test various 

alternative products. The Navy has tested commercially available fluorine free foams to 

determine if they can meet MILSPEC. These tests are critical from a personnel safety 

perspective and validate a foam's performance capabilities. To date no commercially available 

fluorine free foam has demonstrated comparable performance on critical MILSPEC required 

performance tests. 

Exposure Assessment and Health Study: 

We are working with the Agency for Toxic Substances and Disease Registry (ATSDR) to 

support the effort to conduct an exposure assessment at not less than 8 military installations and a 

nation-wide health study, as required by the FY20 18 NDAA. We recently provided ATSDR 

$1OM to begin conducting the exposure assessment and health study and are preparing to send 

them an additional $10M in FY2018. Another $10M will be transferred in FY2019. ATSDR is 

establishing the criteria to select the military installations. 

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55 

Conclusion 

In summary, DoD is proactively taking action to reduce the risks ofPFOS and PFOA to 

human health. The Department is committed to mitigating PFOS and PFOA in the drinking 

water it supplies, as well as addressing releases to the environment under CERCLA that are the 

direct result of DoD's AFFF use. DoD has also invested in research to develop fluorine-free 

substitutes for AFFF that meet the military's stringent performance criteria, and develop 

technologies to quantify and clean up PFOS and PFOA and related PFAS chemicals. These 

combined efforts reinforce DoD's commitment to meeting critical mission requirements while 

protecting human health. 

As the Department addresses this national issue, we strive to work in collaboration with 

regulatory agencies and communities to ensure our resources are applied effectively to protect 

human health across the country as part of a national effort led by EPA. We must ensure our 

response and clean-up resources are effectively applied to result in a reduced risk and exposure 

of personnel on our installations and in the surrounding communities around the country. We are 

prioritizing our investments to those actions which will address the greatest degree of risk. 

Although this is a national problem involving a wide array of industries and commercial 

applications, DoD has taken the lead in protecting the health of persons on and near DoD 

installations by following the CERCLA process to fully investigate releases and determine the 

appropriate cleanup actions based on risk. 

6 
56 

DEPARTMENT OF HEALTH AND HUMAN SERVICES 

NATIONAL INSTITUTES OF HEALTH 

NATIONAL INSTITUTE OF ENVIRONMENTAL HEALTH SCIENCES 

Hearing on "The Federal Role in the Toxic PFAS Chemical Crisis" 

Testimony before the 

Senate Committee on Homeland Security and Governmental Affairs 

Subcommittee on Federal Spending Oversight and Emergency Management 

Linda S. Birnbaum, Ph.D., D.A.B.T., A.T.S. 

Director, National Institute of Environmental Health Sciences and National Toxicology Program 

National Institutes of Health 

September 26, 20 I 8 
57 

Chairman Paul, Ranking Member Peters, Distinguished Members of the Senate Committee on 

Homeland Security and Governmental Affairs, Subcommittee on Federal Spending Oversight 

and Emergency Management, thank you for inviting me to testify at this hearing on a topic of 

increasing interest to the scientific community and to the greater public. I am Linda Birnbaum, 

the Director of the National Institute of Environmental Health Sciences (N!EHS). I am also the 

Director of the National Toxicology Program (NTP), which serves to develop and coordinate 

toxicological testing across the Department of Health and Human Services, to conduct hazard 

assessments of hazardous substances, and to manage the Interagency Coordinating Committee on 

the Validation of Alternative Methods. For over 39 years I have conducted primary research in 

toxicology, and I am here today in my role as Director ofNIEHS to provide a scientific 

perspective about the large, complex, and ever-expanding class of chemicals known as per and 

polyfluoroalkyl substances (PF AS). 

The National Institute of Environmental Health Sciences (NIEHS) 

The NIEHS is one of several Federal agencies actively working to address various aspects 

related to PF AS. The NIEHS mission, as set forth under the Public Health Service Act, is to 

conduct and support research, training and health information dissemination with respect to 

environmental factors that may affect human health, directly or indirectly. 1 With this mandate, 

NIEHS researchers use state-of-the-art science and technology to investigate the interplay 

between environmental exposures, human biology, genetics, and human disease to help prevent 

illness, morbidity, and mortality, and improve human health. No age group or disease is beyond 

the NIEHS mission. Considering this fact, NIEHS researchers collaborate with their peers at the 

other NIH Institutes focused on specific life stages, organ systems, or diseases. 

NIEHS also has responsibilities under the Superfund Amendments and Reauthorization Act of 

1986 (SARA) which created the Superfund Research Program (SRP) within NIEHS. The SRP is 

a broad university-based research program capable of addressing the wide array of scientific 

uncertainties facing the national Superfund program.2 Within this purview is the development of 

methods and technologies to detect hazardous substances in the environment; advanced 

techniques for the detection, assessment, and evaluation of the effects on human health of 

hazardous substances; methods to assess the risks to human health presented by hazardous 

substances; and basic biological, chemical, and physical methods to reduce the amount and 

toxicity of hazardous substances. 

For nearly three decades, 3 NIEHS has been the leading Federal agency sponsoring basic research 

investigating health effects associated with human exposures to PFAS. It is important to note 

that l said health effects associated with exposure, l did not say caused. That fact should neither 

magnify nor diminish the science. It is simply a facet of environmental health. Our science is 

challenging because, although we can and do use animal models, in vitro tissue and cell culture 

1 Section 30 I and Title IV of the Public Health Service Act. 2 Section 209(b) of the Superfund Amendments and Reauthorization Act of 1986. Public Law 99-499. October 17, 

1986. (42 usc 9660). 

'Harris MW, Birnbaum LS. Developmental toxicity ofpcrtluorodecanoic acid in C57BL/6N mice. Fundam App/ 

Toxicol. 1989; 12(3):442-448. DOI: I 0.1 093/toxsci/12.3.442. 

2 
58 

systems, in silica approaches, and high throughput toxicological screening, we cannot ethically 

conduct prospective mechanistic studies in humans. 

The most conclusive human health research isolates a single variable to understand the cause and 

effect of that variable, whether it be a drug, a microorganism, or a mutated gene. With possibly 

toxic chemicals, we are largely limited to natural history and population-based studies that 

attempt to find connections between populations exposed and health effects in the real world. 

For that reason, you will hear me talk about "associations" certain health effects happened to 

more people than normal in populations that arc exposed. 

The research conducted to date reveals associations between human PF AS exposures and 

specific adverse human health outcomes. These include potential effects on children's cognitive 

and neurobehavioral development, immune system dysfunction, endocrine disruption, obesity, 

diabetes and lipid metabolism, and cancer. While knowledge about these epidemiologic 

associations has steadily expanded in recent years, many questions remain unanswered. The 

NIEHS and NTP, in coordination with other government agencies, continue to conduct research 

to enhance our understanding of the potential mechanisms and biological processes through 

which PFAS may be impacting human health. In addition, NIEHS has assumed a lead role in 

coordinating governmental research among agencies to assure applicability, disseminate 

findings, and prevent duplication of effort. To this end, NIEHS has co-hosted and participated in 

numerous symposia and working groups. 

Per and Polyfluoroalkyl Substances (PFAS) 

Before detailing the health effects associated with PFAS exposures, it is necessary to describe 

this class of chemicals. First created in the 1930s and 1940s, PFAS are among some 4,700 manmade chemicals that contain fluorine atoms bonded to a carbon chain.4 The carbon-fluorine 

bond is one of the strongest ever created by man and is rarely seen in nature. The unique 

chemical composition ofPFAS imparts desirable physical and chemical properties for consumer 

and industrial products, such as oil and water repellency, high and low temperature stability, and 

friction reduction. These properties have led to PF AS incorporation in a wide range of consumer 

products, including textiles, paper products, semiconductors, automotive and aerospace 

components, cookware, food packaging, and stain repellants. In addition, PF AS play an 

important role in industrial processes and have been used in aqueous film-forming foams 

(AFFF). 

Our scientific understanding of PF AS compounds stems almost entirely from studies on a select 

few. Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) have been 

manufactured the longest, are the most widespread in the environment, and are the most wellstudied. PFOA was used in the production of Teflon®, and PFOS in Scotchgard®. PFOA and 

PFOS are considered "long-chain" PFAS due to the length of their carbon chain backbones and 

have been studied for several decades. A wide range of"short-chain" PFAS have been 

introduced recently as alternatives to the linear, "long-chain" compounds. They have garnered 

increased attention by both the scientific community and the general public. Current efforts 

4 While approximately 4,700 tlourine-containing, man-made compounds have been created, not all of these 

compounds have entered into commerce or been actively used. 

3 
59 

within the NIEHS and NTP to greatly enhance our understanding of additional long-chain as 

well as short-chain PFAS are detailed later in this testimony. 

The chemical composition ofPFAS impart high stability for product design, but also makes 

PFAS extremely stable in the environment. In fact, PFAS and complex PFAS degradation 

products remain in the environment for so long that scientists are unable to estimate an 

environmental half-life. As PF AS are incorporated into more diverse processes and products, 

they have greater potential for release into the environment. Manufacturing and processing 

facilities, airports, and military installations that use firefighting foams are contributors ofPFAS 

releases into the air, soil, and water, including sources of drinking water.5 Because PF AS are 

resistant to typical environmental degradation processes, they are subject to long-range 

atmospheric and oceanic current transport. PF AS have been identified in some of the most 

remote areas on earth, and PF AS are ubiquitous in a variety of environments. 

As new knowledge is acquired about the breadth of exposures in many communities and the 

potential hazards to human health, questions arise about whether continued usc of PF AS in 

specific applications is necessary, or if alternatives exist that may still provide sufficient 

performance. As part of our portfolio, NIEHS and NTP contribute substantively to the field of 

alternatives assessment to ensure harmful chemicals arc not replaced by equally harmful but less 

well-studied related compounds. 

Human Exposures 

Humans are exposed to PF AS through a myriad of pathways, practices, and products. Ingestion, 

particularly through drinking water, is the predominant human exposure pathway for many 

individuals or communities,6 but recent studies suggest that other exposure pathways, including 

inhalation and dermal absorption, may have significance for human exposure.7

•

8•9.l 0 Some PFAS 

'Hu XC, Andrews DQ, Lindstrom AB, Bruton TA, Schaidcr LA, Grandjean P, Lohmann R, Carignan CC, Blum A, 

Balan SA, Higgins CP, Sunderland EM. Detection of Poly- and Pcrtluoroalkyl Substances (PFASs) in U.S. 

Drinking Water Linked to Industrial Sites, Military Fire Training Areas, and Wastewater Treatment Plants. Environ 

Sci Techno! Lett. 2016;3(10):344-350. DOI:IO. 1021/acs.estlctt.6b00260. 

"Agency for Toxic Substances and Disease Registry (ATSDR). Routes o fExposure and Health Effects. An 

Overview ofPerfluoroalkyl and Polytluoroalkyi Substances and Interim Guidance for Clinicians Responding to 

Patient Exposure Concerns. Interim Guidance. Revised on May 7, 2018. Atlanta, GA: U.S. Department of Health 

and Human Services, Public Health Service, Internet: 

https://www.atsdr.cdc.gov/pfas/docs/pfas clinician ract sheet 508.pJf. 7 D' eon JC, Mabury SA. Is indirect exposure a significant contributor to the burden of Perfluorinated acids 

observed in humans? Environ Sci Techno/. 2011 ;45(19):7974-84. DOl: I 0. l02I/es200171v. 8 Schaider, LA, Balan, SA, Blum, A, Andrews, DQ, Strynar, M, Dickinson, ME, Lunderberg, DM, Lang, JR, 

Peaslee, GF. Fluorinated Compounds in U.S. Fast Food Packaging. Environ Sci Tee/mol Lett. 2017;4(3):105-111. 

DOl: I 0. I 021 /acs.cstlett.6b00435. 9 Franko J, Meade BJ, Frasch HF, Barbero AM, Anderson SE. Dermal penetration potential ofpertluorooctanoic 

acid (PFOA) in human and mouse skin. J Toxicol Environ Health A. 2012;75(1 ):50-62. 

DOl: I 0. I 080115287394.20 II .615108. 10 Winkens K, Vestergren R, Berger U, Cousins IT. Early life exposure to per- and polyfluoroalkyl substances 

(PFASs): A critical review. Science Direct. June 20 17;(3)2:55-68. DO!: I 0.1 () I6/j.cmcon.20 17.05.001. 

4 
60 

bioaccumulate, leading to concentrations in animals that are significantly higher than the 

surrounding environment, and they can enter the human food chain. 11 

Evidence suggests that human exposures to PFAS are extremely widespread. The Centers for 

Disease Control and Prevention's (CDC) National Center for Health Statistics' 2011-2012 U.S. 

National Health and Nutrition Examination Survey (NHANES) reported detectable PFAS blood 

serum concentrations in virtually all individuals (97 percent). 12 The most recent NHANES data 

indicate a reduction in serum concentrations ofPFOS and PFOA since their removal from 

consumer products in the early 2000s, but replacement PF AS appear to be rising quickly and 

exposure is more difficult to assess accurately due to a lack of analytical standards. 

Health Effects Research 

Our understanding of the health effects associated with PFAS and our ability to draw conclusions 

regarding the contribution of any specific PF AS to human disease is based on combined data 

from multiple studies investigating epidemiologic associations in human cohort studies, 

biological plausibility and pathways in animal studies, mechanistic effects seen in human tissues 

and cell culture systems, and rapid high-throughput screening. It is important to note that 

epidemiologic association studies cannot definitively find causation, and while animal studies are 

an important marker of scientific discovery, they are not perfect predictors of human effect. 

However, by combining and carefully considering data from independent studies, we can begin 

to build an understanding of how PFAS chemicals impact human health. 

When looking for possible human health effects of chemical compounds distributed in nature, it 

is also important to recognize that environmental impact is very hard to study and there are 

thousands of individual PF AS chemicals. While we have studies that indicate adverse health 

effects due to PFOA and PFOS exposure, we do not have strong data on which to base 

conclusions for the great majority of thousands ofPFAS and we have only limited findings that 

support the following adverse health effects. Our current scientific method involves using our 

understanding of the biological and chemical processes being influenced by the few well-studied 

chemicals to extrapolate potential conclusions about structurally similar compounds which we 

can reasonably expect to act through the same pathways and have similar effects. More research 

is needed to form definitive links between exposure to PFAS chemicals and adverse health 

effects in humans. 

11 Scher, DP, Kell JE, Huset CA, Barry KM, Hoftbeck RW, Yingling VL, Messing RB. Occurrence of 

perfluoroalkyl substances (PFAS) in garden produce at homes with a history ofPFAS-contaminated drinking water. 

Chemosphere. 2018;196:548-555. DOI:IO.IOJ(j/j.cbcmospbcrc.2017.J.2"179. 12 Hu XC, Andrews DQ, Lindstrom AB, Bruton TA, Schaider LA, Grandjean P, Lohmann R, Carignan CC, Blum A, 

Balan SA, Higgins CP, Sunderland EM. Detection of Poly- and Perfluoroalkyl Substances (PFASs) in U.S. 

Drinking Water Linked to Industrial Sites, Military Fire Training Areas, and Wastewater Treatment Plants. Environ 

Sci Techno/ Lett. 2016;3(1 0):344-350. DOl: I 0. I 021iacs.cstlett.6b00260. 

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Decreased Immune System Function 

As early as 1978, scientists observed immunotoxicity in non-human primates exposed to PFAS. 13 

In 2016, NTP concluded that PFOA and PFOS are presumed to be a hazard to healthy immune 

system function in humans, based on a systematic literature review. 14 This conclusion is based 

on a high level of evidence that PFOA and PFOS suppressed the antibody response in animal 

studies, and a moderate level of evidence that these chemicals affect multiple aspects of the 

immune system in humans. Adult PF AS exposure has also been associated with decreases in 

antibody production. 15 

NTP is in its earliest stages of conducting another systematic review on PF AS immunotoxicity; 

this one will focus on six related chemicals: PFDA, PFNA, PFHxA, PFBA, PFBS and PFHxS. 

Cancer 

The epidemiological data on associations between PFAS and cancer risk are limited. Those 

published studies were recently summarized by the Agency for Toxic Substances and Disease 

Registry (ATSDR) in their Draft Toxicological Profile for Perfluoroalkyls. 16 According to the 

Toxicological Profile, "Occupational and community exposure studies have found increases in 

the risk of testicular and kidney cancer associated with PFOA. No consistent epidemiologic 

evidence for other cancer types were found for PFOA. 17·

18 For PFOS, one occupational exposure 

study reported an increase in bladder cancer, 19 but this was not supported by subsequent 

occupational studies. General population studies have not consistently reported increases in 

malignant tumors for PFOS. Epidemiologic studies examining other perfluoroalkyl compounds 

consisted of two case-control studies. No increases in breast cancer risk were observed for 

PFHxS or PFNA; an increased breast cancer risk was observed for PFOSA.20 Another casecontrol study did not find increases in prostate cancer for PFOA, PFOS, PFHxS, PFNA, PFDeA, 

or PFUA.21 However, among men with a first-degree relative with prostate cancer, associations 

13 Goldenthal El, Jessup DC, Geil RG, Mehring .IS. Final report, ninety day subacute rhesus monkey toxicity study, 

International Research and Development Corporation, study no. 137-090, November I 0. 1978, U.S. EPA 

Administrative Record, AR226-0447. 1978. 14 Sept. 2016. Monograph on Immunotoxicity Associated with Exposures to PFOA and PFOS. Research Triangle 

Park! NC: National Toxicology Program. Internet: https://nip.niehs.nih.e.o\,/puhhealth!hat/noms/pfoa/indcx.htm!. 15 Kielsen K, Shamim Z, Ryder LP, Nielsen F, Grandjean P, Budtz-Jorgensen E, Heilmann C. J lmmunotoxico/. 

2016;13(2):270-3. DOI:10.3109!1547691 X.2015. 16 Agency for Toxic Substances and Disease Registry (ATSDR). 2018. Toxicological profile for Perfluoroalkyls. 

(Draft for Public Comment). Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service. 

Internet: htlps://www.atsdr.cdc.gov/toxprotiles/tp.asp'?id"-1117&tid=,237. 17 Barry V, Winquist A, Steenland K. Perfluorooctanoic acid (PFOA) exposures and incident cancers among adults 

living near a chemical plant. Environ Health Perspect. 2013;121(11-12):1313-!318. DOl:10.12~9/ehp.l306615. 

18 Steen land K, Woskie S. Cohort m01tality study of workers exposed to perlluorooctanoic acid. Am J Epidemio/. 

2012; 176(1 0):909-917. DOI:l 0.1 093/ajc/kws 171. 19 Alexander BH, Olsen GW. Burris JM, Mandel JH, Mandel JS. Mortality of employees of a 

perfluorooctanesulphonyl fluoride manufacturing facility. Occup Environ Med. 2003;60:722-729. 

DOI:l0.ll36/oem.60.10.722. 

20 Bonefeld-Jorgensen EC, Long M, Fredslund SO, Bossi R, Olsen J. Breast cancer risk atier exposure to 

perfluorinated compounds in Danish women: A case-control study nested in the Danish National 

Birth Cohort. Cancer Causes Control. 2014;25(11 ): 1439-1448. DO!: I 0.1007/s I 0552-014-0446-7. 21 Hardell E, Karrman A, van Bavel B, Flao J, Carlberg M. Hardell L. Case-control study on pcrfluorinated alkyl 

acids (PF A As) and the risk of prostate cancer. Environ Int. 20 14;63:35-39. DOl: I 0. I 0 16i].envint.2013.1 0.005. 

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were found tor PFOA, PFOS, PFHxS, PFDeA, and PFUA, but not for PFNA."22 Animal studies 

are consistent with the human epidemiologic studies of cancer endpoints. 

Child Development 

PFOA and PFOS cause developmental toxicity in animals.23•

24•25 Human epidemiology studies 

also show associations between some PFAS and developmental effects. 26 One human study 

found that PF AS exposure during pregnancy was associated with decreased birth weight and 

head circumference only in males.27 Similar decreases in birth weight have been reported in 

rodents for over a decade.28 Recent findings from NIH-supported epidemiological studies of a 

cohort of mothers and babies showed that prenatal exposure to PFOS is associated with cognitive 

effects and decreased ability to regulate behavior in school-age children. However, no similar 

association was observed in this study for PFOA exposure.29 

A review of the epidemiological literature by an NIEHS-fundcd scientist summarized findings 

from several prospective cohorts on the relationship between prenatal exposure to certain PF AS 

and neurodevelopmental and neurobehavioral outcomes- for example, cognitive abilities, 

psychomotor development, attention-deficit hyperactivity disorder, and cerebral palsy. So far, 

the available body of evidence is inconsistent with respect to these associations, both with 

respect to which compounds may have adverse effects and timing of potential windows of 

vulnerability. Additional studies are needed to resolve these questions.30 

Endocrine Disruption 

Studies suggest that some PF AS may interfere with healthy hormonal function in the body. Our 

endocrine system controls our basic physiology, including metabolism, growth, fertility, and 

22 Ibid. 23 White SS, Calafat AM, Kuklenyik Z, Thibodeaux J, Wood C, Fenton, SE. Gestational PFOA exposure of mice 

is associated with altered mammary gland development in dams and female offspring. Toxico/. Sci. 2007;96(1):133· 

144. D0l:IO.I093/toxsci/kl1177. 24 Butenhoff JL. Ehresman OJ, Chang SC, Parker GA, Stump DG. Gestational and lactational exposure to 

potassium pertluorooctanesulfonate (K +PFOS) in rats: developmental neurotoxicity. Reprod Toxicol. 2009 

Jun;27(3-4):319-30. DOl: I 0.10 12fi,reprotox.2008.12.0 I (1. 25 Chen T, Zhang L, Yue JQ, Lv ZQ, Xia W, Wan YJ, Li YY, Xu SQ. Prenatal PFOS exposure induces oxidative 

stress and apoptosis in the lung ofrat otT-spring. Reprod Toxico/. 2012 .Tul;33(4):538-45. 

DOl :_LQJ.O 16/j .reprotox.£QJ.L03 .003. 26 White SS, Fenton SE, Hines EP. Endocrine disrupting properties ofpertluorooctanoic acid. J Steroid Biochem 

Mol Bioi. 2011 Oct;l27(l-2):16-26. DOI:I0.1016/i.jsbmh.2011.03.011. 27 Valvi D, Oulhote Y, Weihe P, Dalgard C, Bjerve KS, Steuerwald U, Grandjean P. Gestational diabetes and 

offspring birth size at elevated environmental pollutant exposures. Environ Int. 2017 Oct; I 07:205·215. 

DOI:lQ,lQJ.(>/j.cnvint.20 17.07.0 16. 28 Hines, EP, White, SS, Stanko, JP, Gibbs-Flournoy, JE, Lau C, Fenton, SE. Phenotypic dichotomy following 

developmental exposure to pertluorooctanoic acid (PFOA) in female CD-I mice: low doses induce elevated serum 

Ieptin and insulin, and overweight in mid-life. lvfol. Cell Endocrinol. 2009May 25;304(1 -2):97· I 05. 

DOI:https://doi.org/1 0.1 0 161i.mcc.2009.0?.021. 29 Vuong AM, Yolton K, Webster GM, SjOdin A, Calafat AM, Braun JM, Dietrich KN, Lanphear BP, Chen A. 

Prenatal polybrominated diphenyl ether and pertluoroalkyl substance exposures and executive function in school· 

age children. Environ Res. 2016 May; 147:556-564. DOl: 10.1016/j.envres.2016.01.008. 30 Braun J. Early-life exposure to EDCs: role in childhood obesity and neurodevelopment. Nat Rev Endocrinol. 

2017 Mar; 13(3):161-173. DOI:IO.I038/nrcndo.2016.186. 

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development. Studies suggest that early-life exposure to some PF AS may contribute to the 

development of metabolic diseases, including obesity and type 2 diabetes, which are major 

public health problems. Although further confirmation is required, the findings from one study 

suggest that exposures to some PF AS during pregnancy may influence lipid metabolism and 

glucose tolerance. 31 A study of pregnant women in Cincinnati found that those with higher 

prenatal PFAS levels had children with higher body fat levels at age eighe2

-a finding 

reinforced by other epidemiological studies33,34 and similar effects on excessive body weight 

gain reported for experimental animals.35 It appears that some PFAS may also affect body 

weight later in life. Scientists at the Harvard School of Public Health have found that adults with 

higher blood levels of some PFAS have lower resting metabolic rates, meaning they burn fewer 

calories while resting, which makes it difficult for them to maintain weight loss.36 Effects on 

weight gain have been seen in numerous animal studies, 37•

38•39 supporting this association in 

humans. It is particularly concerning that some PF AS alter thyroid hormone homeostasis that 

regulates metabolism and growth.40.41

.42 

31 Matilla-Santander N, Valvi D, Lopez-Espinosa MJ, Manzano-Salgado CB, Ballester F, lbarluzca J, Santa-Marina 

L, Schettgen T, Guxens M, Sunyer J, Vrijhcid M. Exposure to Perfluoroalkyl Substances and Metabolic Outcomes 

in Pregnant Women: Evidence from the Spanish INMA Birth Cohorts. Environ Health Perspect. 2017 Nov 

!3;125(11):117004. D01:10.1289/EHP1062. 32 Braun JM, Chen A, Romano ME, Calafat AM, Webster GM, Yolton K, Lanphear BP. Prenatal perfluoroalkyl 

substance exposure and child adiposity at 8 years of age: The HOME study. Obesity (Silver Spring), 2016 

Jan;24(1):231-7. DOI:lO. 1002/oby.2125R. 33 Mora AM, Oken E, Rifas-Shiman SL, Webster TF, Gillman MW, Calafat AM, Ye X, Sagiv SK. Prenatal 

Exposure to Perfluoroalkyl Substances and Adiposity in Early and Mid-Childhood. Environ Health Perspect. 2017 

Mar;125(3):467-473. DOl: 10.1289/EIIP246. 34 Karlsen M, Grandjean P, Weihe P, Steuerwald U, Oulhote Y, Valvi D. Early-life exposures to persistent organic 

pollutants in relation to overweight in preschool children. Reprod Toxicol. 2017 Mar;68: 145-153. 

DOl: I 0.10 16/j.reprotox.20 16.08.002. 35 Hines EP, White SS, Stanko JP, Gibbs-Flournoy EA, Lau C, Fenton SE. Phenotypic dichotomy following 

developmental exposure to perlluorooctanoic acid (PFOA) in female CD-I mice: Low doses induce elevated serum 

leptin and insulin, and overweight in mid-life. Mol Cell Endocrinol. 2009 May 25:304(1-2):97-105. 

DOl: I 0.1 016/i.mcc.2009.02.021. 36 Liu G, Dhana K, Furtado JD, et al. Pcrfluoroalkyl substances and changes in body weight and resting metabolic 

rate in response to weight-loss diets: A prospective study. Basu S, cd. PLoS Medicine. 2018;15(2):el002502. 

DOl: I 0.1371 /journal.pmed.l 002502. 37 Griln F, Blumberg B. Endocrine disrupters as obesogens. Mol Cell Endocrinol. 2009 May 25:304(1-2):19-29. 

DOl: I 0.10 16/j.mcc.2009.02.0 18. 38 Shi Z, Zhang H, Ding L, Feng Y, Xu M, Dai J. The effect ofperfluorododccanonic acid on endocrine status, sex 

hormones and expression of steroidogenic genes in pubertal female rats. Reprod Toxic of. 2009 .lun;27(3-4):352-9. 

DOl: I 0.1 016/j.reprolox.2009.02.008. 39 Holtcamp W. Obesogens: an environmental link to obesity. Environ Health Perspect. 20l2;120:a62-8. 

DOl: I O.l289ichp.120-a62. 40 Byrne SC, Miller P, Seguinot-Medina S, Waghiyi V, Buck CL, von Hippe! FA, Carpenter DO. Exposure to 

perfluoroalkyl substances and associations with serum thyroid hormones in a remote population of Alaska Natives. 

Environ Res. 2018 Oct;166:537-543. DOl: 10.1016/j.cnvrcs.2018.06.014. 41 Kim MJ, MoonS, Oh BC. lung D, Ji K. Choi K, Park YJ. Association between perfluoroalkyl substances 

exposure and thyroid function in adults: A meta-analysis. ?LoS One. 2018 May I 0; 13(5):e0197244. 

DOl: I 0.1371/journal.ponc.Ol97244. 40 Preston EV, Webster TF, Oken E, Claus Henn B, McClean MD, Rifas-Shiman SL, Pearce EN, Braverman LE, 

Calafat AM, Ye X, Sagiv SK. Environ Health Perspect. 2018 Feb 27;126(2):027013. DOl: 10.12891J:J IP2534. 

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Fertility is another outcome related to endocrine effects. A literature review of recent human 

epidemiologic evidence on the association between exposure to some PFAS and measures of 

human fertility show the potential for effects on female fecundability (i.e., the probability of 

conception)Y In addition, several recent studies have shown an association between women 

with higher PF AS exposure and the length of time they are able to nurse their child after birth, 

although not at all levels of exposure.44•

45 This is similar to 2006 findings in animals reporting 

impaired breast development and breastfeeding during and after pregnancy in mice.46 

NIEHS Superfund Research Program (SRP) 

Last year, NIEHS competitively awarded a five-year grant to the University of Rhode Island to 

fund its "Sources, Transport, Exposure and Effects ofPFASs (STEEP) Superfund Research 

Program Center" (Fiscal Years 20 17-2022).47 The Center is assessing the impact of PFAS 

exposures on immune dysfunction and metabolic abnormalities by examining the health of nine 

year-old children from birth cohorts in the Faroe Islands (Denmark). The Center is also tracing 

unique PFAS chemical signature fingerprints at a contaminated groundwater site on Cape Cod, 

leading to exposure through drinking water, as a function ofPFAS chemistry, geochemistry and 

distance from the source. Additionally, the Center is developing and validating novel passive 

sampling tools for PF AS to measure time weighted average concentrations for some PF AS and 

their volatile precursors. These tools can be deployed to aid site managers in their risk 

characterization. Finally, the Center is engaging communities and advising stakeholders on ways 

to effectively reduce human exposure to PF AS. Other NIEHS Superfund Research Program 

Centers are providing technical assistance about PF AS to state and local governments, water 

authorities, and private well users. The University of Michigan and Brown University Superfund 

Research Centers have sponsored or participated at workshops and webinars on the subject 

attended by Federal and state officials-including many facilitated by the Northeast Waste 

Management Officials' Association. The Northeastern University Superfund Center held a 

workshop on PFAS which was widely attended by community organizations as well as state and 

local officials and academics. 

Through Small Business Innovation Research (SBIR) grants, the Superfund Research Program 

provides support to scientists and engineers developing novel technologies for mitigation and 

remediation ofPFAS in the environment. SBIR grantee CycloPure, Inc., is developing novel, 

high-affinity cyclodextrin polymers for the cost-effective remediation of hazardous PF AS from 

43 Bach CC, Vested A, Jorgensen K, Bonde JP, Henriksen TB, Toft G. Pertluoroalkyl and polytluoroalkyl 

substances and measures of human fertility: a systematic review. Crit Rev Toxicol. 2016 Oct:46(9):735-55. 

DOl: I 0.1080/10408444.2016.1182117. 44 Timmermann CA, Budtz-Jargcnsen E, Petersen MS, Weihe P, Steuerwald U, Nielsen F, Jensen TK, Grandjean P. 

Shorter duration ofbreastfeeding at elevated exposures to perfluoroalkyl substances. Reprod Toxicol. 2017 

Mar;68: 164-170. DO!: l 0.10 l6ii.reprotox.20 I 6.07.0 I 0. 

"Romano ME, Xu Y, Calafat AM, Yolton K, Chen A, WebsterGM, Eliot MN, Howard CR, LanphearBP, Braun 

JM. Maternal serum pertluoroalkyl substances during pregnancy and duration of breastleeding. Environ Res. 2016 

Aug; 149:239-246. DOl: I 0.1 Ol6/Lenvrcs.20 16.04.034. 46 White SS, Calafat AM, Kuklenyik Z, Villanueva L, Zehr RD, Helfant L, Strynar MJ, Lindstrom AB, Thibodeaux 

JR, Wood C, Fenton SE. Gestational PFOA exposure of mice is associated with altered mammary gland 

development in dams and female offspring. Toxic of Sci. 2007 Mar:96(1 ):133-44. DOl: I 0.1 093/toxsci/ktl177. 47 NIH Grant No. P42ES027706. Sources, Transport, Exposure and Effects ofPFASs (STEEP). McCann, Alyson. 

University of Rhode Island. Awarded August30, 2017. i'iiH RePORTER Link. 

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65 

water.48 In another SBIR project, EnChem Engineering, Inc. is developing and demonstrating an 

innovative combined in-situ I ex-situ technology to cost-effectively expedite treatment of PFAS 

at Superfund sites. The EnChem approach combines: (1) a non-toxic cyclic sugar (CS) to flush 

sorbed PF AS from the in-situ soil; (2) extraction of the CS-PFAS complex with groundwater and 

treatment in a high efficiency ex-situ reactor that simultaneously degrades, removes, and 

concentrates (I 00-l 000 times) the PFAS; (3) ultimate on-site destruction by alkaline ozonation 

(99+ percent removal); and (4) returns the treated water with low concentration CS amendment 

to injection wells for continued flushing. The ex-situ treatment reactor can also be used as 

pre-treatment to existing granular activated carbon.49 Additionally, the Michigan State 

University Superfund Research Center is developing energy etlicient nanoreactors capable of 

breaking the carbon-fluorine bond. 5° Also of note, the University of California, Berkeley 

Superfund Research Center is combining biological and chemical treatment options to degrade 

and destroy AFFF. 51 

Recent Time-Sensitive Research Awards 

In addition to its regular funding programs, NIEHS has used a mechanism to fund time-sensitive 

research opportunities related to PF AS. Researchers at the Colorado School of Public Health, 

the University of Colorado Anschutz Medical Campus, and the Colorado School of Mines are 

studying PFAS exposures in residents near Colorado Springs whose wells and public water 

systems were contaminated with a wide range ofPFAS, including high levels ofperf1uorohexane 

sulfonate (PFHxS).52.53 This time-sensitive study started near the peak of exposure after 

contamination was discovered and will explore ways to measure how exposure levels to PFAS in 

the residents change over time. 

In 2016, elevated levels of GenX, a short-chain PF AS containing an ether link generated in the 

production of non-stick coatings, were detected in North Carolina's Cape Fear River. The Cape 

Fear River provides drinking water for approximately 300,000 people and a production facility 

had been releasing GenX upstream. NIEHS funded a study at North Carolina State University to 

address community questions about GcnX exposure and health effects, including GenX's 

48 NIH Grant No. R43ES029401. Remediation ofPerfluorinated Chemicals in Water Using Novel High-Affinity 

Polymer Adsorbents. Barin, Gokhan. CycloPure. Inc. Awarded March 22,2018. NIH RePORTER Link. 49 NfH Grant No. R43ES028649. Bench Scale Studies ofNovel In-situ Aquifer Remediation of Recalcitrant 

Fluorinated Organic Compounds at Superfund Sites. Ball, Raymond. EnChem Engineering, Inc. Awarded 

August 28, 2017. 'i1H RePORTER Link. 50 Tian H, Gao J, Li ll. Boyd SA, Gu C. Complete Detluorination ofPcrfluorinated Compounds by Hydrated 

Electrons Generated from 3-Indole-acetic-acid in Organomodified Montmorillonite. Sci Rep. 2016;6:32949. 

DO!: 10.1 0381srcp32949. 51 Yi S, Harding-Marjanovic KC, Houtz EF, Gao Y, Lawrence JE, Nichiporuk RV, Iavarone AT, Zhuang W, Hansen 

M, Field JA, Sedlak DL, Alvarez-Cohen L. Biotransformation of AFFF Component 6:2 Fluorotelomer Thioether 

Amido Sulfonate Generates 6:2 Fluorotelomer Thiocther Carboxylate under Sulfate-Reducing Conditions. Environ 

Sci Techno/ Lett. 2018:5(5);283-288. DOl: I 0.1 021/acs.cstlctt.RhOO 148. 52 NIH Grant No. R21ES029394. Exposure and Health Effects from Poly- and Perfiuoroalkyl Substances in 

Colorado Water. Adgate, John L. University of Colorado Denver. Awarded December 13,2017. 

'iiH RePORTER Link. 

"Exposure study to assess people and water near Colorado Springs; Toxic chemicals have contaminated water 

supplies for 65,000. CU Anschutz Today. December 21, 2017. 

Internet: https://www .cuanschutztoday .org/exrosurc~studv ~asscss-pcop 1 e-\Yater-ncar-co lorado-springs. 

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66 

potential toxicity, how it is stored in the body, and how long it remains in the environment. 54•

55 

Initial results from nearly 200 homes show detectable levels of GenX in treated tap water from 

the Cape Fear River but none above 140 parts per trillion, the current North Carolina public 

health goal for GenX in drinking water. Many other PFAS were also measured in treated Cape 

Fear River tap water. GenX was not detected in the tap water of homes whose groundwater was 

treated with granular activated carbon filtration. Additional analysis, including testing of blood 

and urine samples from study participants, is ongoing. NTP is also studying how GcnX moves 

through the body and whether it is toxic to the placenta, immune system, liver, and other tissues. 

NTP REACT Program 

The NTP Responsive Evaluation and Assessment of Chemical Toxicity, or REACT, Program is 

studying subclasses of PF AS, due to potential similarities in chemical properties and toxicity 

within subclasses. Scientists will be able to compare one PFAS to another, determine the 

relationship between chain length, branching, and toxicity, and work toward understanding a 

common basis for toxicity. 

REACT uses a combination of methods. First, the project analyzes the chemical structure of 

PF AS compounds to sec what information is available in databases for that compound or others 

with similar structure. Chemical structure plays a major role in how chemicals interact and 

chemicals with similar structure often have similar toxicity. This computer-based step is known 

as in silico screening. Based on in silico results, chemicals are prioritized for further laboratory 

testing with cells, known as in vitro testing. Examples include testing whether PF AS cause cells 

to die or substantially alter the function of human liver, placenta, or mammary gland derived 

cells. Some of these tests are conducted through the automated Toxicology in the 21st Century 

(Tox21) Program, a Federal collaboration among the NIH, the U.S. Environmental Protection 

Agency (EPA), and the U.S. Food and Drug Administration (FDA).56 The in vitro data arc then 

examined to prioritize select chemicals for toxicity testing in animals, known as in vivo studies, 

so the data can be considered all together. REACT is a collaborative program with EPA. The 

Program plans to test over I 00 individual PF AS across the PF AS class. Both NTP and EPA are 

generating chemical libraries to consolidate and share what is known about individual chemicals. 

Current Challenges 

Real-world human exposures to PF AS involve complex mixtures. not individual chemicals. This 

fact complicates both the science of exposure and the assessment of health risks.57 Currently, 

analytical techniques are limited for determining which specific PFAS are contained in a given 

54 NIH Grant No. R21ES029353. Assessing Impact of Drinking Water Exposure to GenX (Hexafluoropropylcne 

Oxide Dimer Acid) in the Cape Fear River Basin, North Carolina. l!oppin, Jane. North Carolina State University, 

Raleigh. Awarded on October 31, 2017. NIH RePORTER Link. 55 Researchers receive grant to study GenX exposure in New Hanover County residents. NC State News. 

November 1, 2017. Internet: hllps:i/ncws.ncsu.cdu/20 17/lligcnx-studvi. 56 Toxicology Testing in the 21st Century (Tox21 ). U.S. Environmental Protection Agency. 

Internet: https://www.epa.gov/chem ical-research/toxicology-testing-21 st-century-tox21. 57 Kotthoff, M, BUcking M. 2018. Four Chemical Trends Will Shape the Next Decade's Directions in 

Perfluoroalkyl and Polyfluoroalkyl Substances Research. Fi·ont Cilem. 2018 Apr 5;6: I 03. 

DOl: I 0.3389/khcm.20 18.00 I 03. 

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67 

complex mixture. Further, toxicological information on these combined PFAS mixtures remains 

incomplete. Additional research is needed to assess environmental exposures to mixtures and 

determine their combined effects. 

Apart from the challenge of characterizing PF AS in environmental samples is the challenge of 

studying PFAS in the human body. Our present understanding is that the time required for 

elimination ofPFAS from the human body can vary. While some longer chain molecules may 

remain in the blood for years, shorter chain PFAS may be more quickly eliminated. Differences 

in elimination rates of longer and shorter chain PF AS complicates biomonitoring as well as 

toxicological studies. However, lack of biological persistence does NOT mean lack of toxicity, 

particularly for chemicals like PFAS that may have consistent daily exposures. 

Traditional methods for measuring the body burden of PF AS-namely analyzing serum-are not 

as effective for shorter chain PF AS as for longer chain PF AS. Scientists are beginning to 

measure PFAS in urine, 5

8 in plasma, and in whole blood, as well as in serum. 5

9 These expanded 

biomonitoring techniques for sampling and analyses will further inform our understanding of 

exposures and risks. Using these techniques, many scientists are rightly focusing on measuring 

the total exposure to all PF AS as opposed to the past focus on one substance in isolation. This is 

important as it allows for understanding cumulative effects of PF AS mixtures as a class. 

Examining the person in the context of the measure of all the exposures they have experienced in 

their lifetime and how they relate to their health is in step with the latest science. 

Approaching PF AS as a class for assessing exposure and biological impact is the best way to 

protect public health. Based upon their persistent nature, widespread exposure, and known 

toxicity, it begs the question: does the value of PF AS production and use for modern-day 

convenience outweigh the potential costs and risks to public and environmental health? Thus, 

science is moving in the direction of safer alternatives. 

Manufacturers have begun recently to produce and market AFFF devoid of any PFAS. Such 

fluorine-free AFFF is now being used at Heathrow Airport in London, United Kingdom and at 

major airports in Sweden. It will be important to evaluate these alternatives for potential health 

effects as well. 

Federal Collaboration 

NIEHS and the NTP will continue to provide scientific leadership with respect to PFAS research. 

Communication and collaboration both within the Department of Health and Human Services, 

and across the Federal Government, about PFAS is intensifYing. In February 2018, a Federal 

information exchange meeting about PF AS was held on the NIH campus in Bethesda, 

Maryland.60 NIEHS was among other Federal agencies that participated at the PFAS National 

58 Hartmann C, Raffcsberg W, Scharf'S, Uhl M. Perfluoroalkylated substances in human urine: results of a 

biomonitoring pilot study. Biomonitoring 2017; 4:1-10. DOl: 10.1515/bimo-2017-0001. 59 Poothong S, Thomsen C, Padilla-Sanchez JA, Papadopoulou E, Haug LS. Distribution of Novel and Well-Known 

Poly- and Perlluoroalkyl Substances (PFASs) in Human Serum, Plasma, and Whole Blood. Environ Sci Techno!/ 

2017 Nov 21 ;51(22):13388-13396. DO!: 10.1 021/acs.cst.7b03299. 6

° Federal agencies exchange PF AS updates. NIEHS Environmental Factor. March 2018. 

Internet: https:/ /factor.nichs.n ih.gov/20 1 8/3/scicnce~high!ights/p fas/indcx.htm. 

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68 

Leadership Summit hosted by EPA in May 2018.61 Within the Department of Health and Human 

Services and primarily through NTP, NIEHS works closely with the FDA and the Centers for 

Disease Control and Prevention (CDC) on PF AS matters. Additionally, NIEHS is specifically 

being consulted by A TSDR on the execution of the exposure assessments and health studies 

authorized by the National Defense Authorization Act for Fiscal Year 2018, as amended.62 

Conclusion 

Thank you again for allowing me to share a scientific perspective on this important topic. In 

closing, I note that NIEHS is well-positioned to continue contributing essential scientific 

knowledge about this complex and large class of chemicals. This knowledge can help regulators 

make sound, science-based decisions and informs the medical and public health communities 

about the potential health effects associated with exposure to PF AS. I welcome your questions. 

61 EPA PFAS National Leadership Summit and Engagement. May 22-23,2018. 

Internet: https://w\\ \\ .cpa.go v /p fhs/p f'as-national-!cadcrsh ip-sum mit-and -ene.agcm cnt. 62 Sec. 316 of the National Defense Authorization Act for Fiscal Year 2018. Public Law 115-9!. December 12. 

2017. 

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For Release on Delivery 

Expected at 2:30p.m. ET 

Wednesday, September 26. 2018 

GA0-18-700T 

United States Government Accountability Office 

Testimony before the Subcommittee on Federal 

Spending Oversight and Emergency 

Management, Committee on Homeland Security 

and Governmental Affairs, U.S. Senate 

DRINKING WATER 

Status of DOD Efforts to 

Address Drinking Water 

Contaminants Used in 

Firefighting Foam 

Statement of Brian J. Lepore, Director, Defense 

Capabilities and Management 

J. Alfredo Gomez, Director, Natural Resources and 

Environment 
70 

DRINKING WATER 

Status of DOD Efforts to Address Drinking Water 

Contaminants Used in Firefighting Foam 

What GAO Found 

GAO reported in October2017 that the Department of Defense (DOD) had 

initiated actions to address elevated levels of perfluorooctane sulfonate (PFOS) 

and perfluorooctanoic acid (PFOA) in drinking water at or near military 

installations. PFOS and PFOA are part of a larger class of chemicals called perand polyfluoroalkyl substances (PFAS), which can be found in firefighting foam 

used by DOD. In May 2016, the Environmental Protection Agency (EPA) issued 

nonenforceable drinking water health advisories for those two chemicals. Health 

advisories include recommended levels of contaminants that can be present in 

drinking water at which adverse health effects are not anticipated to occur over 

specific exposure durations. 

In response to those health advisories, DOD's military departments directed their 

military installations to (1) identify locations with a known or suspected release of 

PFOS and PFOA and address any releases that pose a risk to human health, 

which can include people living outside DOD installations, and (2) test for PFO S 

and PFOA in installation drinking water and address any contamination above 

the levels in EPA's health advisories. For example: 

• As of August 2017, DOD had identified 401 active or closed military 

installations with known or suspected releases of PFOS or PFOA. 

• The military departments had reported spending approximately $200 

million at or near 263 installations for environmental investigations and 

responses related to PFOS and PFOA, as of December 2016. According 

to DOD, it may take several years for the department to determine how 

much it will cost to clean up PFOS and PFOA contamination at or near 

its military installations. 

DOD reported taking actions (such as providing alternative drinking 

water and installing treatment systems) as of August 2017 to address 

PFOS and PFOA levels exceeding those recommended in EPA's health 

advisories for drinking water for people (1) on 13 military installations in 

the United States and (2) outside 22 military installations in the United 

States. 

In addition to actions initiated by DOD, GAO reported in October2017 that the 

department also had received and responded to four orders from EPA and state 

regulators that required DOD to address PFOS and PFOA levels that exceeded 

EPA's health advisory levels for drinking water at or near four installations. 

GAO also reported in October 2017 that DOD was taking steps to address health 

and environmental concerns with its use of firefighting foam that contains PF AS. 

These steps included restricting the use of existing foams that contain PFAS; 

testing foams to identify the amount of PFAS they contain; and funding research 

on developing PFAS-free foam that can meet DOD's performance requirements, 

which specify how long it should take for foam to extinguish a fire and keep it 

from reigniting. In a June 2018 report to Congress, DOD stated that no 

commercially available PFAS-free foam has met DOD's performance 

requirements and that research to develop such a PFAS-free foam is ongoing. 

-------------United States Government Accountability Office 
71 

Chairman Paul, Ranking Member Peters, and Members of the Subcommittee: 

Thank you for the opportunity to be here today to discuss our report on the Department of 

Defense's (DOD) attention to drinking water contaminants, part of our body of work on the 

federal government's environmentalliabilities.1 The federal government is financially liable for 

cleaning up areas where federal activities have contaminated the environment. Today's hearing 

addresses federal liability for and procurement of per- and polyfluoroalkyl substances (PFAS), a 

large group of man-made chemicals that include perfluorooctane sulfonate (PFOS) and 

perfluorooctanoic acid (PFOA).2 PFOS, PFOA, and other PFAS can be found in firefighting foam 

used by DOD since the 1970s for training and emergency response activities to put fires out 

quickly while also ensuring that they do not reignite.3 

Exposure to elevated levels of PFOS and PFOA could cause increased cancer risk and other 

health issues in humans, according to the Agency for Toxic Substances and Disease Registry. 

The Environmental Protection Agency (EPA) has found PFOS and PFOA in drinking water 

across the United States, including in drinking water at or near DOD installations. EPA has not 

regulated PFOS and PFOA in drinking water, but EPA did issue nonenforceable drinking water 

health advisories for these contaminants in May 2016, which we discuss further in this 

statement. Addressing PFOS and PFOA contamination represents a potentially significant 

environmentalliabilty for DOD because the regulatory requirements are still evolving, the 

scientific community is still developing the underlying science, and the scope of work needed for 

cleanup is not yet known. 

In our statement today, we discuss actions DOD has taken to address elevated levels of PFOS 

and PFOA in drinking water at or near military installations and to address concerns with DOD's 

1

1n 2017, we added U.S. Government's Environmental Liabilities to our areas identified as government operations 

with greater vulnerabilities to fraud, waste, abuse, and mismanagement or in need for transfonmation to address 

economy, efficiency, or effectiveness challenges. In fiscal year 2016 this liability was estimated at $447 billion (up 

from $212 billion in 1997) and is likely to continue to increase. The Department of Energy is responsible for 83 

percent of these liabilities and DOD for 14 percent Agencies spend billions each year on environmental cleanup 

efforts but the estimated environmental liability continues to rise. GAO, High-Risk Series: Progress on Many HighRisk Areas, While Substantial Efforts Needed on Others, GA0-17 -317 (Washington, D.C.: Feb. 15, 2017). 

2

PFOS and PFOA are no longer manufactured in the United States but have been used since the 1940s. PFOS and 

PFOA have been the most extensively produced and studied PFAS chemicals, and are very persistent in the 

environment and human body-meaning they do not break down and can accumulate over time. 

3

PFAS have also been used to make consumer products more resistant to stains, grease, and water; keep food from 

sticking to cookware; and make clothes and mattresses more waterproof. 

Page 1 GA0-18-700T Drinking Water 
72 

firefighting foam. This statement is largely based on our October 2017 report on DOD's efforts 

to manage contaminants in drinking water.• To perform our review for the October 2017 report, 

we reviewed DOD policies and guidance related to PFOS and PFOA and firefighting foam; 

analyzed DOD data on testing and response activities for PFOS and PFOA; reviewed four 

administrative orders issued by EPA and state regulators; visited seven installations; and 

interviewed DOD and EPA officials. More detailed information on the scope and methodology 

for that work can be found in the issued report This statement also includes updated 

information since our October 2017 report, based on our review of two 2018 DOD reports to 

Congress-a March 2018 report on the department's response to PFOS and PFOA 

contamination and a June 2018 report on firefighting foam alternatives-and on our discussions 

with DOD officials about these issues and their actions in September 2018s 

We conducted the work on which this statement is based in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and condusions based on our audit objectives. 

Background 

EPA regulates drinking water contaminants by issuing legally enforceable standards under the 

Safe Drinking Water Act that generally limit the levels of these contaminants in public water 

systems.s EPA has issued such regulations for approximately 90 drinking water contaminants. 

4GAO, Drinking Water: DOD Has Acted on Some Emerging Contaminants but Should Improve lntemal Reporting on 

Regulatory Compliance, GA0-18-78 (Washington, D.C.: Oct. 18, 2017). In addition to PFOS and PFOA issues, we 

reported in October 2017 that DOD had not internally reported all data on compliance with health-based drinking 

water regulations. We also reported that DOD had not used available data to determine why systems that provide 

DOD-treated water had different compliance rates from systems that provide non-DOD-treated water. We made five 

recommendations to improve DOD's reporting and use of drinking water data. DOD concurred with the 

recommendations and in May 2018 reported actions that were planned or underway to implement them. For example. 

the military departments stated that they were providing training to their installations on DOD's drinking water 

reporting requirements. We will continue to monitor DOD's status in implementing these recommendations. 

5

The Deputy Assistant Secretary of Defense for Environment, Safety, and Occupational Health, Addressing 

Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA) (March 2018); Under Secretary of Defense for 

Acquisition and Sustainment, Department of Defense Alternatives to Aqueous Film Forming Foam Report to 

Congress (June 2018). 

6

The term "public water system" refers to the provision of piped drinking water to the public, where the system serves 

at least 15 service connections or serves an average of at least 25 people at least 60 days out of the year; it does not 

refer to whether the system is publicly or privately owned 

Page2 GA0-18-700T Drinking Water 
73 

Public water systems, including the DOD public water systems that provide drinking water to 

about 3 million people iving and working on military installations, are required to comply with 

EPA and state drinking water regulations. 

While EPA has not issued legally enforceable standards for PFAS in drinking water, the agency 

has monitored water systems in the United States for six types of PFAS chemicals-including 

PFOS and PFOA-in order to understand the nationwide occurrence of these chemicals-' This 

monitoring effort was part of a larger framework established by the Safe Drinking Water Act to 

assess unregulated contaminants. Under this framework, EPA is to select for consideration from 

a list (called the contaminant candidate list) those unregulated contaminants that present the 

greatest public health concern, establish a program to monitor drinking water for unregulated 

contaminants, and decide whether or not to regulate at least 5 such contaminants every 5 years 

(called a regulatory determination)" 

EPA's regulatory determinations are to be based on the following three broad statutory criteria, 

all of which must be met for EPA to decide that a drinking water regulation is needed: 

the contaminant may have an adverse effect on the health of persons; 

the contaminant is known to occur or there is a substantial likelihood that the 

contaminant will occur in public water systems with a frequency and at levels of public 

health concern; and 

in the sole judgment of the EPA Administrator, regulation of such contaminant presents 

a meaningful opportunity for health risk reduction for persons served by public water 

systems. 

To date, PFOS and PFOA are unregulated because EPA has not made a positive regulatory 

determination for these chemicals. 

Even when EPA has not issued a regulation, EPA may publish drinking water health advisories. 

In contrast to drinking water regulations, health advisories are nonenforceable.9 Health 

7

This monitoring took place from 2013 through 2015 under EPA's unregulated contaminant monitoring rule program. 

According to DOD, 63 DOD public water systems were sampled during this time. For more information on EPA's 

unregulated contaminant monitoring rule program, see GAO, Drinking Water: EPA Has Improved Its Unregulated 

Contaminant Monitoring Program, but Additional Action is Needed, GA0-14-103 (Washington, D.C.: Jan. 9, 2014). 

8

PFOS and PFOA were placed on the contaminant candidate list in 2009 and again in 2016. EPA met the time frame 

for publishing the first contaminant candidate list, but has not adhered to the 5-year cycle for subsequent lists. 

9

EPA has issued administrative orders to address contaminated drinking water based on health advisory levels. We 

discuss such orders related to PFOS and PFOA later in this statement. 

Page3 GA0-18-700T Drinking Water 
74 

advisories recommend the amount of contaminants that can be present in drinking water-

"health advisory levels"-at which adverse health effects are not anticipated to occur over 

specific exposure durations. Most recently, in May 2016 EPA issued lifetime health advisories 

for PFOS and PFOA. 10 These advisories set the recommended health advisory level for each 

contaminant-or both contaminants combined-at 70 parts per trillion in drinking water. 11 

According to DOD, the department also considers information in these health advisories when 

determining the need for cleanup action a: installations with PFOS and PFOA contamination. 

DOD Has Initiated Actions to Address Elevated Levels of PFOS and PFOA in Drinking 

Water and Concerns with Firefighting Foam 

DOD Has Initiated Actions to ldentifv. Test, Address. and Respond to Orders from Regulators 

Regarding PFOS and PFOA in Drinking Water 

We reported in October 2017 that, following the release of EPA's lifetime health advisory for 

PFOS and PFOA in May 2016, each of the military departments directed their installations to 

identify locations with any known or suspected prior release of PFOS and PFOA and to 

address any releases that pose a risk to human health-which can include people living 

outside DOD installations; and 

test for PFOS and PFOA in their drinking water and address any contamination above 

EPA's lifetime health advisory level. 

We further reported that, as of December 2016, DOD had identified 393 active or closed military 

installations with any known or suspected releases of PFOS or PFOA. 12 Since we issued our 

report, DOD has updated that number to 401 active or closed installations, according to August 

10EPA, Drinking Water Health Advisory for Perfluorooctane Sulfonate (PFOS) (May 2016); EPA, Drinking Water 

Health Advisory for Perfluorooctanoic Acid (PFOA) (May 2016). These lifetime health advisories for PFOS and PFOA 

replaced provisional health advisories that were issued by EPA in January 2009, which set health advisory levels of 

200 parts per trillion for PFOS and 400 parts per trillion for PFOA 

110ne part per trillion is comparable to one drop in a swimming pool covering the area of a football field 43 feet deep. 

12We reported in October 2017 that this number included 391 installations identified by the military departments and, 

according to DOD officials, 2 installations identified by the Defense Logistics Agency. DOD efforts to test for and 

respond to PFOS and PFOA at overseas installations were outside the scope of our October 2017 report. 

Page4 GA0-18-700T Drinking Water 
75 

2017 data provided in a March 2018 report to Congress on the department's response to PFOS 

and PFOA contamination. 13 

We stated in our October 2017 report that the military departments had reported spending 

approximately $200 million at or near 263 installations for environmental investigations and 

response actions, such as installing treatment systems or supplying bottled water, as of 

December 2016. 14 

The Air Force had identified 203 installations with known or suspected releases of PFOS 

and PFOA and had spent about $153 million on environmental investigations and 

response actions (accounting for about 77 percent of what the military departments had 

spent on PFOS and PFOA activities as of December 2016). For example, the Air Force 

reported spending over $5 million at Peterson Air Force Base in Colorado. During our 

visit to that installation in November 2016, officials showed us the current and former fire 

training areas that they were investigating to determine the extent to which prior use of 

firefighting foam may have contributed to PFOS and PFOA found in the drinking water of 

three nearby communities. Additionally, the Air Force had awarded a contract for, among 

other things, installing treatment systems in those communities. 

• The Navy had identified 127 installations with known or suspected releases of PFOS 

and PFOA and had spent about $44.5 million on environmental investigations and 

response actions (accounting for about 22 percent of what the military departments had 

spent on PFOS and PFOA activities as of December 2016). For example, the Navy 

reported spending about $15 million at the former Naval Air Station Joint Reserve Base 

Willow Grove in Pennsylvania.15 During our visit to that installation in August 2016, 

officials told us that the Navy was investigating the extent to which PFOS and PFOA on 

the installation may have contaminated a nearby town's drinking water. At the time, the 

" 3

The Deputy Assistant Secretary of Defense for Environment, Safety, and Occupational Health, Addressing 

Perf/uorooctane Sulfonate (PFOS) and Perf/uorooctanoic Acid (PFOA) (March 2018). This report was provided in 

response to language included in House Report 115-200, accompanying a bill for the National Defense Authorization 

Act for Fiscal Year 2018. 

14DOD did not provide updated information on costs for responding to PFOS and PFOA in its March 2018 report to 

Congress. According to DOD data in our October 2017 report, 204 of the 263 installations where environmental 

investigations and response actions occurred were active installations, and 59 had been closed under the Base 

Realignment and Closure process-a process DOD has used to reduce excess infrastructure. 

15Naval Air Station Joint Reserve Base Willow Grove was closed under the 2005 Base Realignment and Closure 

round. 

Page5 GA0-18-700T Drinking Water 
76 

Navy had agreed to pay for installing treatment systems and connecting private well 

owners to the town's drinking water system, among other things. 

• The Army had identified 61 installations with known or suspected releases of PFOS and 

PFOA and had spent about $1.6 million on environmental investigations (accounting for 

less than 1 percent of what the military departments had spent on PFOS and PFOA 

activities as of December 2016), but had not yet begun any response actions. At the 

time of our October 2017 report, the Army had not yet completed testing its drinking 

water for PFOS and PFOA. 

DOD's March 2018 report to Congress provided updated information on actions taken (such as 

providing alternative drinking water or installing treatment systems) to address PFOS and PFOA 

in drinking water at or near military installations in the United States, as shown in figure 1 below. 

Specifically, DOD reported taking action as of August 2017 to address PFOS and PFOA levels 

exceeding those recommended in EPA's heaHh advisories for drinking water for people (1) on 

13 military installations and (2) outside 22 military installation& 16 

16At the time of our October 2017 report, DOD data showed that the department had initiated actions to address 

PFOS and PFOA in the drinking water for people (1) on 11 military installations, as of March 2017, and (2) outside 19 

military installations, as of December 2016. Two installations (Chanute Air Force Base and Wright-Patterson Air 

Force Base) that DOD had previously reported to us as locations where actions had been taken to address PFOS 

and PFOA in drinking water outside the installations were not included in DOD's March 2018 report. DOD officials 

told us in September 2018 that there are no PFOS and PFOA impacts to drinking water outside these installations. 

Page6 GA0-18-700T Drinking Water 
77 

Figure 1: Military Installations Where DOD Has Reported Taking Action to Address 

Elevated Levels of PFOS and PFOA in Drinking Water, as of August 2017 

We reported in October 2017 that, in addition to actions initiated by DOD, the department also 

took action in response to state and federal regulators. DOD responded to four administrative 

orders requiring that DOD address PFOS and PFOA levels that exceeded EPA's health 

advisory levels for drinking water. One order was issued by the Ohio Environmental Protection 

Agency at Wright-Patterson Air Force Base in Ohio, and three orders were issued by EPA at the 

former Pease Air Force Base in New Hampshire; Horsham Air Guard Station in Pennsylvania; 

and the former Naval Air Warfare Center Warminster in Pennsylvania. 17 For example, at WrightPatterson Air Force Base, levels of PFOS and PFOA that exceeded EPA's lifetime health 

advisory levels were found at two wells on the installation in 2016. In response to the order from 

the Ohio Environmental Protection Agency, the Air Force closed drinking water wells, installed 

17Under Section 1431 of the Safe Drinking Water Act, EPA may issue orders necessary to protect human health 

where a contaminant in a public water system presents an imminent and substantial endangerment and if appropriate 

state and local authorities have not acted to protect human health. Pub. L. No. 93-523 (1974). These orders may 

require, among other things, carrying out cleanup studies, providing alternate water supplies, notifying the public of 

the emergency, and halting disposal of the contaminants threatening human health. The Ohio Environmental 

Protection Agency has similar authority. 

Page7 GA0-18-700T Drinking Water 
78 

new monitoring wells, and provided bottled water to vulnerable populations on the installation. 

Additional details on each order and examples of actions by DOD to address the orders were 

reported on in our October 2017 report. 

According to DOD, it may take several years for the department to determine how much it will 

cost to clean up PFOS and PFOA contamination at or near its military installations. Additionally, 

DOD officials told us in September 2018 that they believe a legally enforceable EPA drinking 

water cleanup standard would ensure greater consistency and confidence in their cost 

estimates because such a standard would give them a consistent target to clean up to. In a 

January 2017 report on environmental cleanup at closed installations, we recommended that 

DOD include in future annual reports to Congress best estimates of the environmental cleanup 

costs for contaminants such as PFOS and PFOA as additional irtormation becomes available.18 

DOD implemented this recommendation by including in its fiscal year 2016 environmental report 

to Congress (issued in June 2018) an estimate of the costs to respond to PFOS and PFOA 19 

DOD Has Taken Steps to Address Health and Environmental Concerns with Its Firefiqhting 

Foam 

In our October 2017 report, we found that DOD was taking steps to address health and 

environmental concerns with its use offirefighting foam that contains PFAS20 These steps 

included restricting the use of existing foams that contain PFAS, testing DOD's current foarns to 

identify the amount of PFAS they contain, and funding research into the future development of 

PFAS-free foam that can meet DOD's performance and compatibility requirements (see table 

1).21 Some of these steps, such as limiting the use of firefighting foam containing PFAS, were in 

place. Others, such as researching potential PFAS-free firefighting foams, were in progress at 

the time of our review. 

18GAO, Military Base Realignments and Closures: DOD Has Improved Environmental Cleanup Reporting but Should 

Obtain and Share More Information, GA0-17-151 (Washington, D.C .. Jan. 19, 2017). 

190ffice of the Under Secretary of Defense for Acquisition and Sustainment, Defense Environmental Programs 

Annual Report to Congress for FY 2016 (Washington, D.C .. June 2018). 

2

°Firefighting foam used by DOD contains other types of PFAS, in addition to PFOS and PFOA. 

21 DOD's military specification for firefighting foam outlines performance and compatibility requirements. For example, 

the specification states how long it should take for foam to extinguish a fire and prevent the extinguished fire from 

reigniting and requires that firefighting foam approved for use by DOD from one manufacturer be compatible with 

foam from another manufacturer. At the time of our review, the military specification in place for fire fighting foam was 

DOD, Mii-F-24385F, Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, for Fresh 

and Seawater(Aug. 5, 1994). 

PageS GA0-18-700T Drinking Water 
79 

Table 1: Department of Defense (DOD) Steps to Address Concerns about Perfluorooctane Sulfonate (PFOS) 

and Perfluorooctanoic Acid (PFOA) in Firefighting Foam 

Step 

Restricting use of 

firefighting foam 

Testing firefighting 

foam with PFAS 

Funding 

firefighting foam 

research 

Goal 

Following the May 2016 issuance of 

the Environmental Protection 

Agency's lifetime health advisory for 

PFOS and PFOA, the military 

departments issued policies 

restricting the use of firefighting 

foam at their installations. 

DOD's intent was to eventually 

replace the existing firefighting 

foam that contains PFOS and 

PFOA. 

DOD was funding research into the 

development of PFAS-free 

firefighting foam because DOD 

believes that such a foam would 

significantly reduce the 

environmental impact of fire 

suppression training and 

operations, while maintaining the 

safety of personnel from fire 

hazards. 

Source: GAO analySi$ of DOD data I GA0-18-?00T 

Actions/status 

Actions called for in military department policies: 

Air Force: Stop routine testing of firefighting equipment 

unless the released foam can be contained and 

managed. Treat all releases of fire fighting foam with 

PFOS or PFOA as hazardous material releases' 

Navy: Stop the uncontrolled release of firefighting foam 

except in emergency situations. Ensure that any foam 

that is discharged in a nonemergency situation is 

contained, captured, and properly disposed ofb 

Army: Prohibit all nonemergency discharges of firefighting 

foam, to include training and equipment testing.' 

According to DOD, firefighting foams approved for 

purchase and use by DOD since at least December 2015 

do not contain PFOS, but these firefighting foams contain 

other types of PFAS and may contain PFOA. 

The Naval Research Laboratory was testing the different 

types of firefighting foams that were approved for 

purchase and use by DOD to determine the extent to 

which they contain PFOA and other types of PFAS-" 

Testing was expected to continue until late 2017 or 2018. 

Navy and Army officials said that they planned to wait for 

final testing results before deciding whether to select a 

specific firefighting foam to replace the foam used at their 

installations. The Air Force, however, had already 

selected a specific foam for use at its installations. This 

foam contains PFAS but, according to the Air Force, does 

not contain PFOS and contains little or no PFOA. Officials 

said that all Air Force installations in the continental 

United States had received this new foam. 

In October 2015, DOD's Strategic Environmental 

Research and Development Program issued a statement 

of need calling for proposals to develop a PFAS-free 

firefighting foam that can meet DOD's performance 

requirements and be compatible with existing foams and 

equipment. 

In fiscal year 2017, DOD funded three research projects 

that responded to the statement of need-one led by the 

Naval Air Systems Command, one led by the Naval 

Research Laboratory, and one led by a private firefighting 

foam manufacturer-with an estimated total cost of $2.5 

million and an estimated completion date of 2020. 

3

0ffice of the Assistant Secretary of the Air Force for Installations, Environment, and Energy Memorandum, SAFIIE Policy on 

Perfluorinated Compounds (PFCs) of Concern (Aug. 11, 2016). 

bOffice of the Assistant Secretary of the Navy for Energy, Installations, and Environment Memorandum, Aqueous Film Forming 

Foam (AFFF) Control, Removal, and Disposal (June 17, 2016). 

cAssistant Chief of Staff of the Army for Installation Management Memorandum, Limiting Use of Aqueous Film Forming Foam (June 

29, 2016). 

dNavy officials told us during our review that they were testing the firefighting foam products that were currently included on DOD's 

qualified product list, which is the list of firefighting foams that have been approved for purchase and use by DOD. 

Page9 GA0-18-700T Drinking Water 
80 

DOD's military specification for firefighting foam, which outlines performance and compatibility 

requirements, also requires that firefighting foam purchased by the department contain PFAS. 

We reported in October 2017 that, according to DOD, there was no PFAS-free firefighting foam 

that could meet DOD's performance and compatibility requirements. As a result, the Navywhich is the author of the military specification-had no plans to remove the requirement for 

firefighting foam to contain PFAS. However, Navy officials told us during our review that if a 

PFAS-free foam were to be developed that could meet DOD performance and compatibility 

requirements the Navy would make any necessary revisions to the military specification at that 

time. Navy officials also said during our review that they were planning to revise the military 

specification to set limits for the amount of PFAS that are allowed in firefighting foam, following 

their testing on the amounts of PFOS, PFOA, and other PFAS found in foam used by DOD. 

In June 2018, DOD reported to Congress that its military specification for firefighting foam was 

amended to set a maximum level of PFOS and PFOA (800 parts per billion}. 22 DOD officials told 

us in September 2018 this maximum level applies to the amount of those chemicals in 

firefighting foam concentrate before it is mixed and diluted with water to create firefighting 

foam. 23 The DOD officials also said that 800 parts per billion is the lowest level of PFOS and 

PFOA that can be detected in firefighting foam concentrate by current testing methods and 

technologies, but DOD is working with foam manufacturers and laboratories to achieve lower 

detection limits. According to the June 2018 report, DOD plans to establish lower limits for 

PFOS and PFOA in firefighting foam in late 2018. The June 2018 report reiterated that, 

according to DOD, no commercially available PFA&free foam has met the performance 

requirements of the military specification, and the report also stated that DOD-funded research 

efforts to develop a PFAS-free foam that can meet performance requirements are still ongoing. 

Chairman Paul, Ranking Member Peters, and Members of the Subcommittee, this completes 

our prepared statement. We would be pleased to respond to any questions that you may have 

at this time. 

22Under Secretary of Defense for Acquisition and Sustainment, Department of Defense Alternatives to Aqueous Film 

Forming Foam Report to Congress (Washington, D.C.: June 2018). 

23This level is distinct from EPA's lifetime health advisory levels for PFOS and PFOA (70 parts per trillion), which 

apply to drinking water and not to. for example, firefighting foam concentrate. 

Page 10 GA0-18-?00T Drinking Water 
81 

GAO Contact and Staff Acknowledgments 

If you or your staff have any questions about this report, please contact us at Brian J. Lepore, 

(202) 512-4523 or leporeb@gao.gov or J. Alfredo Gomez, (202) 512-3841 orgomezj@gao.gov. 

Contact points for our Offices of Congressional Relations and Public Affairs may be found on 

the last page of this statement. Other individuals who made key contributions to this statement 

include Maria Storts (Assistant Director), Diane B. Raynes (Assistant Director), Michele Fejfar, 

Karen Howard, Richard P. Johnson, Mae Jones, Arnie Lesser, Summer Lingard-Smith, Felicia 

Lopez, and Geoffrey Peck. 

(103014) 

Page 11 GA0-18-?00T Drinking Water 
82 

TESTING for PEASE 

09/26/2018 

MY PERSONAL STORY: 

My name is Andrea Amico and I live in Portsmouth, New Hampshire. PFAS water 

contamination is a very personal issue for me. My husband and I moved to the beautiful 

seacoast part of New Hampshire in 2007 when my husband took a job at the Pease 

International Tradeport. Pease was a former Air Force Base that was open from 1956 to 

1990. After closing in 1990, it was then redeveloped into an International Tradeport that 

is now home to more than 200 businesses and brings- 10,000 people a day there for 

work, college, healthcare, childcare, etc. 

My husband and I were blessed with our first child in 2011 and it was a hard decision to 

pick the right daycare setting to send our daughter. I did not have the option to stay 

home with my daughter full time and my husband and I did the next best thing and 

found her a loving and caring daycare center. After months on the waiting list, we were 

thrilled to learn of an opening at a beautiful, new daycare center on Pease. The daycare 

was built in 2010 and it was right next door to my husband's work on Pease. It was a 

beautiful facility with bright colored classrooms and loving teachers. My husband could 

see the window of my daughter's classroom from his office and would stop by on his 

lunch break to feed her a bottle or take her for a walk. And in 2013, we were blessed 

with our second child, a son, who we also enrolled in the same daycare center on 

Pease right next door to my husband's work. Both of my children started daycare on 

Pease at the young age of 12 weeks old. When looking into child care facilities, we 

asked many questions of the daycare center (are your teachers experienced, what is 

your curriculum, what are your safety policies), but NEVER did it cross our minds that 

we had to question the quality of the water at the picture perfect daycare center my 

children were attending. 

You can imagine the feeling of my heart sinking when I read in a local newspaper article 

on the Friday before Memorial Day weekend in May of 2014 that high levels of 

contaminants had been found in one of the Pease wells that supplies drinking water to 

the tradeport and was shut down. I immediately thought of my husband and two small 

children that were on Pease for work and daycare every day and drinking the water. 

When I first read the article, PFAS was being referred to as PFCs. I had never heard of 

these chemicals prior to May 2014, but I quickly learned that there were many areas of 

concern related to PFAS exposure. I learned that PFAS are extremely persistent in the 

environment and don't break down or attenuate over time like other contaminants. I 
83 

learned that they bio accumulate in the body and have half very long half-lives, some 

taking decades to leave the body. And I also learned that they are associated with 

multiple adverse health effects that impact many systems of the body such as different 

types of cancers, impaired immune function in children, elevated cholesterol, fertility 

issues, and more. And that they cross the placenta to unborn children and can be 

passed to infants through breast milk which means future generations are at risk for the 

contamination we are facing today. 

I started my advocacy journey 4 years ago with the initial intention of advocating for 

blood testing for my family and wanting to better understand their exposure to PFAS at 

Pease. My work quickly evolved into advocating for the entire Pease community (both 

past and present) to better understand the long term health impacts given this 

significant environmental exposure. I am a co-founder of a community action group 

called Testing for Pease with two other mothers, Alayna Davis and Michelle Dalton. Our 

role as community leaders has evolved in to working with other impacted community 

leaders across the nation by advocating on behalf of millions of Americans that have 

been unknowingly exposed to contaminated drinking water and now need more action 

and answers. As a community leader and advocate for impacted communities, I feel 

strongly that we must help impacted communities that are suffering now, we must learn 

more about the long term health impacts of PFAS, and we must advocate strongly for 

more protective measures to be put in place to prevent any other families from being 

exposed to harmful contaminants in drinking water in the future. 

Since 2014, I have learned so much more about the chemistry, remediation, and 

possible health effects of PFAS. In 2015, my family participated in the PFAS blood 

testing program offered by NH DHHS and their PFAS levels were found to be elevated. 

My 7 year old daughter has the highest level of PFAS in her blood in our family. My 

children were exposed to highly contaminated water at daycare at an early and critical 

stage of their development. I will never stop worrying about the health of my children 

and I will forever live with the guilt that I unknowingly sent them to a daycare where they 

drank contaminated water. At times, the worry and guilt is consuming and I don't sleep 

much at night. However, I have tried really hard to channel this negative energy into 

something positive through my advocacy work because I feel strongly that families like 

mine deserve access to blood testing, medical monitoring, health study opportunities, 

clean water, remediation to remove these chemicals from the environment, and more 

answers to what the long term health impacts are given PFAS exposure. It is critical we 

learn from this very important public health crisis and do everything in our power to 

prevent another opportunity for so many Americans to be exposed to harmful 

contaminants in their drinking water. 

THE PEASE STORY: 

Being one of the first Department of Defense (DoD) sites to discover PFAS drinking 

water contamination, the Pease community has been a leader on many fronts and has 

been blazing a new trail in how to respond to this growing crisis around our nation. 

Through strong community organization, collaboration with several government 

agencies, and progressive leadership from the New Hampshire Congressional 
84 

Delegation, the Pease community has been offered a PFAS blood testing program to 

exposed community members, have treatment on drinking water wells & ongoing 

ground water treatment, and are currently working with ATSDR through the Pease CAP 

to coordinate a health study at Pease and a multi-site PFAS health study around the 

nation. We are extremely thankful to Senator Hassan and Senator Shaheen for their 

close collaboration with the impacted members of the community, the unprecedented 

legislation to help impacted communities, and their fierce leadership in addressing 

PFAS from the beginning of the discovery of the contamination at Pease. Senator 

Hassan was Governor of New Hampshire when the PFAS contamination was 

discovered at Pease and allowed for an open blood testing program of all impacted 

community members at Pease that started in 2015. She also re-opened the blood 

testing program at the community's request in 2016 when more community members 

were showing interest in participation after high levels of PFAS were found in the blood 

of the Pease community. Senator Hassan has sent several letters on behalf of the 

impacted community to federal agencies advocating for more action from the federal 

government for communities impacted by PFAS contamination. She also cosponsored 

legislation (introduced by Senators Schumer and Gillibrand) to require the EPA develop 

a maximum contaminant level for perfluorinated compounds (including PFOA and 

PFOS), 1 ,4 dioxane, and perchlorate in public water systems across America within two 

years of the bill's enactment. Senator Shaheen has also written several letters to federal 

agencies on behalf of the Pease community and coordinated a meeting with the Pease 

community and the Assistant Secretary of the Air Force, John Henderson. She has 

been instrumental in introducing legislation through the NOAA that mandates DoD to 

fund a PFAS health study at Pease, exposure assessments at eight DoD sites across 

the country, and a multi-site PFAS health study across the nation. Senator Shaheen 

was also critical in appropriating the resources to fund the studies for ATSDR to do this 

very important work. She has also introduced legislation on a PFAS Registry Act 

(supported by Senator Hassan), that directs the Secretary of Veterans Affairs to 

establish a registry to ensure that members of the Armed Forces who may have been 

exposed to PFAS on military installations receive information regarding such exposure 

for Veterans as this is a critical population that needs more attention and that we can 

learn from their PFAS exposure. Senator Hassan and Senator Shaheen have worked 

very hard from early on when the PFAS was discovered at Pease and our community is 

extremely grateful for their support, hard work, and continued leadership on this very 

important issue. 

As a result of a strict order issued by the EPA in July of 2015, The Air Force has spent 

millions of dollars at Pease to investigate the PFAS contamination and take aggressive 

remediation action. Pease currently has two large Granular Activated Carbon (GAC) 

vessels on two of the drinking water wells with plans to add GAC and resin technology 

to the drinking water wells in the near future. The Air Force has also installed a ground 

water treatment system at the firefighting training area on Pease where large amounts 

of AFFF were released for training purposes and have very high levels of PFAS 

detected in the groundwater and soil. There is also ongoing construction of another 

groundwater treatment system in the airfield at Pease being coordinated and funded by 

the Air Force. 
85 

THE NATIONAL STORY: 

The progressive work being done at Pease is not the same story that is playing out at 

other PFAS impacted communities across the nation. Multiple communities have 

discovered their contamination in the last few years, but their calls for blood testing, 

filtration, remediation, medical monitoring, and answers to health questions and 

concerns go unanswered by their government officials. In the absence of a consistent 

and coordinated approach from the federal government, states are taking different 

approaches to address this public health crisis. Without federal leadership, states are 

scrambling to find the resources to investigate PF AS contamination and to provide 

remediation to impacted sites. Some states take more protective measures to lower the 

acceptable levels for PFOA & PFOS than the current EPA health advisories (i.e. 

Vermont, New Jersey) and other states are including more than 2 PFAS in their total 

acceptable PFAS levels in drinking water (i.e Massachusetts, Connecticut, Vermont). 

Although the source of the PFAS contamination at several communities across the 

nation vary from DoD sites, chemical manufacturers, tanneries, and other industrial 

sites, the impacted communities wants and needs are very similar. 

The need for the federal government to be the leaders in addressing the contamination 

is now. Although impacted communities are only recently discovering their 

contamination, the reality is that most communities have had ongoing exposure for 

decades and are dealing with the consequences of their exposure. Impacted 

communities cannot wait any longer for inaction and a disjointed effort from our 

government and instead need a consistent and coordinated effort at the federal level to 

tackle this growing and concerning public health issue. 

COMMUNITY CHALLENGES: 

According to the Environmental Working Group (EWG), PFAS water contamination is 

estimated to be impacting 110 millions of Americans across the nation. We must not 

Jose perspective that these impacted communities are not just a dot on the map and 

remember that they are real people with families, and the consequences of the 

contamination is very personal and life changing. 

A National PFAS Contamination Coalition formed in June 2017 after a successful and 

unprecedented national PFAS conference at Northeastern University in Boston that 

brought together scientists, academics, impacted community leaders, environmental 

lawyers, physicians, government officials, journalists, and more to address the growing 

PFAS issue in our country. The National PFAS Contamination Coalition has held 

monthly calls and webinars to bring community leaders across the nation together to 

collaborate, learn from each other's stories, stream line efforts, share best practices, 

and develop a coordinated plan at a national level to get more action. 

Challenges faced by impacted communities: 

PFAS are presumed safe until proven toxic and ongoing exposure continues 

• Lack of federal health advisories for all PFAS 
86 

• Current EPA Lifetime Health Advisories (LHAs) for PFOS & PFOA are too high 

and not protective of public health and sensitive populations (infants, children, 

already exposed populations) 

• Lack of health and toxicology data for all PFAS 

• Multiple health effects impacting many systems in the body associated with 

PFAS exposure 

• Communities should not be financially responsible for the cost of alternative 

water supply, remediation, filtration, blood testing, medical monitoring, etc 

• Replacement PFAS are replacing "one evil with another" 

• Limited labs capable of standardized testing of water and blood means testing is 

not easily accessible, time consuming, and expensive 

• Cost of PFAS is more than just remediation/filtration and has significant 

economic consequences on individuals, businesses, and our entire society (i.e. 

property values decreased; businesses lack the ability to attract/retain talented 

employees and customers; chronic illness reduces employee attendance & 

productivity and drives up healthcare costs) 

• Chronic illness as a result of PFAS exposure result in loss of work/wages; loss of 

happiness; loss of productivity; loss of life 

PFAS cross the placenta and pass through breast milk indicating future 

generations will be impacted by PFAS contamination 

• Additional expenses related to PFAS exposure that are burdening community 

members are medical bills; bottled water; home filtration systems; diagnostic 

testing; community organizing/operating costs 

• Communities are often not seen as stakeholders that deserve a seat at the table 

for important discussions and critical decisions 

Lack of transparency from government agencies 

Lack of funding causes roadblocks in research, remediation, and making 

decisions for public safety at state/federal level 

Data is technical and not easily understood 

Inconsistent messaging from government agencies re: health effects, blood 

testing, and medical monitoring that down plays risks 

• Inconsistent responses to contamination at local, state, and federal level creates 

community confusion, uncertainty, and mistrust 

Difficulty streamlining communication between multiple goverment agencies and 

community 

• PFAS are unregulated contaminants which means communities continue to be 

exposed to multiple PFAS (most without any health or toxilogical data) 

• Impacted communities worry about adverse health effects, safety/quality of their 

water, lost property values, chronic health issues, financial burden, how to 

monitor health, lack of accessible labs, lack of government guidance, lack of 

accountability from responsible parties 

COMMUNITY CALLS FOR ACTION: 

• Establish MCL of 1 ppt for all PFAS 
87 

• Classify PFAS as hazardous substance 

• Treat PFAS as a class/family and regulate them together and not one compound 

at a time 

• Improve lab analytical methods to test for many PFAS in water and blood and 

make those more accessible nationwide 

Prioritize public health and not chemicals when making critical regulatory 

decisions 

Improve response time on taking meaningful action 

• Value community members as critical stakeholders by including us in meetings 

and ask for our input on important decisions "Nothing about us without us" 

• Provide more funding to states to allow for more testing and community 

response 

• Do not give into industry and political pressure when making important decisions 

that impact public health. The protection of public health should be the top priority 

of our government. 

• Work with DoD to find non fluorinated firefighting foam alternatives and to 

completely phase out the use of fluorinated foams. 

Do not allow the introduction of any new PFAS into production due to the large 

number already in production/environment with limited data 

• Conduct another round of UCMR testing that includes more communities, a 

greater number of PFAS to test for with lower detection limits to provide a more 

accurate picture of the PFAS contamination picture nationwide 

• Be honest and fully transparent in all the action steps taken to address PFAS 

contamination 

CONCLUSION: 

The federal government must take swift and protective action against all PFAS and not 

just a couple chemicals within this class. The government must stop giving PFAS the 

benefit of the doubt and instead give public health the benefit of the doubt. It is known 

that some of the chemicals in this class of PFAS cause harm to human health and 

therefore the government should not allow these chemicals to be in the products, 

environment, and drinking water of millions of Americans. Communities need a 

consistent and coordinated action plan from federal agencies to address PFAS 

contamination and we need action now. It is critical the federal government take a 

leadership role by lowering the standard for all PFAS to 1 ppt, prioritize health & 

toxicological studies on PFAS to advance the science, allocate resources for ongoing 

investigations & remediation efforts, and hold the polluters responsible for their actions. 

Impacted communities have suffered enough by being exposed to harmful 

contamination in their drinking water and the burden to pay for clean water, remediation, 

filtration, blood testing, medical monitoring, and health related expenses should not fall 

on the communities, too. Community members have already "paid" enough by 

unknowingly and to no fault of their own being exposed to these harmful contaminants 

and it is time for the government to step up, take control, and implement meaningful 

action in the best interest of public health and not in the interest of the polluters. 

Impacted communities cannot even begin to compete with the billion dollar budgets and 
88 

extensive legal teams of the responsible parties such as DoD and industry 

representatives that use and manufacture these chemicals. Instead we rely heavily on 

our government agencies charged with protecting public health and the environment to 

take action that put our best interests first. Thank you for the opportunity to testify at the 

Senate Subcommittee hearing and to provide this written statement for the record. 

Sincerely, 

Andrea Amico 

Testing for Pease, Cofounder 
89 

Arnie Leriche 

Community Co-Chair 

Wurtsmith Restoration Advisory Board 

Testimony before the Senate Homeland Security and Governmental 

Affairs Subcommittee on Federal Spending Oversight and 

Emergency Management 

"The Federal Role in the Toxic PFAS Chemical Crisis" 

September 26, 2018 
90 

Good afternoon Chairman Paul, Ranking Member Peters, and honorable members of the 

Subcommittee. My name is Arnold Leriche and I am a retired environmental engineer from the 

EPA and a Vietnam era veteran. 

I retired to Oscoda, Michigan mostly because I wanted to go fishing on the Au Sable River, the 

many beautiful inland lakes, and Lake Huron. 

One thing I quickly learned after moving to Oscoda, is that many people fill their freezers with 

the fish they catch and the wildlife they hunt. It's second nature to the residents of Northern 

Michigan. 

Oscoda sits next to the former Wurthsmith Air Force Base on the banks of the Au Sable River 

and the shores of Lake Huron. The Air Force used firefighting foam at a training site on base. 

That training site is adjacent to Clark's Marsh, a beautiful wetland. 

For more than 25 years PFAS contamination drained into Clark's Marsh and from that marsh 

into the rivers and lakes ofNorthern Michigan. The base closed in 1993, but it wasn't until2010 

that our state environmental department started to investigate the site for potential PF AS 

contamination. 

I learned from news reports in 2012 that they had discovered fish in Clark's Marsh with the 

highest levels ofPFAS contamination found anywhere in the world. Then they found very high 

levels of contamination in the adjacent Au Sable River. !learned then of the health effects of 

PFAS contamination. We were advised not to eat the fish. You can imagine how that feels to 

residents of Oscoda who have spent their lives eating that fish and serving it to their children. 

We now know that the contamination is in the groundwater and the drinking water. And it's 

even spreading into Lake Huron, which is a source of drinking water for hundreds of thousands 

of Michiganders. 

I participated in sampling the drinking water around Van Etten Lake which adjoins the base. 

will never forget the lake resident who asked, "How long has the contamination been in my 

well?" I could see the fear in her eyes as she thought about her grandchildren who had been 

drinking that water for twenty years. 

The Air Force owned a beach on Van Etten Lake, which has been given to the township. On this 

beach, our friends fish and have picnics, children play and learn to swim. At this beach, on most 

days, you will find a bright white foam washing up on shore. The EPA says that PF AS 

contamination in drinking water is safe up to 70 parts per trillion. In this foam, it is found at 

165,000 parts per trillion. 

Would you want your children and grandchildren playing in that water? Would you want them 

eating the fish? 

The harm extends beyond the residents of Oscoda. We know that there was contamination in the 

drinking water on Wurtsmith when it was an active base. I have personally heard ftom veterans, 

2 
91 

such as SSG Rick Thempto and Airman James Bussey, who are to this day suffering from health 

effects. 

I appreciate that the Air Force has taken some steps to address the contamination at Wurtsmith. 

But our water is still poisoned and we still cannot eat what we catch. I listened to the testimony 

of the government witnesses. I am glad that DOD and EPA are beginning to acknowledge this 

problem and think about steps to help fix it. 

But the people of Oscoda don't have any more time for delay or missteps. We need action now. 

We want the responsible parties and the federal government to take this seriously right now. 

We need interim mitigation. They already have enough information to take remediation actions. 

For businesses on the former base, we need assistance with indemnification and insurance to 

secure employment and encourage development. We need assistance in providing municipal 

water to residents who cannot drink from their own wells. 

I ask this Subcommittee, please do not forget about the people of Oscoda-Au Sable Townships, 

and those like us all around the country. Thank you for the opportunity to speak on their behalf, I 

look forward to you questions. 

3 
92 

INTERNATIONAL ASSOCIATION OF FIRE FIGHTERS 

Statement of 

LIEUTENANT TIMOTHY PUTNAM 

VICE-PRESIDENT, TIDEWATER FEDERAL FIRE FIGHTERS 

before the 

SUBCOMMITTEE ON FEDERAL SPENDING OVERSIGHT & 

EMERGENCY MANAGEMENT 

UNITED STATES SENATE 

On 

THE FEDERAL ROLE IN THE TOXIC PFAS CHEMICAL CRISIS 

SEPTEMBER 26, 2018 
93 

Thank you Chairman Paul, Ranking Member Peters, and distinguished members of the 

Subcommittee. My name is Timothy Putnam and I am Vice-President of the Tidewater Federal 

Fire Fighters, local F 25 of the International Association of Fire Fighters (IAFF). I appreciate the 

opportunity to appear before you today on behalf of the International Association of Fire 

Fighters, General President Harold A. Schaitberger, and over 315,000 fire fighters and 

emergency medical personnel who serve this nation as the first line of defense against 

emergencies and disasters, natural or man-made. 

I come before you today to offer my testimony on the federal role in the toxic PFAS 

chemical crisis. For over twenty-eight years I have been employed by the Department of 

Defense, first as an active-duty United States Marine where I served as an Aircraft Rescue Fire 

Fighter. After four years of military service I immediately transitioned to a civilian fire fighter 

position with the Department of Navy, specifically with the Navy Region Mid-Atlantic Fire and 

Emergency Services where I currently hold the rank of lieutenant, assigned to serve at Joint 

Expeditionary Base little Creek I Fort Story. As an active fire fighter, I have witnessed and 

participated in the routine use of Aqueous Film Forming Foam (AFFF) which is now known to 

contain the toxic chemicals referred to as Per- and Polyfluoroalkyl substances or PFAS. 

The primary mission of the fire service is to deliver critical life-saving fire extinguishment 

as rapidly as possible. This is particularly true when the fire is being fed by vast quantities of 

flammable liquids in close proximity to people, such as aboard aircraft. To rapidly combat those 

fires, since the early 1970s, fire fighters have employed AFFF to aid in extinguishing Class B 

flammable liquid fires. AFFF works by forming a foam and film coating around the liquid, which 
94 

acts as a thermal and evaporation barrier to stop the combustion process. Until 2002 

production of toxic AFFF included Perfluorooctane Sulfonic Acid (PFOS). PFOS was essentially 

banned in the United States that year and manufacturers switched to a less toxic formula which 

does not contain PFOS. However, the less toxic formula isn't without its own hazards. As this 

formulation breaks down, it forms a harmful substance known as perfluorooctane acid (PFOA). 

Today, most foam manufacturers have transitioned to the use of short-chain fluorosurfactants 

known as C6, but AFFF containing PFOA remains in widespead use. 

PFOS and PFOA are part of a larger family of chemicals known as PFAS. PFAS is a very 

stable man-made chemical, sometimes referred to as a "forever chemical," that does not occur 

naturally in the environment and may take up to a century to completely break down. 

Produced in large quantities, substances containing PFAS have been widely used for their ability 

to repel stains, grease, water, and oil. Further, they were used in the manufacturing of coatings 

and treatments intended to for textile materials, carpets, packaging, and cookware. You have 

undoubtedly have heard of them as they are commonly referred to as Teflon and Scotchguard. 

Human Exposure to PFAS and the Fire Fighter 

Individuals are exposed to PFAS released into the air, water, and soil in areas where they 

are manufactured, stored, or used. Following the initial release, PFAS can be transported to 

other areas through windy conditions, movement of groundwater, flooding, or even food 

production. With their persistence in the environment, concentrations of PFOS and PFOA 

accumulate in people, wildlife, food sources, soil, and drinking water. 
95 

Typically, toxic chemicals enter the body through one of three routes: ingestion, 

inhalation, or absorption. Most commonly, people are exposed to toxic PFAS through ingesting 

contaminated food or drinking contaminated water. For some individuals, like fire fighters 

working with materials containing PFAS such as AFFF, the chemicals are likely to enter the body 

through inhalation or absorption. 

While engaged in operations requiring the use of AFFF, fire fighters are regularly 

exposed to toxic PFAS. Personally, I have worked with toxic AFFF on a regular and continuous 

basis throughout my fire fighting career. During my twenty-eight years with the Department of 

Defense, the majority of my contact with AFFF containing PFAS occurred without the benefit of 

adequate personal protection equipment (PPE). 

ARFF units are the first responder fire fighting vehicles at airports and airfields. 

Equipped with separate tanks holding large quantities of water and AFFF, airport fire fighting 

vehicles can place tremendous quantities of extinguishing agent on a fire. Typically, in aircraftrelated incidents foam agents are the first line of attack. The effort to extinguish an aircraft fire 

frequently involves multiple ARFF vehicles working in a choreographed manner attacking the 

fire from different angles. Each of the attacking apparatus can place 1,500 to 2,000 gallons of 

the water and AFFF solution per minute on the fire. Some toxic foam becomes aerosolized as 

the agents are discharged from the vehicle. 

During the 1990's the use of fire fighting foam agents at military bases was virtually 

unchecked. There was an abundant supply kept in the fire station without any limitation on its 

use or a requirement to protect one's self with PPE. In fact, during the early part of my career, 
96 

AFFF was thought to be so safe that I recall using it as a substitute for vehicle soap to wash fire 

department vehicles. We also used AFFF foam to clean the fire station floors. Of course, the 

primary use of AFFF foam was to fight fire and to prepare for any potential incidents. Fire 

fighters were required to train with and ensure the ready avilability of such foam. Thus, I 

performed daily apparatus equipment checks in which I determined the readiness of my 

assigned ARFF truck. Readiness checks are done by flowing a few gallons of the water and AFFF 

solution. The newly discharged foam suds were then captured and placed on a visual 

spectrometer to determine if the proper ratio of AFFF and water are present. We also 

conducted training exercises involving hands-on fire extinguishment of jet fuel supplied in an 

open-air burn pit. While training with handlines, fire fighters would wade into the flaming fuel 

pit to practice the technique of "pushing foam" across the burning jet fuel. Between the 

apparatus checks and hands-on training, use of and exposure to AFFF was a regular and 

common occurrence happening six to eight times a month for fire fighters working alternating 

shifts like me. 

In the mid-1990's, the burn pit at Naval Air Station Oceana used for training was 

decommissioned and replaced by a stationary aircraft simulator fueled by propane. Different 

techniques and agents are used to fight gas fires versus liquid fuel fires. Burning propane gas 

fires are fought with plain water as AFFF foam agents are not normally used for gas fires. The 

move to the propane fed simulator greatly reduced the frequency of AFFF discharge during 

training. 

As my career progressed, so too did base awareness of the environmental impacts of 

toxic foam as base officials began limiting the locations where fire fighters were permited to 
97 

release AFFF. In the early days of my career, AFFF was discharged from fire fighting vehicles on 

the front and rear apron of the fire station or on nearby grassy areas. Since the late 1990's 

base environmentalists have designated the areas where fire fighters could routinely discharge 

the foam. The first designated area I recall was both in and near the decommissioned open-air 

burn pit. After a few years, the designated area was again relocated to a refueling pit. A 

refueling pit is a recessed concrete pad that is equipped with drains and an oil-water separator. 

As these transitions occurred, the frequency of foam discharges occurring as part of regular 

vehicle readiness checks decreased from several times a month to once a week. By the time of 

my first transfer from Oceana in 2009, AFFF discharges happening as part of apparatus 

readiness checks dropped off to a monthly basis and now non-emergency AFFF discharges are 

taking place on a substantially reduced quarterly or a semi-annual basis in very controlled 

conditions with an effort being made to capture and recover those discharges. Speaking 

holistically, as more has been learned about the environmental consequences of PFAS release, 

fire departments have become more cautious in AFFF discharges. 

The Health Effects of PFAS on Fire Fighters and the Need for Medical Monitoring 

As we have become more aware of the environmental impacts of PFAS, our knowledge 

of the human impacts continues to evolve. We know that a single exposure to AFFF by fire 

fighters results in PFAS entering the body. PFAS remains in the human body for years even if 

there are no additional exposures. The half-life of PFAS ranges from 2-9 years. This long halflife means that the chemicals remaining in the body where they can build up to 

concentrations that may cause health effects. When fire fighters experience repetitive 

exposures, it is highly likely that they will maintain a high concentration of PFAS within the 
98 

blood and body tissue as compared to non-fire fighters. 

There is evidence suggesting that PFAS can cause tumors in lab animals exposed to 

very high doses, particularly in the liver, reproductive organs, and pancreas. Studies among 

highly exposed populations have shown a more than insignificant risk of testicular, kidney, 

bladder, and thyroid cancer related to PFOA and PFOS exposure. The International Agency 

for Research on Cancer (IARC) classifies PFOA as a Group 2B carcinogen, meaning it is 

"possibly carcinogenic to humans" based on limited evidence of carcinogenicity in humans 

and limited evidence in lab animals. 

Studies on non-cancer health effects are also limited due to small study populations 

and inconsistent results. However, research suggests that high exposures to PFAS are 

associated with developmental effects during pregnancy or breastfeeding, thyroid damage, 

increases in blood cholesterol levels, and liver damage. PFAS are corrosive and can cause 

damage to the skin and eyes, including blindness. Unfortunately, I only learned of this 

through information provided by my union, the International Association of Fire Fighters, 

and not my employer. I am convinced all fire fighters should receive mandatory annual 

training on the hazards of toxic foams. 

Regulating PFAS and Approving Safer AFFF Formulas 

In 2000, the United States Environmental Protection Agency (EPA) and 3M, the 

primary manufacturer of PFAS, agreed to a voluntary phase-out of production of AFFF 

containing PFOS, which was completed in 2002. AFFF containing the more harmful PFOS is 

no longer made in the U.S. 
99 

In 2006, the EPA and the eight major companies that manufacture PFOA launched 

the 2010/15 PFOA Stewardship Program, in which companies agreed to reduce emissions 

of PFOA by 95% by 2010 and phase out production by 2015. These voluntary phase-outs 

did not affect existing AFFF products containing PFAS. 

Despite these voluntary efforts, AFFF containing PFOS may still be in use or in 

stockpiles stored in fire stations and warehouses for many years to come. With a twentyfive-year shelf life, AFFF containing PFOS will be around for another decade or possibly 

two, and will continue to remain aboard ARFF apparatus despite health concerns. 

A suitable substitute for PFAS in fire fighting foams not only has to meet health and 

environmental standards, but it also must be effective at extinguishing Class B flammable 

liquid fires. The AFFF used in the U.S. military and in most civilian applications must meet 

specific requirements for surface tension established in Military Specification Mll-F-24385F 

to ensure its effectiveness against a wide variety of flammable liquid threats. 

The EPA has engaged in reviews of safer substitutes for PFAS AFFF as part of the 

2010/15 PFOA Stewardship Program and the New Chemical Program. One suitable 

substitute is an AFFF that contains certain fluorocarbon surfactants with fewer than six 

carbons (also referred to as C6 or fluorotelomer foam) made through telomerization. These 

foams do not form PFOA when they degrade and are generally less toxic and less persistent 

in the environment compared to the longer chain PFOA, although they are likely to contain 

trace amounts of PFOA as a byproduct of manufacturing. 

Another option is to develop an effective AFFF that is free of fluorocarbon surfactants 

altogether, which eliminates the environmental and health hazards associated with PFAS. A 
100 

number of these foams are currently on the market. While available for commercial and 

civilian uses, such foams may not meet the more stringent U.S. military performance 

standards. 

Moving Forward Without Toxic Foam 

Despite important advances limiting human and environmental exposure to PFOS and 

PFOA, we remain concerned that fire fighters continue to be exposed to these toxins in legacy 

foams still in use or in stockpiles. As a result, fire fighters are continually regularly exposed to 

foam containing PFAS and at risk for potential health impacts. As we learn more about the 

potential health impacts of fluorinated chemicals, we must take steps to reduce fire fighters' 

exposure and protect their health. 

Washington State is leading the way in these efforts. In March, Governor lnslee signed 

legislation banning PFAS in Class B firefighting foam designed for flammable liquid fires and 

firefighting personal protective equipment. Steps are also being taken at the federal level. The 

recently negotiated FAA Reauthorization Act contains language championed by Senator Peters 

permitting airports to use non-fluorinated fire fighting foams. We support this language and 

are pleased airports will now have the ability to transition away from toxic foams. 

We know PFAS presents a health risk to workers, such as fire fighters, who are exposed 

on a regular basis and thus we seek to ultimately discontinue the use of PFAS foams. In recent 

years, driven by the European and US reforms, fluorine-free foam technology has advanced to 

counter concerns raised with PFOS and PFOA fluorinated foams. Fluorine-free foams are now 

available in the international market. 
101 

Fluorine-free foams continue to gain wide acceptance in Europe and Australia where the 

use of Mil-Spec AFFF isn't required. Several European locations having transitioned to the new 

formulations have reported acceptable firefighting experiences with fluorine-free UL approved 

foams. In 2015 an engine fire occurred on a British Airways aircraft located at london's 

Heathrow International Airport. The fire was successfully extinguished using a fluorine-free 

foam. Following the incident, officials were not only pleased by the performance of the 

fluorine-free foam, but also recognized the fluorine-free foam came with the benefit of an 

absence of known health hazards, zero clean-up cost and no environmental damage. The IAFF 

supports the use of non-toxic foam formulations. 

In the interim, we must acknowledge that fire fighters have been, and will continue to 

be, exposed to toxic PFAS. In addition to exposures from foam and as a by-product of 

combustion of consumer goods manufactured with PFAS, such as upholstery, in the past, PFOA 

was a chemical building block or by-product created within the manufacture of water repellent 

treatment and moisture barriers for turnout geat. Major U.S. manufacturers have assured IAFF 

that PFOA is no longer present within the moisture barrier of turnout gear or in the barrier 

treatments of used on turnout gear, but the toxin may be present in legacy gear. To better 

protect fire fighter health, we support discontinuing the use of legacy foams and turnout gear 

containing PFOA. 

Few scientific studies of PFAS examine fire fighters. Those that have are of little 

statistical significance due to the limited size of the test group. We believe more studies on fire 

fighters' exposures and health impacts must occur. Additionally, we believe all fire fighters 

must receive annual physicals which include blood testing to determine the level of PFAS in the 
102 

fire fighter's bloodstream. Such information will allow fire fighters and their doctors to take 

active steps to better protect their health and treat any potential health impacts which may 

have already occurred. 

Conclusion 

On behalf of the International Association of Fire Fighters, I appreciate the opportunity 

to testify on the federal role in the toxic PFAS chemical crisis. As a nation, we have made 

significant positive progress in recognizing the emerging threat to human health caused by 

PFAS exposure. It is crucial that as we move forward, we take immediate steps to limit the fire 

fighter exposure to the toxic formulations of AFFF. To the extent that I or the IAFF can assist 

the Subcommittee in these efforts, I am happy to offer our expertise and pledge to work closely 

with you and your staffs. 

Again, I'd like to thank the Subcommittee for the opportunity to testify today and am 

happy to answer any questions you may have. 
103 

Hello, my name is Scott Markham, and I am from the 

Parchment area in Michigan. I am here today as part of 

a contingent of citizens and activists, concerned and 

deeply affected by the pfas poisoning of our water and 

soil in the community in which we live. As you may 

know, our entire city water supply was contaminated by 

pfas pollution. Every member of my family drank this 

wat~r at some point. Its effects on myself and my 

family remain unknown at this time. 

Industries, like the paper mill responsible for the 

contamination in my community, are able to declare 

bankruptcy and skip town leaving their pollution behind 

for small towns like mdne to grapple with. Mechanisms 

designed to address this contamination, like the 

Superfund program, and brownfield remediation programs, 

are consistently underfunded and given a low priority 

by legislators. The result has been to allow polluted 

industrial sites like ours to leak their contamination 

into the ground, air and water. 

The time has come for Congress to do right by these 

communities. These polluting industries provided 

rniddle class jobs at one time, but those jobs are now 

long gone, and the legacy of those industries is often 

the pollution they've left behind. Human health, 

particularly in vulnerable low income communities, is 

suffering. I am here today to ask congress to make 

cleaning up these industrial sites a top priority, and 

to fund those remediation programs appropriately so 

that lives can be saved through removal of carcinogens 

and other harmful pollutants. 

In addition, current EPA policy is that human 

impact studies are not required, and nothing is 

currently being done to know what a chemical's impacts 

will be on human health before its' released. I am 
104 

asking Congress to refoDm the EPA guidelines so that 

those studies are required before a chemical is 

released into our communities for mass use and 

consumption. In fact, in the case of pfas, 3M knew as 

early as 1981 that pfas caused cancer in mice and it 

was allowed to continue to be included in an endless 

number of products in the decades that followed in such 

massive quantities, that as of today there is nowhere 

on earth that does not have some detectable level of 

pfas. 

I hope that hearings, testimonials, and reporting 

about pfas and other pollution will be a lesson to 

Congress that reforms are necessary. I ask that 

Congress put the value of human life above 

corporations, because this is not an economic issue, 

this is a social justice issue, with human lives 

including the lives of those in my community and my own 

family depending on Congress taking action so that 

never again will communities be helpless to deal with 

the contamination that is a threat RIGHT NOW, all 

across our country. 

Thank you 
105 

Date: September 26th, 2018 

To: U.S. Senate 

From: Bob Allison, Deputy Director, Michigan League of Conservation Voters 

Re: Signatures requesting action from the U.S. Senate on PFAS contamination in Michigan 

The Michigan League of Conservation Voters joins more than 500 of our members in urging the 

U.S. Senate to take immediate action on PFAS water contamination in the state of 

Michigan. 

On behalf of !he undersigned: 

I am writing today to urge you to take immediate action to address the growing threat of 

PFAS drinking water contamination in Michigan. 

There are now 29 communities where PFAS contamination has harmed public health and made 

our water undrinkable. This forever chemical, which builds up in the blood and stays there for 

years, does not present itself in illness or immediate symptoms, but causes chronic, life-altering 

disease and health issues that will plague thousands of Michiganders, and will continue to 

unless action is taken. 

Worse still, the handling of the discovery of this contamination by our state has been marked by 

a continued lack of transparency. Six years ago, the Michigan Department of Environmental 

Qua!Jty ignored a 2012 report that warned of widespread PFAS contamination in Michigan and 

proposed urgent recommendations that could have protected families. This was done with the 

knowledge of the irreversible harm contamination would have on the health of Michiganders 

whose drinking water was polluted. 

Michigan residents, like everyone, deserve to be able to trust that the water coming out of their 

own tap is safe to drink-yet increasing discovery of drinking water contamination statewide 

means thousands of residents cannot. 
106 

Moms, dads, children, grandparents, aunts, uncles-they are all being affected. Everyday 

people, who have done nothing but drink the water that they have access to, face life and death 

situations. Daily, they wonder: is this ailment due to contamination? Will their home now be 

unsellable? They feel they have been unknowingly poisoned-and no one is there to help them 

deal with the aftermath. 

I urge you to take steps to lead on this issue and address the growing threat that PFAS 

oontamination means for the people of our state. We cannot afford to wait for Michigan to act. 

This is a public health crisis that cannot be ignored. 

Sincerely, 

iviall Name City State Zip 

Michael Salgat Plymouth Ml 48 

Phillip Alward Fenton Ml 48 

Matthew Herrington Flushing Ml 48 

Bette Swando Saint Clair Shores Ml 48 

Robbi Chisholm Wyandotte Ml 48 

Alicia Baker New Hudson Ml 4. 

Erik Peterson Troy Ml 48 

Carol McGeehan Holland Ml 49 

Mark Johnsen Commerce Township Ml 48 

Jazmine Harvey Kincheloe Ml 49 

Laura Lyons Ludington Ml 49 

Susan Peters Dewitt Ml 48 

Melissa Hoving Portland OR 97 

Carol Shuckra Traverse City Ml 49 

Louis Under Briarcliff Manor NY 10 
107 

Bill Polosnak Troy \111 

JoanPe Wiertel!a Dexter Ml 

Delisa Nonb Southfield Ml 

Gill Kastler New Baltrrnore Ml 

l\·1ark Suchyla Ann Arbor tAl 

Su<<:~nne Zelnik Geldys Dearborn Heights Ml 

Marjorie Castanien Defiance OH 

Barbara Stevenson Detro.! Ml 

Barb Wallace Grand Rapids Ml 

p fs Ann Arbor ~-~~ 

Deborah Gardne' Caseville Ml 

Kathy ruckerman Traverse C:ty Ml 

Rebecca D. Steel Kalamazoo tv I 

Juanita Butcher Plainwell Ml 

Dorene Doane Sylvan Lake Ml 

Wendy Nystrom Big Rapids M! 

Jim Murphy Havertown PA 

Margaret Rink Chelsea Ml 

Natalie Keast Berkley Ml 

Carol Berard Snini Joseph Ml 

Donna Wethy S:erling heights Ml 

Karen Roeper Traverse City Ml 

Courtney Stanley Comstock Park Ml 

Shan!'lon Abbot: Grand Ropias Ml 

Brenda .Jellies Lawton Ml 
108 

Leslie Sutliff Ashley Ml 

Justin Eldndge Wyoming Ml 

Linda Prostko Caledonia Ml 

Lindsey Walker Petoskey Ml 

Dean Sherwood Farmingtor1 Hills Ml 

Jeremy Day Greenville Ml 

Ann Kraft Chelsea Ml 

David helfrecht Saginaw Ml 

Sheila Martin Grand Rilpids Ml 

Aliln WaiC78k Grand Rapids Ml 

Barbara Bachman Farmington Hills Ml 

Becky Sulliva'l Saginaw Ml 

Mary Thoma Oak~<~:ood OH 

Julie Moylan Troy Ml 

James MCFA! .L Topinabee Ml 

Margaret VanHoudt Spring Lake Ml 

Elaine Connors Madison Heights Ml 

Laurie Muntter Jenison Ml 

Mark Boik Sterling Heights Ml 

S<Jndrn Lintz Indian River l'vll 

Marilyn Scott Ann Arbor l'vll 

Mary Peterson Saint Joseph l'vll 

Lon McElhaney Hudsonville l'vll 

Marc Taras Ann Arbor Ml 

Jeanine Weber Grand Rapids Ml 
109 

Carolyn Morado Ann Arbor Ml 

Paula Osburn Onsted Ml 

Michael Buza Swartz Creek Ml 

Charles Wolterink Traverse City Ml 

Edmund Ammen Ann Arbor Ml 

Barbara McGraw LivoniA Ml 

Susanne Matthews Wyoming Ml 

Sue Balk Monroe Ml 

Robin Ripmaster Grand Rapids Ml 

Steven Johnson Portage M! 

Nicholas PAgAnelli Grand Rapids Ml 

Scotl Golding Ann Arbor Ml 

i<en Zimmerman Ithaca Ml 

Gina Bates Apple Creek OH 

Thomas McKarns Ann Arbor Ml 

Cynthia Sherman-Jones Chatham Mf 

Jack Adams Deford till 

Debra Moore Clio Ml 

Marta Johnson Grand Rapids Ml 

Gary Salata Canton Ml 

Kristine Melendez Livonia Ml 

Trudy Hughes Ann Arbor Ml 

Mike Soto Westland Ml 

Odn Gelderloos Dearborn Heights l'vll 

Lynn Done!! Livonia Mf 
110 

Debra Glen Pinckney Ml 

Susan Shink Ann Arbor Ml 

Natalie Cizmas Ypsilanti Ml 

scott flood Niles Ml 

Bob Kubiak Clay Ml 

Timothy Shields Dearborn Heights Ml 

S!",a;·on Bodek Rochester Ml 

Mon!P. RogP.rs Spring Lake Ml 

Jacqueline TP.ssrnan Benton Harbor Ml 

Tom Emmott Traverse City Ml 

Dorothy Frisch Grand Rapids Ml 

Dency Lppert Manistoo Ml 

patricia martin Mackinac Island Ml 

Jerry Mawhorter Royal Oak Ml 

Martin Schnur Comstock Pork Ml 

Moria Ross Beverly Hills Ml 

Jarnos Lange Alto Ml 

3iephen Fuller Charlotte Ml 

J McDaniels Williamston Ml 

Tamara Meyers Ada Ml 

Linda Looney Grandville Ml 

Theresa and Barbara Larnarr Detroit Ml 

Suzannah Greve Traverse City Ml 

Karen Rossman Whitehall Ml 

Phoebe Schutz Lake Orion Ml 
111 

.Jn~r;;ph Byme Birmingham rv11 

Marianne Fix Trenton lvl! 

Katherine Heins Traverse City Ml 

Steve Frederick Sault Sainte Marie Ml 

Nichole Welch Galesburg Ml 

Virginia Jones Kalamazoo Ml 

Susan Burack Hancock Ml 

Gregory Cole Oscoda Ml 

Geraldine Seger Lake City Ml 

Marisa Gies Detroi; Ml 

Liz Storm Petoskey Ml 

J:me Westerfield Allendale Ml 

Marion Collier Birmingham Ml 

Susan Frahm Middleville Ml 

Kaylee Swanson Grand Rapids Ml 

Shannon Donley Grand Haven Ml 

Janet Lenic Comstock Park Ml 

Jeanne Sekely Marquette Ml 

Tara Conaway Byron CentM Ml 

Wtlliam.lcnes Allegan Ml 

Sherril VandePutte Ortonville Ml 

Joe Kellerman Bay City Ml 

Audrey Minick Minick Milan Ml 

Pat Nicely Grand Repids Ml 

Bonnie E!bodc Eastpointe Ml 
112 

Georgette and Paul Engard Grand Blanr: Ml 

Mary O'Neill Presque Isle Ml 

Katie PArrish Ann Arbor Ml 

Anna Roush Ypsilanti Ml 

Chad Cooley Grand Ledge Ml 

L:ori Pescj Lake Orion Ml 

Pat Arrowood Gulliver Ml 

Sandy Pardo Garden City Ml 

Lynne Crandall Ann Arbor Ml 

Debra Lisull Ann Arbor Ml 

Pamela Bloink Rockford Ml 

Marsha Boettger Waterford Ml 

Amanda Beilfuss Rockford Ml 

Melissa Garey Rockford Ml 

Connie Tennant Ann Arbor Ml 

Mary Matthews Northville Ml 

Tessa Harvey Ann Arbor Ml 

james smit Marquette Ml 

Debbie Shannon Grand Blanc Ml 

Judith Richards Lathrup Village Ml 

Mary Mudie West Bloomfield Ml 

Michael Kwitt Warren Ml 

Sarah Schaefer Grand R;:;pids Mi 

Laurie Smith Evart Ml 

Michelle Daugherty Ann Arbor Mi 
113 

Lisa Frucci Niles Ml 

Wilfred Von zastrow Bloomfield Hills Ml 

Johanna Harding lansing I\.~ I 

Laura Fl8k Wyandotte Ml 

Roy Smith Flint Ml 

Diane Merman Monroo Ml 

Martha M. Wileon Van Buren Twp Ml 

Peggy Johnson Lake Ann Ml 

Joseph Good Oxford Ml 

BfBayha Westland Ml 

Lynda Charlebois Lapeer Ml 

Julia Skelton Van Buren Twp Ml 

Roberta Marine Lansing Ml 

AI Norkey Jackson Ml 

Kathy Mason Sebewaing Ml 

Mike and Susan Raymond Shelby Township Ml 

Stacy Niemann Battle Creek Ml 

Melody Arnott Dearborn Heights Ml 

Peter & Martha Blom Orchard lake Ml 

Barbara Speiser Canton Ml 

Janet Ginepro Monroe Ml 

June Picard Picard Bay City M! 

Lome Beatty Brighton Ml 

K Sneden Lowell Ml 

Cathy Wusterbarth Oscoda Ml 
114 

Margaret Halpern Ann f\rbor Ml 

Alyssa Moritz Flat Rock Ml 

Douglas Harter Kalamazoo Ml 

Loe Gorman Ann Arbor Ml 

D;:;nnis t'Cichtinger Trenton Ml 

Toby Weiner Dolinka Grand Rapids tvll 

Kristen White Grayling Ml 

Katherine Bu~ch Wyoming Ml 

Marlhea Jager Grand Rapids Ml 

Sarah Adrian Southfield Ml 

Cody Angell Belmont Ml 

Steve White Midla:td Ml 

Matthew Schaut Minneapolis MN 

steve lrevaskis Clarkston Ml 

Mary Naour Adrian Ml 

iviichaef Seiler Rochester Ml 

Robert & Georgia Simpson Flint Ml 

Francine Dolins Ann Arbor Ml 

Ann CMcGi!l Brunswick OH 

Nzingra Masani·Manuet Detroit Ml 

Kimberly Gilbert White Lake Ml 

Ann Therese Foley Nazareth M! 

Fawn Guffey Charlotte Ml 

NelsonS Ypsilonti Ml 

Kyle de Boausset Grosse lie Ml 
115 

Kevin Cranial< Boyne Falls Ml 

Joyce Oatley Cadillac Ml 

Steve Smiih Smith Bellaire Ml 

Linda Kolich Kalamazoo Ml 

Dawn Uhen Grand Rapids Ml 

Kahley Crittenden Grand Rapids Ml 

Dlx'e Lumbard Otsego Ml 

Ginni Wandron Travers<:~ City !Vll 

Marcia Kutchin Ada Ml 

FARlAN MENDEZ Grand Rapids Ml 

Joyce Root Kalamazoo Ml 

Melisse~ Starrett Kalamazoo Ml 

Joel! Garber Grand Rapids Ml 

Matt Lockwood Belmont Ml 

Darin Ellard Kaiamazoo Ml 

Stacy Gaudio Rockford Ml 

Stephanie Morris Cedar Springs M! 

Patricia Johnson Oscoda Ml 

Gail Weatherwax Kalamazoo Ml 

Casey Amidon Kalamazoo Ml 

Rrandon Moeller Portage Ml 

Kathleen Steffens C>!rp take Ml 

Jane Henshberger Hudsonville Ml 

Kris VanKampen Grand Rapids Ml 

Terri lupo Plainwell Ml 
116 

Vicki Reese Wyoming Ml 

Monica Vandervegte Nl':waygo Ml 

Shannon Schwenke Orioons Ml 

Kevin Brown Grand Rapids Ml 

Fran Silva-Biayney Colorado Springs co 

Julie Wiser Belmont Ml 

Robin DeHaan Kaiarnawo Ml 

Jade Orlich Grand Rapids Ml 

Tarnrny Cooper Kalamazoo Ml 

GA YE RACZKOWSKi Grand Rapids Ml 

Krist! Lloyd Hickory Corners Ml 

Bonnie Anderson-Butler Ka:amazoo Ml 

Roger Storm Wyoming Ml 

Belinda Johnson Oscoda Ml 

Tess Nelkie Tawas City Ml 

Becky Snyder South Haven M! 

Jade Cruz Grand Rapids Ml 

Shelry Pennington Dorr Ml 

Susie Austin Belmont 1\M 

Angela M. Garcia-Johnson Bellevifle Ml 

Thomas Pnttok Belmont Ml 

Tony James Kalamazoo 1\11 

Heidi Zuniga Allendale Ml 

Colby Crittenden Grand Ropids Ml 

Ross Blake Utica Ml 
117 

Debi Pulido Nashville Ml 

Mary Michela Prudenville Ml 

Donna Tingley Oscoda Ml 

Linda Rothentholor Rockford Ml 

Sharon Andre Prudenville Mt 

Jane Ludtl~e Rockford Ml 

Rich Deszell While Lake Ml 

J Malla:·1ey Sparta Ml 

Ben Geiger Kalamazoo Ml 

Valerie Wychers Dorr Ml 

Ted Storm Grand Rapids Ml 

Stephanie Smith Belmont Ml 

Nancy Martin Grand Rapids Ml 

Chantal Storm Grand Haven Ml 

Jessica Federico Grand Haven Ml 

Lourene Rife South Haven Ml 

Paul Storm Cedar Springs Ml 

Nicole Eklund East Tawas Ml 

wililam weber Newberry Ml 

Tamara McArthc;r West Haslett Ml 

Courtney Breining Rosr.omrnon Ml 

Liz Cox Belmont Ml 

J::lmi Price Caledonia Ml 

Elissa Barkema Grand Rapids Ml 

Jennifer Van Eyk Kalamazoo Ml 
118 

Cynthia Rouse!! Caledonia Ml 

.Jeanette Solomon Rockford Ml 

Laurel Joseph Grand Rap:ds Ml 

Jennifer Kramarz Belmont Ml 

Ron Osga Thompsonville Ml 

Michael LaCroix Grand F\apids Ml 

Melissa Walters Kalamazoo Ml 

Barbara Porter Grand Rapids fv11 

Michal Enders Middleville Ml 

Dave O'Leary Oscoda fVH 

KIM LEPERT Kalamazoo Ml 

Nancy Craig Kalamazoo Ml 

Bieler Craig Kalamazoo Ml 

Roberta Friday Houghton Lake Ml 

Usa Daubenspeck Oscoda Ml 

Casey Gabhart Kalamazoo Ml 

Sue Smits Comstock Park Ml 

bruce evans Hamilton Ml 

Robin Trebilcock Rockford Ml 

Brenda Maurer Kalamazoo Ml 

Meghan Stanfo'd Pnrt8oe Ml 

Kimberly HBihe' Grand Rapids Ml 

Karen Jaynes Black River Ml 

Marilyn Overholt Oscoda Ml 

Sue Bockstanz Kalam;Jzoo Mi 
119 

Amy Schneider Comstock Park Ml 

CrysiRI Gray Grand Rapids Ml 

Melanie Karr Grand Rapids Ml 

Patricia Baldwin Grand Rapids Ml 

Gordon Vanloozenoord Belmont Ml 

Sharon VonLoozcnoord Belmont Ml 

James Mcpheron Grand Rapids Ml 

Deborah Finkler Grand Rapids Ml 

Deb Brase Belmont Ml 

Ken Brase Belmont Ml 

ELIZABETli MARCKINI Cedar Spnngs Ml 

Judy Croff Grand Rapids Ml 

Wyneese Stanfort! Grand Rapids Ml 

Colin McHugh Plainwell Mi 

EHeen .Johnson Lake Orion Ml 

Susan Axtell Gwinn Ml 

Kim Miller Cassopolis Ml 

Linda Francisco OakPark Ml 

Patricia I Sitran Warren Ml 

Del Tavares-Proctor Pangburn AR 

Simone Proulx Haslett Ml 

Patricia Czurak Crater Grand Rapids Ml 

Cinda Birely Rockford Ml 

Janice Tomlian l.ansing Ml 

Janet Hansen Pontiac Ml 
120 

Danielle Congleton Dewitt Ml 

Brandy Storm Grand Haven Ml 

Helrn Silas Portland Ml 

Katy Steele Gnmd Rapids Ml 

Chflryl Church Wells Ml 

Victoria Honold Eastpointe Ml 

Judy Barber Bradenton FL 

Hiiary Hunt Kalamazoo Ml 

Joyce Taczer Glendale Cl>, 

Michael Hansen Westland Ml 

KodyVitale Brighton Ml 

Joseph Cornelius Gwinn Ml 

Lisa James Novak Kalamazoo Ml 

Barl:Jara Goudreau Comstock Park Ml 

Hannah Taylor Wyoming Ml 

Robert Goosney Onaway Ml 

Steven t:lizzis Portage Ml 

Brenda Shinabarger-Howe Dowling Ml 

Melissa Leitch Grand Rapids Ml 

Stacy Loew Grandville Ml 

Torisa Baranoski Comstock Park Ml 

Lori Sharrar Temperance Ml 

Steve Hartzler Lake Ml 

Robir, Vanderjagt Belmont Ml 

John Latta Ann Arbor Ml 
121 

Karen Dukovich r:rankenmu!h Ml 

Stephen Wooden Grand Rapids Ml 

William Herman Livonia Ml 

Ronald Zurawski Menominee Ml 

Sherry Opalka Kalamazoo Ml 

Jon Krueger Jackson Ml 

Micho!e Kowalski Eaton Rapids fvll 

John Poore Lansing Ml 

Debra Bayley Walled Lake Ml 

Steve Keirn Columbiaville Ml 

Matt Brzezinski Saint Clair Shores ~111 

Deborah Glbbs-Halm Grand Blanc Ml 

Lynda Asher Ann Arbor M! 

Urmila Padmanabhan Fremont CA 

Cheryl Landrum Port Huron Ml 

Lana Bobak Rochester Hills Ml 

Heath Post Lansing Ml 

Dianne Minicucci Lake Ann Ml 

Gretchen Rose Cedar Ml 

Evelyn Millstein Royal Oak Ml 

Vince Cerutti Ann Arbor Ml 

rosemarie werner Standish Ml 

Bonnie German Rochester Hills Ml 

Jeff Kronick Lake Orion Ml 

Marty Albert Battle Creek Mf 
122 

Kathrina Spyriclakis Birmingham Ml 

Sarah Sercombe Royal Oak Ml 

Rosalind Folman Royal Oak Ml 

Dan Fogarty Santa Rosa CA 

Mark Messing Traverse City M! 

Shelly Winney Grand Rapids Ml 

Cynthia Edwards Ann Arbor Ml 

Lori Mulvey Comsiock Park fV:I 

Dert:k Gendvil Las Vegas NV 

Philip Robar Saint Luui::s fV:I 

John Lorand Mount Pleasant Mi 

Gale Shafl<ind Royal Oak M! 

Robin Graubartll Ann Arbor Ml 

Margo Lesser Birmingham Ml 

Kenneth Large Royal Oak Ml 

Andrea Zajac Williamston Ml 

Susan Gitterman Ypsilanti Ml 

Kristin Klass BridQman Ml 

kathleen brown Pinckney Ml 

Elise Muffitt Ann Arbor Ml 

Daniel Cavanaugh Belleville Ml 

Debra Lane Fort Bragg CA 

Patricia Austin South Branch Ml 

Susan Sorg Grand Rapids Ml 

Peggy Malnati Farmington Hills Ml 
123 

Francine Melotti Oxford tvll 

Jeffery Morgenthaler LowP.II !'vll 

Ken Galica Farmington Hils Ml 

Maureen SheAhan Southfield M! 

Carl Michel Ann Arbor Ml 

Gavin Bornholtz Gmnd Blanc Ml 

Sue Basta Commerce Township Ml 

Don Thompson Cambridge MA 

Carol Mohr Ann Arbor Ml 

Tia Pearson Wahiuwo HI 

Greg Bcown Key West FL 

Brenda Albunese Sparta Ml 

Lori Lyles Flint Ml 

Robert Moore Clio Ml 

Jason Moritz Jackson Ml 

James Shepherd Rives Junction Ml 

Ann Hifdebrandt Detroit Ml 

Charles D'neen Lawton fvll 

Frank Vaydik Sag:naw Ml 

Ann Marie Teli Chesterfield Mi 

Kala Friddle Grand Rapids M! 

Steven Cypher Rochester Ml 

Tom Kozel Clarksville OH 

Nicole Wolf Rochester Ml 

Roxanne Haslem Grand Rapids Ml 
124 

Michael Sklar Huntington Woods Ml 

Richard Tipton Hubbardston Ml 

David Warren Traverse City Ml 

Grace Strong Ironwood Ml 

Marilee Mouser Ithaca Ml 

Freya Hi'mis Atlanta GA 

Anne Pavlic Northville Ml 

Henry Velick Ann Arbor Ml 

Marlea Shirley Free Soil Ml 

Paul Kennan Hazel Park Ml 

Leslie Watson Gwinn Ml 

JoAnn Render East L<:msing Ml 

Joan Berger Brownstown Ml 

Cynthia Dudley Ludington Ml 

JoE!Ien Rudolph Petos~.ey Ml 

Marianne Kovalcik Sterling Heights Ml 

Bob Johns Saint Johns Ml 

Julie Ozias Waterford Ml 

Janet Anderson OakPark Mi 

Megan Faber Denver co 

Christine Mathews Fenton Ml 

Mark Swanson Ann Arbor Ml 

daniel polley Chicago IL 

Diana Munch Southfield Ml 

Annie McCombs Kalamazoo Ml 
125 

Rob Jenkin Walled Lake Ml 

Georgiann Young Saint Joseph Ml 

DENISE HAWKINS Lathwp Village Ml 

Stefania Johns Royal Oak Ml 

M<'lria Prokopowycz Lapeer Ml 

Michael Maggied Mesa AZ 

Cindy Borske New Hampton 1/\ 

Timothy Schacht Grosse Pointe Park Ml 

Carol Sears Grand Rapids M! 

Eric Stordahl Marquette Ml 

George White KalamaLoG Ml 

Maria rJliller Grand Rapids Ml 

Carol Stoody Clay Ml 

Jeanine Center Ann Arbor f'vll 

Nancy Godwin Tucson AZ 

John Renfrew Marquette Ml 

Diane Good Bellaire Ml 

lindsay Conkli:l Howell Ml 

Anne Horn Okemos Ml 

Denise Brennan Auburn Hills Ml 

Kristyn MacPhail Littleton co 

Martha Vermeulen Grandville Ml 

Tracy Holthaus Kansas City MO 

Ester Fuchs Lapeer Ml 

Usa Hammermeister Granada Hills CA 
126 

Deborah Nicholas Plymouth Ml 

Kyle Peterson Sterling Heigh:s Ml 

Lee Hegstrand Grand Rapids Ml 

Amanda Davis MoiJnt Clemens Ml 

Susan Welsford Norton Shores Ml 

Oksana Bohatch Grand Rapids Ml 

Leslie Dryg Grand Rapids Ml 

Martha f<ransdorf Ann Arbor Ml 

JAMES DAWSON Davis CA 

Greg Collins Coopersvflle Ml 

Michelle Ash Lake City Ml 

Peter Rogan Royal Oak Ml 

F>arnela York Beverly Hills Ml 

Patricia Murray Ann Arbor Ml 

Michele Reynolds Oak Park Ml 

Ann Wright Ypsilanti Ml 

Daniel Coyne Kalamazoo Ml 

Alison Zaharee Whitmore Lake Ml 

Dale Carpenter Lake Crion Ml 

Marilyn White Whitehall Ml 

Richard Han Ann Arbor Ml 

Emily Bovee Rochester Hills Ml 

Ernest McCaruB Ann Arbor Ml 

Nancy Weatherwax Albion Ml 

Tom Porter Ann Arbor Ml 
127 

Becky Posey Clawson Ml 

Peter Quackenbush Dewitt Ml 

Annette Briggs Three Rivers Ml 

Rick Brigham Douglas Ml 

Jack Preiss East Lansing Ml 

Andrea Rendzipcris Saline Ml 

Dolores Reynolds Grand Junction Ml 

Jackie Byars Ann Arbor Ml 

Amanda Robert Milford Ml 

Ron ChellamJ Norton Shores M! 

Margaret Kephari Ann Arbor Ml 

Kay Clifford Ann Arbor M! 

Sharon Klotz Parma Ml 

kay courtney Grand Rapids Ml 

James Crowtoot Ann Arbor Ml 

John Krohn Lansing Ml 

Stephanie Seme<:er Port Huron Ml 

Margaret Slawson Traverse City Ml 

Ruth Lezotte Suttons Bay M! 

GeorgAnne Dian Marysville Ml 

Daniel livingston Marshall Ml 

Linda Luke Van Buren Twp Ml 

Karen Stankye White L<1ke Ml 

Jill Marcusse Grand Rapids Ml 

JO ANN MARCOUX Ann Arbor Ml 
128 

Lee Engstrom Grand Rapids Ml 

Pat Tessler Ann Arbor Ml 

Judith Foy Ann Arbor Ml 

JoyGe Stein Brooklyn Ml 

Kelly Anderson Ann Arbor Ml 

Thomas BE~nnctt Evart Ml 

riGhord smith Mei'tindale Ml 

Hugh Hazelton Hinsdale ll 

Tf:eone Thomas Royal Oak Ml 

Anne Wither, Alexandria VA 

Michelle Bryan! Lake Orion Ml 

Caroi Hayford Bloomfield Hills Ml 

Paula Globerson Ann Arbor Ml 

Kathie E Takush Reading PA 

Georgia Donovan Rockford Ml 

Gordon Jones Grand Rapids Ml 

Jan Sockness Ann Arbor Ml 

Sharon Kamarainen Gladstone Ml 

Brian Dalton Dearborn Heights Ml 

Katherine Mouzourakis Westland Mi 

Sandra Maar Gwinn Ml 

Virgirfa Catanese Grosse Poir.te Mi 

Chantelie Hosner Burt Ml 

Jasmine Shock Chesterfield Ml 

Mort Zukerman Grand Rapids Ml 
129 

,Janice Prokop-Heitman Plymouth Ml 

BenjHmin I eP. Cottrell ville Ml 

Charlene Jones Lansing Ml 

Christy Giesick Clinton Township Ml 

Michele St Peter Flat Rock Ml 

Jerry Bierens l\1i!ford Ml 

william brooks Roseville Ml 

Ron Katz Huntington Woods Ml 

Lynne Van Ness Traverse City rvu 

Paul McCullough Prudenville Ml 

Mindye Forlgang fvltmick NY 

Frank Gonzales Jr. Plymoctlh Ml 

Jack Lutz Troy Ml 

C. James Ringwald Houghton Lal\e Ml 

Lorraine Thompson Saline Ml 

Donna Browne Sewell NJ 

Carolyn VandenBerg Grand Rapids MJ 

Mike Duffy Hazel Park Ml 

John P Davis Huntington Woods Ml 

Kathleen Davis Marquette Ml 

Matthew Rife Ann Arbor Ml 

Marie chuchvara Davison Ml 
130 

Dear Chairman Paul, Ranking Member Peters, and Committee Members: 

My name is Tess Nelkie. I live in Tawas City, Michigan, 12 miles south of Oscoda and the former 

Wurtsmith Air Force Base. I have lived in this area since 197 4 and am a retired teacher of deaf and hard 

of hearing children. I taught for 41 years and worked with children from the whole county, including 

children !rom Oscoda. My program was housed in the Oscoda Area Schools for many years before 

being moved to a more centrally located classroom in the Tawas Area. My husband and I own Nordic 

Sports, a specialty sporting goods store in East Tawas. We opened the store in 1976. I am a member of 

Anglers of the Au Sable (I'm on the board of directors.), Fly Fishers lntemalional, Trout Unlimited, and 

Ducks Unlimited. 

I became aware of PFAS in 20i 2 when I went to a public informational meeting in Oscoda. I fished and 

canoed on the Au Sable River, and its health wa~ important to me. After the meeting, my husband and I 

were asked to be on a committee in conjunction w'1th rne Michigan Department of Health and Human 

Services to warn the public that they should not eat resident fish on the Au Sable River due to PFAS 

wnramination. We met as a committee several times until warring signs were erected along the river. 

Because I fish, recreate, and hunt In and around the Au Sable River, its health Is important to my health 

and my family's health. People in northeast Michigan filllheir freezers with wild game such as venison, 

fish, ducks, geese, and rabbits. They forage tor mushrooms and berries. This is not uncommon here. 

The schools in the county are closed on November i 5th every year because that day is the opening of 

rifle season for deer hunting. This has gone on for decades dating bacK to long before I moved here over 

40 years ago. The contamination has ruined this lishingfhun\ing tradition lor many residents and visitors. 

It has cut off a reliable food source. Wild game used to be thought of as the healthy alternative to what 

was available in stores. No longer is this true. Our natural resources are contaminated to the point 

where every time I pour myself a glass of water from the tap, I question its safety. No longer do l enjoy a 

meal of bluegills. When duck hunting, I wonder where the duck's last resting pond was. Was it Clark's 

Marsh (a Duck's Unlimited project just off the former Wurtsmith AFB runway)? A marsh so contaminated 

with PFOS that the public is warned not to eat lillY fish of fttll1 size from there. If so, I'll pass on that duck. 

The hunting/fishing tradition and way of life is being ruined here. The fabric of the rural American life is 

deteriorating due to contaminated natural resources. Thls Is a crisis because PFAS has sickened people 

and wildlife, and it continues to do so every day. 

I want my government to require the U.S. Air Force to contain and remove the plumes of contaminated 

ground water that are sickening our people and natural resources. I want my government to listen to the 

ATSDR's recommendation for drinking water standards and make them more in line with what the 

scientists recommend. 1 want my government to require that the mess that was left by the Department of 

the Defense in Oscoda, Ml be cleaned up by the Department of Defense. I want the Department of 

~"fsro~e to take care of the heallh of the veterans, !heir families, and all th& families who live here and are 

dealing with health issues related to PFAS. I want to be proud of my government and defense 

department because they do the right lhing because they are honorable people from an honorable 

country. 

I ask that you please submit this latter into the record for the hearing titled "The Federal Role in the Toxic 

PFAS Chemical Crisis." 

Sincerely, 

Tess Nelkie 

September 20, 2018 
131 

Sa~ Sep 22,2018 al12:01 PM 

IMPACT OF PFAS CONTAMINATION - WURTSMITH AIR FORCE BASE OSCODAMI 

PFAS contaminalion has changed my life in ways I did not dream possible. 

Living in Oscoda Ml had always been my dream. My great grandparents homesteaded within a few miles of 

my current Oscoda home. After receiving degrees from Michigan State and the University of Michigan and 

pursuing a career in the metro Detroit I Ann Arbor area, I retired 1o Oscoda. During my entire life I had always 

returned to the Oscoda community on the weeK.;!nds. It felt as though it was a pristine place. lake Huron is 

majestic with beautiful sandy beaches, !he AuSable River is mighty, providing for our electricity, and VanEtten 

lake provides our fishing and boating water. The national and state forests are beyond compare. All provide 

needed employment in our area. 

For many years Wurtsmith AFB was an integral part of our Oscoda community. The base was what we always 

thought to be a "good neighbor." My daughter pursued a medical career mottvated by the wonderful 

experience she received as a civilian base volunteer at the military hospital. The members of the military 

enriched our lives; they came from all comer of our country and always were open to new friendships. 

Then it ended. The military packed up and left. The problem was that they left a dirty big secret -- lethal 

~nt.;:af'!1l~stion. Periodically military and federal staff are sent in to placate us. Small actions are taken but they 

can only be compared to the tiniest of band-aids taken from your medicine cabinet. Would you place such a 

small patch on a severed artery? I think not. 

What do we need? 

1. Appropriations so our rural community can test and extend municipal water lines to all of our citizens who fear their own wells 

2. Appropriations lor monitoring and restoring beautiful vanEtten Lake (runmng next to the AFB} 

3. Appropriations lor research on the removal or neutralizing of Chemicals that have poisoned our water 

supply 

4. Recognition that the OScoda 1 WUrtsmllh contamination IS unique in that 1t enters nearby Lake Huron, one 

of the Great Lakes that hOld 84% of our fresh water 

My experience with PFAS contammation IS a common story. It haunts me, impacting each day of my life. As I 

lock out my windows, watchtng an eagle soar by, I reel guilty. The reason? I brought my small famtly here. 

- one has died of lymphoma 

- a 2nd is currently receiving chemo for lymphoma 

- another developed a thyroid disease 

- another developed a rare form of vaginal cancer -- still another is recovering from a brutal University of Michigan transplant ln a final attempt to arrest his 

cancer 

When my CA grandchild visits she is no longer able to fly the fish she catches over our campfires. She no 

;"''Y"' ··lObes'' behind our boat as there are often mounds of sticky whtte PFAS foam nngtng vanEtten Lake. If 

we take her to the once pristine take Huron beach, in town, we have to be sure 1t !S on a day when there IS no 

foam. 

There are the conslent demands of hauling and paying for bottled water. At age 81 my spouse (with metal 

rods and 2 bacK fusions) never imagined having to watch me have the burden of constantly lifting cases of 

water. We are repeatedly told by a state agency that our "contact information has been forwarded" so our well 

can be tested. Proper forms have been filed with the health department. At first the government agency words 
132 

Wurtsmith PFAS Contamination -Impact Statement 

were reassuring but then we came to the realization that no date for testing has ever actually been 

established. Nothing is done. Data is continually published on government websites showing that a 

contaminated well is only 800 feet from our welL 

The obvious question becomes, "Wny not have your well tested independently if you are so conoerned?" Even 

though the cost is in the hundreds, I tried. A toxicologist for the state of Ml sent me a sheet listing 24 testing 

companies. None were in Michigan. I stopped calling after the first nine all told me that PFAS testing is 

considerably more involved that normal testing and that they do work for municipalities and commercial 

establishment but not for individuals. 

Our once pristine community desperately needs IMMEDIATE FEDERAL ASSISTANCE to restore our beautiful 

waters, provide us with extended water mains for safe drintctng water, and keep our economy producing jobs. 

How ironic that the charity my husband and I chose, long ago to heavily support, is one that drills wells for safe 

d~~r:~!flll water in poverty stricken African nations. 

Your fiscal action is imperative to the health and economic welfare of Oscoda citizens as well as to your own 

political futures. If your concern is not about those of us who have always supported the U.S. mili1ery at 

Wurtsmith AFB in Oscoda, then please plan for the impact of Wurtsmith contamination of the vast fresh water 

supply of the Great Lakes. The health of millions of citizens is at stake. 

Jane Lauber 
133 

Fwd: Martha's Personal PFAS Story 

--Forwarded message --

From:!!!!I!!!!!I!!IJ!IIIJ!!!I!IJ!I.!!!I!!IJII!!!••••••• Date: Sat, Sep 22, 2018 at 12:07 PM 

SublojellcltiFiwldl: IMIIallrth

1

a

1

•siiiiPiersonal PFAS Story 

To:• 

Dear Chairman Paul, Ranking Member Pe1ers, and Committee Members: 

Sa~ Sep 22, 2018 at 12:11 PM 

l grew up spending my summers at my grandmothers cabin in Oscoda. When my grandmother passed away, 

my mom continued to spend spring, summer, faH at the cabin and us Kids would continue to visit in the summer. 

My mom was diligent about having our wen water tested every year to make sure the water was good and the 

tests always came back clean. Of course they were not testing for PFAS. Before my mom passed away from 

cancer she told me that she felt like something was eating her body for the past year. She told me to pay 

attention to my body and act when something doesn't feel right. ln fact, my mom's hands the last year she was 

alive were so bad that she cou!dn't barely hold a glass. Her joints ached. 

In 2009 we renovated the cabin into our family year round nome and moved up to Oscoda full time. My 

husband and I continued to test our well water and a!l was good. Then about a year after Bvfng full time in 

Oscoda and doing Reflexology for people in the area, my hands started to ache and t started to same the same 

troubles my mother had and I cou(d no longer do Reflexology. It was only when I took a job in Grand Raprds 

and worl~ed away from the home during the week did l notice that my hands didn't ache when l was not in the 

house. I started to investigate why this was happenmg and started to bring up my own bottled water. My hands 

no longer ached so l told my husband I wouldn't drink the water. As well our dog would not drink the water and 

U1ere was no we!f water smell or anything. it tasted, smelled and looked perfectly fine. 

Then the news came out in 2012 (but I didn't near about it until2016) that there is a PFAS contamination and it 

is affectmg wells. We hall our well tested for PFAS in late 2016 and they detected low levels of PFAS in our weil 

commg from the airbase so they installed a water f!lter on our faucet. Our family, friends, visitors, and dog drink 

the fiftered water. I have no problems with my hands. And since the PFAS revels in our we!! were apparently 

!.:;.;·;01 if1an what they detected h the township water supply ! asked them why they recommend using the filter 

and eventually tying in to township water supply. They saJd it was because they don't know if the plume has 

aiready gone though our well system or is on its way or in the middle- they just don't know. 

Many neighbors on our street who lived here before 2012, and were not tied-in to city water, have passed away 

from vanous forms of cancer or alzheimers. Seems very suspidous 

Bottom Hne: \/Vith these chemicals mal<tng thelr way unde ground and into wells ~we need money to not only try 

to mitigate the plumes {if that is even possible) and more Importantly tie all residents vvith wells into the 

municipal water supply. The township or DEQ or DHHS only need to lest the municipal supply and not 

thousands of wells. Oscoda Township estimated that to clean up and tie everyone affected into municipal w8:ter 

supply would cost $1OM. This needs to happen immediately as we have been dealing with this for 20 years. 

The airbase has contaminated the people of our town and they need to ctean it up and fix it It shou!d be 

considered a ''Natural Disaster" and "Disaster Relief' from the government should be mandatory for all the 

taxpayers in Iasco Countyl 

One more very important concern: They say that P.FAS can't penetrate the skin, ·which l don't believe for a 
134 

mmute And your skm is the largest organ in the body~ thus all of us ~;~Jith wells that don't have whole house 

filtration systems are continuing to expose ourselves through bathing and watering our vegetable gardens. 

ivlahha Gottlieb 

"H fu:u the pml'er of !m•c Ol'ercomes tl!e hm: t!f pmt·er, the Ll'Otitf wi/1 liuow peace." Jimi !Jemlri.\' 

:@,' 

~ ~-"""' • .:.Ll~ ·~·~ ~ 
135 

nna11 ~ Jen tcsttmomal 

Jeri testimonial 

Tue, Sep 25. 2018 at 10:52 AM 

I have contaminated water. !n my 40 years of l!vmg m Oscoda we have always had wen water. Always believing 

that It was safe and sound having had it checked on numerous occasions. L1ttle did I know that there was 

something nasty lurking in that water. Now I find that I'm diagnosed with Parlonson·s disease. There is not 

P~rkino:>":'!""lS disease in my family, Is there a correlation between contaminated water and ParktnsonsDisease? 

There's literature and scientific information indicating there is a probable connection between contaminated water 

and Parkinson's. So for 40 years l dranl( my water from A contaminated well UYdt l did not know Was dangerous 

for me. Because l'v not been able to easily obtain information from The state of Michigan,on the situation and how 

dangerous it is now I must purchase water from the grocery store. I am a 76-year--old widow Seeking help from 

my friends to bring my gallons of water into the house for me Since I can't lift the bottles by myself. Now I wonder 

about my married children. Are they going to be OK? Is there a chance that the1r bodJes have been affected by 

this Contaminated water? 

My long-term solution to this problem ls to connect city water Just estimated that it will cost mo approximately 

$7000 to do so. I ask you to please make this a priority for Michigan to have safe water for !heir citizens. Thank 

you 

Jeri-lynne Richardson 

Oscoda Michigan 

Sent from my iPhone 
136 

To Whom It May Concern, September 21, 2018 

I am Marcy Harig. This is my testimony. I moved into the Belmont/ Rockford area 

starting in 1988. My husband Brian and I purchased a mobile home in the Northern Estates 

South Mobile Home Park, off of 131 and Post Drive. Only a mHe away from what is now a major 

dump site on House Street. My husband passed away from cancer in 1998. I remained in our 

home until 2003. 

In 2003, I moved into an apartment off of Plainfield and Five Mile Rd. In 2006, I moved 

back to Belmont/Rockford area. I purchased a mobile home in ••••••••••• 

••••••••••••••. I am a current a resident. Again, only a mile away from 

the dump site on House Street. 

The water in this area has always had a funny taste, even when my husband and I first 

moved here in 1988. We, (Brian and I) purchased a Brita water filter and installed it on our 

kitchen faucet when we lived on the South side. When I moved back to the Mobile Home Park 

in 2006. I used a Brita water Pitcher to filter the impurities. I found out many years later that, it 

does not filter out the PFAs. I didn't know there were PFAs in the water. 

In 2017, I had been having health issues and went to have testing done. At first the 

Doctors couldn't find anything wrong. But, in February of 2018, I had some very serious health 

issues that put me in the hospital. After extensive tests, I have been diagnosed with MS. I was 

fifty-eight years old at the time. MS is usually diagnosed between the ages of thirty and fifty. I 

am almost sixty. I have no family history of MS. I now have to be on a specific diet, take vitamin 

supplements, avoid extreme heat, avoid extreme cold, and watch my physical activity output. if 

I do not, I could suffer a flare up. I have had four flare ups since February 2018. Each one lasts 

longer than the previous one. The last one was in August, and lasted 9 days. 

I believe that the contamination which has been found in our drinking water may have 

caused this illness. I asked my Doctors about whether this could be a factor. Right now with lack 

of studies, there is no way to tell. But, said could be. Which brings me to another question, 

could this be what caused my husband's death? 

! have he en a resident of this area for a total of 25 years, and have drunk the water until 

February 2018. I now buy bottled water and do not drink water from public fountains, or in 

restaurants. I demand there be action taken to remedy this contamination so that nobody else 

has to get ill due to reckless dumping of toxic materials! 

Sincerely, Marcy Harig 
137 

To Wl1om it May Concern, 

My husband and I bought our tlrst home in 2012 in Plainfield township in Grand Rapids, MI. We started out 

life her not knowing the water we were drinking could be harming us. In 2015 we had our first child and after a 

few months I was no longer able to breastfeed. I used our water to make my daughters bottles. 1 trusted that 

my township would only give us safe, clean water to drink. I mean why wouldn't they? I It sickens me to think 

about what me, my husband and daughter have been exposed to because our township swept the urgency of 

these chemicals in our water away. There was proof decades before today about the harmful chemicals in or 

water and no one did anything. We have recently installed a water flltration system in or kitchen so we at least 

have SAFE. drlnking water. We used money out of our own pocket to do this. We are still using the 

contaminated water to bathe and do our laundry with until we can afford a full house filtration system. 

It's heartbreaking that the state of Michigan, which is surrounded by fresh water. does not care enough about 

it's residents enough to give us safe water. I hope this issue begins to be taken seriously and immediate 

actions are taken to make our water safe I 

Sincerely, 

The Crittenden Family 

Grand Rapids, Ml 
138 

To Whom It May Concern, 

I am the mother of three young children, and I have concerns for their health_ Why? I happen to live in the first 

home that is downstream from the Wolverine Wortd Wide former tannery. Whatever the company recklessly 

dumped into the Rogue River--mercury, arsenic, cyanide, ScotchGuard-that poison continues to flow through 

my backyard. My ch'ldren have been swimming in the polluted river and playing in the toxic muck since they 

were babies. Why? Because I was told it was ·perfectly safe." Yet the EPA, the DEQ and the City of 

Rockford-THREE deparlments-they all knew that there were unsafe chemicals in the Rogue. All three fought 

to protect the interests of the City of Rockford and Wolverine World Wide. Nobody acknowledged that local 

children, my children, might be at risk. 

Are they that callous? Perhaps' Local children had been at risk and, in fact, dying for years. We all had heard 

the whispers about the two cancer-stricken children whc were on Cahill Road. We heard 

the rumors about the sick kids who lived near the river just north of the tannery. We heard the rumors, but we 

wanted to believe our city leaders and neighbors who told us that everything was okay 

I had let my kids swim in the river. Why? I thought they were safe. City leaders had told me so. In the Rockford 

Squire. the City Manager said that the EPA was leaving town. and he called that "very good news." The citizen 

activists who fought that decision were ridiculed. Those activists are the same people who brought forth the info 

House Street. I trusted my city, my state and my federal government to protect me. I gave you my iaith, and 

you put my children at risk. You publicly ridiculed those who were trying to keep my children away from danger_ 

Who can I trust? 

So yes, I have been affected I live on a river that my children can not play near, swim in or eat the fish from. I 

still fear that the chemicals will make their way into my home, be it on my dog's feet or from the shoes or dust. 

Do you worry about arsenic, mercury and cyanide? I do_ Every day, I worry_ 

A polluted river flows in my backyard. Am I safe? The city, the state-they tell me I am. Do I trust the people 

who once tried to deceive me? 

I urge the federal government to move forward with the tannery cleanup and to hold all parties responsible for 

their action AND inaction. Please help us. 

Best, 

Julie Spahn 
139 

I was stationed at Wurtsmith AFB in the mid to late 80s and lived off base. We had well water. I was a 

firefighter at this base so I am sure 1 was exposed to the chemicals used in fire suppression. I was later 

diagnosed with Thyroid cancer and had it removed some 16 years ago now. You think I could get the VA to 

listen? Nope. Hope this helps. 
140 

To whom it may concern: 

As a resident in the Belmon/Rockfordt, Michigan area, I have recently become startlingly aware of the chemical 

crisis in our water and food supply. Official testing of PFAS in well water has reached properties across the 

street from us. How can our water supply, which ultimately irrigates our food supply, have such poor 

government oversight? How can refuse and manufacturing companies IJave so little oversight regarding what 

they dump into our rivers and streams? Tne state of Michigan has several communities with PFAS 

contaminated drinking water. Shameful' 

We had our well water privately tested, at a cost of hundreds of dollars. We are fine ... for now. What about 

the past? What about the future? The water table ebbs and flows. With contaminated water a few miles from 

us, we will always be at risk. 

Why is the government not monitoring the huge companies near our rivers and streams? Why is the 

government not forcing them to clean up the areas they contaminated? Why are lobbyists allowed to influence 

our government officials on issues regarding our heallh and safety? 

""ve~~.-ne>ni can regulate how manufactures !ist food statistics on food products, how gasoline for vehicles 

must be manufactured to ease the impact on air quality. Yet, it cannot ensure its people non-contaminated 

drinking water. Shameful!!' 

Respectfully, 

Susan Turoski 

Rockford, Ml 
141 

I wish to inform you of my concerns on our health issues here in Oscoda Mi. I purchased my home in 

1990 on lake Van Etten. I knew Wurtsmith Air Force base was there close to the lake. What I didn't know 

was how the base was was contaminating the ground water All the private wells of the residents in the 

area as well as the wells the base had put in for its service men and there families living on the base were 

contaminated. The chemicals from fuel spills and jet engine cleaning chemicals as well as fire fighting 

fco'"~ were washed down into the ground. The base closed but the contammation was identified before 

that and the process of letting the residents know about it had began. The Air Force was pushed and 

prodded into doing cleanup process but the worst of the contamination was knot known untii a few years 

ago. That fire fighting foam had the worst contaminating chemicals in it to the human body and all types 

of animals and fish. The PFOS and PFOA chemicals have been tested and found to have serious health 

consequences for anyone exposed to them. My wife and I have health issues affecting us that no one our 

families have. Our well was tested and found to be contaminated with those chemicals. We now have 

Reverse Osmosis filters installed for drinking water but that was only for the last year or so. All those 

years before last year that we drank our well water has had an affect our bodies. The lake has the PFOA 

and PFOS in it and the fish we caught and ate were contaminated. This lake water is flowing out into 

Lake Huron where other cities draw there water from. The only way to get those chemicals out of the 

water is to run it through a special granulated charcoal filter system much like the Reverse Osmosis 

system. To my knowledge no city water is processed in that way to remove those chemicals. More people 

will be affected by these chemicals if they are not eliminated from any and all possible uses for them. A!l 

areas where iire fighting foam has been used or dump sites where these chemicals are found must be 

purged of them. We all want and need clean and safe drinking water. Our government needs to put into 

place standards and rneasures that assure we all have good clean water. I think you are in a position in 

government to do something about this issue of safe and clean drinking water for all people in Michigan 

and in the USA Every day that these chemicals continue to be used anywhere in anything is a danger 

they will get into our water supply. Please take your position responsively as the peoples representatives 

in government and do the right thing. Give us clean and safe drinking water. All around the country PFOA 

and PFOS chemicals are being found in water supplies. The limit of 70 ppt is way too high for safe 

onnking water. Every affected city that did testing for the chemicals has said the limit needs to be 

lowered. l agree with that, what that number should be is zero as far as I'm concemed. Get an experts 

opinion and I hope it's less that i 0. Ken Turczyn 
142 

i arnved ill my first duty d:,signmutl dl Wmtsmi;:h 1\FB, Michigan in March 19tH as a 

young healthy 19 year old Ainnan. 

!lived in the dormitory on base and utilized the hasrc w;JtPt· tor <>llJwrsonal needs ;1t worl' 

nnd during nfftirnP. 

In December 1985 :1ftur being on base lc;;s th'm 2 years I wa;; iHJmitted lo the bast huspitdl 

lor(; ddys as a newly diagnosed Tyj.>e 1 insulin dependent diabetic. I was placccl in medical 

iintbo lor 6 months while tile Air Force mcchcJI rcv1cw board dc'cided my fate. 

It was llldndatcd that l cha~ge careers, one thdll had hopNI to lw my :ifctime vocation. and 

work in an entirely new field I m:1rcied another iltr Force member, Tammy, Jnd lived in 

b:Jsc housmg a few more ye,lrs. We left Wu:·Lsmith AFB in November 1 'J92. 

Not long afte:·lcaving my healtl1y young w1fe w;:;s d:Jgnosed with Graves Disease 

[iiypertilyro:dism). f\ot long after that!, too. we1s diagnosed wit!-. Graves' disease. Both 

condition:; (Type• 1 diabetes's and Graves' d:scase) are part oftfw Pndouirw systf•rn :md 

~\l~e auto-immunP disordprs. 

Whot arc the odds of one household having 3 endocrinologic/autoimmune disorders atter 

living <~L WAF!P It seems awfully suspicious. There IS one cor1mon factor; we both drank 

tiJeWdteL 

So many others have suffen·d. ;!'; wPII. My base housing neighbors' I() yjo daughter was 

also diagnosed as a 'l'yoc 1 diabetic a year ilftcr rnyoclf. I wish I could lind her so she could 

tell her story. L;kc me, she must give hct·scM nrultiple injections, everyday. Must stick 

herse'f m<~try limes a day to check her blood sugar, everyday. Mmt worry about blood 

sugar il1ghs & lows, ,1Jl day, everyday, tor more than :)0 years nnw, as we will have to do for 

the rest of our l:ves. 

The burden of the J<Jily struggle & expense to JtL>t stay alive, trying to avoiJ kidney 

failure, blindness dnd neuropathy, can be overwlll~lrning. 

Tammy & I takl' d,l!ly medicines lo treat our thyroid alter h<lvinr; to undergo r:~dioahlation. 

'v'ic··ve Mth have spent huge amounts of time & money with hundreds of visits to 

c:ldocrinologists over the ye<t!·s. 

!'lcJsc wkc the Vctc1·ans and lool communities plea fol' hdj.J seriou:-;ly and do the right 

thing: Rccogni:r.c us <nHI L!w rv<il cause ot so many sick people. TilE WATER' 

Chris Rogers 

llliiiiiiiiill 
143 

My name is Tammy Cooper and I live in Parchment, Michigan with my husband and 

three year old daughter. We moved to our dream home two and a half years ago. We 

thought we were coming to a city with wonderful schools, thoughtful citizens and to a 

place that is safe and secure. Our security was ripped from us the day we moved in, but 

we weren't made aware of that until July of 2018. 

Parchment was once a town known for its paper mill, hence the name 'parchment' for 

parchment paper. Our city now is known for its record setting levels of PFAS in the 

municipal water. This is a legacy that will forever follow Parchment, and the tone of our 

town has changed. This city was built by hard working, middle class Americans, like the 

majority of cities across America. These honest, humble people have had their trust 

irreparably damaged as they have had to come to terms with feeding toxic chemicals to 

their families. to their children, to themselves. There is a sense of grieving in the 

community, and fear. 

We should be able to feel secure in our homes. We lock our doors, we buy smoke 

detectors, we protect our families from physical dangers. We cannot control the actions 

of corporations that decide to dump contaminants into our soil. We trust government to 

do that. We believe that politicians are protecting us, and at a minimum ensuring we 

have clean food and water. We have to believe that, because we know we are doing all 

the right things for our families, and we believe that if we are good people and do good, 

go to work, pay our taxes, and contribute to our communities- we know if we do those 

things, we will reap what we sow. 

It is earth shattering to come to the realization that government doesn't care about you. 

Se!:!1, politicians are people too, and they may care on a personal level. We need you 

start caring on a legislative level. How many families need to be poisoned before you 

act? How much does the cancer rate need to rise to get you to stand up to corporations 

who put their profits before people? The cancer rate is one in three. We all know that 

corporations are lobbyists, and we know you take their money for your campaigns. 

Please do not sell your soul to them. Please help us protect our kids, our spouses, our 

pets and ourselves. 

I am a mother who is still breastfeeding my three year old. I never thought I would still 

be nursing, but here I am. I exercise, I eat healthy, I don't drink or smoke. Health and 

safety are my top priorities. I have stopped consuming high levels of PFAS, but I am still 

feeding it to my daughter directly through my body. She is my only child, and the bond 

of breastfeeding will end with the knowledge that I am feeding her hazardous chemicals. 

At what concentration? I don't know. What are the long term effects? I don't know, and 

neither do you. 

Where are your studies? I keep hearing the term 'emerging contaminant.' but what are 

your plans to do these studies? Are you securing funding, gathering data, contacting 

scientists? Do you even know what PFAS is? Do you know what filters will work? Do 

you know where the used filters can be properly disposed of? Do you care? What 

chemical is next, that we haven't even heard of? Corporations have scientists producing 
144 

these contaminants that you have never even heard of. They are looking out for 

themselves, but who is looking out for us? 

We don't know where the contaminants are moving through the ground water, or what is 

even in the ground. The old paper mill, once filled with workers using 3M products, is 

now a rotting pile of toxic waste. Who is going to clean it up? Government is silent. Now 

is the time to act Do not abandon us. Do not abandon the people who built this country. 

Do not allow these chemicals to mutate our genes, so that our great great grandchildren 

are predisposed to disease from something as unimportant as paper additives. We do 

not Need these products. We do not need things like toxic herbicides, or pesticides. 

Say 'No' to companies promising convenience, when they are lining their pockets at the 

expense of human life. Make us proud to be citizens of this country that has so many 

resources, resources that we are destroying with no long term plan to address the 

damage we are allowing these companies to inflict on our environment. Pure Michigan 

is our slogan, but there is no such thing anymore. To our children, the beautiful 

freshwater lakes, forests filled with wildlife, will only be a legend unless you act 

immediately. Expand testing for contaminants, stand up to corporations, and represent 

the people who elected you. All of our lives depend on it 

Thank you. 
145 

I was stationed at WAFB from 1974 to 1979. During that time my family (Daughter, Son, and their 

Motherl lived on base with me). During that time the USAF discovered a TCE leak outside the Jet Engine 

Repair Shop (AKA Building 43). appx. 900 gallons were pumped out of the ground. It was discovered 

later that the water wells were contaminated with a cocktail of chemicals (TCE, Benzene, Jet Fuel, Fire 

Fighting Foam, just to name a few). According to MSDS all these chemicals cause severe health issues if 

not handled properly. We that were exposed to them are living proof they 

do. 

My daughter has had several tumors remove from her female parts, my son has had heart issues and is 

mentally behind his age and is hyper active. Their mother has had cancer and tumors removed. The 

common denominator is they drank the poisoned water and we ate a steady diet of fish from Ausable 

River, Van Etten Lake, and Clarks 

Marsh. 

I am experiencing complete loss of cartilage in my hands 

and feet and Austo Arthurites in most of the joints in my body above and beyond age related, Gastro 

Intestinal issues with severe bloating, diarrhea, constipation, and my thyroid is being watched by my 

doctor due to marginal readings. 

Before you make any decisions ask yourself "How would I feel about drinking a glass full of water 

contaminated with the above chemicals?" How about giving a glass full to your children? Now do it day in 

and day out for five years as my family did. 

Kespectfully 

Danny R Burns 
146 

H1 my name 1s Lmda Cole. !'m writing this email as I want somethmg to be down with the water problem~~ 

Oscoda Michigan. I have lived in the area, and have a!! kmds of med1cal issue's they know are related to Pfas. 

I've had a baby that I lost due to Trisomy 18. I've also had throid cancer, and a stroke. I have ~r children I 

pray have no ISsue so far from the contaminated water I consumed there My ex husband Rex -was 

stat1oned at Wurtsmi:h air Force Base for 4 years. He has so many 1ssue. Non hogkins cancer. both h1p 

repacements 2 times each, along with both his shouide•s being replaced I want th1s issue to be priority as it 

has effectea my family dealy and alot of others out trere. Please help us. 

I'm also a member of the Veteraos Civialans c·eao Water Alitance. 
147 

~-~Y 11d1T16 is David Gregory. I was stationed at Wurtsmith AFB from 1983 to 1987. During thatt:me I lived on 

base as a B-52 crew chief 1 Oyrs after my honorable discharge, I was diagnosed with testicular cancer. At that 

time I was unaware I was exposed to PFAS in the base water supply. The cancer made me unable to have 

children. I've had several revision surgeries due to the mesh implant I have in my abdomen, My inability to 

have children cost me my marriage. I never thought my governmen:. whic1 I served with honor, would put me 

in :his position. 

David Gregory 

USAF Veteran 
148 

My name is lisa (Whisenant) Storey. I am frorr. Oscoda and nave :ived there from 1961 1993. 

Here is a blief family medical history (rea,;on for n;y concern)· 

1 My fa:trer died of cancer (spread throughout hrs whole bocy) He worked on the WAI-B froM before 

1961 lhrougl11984. 

2 My brother died of bratn cancer. He was >n the Navy and atter re got out he started working at WAFB 

in the 1970s until sometime in mid to late 1980s 

3- My btologtcal father dted ot cancer. He was statroned at WAFB in the late 1950s to the early 1960s 

For these three the only thing that they have in common is WAFB -none of them are related by blood 

4 - My mother had a form of uterran cancer She rad worked on WAFB off and on throughout her adult 

life. 

5 Bo:h of My two sons have ADHD. They were both born on WAFB a nil we lived on WAFB frnm 1984 

through 1992 

E - I have a skin cisease - Roseacea- that started showing up on my face around 1990. 

There are more issues. but not sure :f the; would be related O' not. 

The easiest way to get a hold of is pcobably by email or my cell phone 

Thank you, 

Lisa (Whisenant) Storey 

-
149 

My n<Jme is J<Jrnes M. Bussey. I served at Wurtso1rth afb Michigan from 1989-92 In January of this year i 

was sent to a special VA facility in New Jersey due to declining health. Durrng my stay h Jersey i was 

tested for exposure to PFAS and other related compounds. I testod abnor·nally high 'or PFAS and 5 other 

related compounds. During my stay i was diagnosed with endocrine,heartlung and !rver damage among 

about a dozen other conditions. I have no doubt :hat my expos.Jre is related to all my related health 

1ssues. 

During my time at Wurtsmi!h i drank the water I ate the fish i caught and on 2 occasions i was directly 

exposed to AFFF firefighting foam. I served proudly during my time but never bargained on the faot i was 

being poisoned. The Air Force knew Wurtsmith was porsoned and did nothing to notify service members 

about what was being done to them. Only now decades later are we finding out what was done to us. 

This is criminal and something needs to be dcne. People need to be provided with access to proper 

healthcare. I respectfully request that all the talking end and action to ciean up the military mess begin. 
150 

September 25, 2018 

Senator Gary Peters 

724 Hart Senate Building 

Washington, DC 20510 

Sen::>tor Peters: 

I thank you for taking the time to hold this very important meeting on September 26, 2018 

regarding the Federal Role in the PFAS Crisis. It was one year ago we received our well water 

test results letting us know we had been drinking poison. We were amongst only a dozen or so 

homes that had high levels of PFAS in our area, we didn't know many more would also be 

discovered. At the time, we felt so alone, we didn't know where to turn, we didn't think anyone 

would pay attention or care to help. For you to be advocating for assistance on a federal level 

truly means so much. 

My husband and two children have lived in our home for 8 years. We were so excited when we 

looked at our house for the first time, we couldn't believe we we're buying it! We were moving 

from a small place on a city Jot to this one with over 5 acres, wooded, with a pool, a barn, and Jots 

of room. It was a struggle to afford with both kids in daycare, but for years we did it on a very 

tight budget. Awhile after moving in, I started having sporadic health issues ... which I brushed off 

but in the back of my head, did concern me. A few years ago however, a flood of symptoms came 

on which I could not ignore. It disrupted every aspect of my life. I went through a series of tests 

and exams and waiting and testing and scanning and waiting more. None of the doctors I saw 

could tell me Rny answers about why all of this was happening. And then. August 23, 2017, we 

received that letter that explained it all. It was the letter letting us know to stop drinking our water 

immediately because it's likely contaminated. Contaminated it was - 147.9ppt that day. Other 

tests showed the numbers doubled. I never imagined that the home we loved was what was 

hurting me. It was bittersweet news. I now knew that my symptoms were the result of chemical 

poisoning, I could stop chasing a diagnosis. Last year, I was buying life insurance and writing my 

will and estate. Now, my doctors are able to help me and, I am starting to feel better. 

Our lives will never be the same, I struggle a Jot of times enjoying nature and have difficulty eating 

and drinking- everything I look at feels contaminated. I go through periods of time which it's hard 

for me to drive home without crying because as I get closer to home it just makes me sad seeing 

how many homes and family's lives have been affected and how the area has been forever 

changed by the mishandling of this chemical. As people visit our home since we've found out the 

news, we have to instruct them not to use the taps, only drink from the water machine. I feel a Jot 

of guilt for unknowing exposing others who all came to my home prior to knowing our water was 

bad. I also feel an enormous amount of sadness when I reflect on ailments of my own two children, 

they have drank this water for 8 years of their lives beginning at the ages of 6mo and 7 yrs old. 

Both complain of stomach issues and headaches frequently. 
151 

After living with this for the past year, I believe I've been able to capture my goals in four simple 

objectives; overall testing and monitoring, studies on medical effects, reasonable MCL's 

established, and prevention of water systems being contaminated. 

In my particular situation, had industry and government put people's health first, the aquifer 

feeding the drinking wells in my area would've all had monitoring wells testing for PFAS. Both 

entities were fully aware of what was being disposed of directly into the soil. I'm told my long term 

solution for water is to install municipal water lines. Then I find out regulations on these systems 

also come with a curious set of rules. Rules such as, tests are done sporadically, no regulation 

on testing certain chemicals. less testing is done if the customer base is under X number of 

residents. My ideal situation would be that any area which has industry and/or a landfill (including 

past dumpsites) must have monitoring wells. Also I believe that municipal water systems should 

all be tested the same - no matter the customer base. 

Any community which has been exposed to PFAS should have a medical study conducted. The 

C8 study was good research to add to a piece of the puzzle, however we cannot accept that as 

me only report we reference. Affects from exposure are going to have a wide range of results 

depending on the subjects, environment, genetics, type of PFAS exposed to, path of exposure. 

etc. We need to collect as much data as possible to see a comprehensive picture of what this 

family of chemicals can do to the body. I would've be so grateful had somewhere along my path 

of searching for a medical diagnosis, there had been a box for one of the doctors to check off to 

test for water contamination. I was tested for many things, but never did anyone ask me about 

what I was consuming for drinking water. 

With the health studies being done, I feel the medical and science community would be able to 

come together and determine a more realistic MCL level for each of the PFAS types based on 

actual research. Today, we continually hear that 70ppt is the golden number. We are given the 

message that it is okay to stay at an elevated number until it's proven to be harmful... then it'll be 

lowered, this seems contradictive of how people should be taken care of- typically one would do 

the opposite ... you exercise care until you find the limit which causes harm. 

Lastly, we know there is no way to eliminate these chemicals once they are produced. I believe 

we need to heavily assess the benefits of these types of chemicals. How much do we need these 

given the fact they cause so much harm and we cannot get rid of them. Is there an alternative? 

r<>~ we educate the public on how to lessen their PFAS "footprint" per say? I'd like to see the US 

adapt a practice that would treat industrial chemicals like food or pharmaceutical products; if it's 

found to be too harmful, it's not allowed to be produced. There should be a threshold which risk 

outweighs the benefit. 

We thank you again for all of your time. 
152 

TOXIC$ 

ACTION 

CENTER 

September 26, 2018 

Senator Rand Paul, M.D. 

Chairman 

Subcommittee on Federal Spending 

Oversight & Emergency Management 

Committee on Homeland Security and 

Governmental Affairs 

U.S. Senate 

Washington, D.C. 20510 

Senator Gary Peters 

Ranking Member 

Subcommittee on Federal Spending 

Oversight & Emergency Management 

Committee on Homeland Security and 

Governmental Affairs 

U.S. Senate 

Washington, D.C. 20510 

Re: August 26 Hearing on "The Federal Role in the Toxic PFAS Chemical Crisis" 

Dear Chairman Paul and Ranking Member Peters: 

We, the undersigned organizations, are writing to commend the Committee for holding 

a hearing on PFAS chemicals and to urge decisive federal action to stop further 

contamination of our drinking water. Per- and polyfluoroalkyl substances (PFAS) are a 

family of toxic chemicals that pose serious threats to human health. Research shows 

probable links between PFAS and cancer, immune system deficiencies, high cholesterol, 

low fertility, and developmental issues in children and infants.' Moreover, the health 

risks of PFAS are magnified because they bioaccumulate in the food chain and persist 

for a long time in the environment. Even trace amounts of PFAS can be hazardous to our 

health. 

Unfortunately, these widely-used toxic chemicals are contaminating drinking water 

across the country. In Oakland County, Michigan, wastewater from Tribar 

Manufacturing Inc. has led to PFAS concentrations in Norton Creek more than 450 

times higher than the U.S. Environmental Protection Agency (EPA) alert level. 2 In 

Fayetteville, North Carolina, privately-owned wells near the Chemours plant are 

1 1202B, JanoarylO). PFAS Health Effects. Retrieved September 25, 2018, from 

(2018, September 24). 'Astronomical' PFAS level sets new Michigan ... - Mlive.com. Retrieved September 25, 

2018, from !"-'J~.'-'LD!L~'·"•'-'12'l.Y.S'-.~.U.'L'J.':'-"'?l'U!d.'2'~12!~L±!21~'.<1-'i!.!.'LLY-'U'1'...:!.1'...1!!.£'-.-"".Ll'-0.!l!.'.l;LW,L.!J..LW.! 
153 

contaminated with GcnX as well as 16 other types ot PFAS chemicals." Studies indicate 

that kno\\11 cases ofPFAS contamination represent only a fraction of the problem; it is 

estimated that 1,500 drinking water systems serving uo million Americans could be 

contaminated.4 

Despite these staggering numbers, the actions taken so far at the federal level have 

neither matched the scale nor urgency of our national PFAS emergency. So far, the U.S. 

EPA has only issued lifetime health advisories, and for only two types of PFAS-PFOA 

and PFOS-out of the thousands of types of PFAS currently polluting our drinking 

water. Moreover, EPA's health advisory for 70 parts per trillion does not set an 

enforceable standard, and is 70 times higher than what is thought to be an approximate 

"safe" concentration in drinking water. Prominent experts recommend a health 

protective standard of only one part per trillion.5 

The federal government has an important and necessary role in keeping people safe 

from thPse public health threats, and there are a number of actions that can and should 

be taken to remedy the PFAS crisis and to prevent future incidents from occurring. 

We are calling on Congress and the EPA to take the following actions: 

1. Prevent future contamination. To safeguard our drinking water and health, 

we need a national moratorium on further use of PFAS chemicals until and 

unless any specific ones are proven safe. Any exceptions should be strictly limited 

to true emergency needs where alternatives are not yet available, and we should 

work to develop safer alternatives for these uses as soon as possible. 

2. Ensure safe drinking water. The federal government should set a health 

protective standard of one part per trillion for PFAS as a class of chemicals. EPA 

could accomplish this by setting a Maximum Contaminant Level (MCL), which 

would protect drinking water and ensure adequate cleanup of contaminated sites. 

3. Hold polluters accountable. Instead of imposing a significant burden on 

communities and states, users and manufacturers of PFAS should pay for clean 

up, monitoring, and other expenses of this contamination. EPA should designate 

PFAS under existing polluter-pays programs, including section 311 ofthe Clean 

Water Act, Superfund, and the Resource Conservation and Recovery Act (RCRA). 

3 (2018, September 8). More compounds found in wells near Chemours · News- The .... Retrieved September 25, 

2018, from http· //www. f ayobserver .com/news/20 180908/lnorej:;omooL!tl02.:. found- in-weiJs-neac-chemQurs 4 (2018, May 22). Report: Up to 110 Million Americans Could Have PFAS ... · EWG. Retrieved September 25, 2018, 

from https :1/www ~OrF /research/ r cpor t ·110 -mi l!ion··amencans· could hZ!vc•-nf as-tontam~na ted-drink1na-water 5 Grandjean, P., & Clapp, R. (2015). Perfluorinated alkyl substances: emerging insights into health risks. New 

solutions: a journal of environmental and occupational health policy, 25(2), 147·163. 
154 

We look forward to working with the committee on this important issue. 

Sincerely, 

Bart Johnsen-Harris 

Clean Water Advocate 

Environment America 

6oo Pennsylvania Ave SE, Suite 400 

Washington, DC 20003 

Shaina Kasper 

VT /NH State Director 

Toxics Action Center Campaigns 

141 Main St., Suite 6 

Montpelier, VT 05602 

Kara Cook-Schultz 

Toxics Program Director 

U.S. PIRG 

1543 Wazee Street, Suite 460 

Denver, CO 80202 
155 

NAN WHALEY 

MAY On 

September 20, 2018 

The Honorable Rand PauL Chairman 

Subcommittee on Federal Spending Oversight 

And Emergency Management (FSO) 

United States Senate- Committee on Homeland 

Security and Government Affairs 

340 Dirksen Senate Office Building 

Washington. DC 20510 

The Honorable Gary Peters, Ranking Member 

Subcommittee on Federal Spending Oversight 

And Emergency Management (FSO) 

United States Senate- Committee on Homeland 

Security and Government Affairs 

340 Dirksen Senate Office Building 

Washington, DC 20510 

Dear Chairman Paul and Ranking Member Peters, 

OFFICE OF THE MAYOR 

ClfY H1\LL • 101 Wr'Sr fHIRO STRF[1 

P 0 BOX 22 • DAYTON. OHIO 45·101 

{937) • www d<1ytonoh!o.gov 

The City of Dayton, Ohio commends you for focusing the Subcommittee on Federal Spending Oversight and 

Emergency Management's (FSO) attention on the important topic of drinking \\-·ater quality through your hearing 

titled, .. lt]hc Federal Role in the Toxic PFAS Chemica! Crisis." The City is currently dealing with the impact of 

Perfluorinatcd Chemicals on its water supply, just as other communities across the United States are dealing with 

this emerging contaminant. The City was pleased to learn that the Senate decided to follow up on previous 

hearings on Perfluorinated Chemicals. 

One of the City's greatest assets is the sole source aquifer which supplies the City and surrounding communities 

with access to clean drinking water. Since 1985, the City of Dayton has proactively protected the regions ground 

water through the. Somce Water Protection Program. Through this program. the City has a network of 

dpp.-oximately 400 groundwater monitoring wells which a\!0\vs the City to proactively detect and address 

contaminants before they harm the Great Miami Buried Valley Aquifer. 

In late 2016, the City's monitoring wells near \Vright~Patterson Air Force Base (WPAFB) detected high levels of 

PFOS/PFOA, and earlier this year. the City detected very !ow levels of PFOS/PFOA in its finished drinking 

water. While the levels in the finished drinking water remains well below the Health Advisory Level established 

by U.S. EPA, discussions with WPAFB to prevent fmihcr contamination of the City's drinking water have been 

slow because of internal rules and a lack of federal resources. Current law and regulations do not require WPAFB 

to take action unless the actual drinking supply (production wells) are contaminated, so all of the costs incurred by 

the City prior to the detections in the finished water are not currently eligible fOr reimbursement by WPAFB. 

Prior to these detections, the City has expended over $1.3M to install 136 new monitoring wells and complete 

sampling and analysis of the groundwater which supplies the City. These st~ps were all necessary to address the 

PFOS/PFOS contamination emanating from WPAFB and impacting the City's we!! field. The City feels this is the 

wrong approach. A change in the Department of Defense approach to one which enables WPAFB and other 

f~tcilities to reimburse local communities for the costs incurred to prevent the contamination of the region's water 

supplies with PFOS/PFOA can save tens of millions of dollars because it is significantly less costly to prevent 

drinking water wc!Js from being contaminated versus cleaning contaminated wells with expensive equipment. 
156 

The City of Dayton is grateful that the subcommittee is holding such an important hearing on PF AS. Given the 

City's experience with this issue, we believe robust federal funding should be available to local communities to 

use on preventative activities that mitigate PFAS contamination of drinking water; the Department of Defense 

should eliminate internal guidance or rules and allow the use of DoD funding to mitigate PFAS contamination at 

military installations and communities around military installations even though water tests may not show PFAS 

levels at or above 70 parts per trillion (ppt) health advisory level; and, the federal government should allocate 

resources to address potential PF AS contamination to communities that will see the greatest impact because of 

factors such as population size and economic costs associated with the cleanup of PFAS contamination. 

Access to clean and reliable water is vital to the health and growth of communities across the country. Water 

contamination problems are far more expensive to clean up than they are to prevent. We strongly support the 

Subcommittee investigating this important issue and appreciate your consideration of the information shared in 

this letter. Thank you for your support of protecting our water supply from the spread of harmful chemicals. If 

you have any questions. please feel tree to contact me. !look forward to hearing from you. 

Sincerely, 

Nan Whaley 

Mayor of Dayton, Ohio 
157 

se,t<>mbcr 23, 2018 

Senator Gary Peters 

724 Hart Senate Office Building 

Washington, DC 20510 

Dear Senator Peters, 

I'm a mother, wife, daughter, sister, aunt, neighbor, teacher, and friend. I feel like I am writing 

an obituary, well before my time. To most this contaminated water is just a headline. To our neighbors 

it means anxieties, stresses, and anger. For me, I truly have been poisoned. PFAS is our lives and deaths 

and so we are turning to you to turn inaction into action. 

Every activity involving the usc of our water that we used to do without having to think about 

the safety or cleanliness of the water, we must now do that same activity with water we know is 

contaminated, not do the activity altogether, or at the very least question the safety of the water. We 

have thought about the nightmare Wolverine and 3M have created in our lives every moment of every 

day. We wake up every morning with this tragedy on our minds, and we go to bed hoping the next day 

will not be s0 difficult. 

Unfortunately, the next days have proved to be harder. lt is my son getting sick constantly 

because his vaccines were found to be incflcctivc. It is having 13 vials of blood being drawn all at the 

same time from a small, two-year old body. It is taking away the joy of a child being able to drink 

safely from his hose on a hot summer day or play with cups in the bathtub. It is a home that doesn't feel 

the same. The days are my husband having high cholesterol, depression, and anxiety. 

We were planning to grow our family in October 2017; but, again, PFAS and the company that 

dumped it stole those plans. We decided to put it off for a while when on June 20, 2018 we found out 

we were pregnant again; but, by July 21, we were wondering why we lost our 2nd child--10 weeks in 

the womb. It is sadness, grief~ and constant wondering. Wondering why other humans would think it's 

okay to dump sludge on the bare ground. Why they think it is okay to minimize the impact on us. 

Wondering if every ailment we have is related to the water. Wondering if we would ever be able to sell 

our house if we wanted to. Wondering if the whole bouse filter is I 00% reliable. Water, clean water, 

should be a human right and a life source. 

Our concerns about our son pain us every day. We have gone above and beyond to try and fix 

the curse Wolverine and 3M have left on his young life. We brought him to a toxicologist with research 

on a certain type of algae that could potentially help him excrete the chemicals faster. The toxicologist 

:;:::id iioi io do this for him because he could not risk any more depletion of essential nutrients and 

vitamins he needs to stay somewhat healthy. We have expressed time-and-time-again how hopeless we 

feel because there is nothing we can do for our baby. There arc no medications or procedures to safely 

remove these chemicals from his body. We are left with horrible thoughts in fear of his future. What if 

he gets cancer? What if he does not reach puberty at the right age? What if he is infertile and cannot 

have kids? These worries, among countless more, will haunt us forever. 

We arc disgusted with how the investigation has played out, learning that our house may have 

been tested several months earlier had Wolverine not downplayed the severity of the situation to the 
158 

MIDEQ. Instead of our water being tested in April 2017, it was not tested until September 2017, 

resulting in months of unnecessary exposure. That is one of the reasons why were are turning to the US 

government, to help turn inaction in to action. PFAS has stolen nearly every happy moment of our 

lives. PFAS has robbed us of living norn1allives; it can never fix the tainted memories it has cemented 

in our minds. 

Sincerely, 
159 

September 20, 2018 

Dear Senator Shaheen, 

On Wednesday September 26, 2018, citizens from Merrimack NH who have been impacted by 

PFAS contamination are traveling on their own time and expense to attend the Senate 

Committee on Homeland Security & Government Affairs' subcommittee hearing The Federal 

Role in The Toxic PFAS Chemical Crisis. While we are aware that we cannot engage in the 

hearing process, we are compelled to join residents from all over the country that have formed 

a national PFAS Contamination Coalition group who will attend in support of and solidarity with 

our testifying members, Andrea Amico from New Hampshire and Arnie Leriche from Michigan. 

As a long-term New Hampshire resident, who has been compelled to fight for my community's 

health and wellbeing, I am hoping that Merrimack's impact statement can be present at this 

first and very important senate hearing. 

The known extent of contamination of American communities with toxic fluorinated 

compounds, known as PFAS chemical, continues to grow at an alarming rate. In a March of 

2018 report to the House Armed Services Committee, the Defense Department detailed that 

drinking and groundwater at or around at least 172 sites in 40 states, including military bases, 

civilian airports, industrial plants, landfills and fire training sites contains Perfluorinated 

chemicals at unsafe levels. It is currently estimated that 1500 drinking water systems, serving 

up to 110 million Americans, are contaminated with PFAS chemicals. 

PFAS chemicals, used in a wide range of industrial applications, fire fighting foam and consumer 

products have been definitively linked to kidney and testicular cancer, liver and thyroid 

damage, developmental disruptions for fetuses and infants, and other serious health 

conditions. In June of this year, the Agency for Toxic Substances and Disease Registry released a 

report on PFAS stating that the safe level of PFAS chemicals in drinking water should be at least 

7-10 times lower than the threshold recommended by the EPA. 

Here in Merrimack, NH, we learned in March of 2016 that we have been exposed to drinking 

water that exceeded EPA PFOA advisories for almost 2 decades. With the closing of 2 much 

needed wells, our public water supply system still exposes us to 23-26 ppt PFOA exposure and 

also the additional presence of other PFAS compounds including PFOS, PFNA, PFHxS, PFHpA, 

PFBS, and the latest member of the family, GenX. 1,500 of our 27,000 Merrimack residents 

utilize private wells which if tested typically show a high level of the same PFAS compounds. 
160 

According to New Hampshire Department of Environmental Services data generated by testing 

ground water, surface water, drinking water, storm drain outfalls, air emissions from the Saint 

Gobain facility in Merrimack and soil testing, all in an ongoing contaminant investigation area of 

approximately 60 square miles, we have exposure from past PFOA and PFOS and continued 

exposure from many additional and replacement PFAS compounds. The majority of the current 

and growing PFAS chemicals contaminating the Merrimack area bear no responsibilities to 

polluters as only PFOA and PFOS currently have health advisories, despite an extensive and 

growing library of health science linking every PFAS compound studied to health disruptive 

outcomes. 

Merrimack is just one of many PFAS impacted communities across America I have become 

familiar with as in community after community I hear stories of childhood cancer clusters, 

severe ond progressive autoimmune diseases, endocrine and reproductive health issues in 

children and adolescents, infant health disruptions, neurological anomalies and many, many 

cancer stories. New Hampshire has recently been identified as having the highest pediatric 

cancer rate in the nation, in my community alone, we currently have 3 elementary aged 

students whose childhood is being disrupted by having to fight for their life. Additionally, in 

Merrimack, state data ending in 2014 (which is overdue for updating) shows higher than 

expected cases of the following cancers: kidney, bladder, prostate, thyroid, leukemia, brain, 

uterine, colorectal and mesothelioma. I have come to loath the word "case" as each is more 

than a case and more than a statistical or cost/benefit analysis variable; each is a child, mother, 

father, brother, sister, friend, neighbor and most of all, a victim. 

Merrimack is just one of countless communities identified in 40 states and as victims of this 

chemical crisis we don't just bear the pain of our losses and health struggles but also the cost of 

bottled water, water filtration systems, medical bills and chronic stress, depression and anxiety. 

Remediation, cleanup and cessation of pollution are needs we have yet to see, we do not have 

access to the labs that provide blood testing, our physicians have no guidance, our health data 

is not gathered or acknowledged and as a social worker of 20 years I can assure you that the 

impact of millions of Americans who feel abandoned by their nation is not a healthy state for 

our nation. 

We are traveling to Washington with communities all across America to begin a partnership 

with congress, to ask for your hand, to work together for solutions. We cannot change the past 

but I know we have the ability to do better and together we must make America safe again. Our 

children are our future, we must work to remove these toxins from their path and make right 

what we can as despite our differences do we not share a love of country and our people? 

Laurene Allen, LICSW, Merrimack, NH 
161 

September 26, 2018 

The Honorable Rand Paul 

Chairman 

Senate Committee on Homeland Security and Governmental Affairs, 

Subcommittee on Federal Spending Oversight and Emergency Management 

439 Hart Senate Office Building Washington, DC 20510-6250 

The Honorable Gary Peters 

Ranking Member 

Senate Committee on Homeland Security and Governmental Affairs, 

Subcommittee on Federal Spending Oversight and Emergency Management 

439 Hart Senate Office Building 

Washington, DC 20510-6250 

Dear Chairman Paul and Ranking Member Peters, 

Thank you for holding this important hearing. We are writing on behalf of the millions of people across 

the United States impacted by PFAS in their drinking water, in their homes and in their communities. 

Commonly used in firefighting foam, food packaging, textiles and manufacturing processes, PFAS 

contamination constitutes a public health emergency that must be remedied quickly. 

PFAS is a family of approximately five thousand chemicals that are used as grease proof and water 

proofing agents. They are used in class B firefighting foam, food packaging, clothing, building materials 

and manufacturing processes. They are incredibly persistent and do not break down, prompting 

scientists to call them "virtually indestructible." They can stay in our bodies for up to 8 years or more, 

and h~'!e been linked to health effects such as cancer, hormone disruption and immune suppression. 

Even newborn babies have been found to have PFAS in their bodies, exposed before birth. 

While chemical makers were forced to stop making two older generation PFAS -PFOA and PFOS-, 

thousands of PFAS remain in use. This means that even as we address legacy contamination, 

communities face ongoing pollution from the next generation of PFAS, trading one problem for another 

and creating a whack-a-mole approach to regulation. 

We are encouraged that the committee is investigating this issue. States have been at the forefront of 

confronting this issue for many years. Several states have taken action in the past three years to address 

PFAS including setting their own reference levels, suing manufacturers and preventing future 

contamination by banning products containing these chemicals. 

In addition to cleaning up contamination around military bases and in communities, there are several 

specific actions that Congress, the Administration, and states can and should take to protect public 

health and prevent ongoing contamination of drinking water. Specifically: 

1. Phase out the use of fluorinated firefighting foams in favor of safer alternatives. Fluorinated 

{PFAS) firefighting foams have been widely used by airports, ferry systems, transportation 

departments, oil refineries, railroads, chemical plants, as well as by local fire departments and 

fire training facilities for decades. The PFAS-containing foams used at military bases and other 
162 

locations are largely responsible for contaminating drinking water and creating many 

contaminated sites across the country at great cost to states and federal taxpayers. The 

Department of Defense has estimated it will cost more than $2 billion to address PFAS 

contamination at military bases alone. 

2. Preventing future contamination by reducing sources of these chemicals must be a priority to 

protect public health and avoid skyrocketing costs of cleanup. Washington State recently 

banned the sale of PFAS foams to fire departments and other users, as well as banning the use 

of PFAS foams in fire training, including at airports. Congress should phase out PFAS chemicals in 

firefighting foam, mandate the proper disposal of remaining stocks by the manufacturers, and 

require safer effective alternatives that protect life, property and fire fighters. In addition, the 

Department of Defense must change its military specification requiring the use of fluorine-based 

firefighting foams. Effective firefighting capability can be achieved without the use of PFAS, yet 

the current military specification requiring PFAS limits the options available to the military and 

only exacerbates contamination of drinking water. An updated specification is sorely needed. 

3. Require Polluters to Pay for Clean Up. It will cost billions to clean up PFAS pollution. Taxpayers 

should not be forced to cover these costs. Communities facing PFAS contamination should not 

bear the added burden of paying to clean up pollution they did not create. Manufacturers must 

be held accountable. Congress should establish a program that requires PFAS manufacturers to 

pay for cleaning up contaminated sites. In addition, citizens must have the ability to take action 

against PFAS polluters. 

4. Stop further contamination by banning PFAS. States are already stepping up to eliminate PFAS 

from key product sectors including food packaging, firefighting foam and textiles. Congress 

should phase out all uses of these chemicals to avoid further contamination and additional clean 

up costs. 

5. Ensure states, local governments and the public have adequate information and technical 

assistance to fully address the PFAS crisis. Congress should require food and drinking water to 

be fully tested for PFAS. Congress should further require that PFAS are added to the Toxic 

Release Inventory list in the Emergency Planning and Community Right-to-Know Act and 

regulated as: toxic pollutants and hazardous substances under the Clean Water Act; hazardous 

substances under Superfund, and hazardous waste under the Resource Conservation and 

Recovery Act. Doing so would ensure that federal, state and local agencies can identify and 

prioritize areas in need of remediation. Finally, Congress should also provide funding to EPA to 

develop and provide technical assistance and testing methods needed to sufficiently address the 

problem 

Decades of widespread use of PFAS means that these chemicals are everywhere. PFAS contamination 

impacts everyone in a community. We need solutions now to ensure clean and safe drinking water for 

all. 

Sincerely, 

Pamela Miller 

Executive Director 

Alaska Community Action on Toxics 

Katie Huffling 

Executive Director 

Alliance of Nurses for Healthy Environments 

Linda Reinstein 

President 

Asbestos Disease Awareness Organization 

Nancy Buermeyer 

Senior Policy Strategist 

Breast Cancer Prevention Partners 
163 

Ansje Miller 

Director of Policy and Partnerships 

Center for Environmental Health 

Kathleen Curtis 

Executive Director 

Clean and Healthy New York 

Emily Donovan 

Co-Founder 

Clean Cape Fear 

Lynn Thorp 

~!::itivddl Campaigns Director 

Clean Water Action/Clean Water Fund 

Andrea Delgado 

Legislative Director, Healthy Communities 

Earthjustice 

Rebecca Meuninck 

Deputy Director 

Ecology Center 

Bruce Speight 

Director 

Environment Washington 

Patrick MacRoy 

Deputy Director 

Environmental Health Strategy Center 

Scott Faber 

Vice President 

Environmental Working Group 

Marcia Cooper 

President 

Green Newton 

Sue Phelan 

Director 

Green CAPE 

Lynn Nadeau 

Treasurer 

Healthlink 

Bill Walsh 

Founder & President of the Board 

Healthy Building Network 

Laura Rubin 

Executive Director 

Huron River Watershed Council 

Madeleine Foote 

Legislative Representative 

League of Conservation Voters 

Maureen Swanson 

Director, Healthy Children Project 

Learning Disabilities Association of America 

Kaci Smith 

Co-President 

Learning Disabilities Association of Arkansas 

Carolyn P. Kingsley 

Learning Disabilities Association of Georgia 

Tracy Gregoire 

Healthy Children Project Coordinator 

Learning Disabilities Association of Maine 

Anne Fogel 

Secretary, LDA of South Carolina 

Learning Disabilities Association of South Carolina 

Dr. JoyS. Marsh 

State President 

Learning Disabilities Association of Tennessee 

Cheryl Osimo 

Executive Director 

Massachusetts Breast Cancer Coalition 

Janet Domenitz 

Executive Director 

MASSPIRG 

Laurene Allen, LICSW 

Merrimack Citizens for Clean Water 

Cody Angell 

Michigan Demands Action Against Contamination 

Lisa Wozniak 

Executive Director 

Michigan League of Conservation Voters 

Diana Zuckerman, PhD 

President 

National Center for Health Research 
164 

Erik DOlson 

Senior Director, Health & Food 

Natural Resources Defense Council 

Liz Hitchcock 

Acting Director 

Safer Chemicals Healthy Families 

Sarah Doll 

Executive Director 

Safer States 

Kristi Marsh 

Founder and President 

Savvy Women's Alliance 

Ted Schettler MD, MPH 

Science Director 

~c1ence and Environmental Health Network 

Robin Schneider 

Executive Director 

Texas Campaign for the Environment 

Laurie Valleriano 

Executive Director 

Toxic Free Future 

Shaina Kasper 

Vermont and New Hampshire State Director 

Toxics Action Center 

Kara Cook-Schultz 

Taxies Director 

U.S. PIRG 

Andrew Rosenberg, Ph.D. 

Center for Science and Democracy at the Union of 

Concerned Scientists 

Union of Concerned Scientists 

Miriam Gordon 

Program Director 

UPSTREAM 

Lauren Hierl 

Executive Director 

Vermont Conservation Voters 

Adrienne L. Hollis 

Director of Federal Policy 

WE ACT for Environmental Justice 

Michelle Naccarati-Chapkis 

Executive Director 

Women for a Healthy Environment 

Jamie McConnell 

Director of Program and Policy 

Women's Voices for the Earth 
165 

The Honorable Rand Paul 

Chairman, Subcommittee on 

FSO and Emergency Management 

Committee on Homeland Security 

U.S. Senate 

Washington, DC 20510 

September 26, 2018 

The Honorable Gary Peters 

Ranking Member, Subcommittee on 

FSO and Emergency Management 

Committee on Homeland Security 

U.S. Senate 

Washington, DC 20510 

:ie. September 26 hearing on the Federal Role to the Toxic PFAS Crisis 

Dear Chairman Paul and Ranking Member Peters: 

The National Ground Water Association (NGWA) applauds the Subcommittee's holding of the hearing on 

"the Federal Role in the Toxic PFAS Crisis." Contamination from per- and poly-fluoroalkyl substances 

(PFAS) is nearly ubiquitous across the country, and more resources--technical and financial--are needed 

to accurately identify and address the scale of the problem. 

NGWA is a trade association and professional society with over 10,000 members committed to the 

management, protection and use of groundwater resources. Our members are contractors, scientists, 

engineers, manufacturers and suppliers, who are actively working to address PFAS contamination on a 

daily basis--whether working on contaminated sites to devise remediation plans or assisting individuals 

directly with the testing and treatment of drinking water supplies. 

NGWA offers the following recommendations and observations about the federal role in responding to 

the PFAS crisis: 

To most effectively manage PFAS contamination, regulatory certainty that is enforceable must 

be established at the federal level, as soon as possible. Absent of this certainty, states are 

enacting their own limits, creating additional challenges for the detection and remediation of 

contamination across states. 

Sound science is an integral part of any regulatory determination. Therefore, chemicals must be 

assessed individually, and limits must not be set until toxicology values are determined for each 

chemical. This science must be conducted at the federal level to provide greater certainty 

across all states where contamination has been detected. 
166 

rederal resources must be provided to increase the number of labs capable of testing for PFAS 

via EPA's method 537. Many states have no labs that use method 537, and the limited number 

of labs make testing for PFAS cost-prohibitive, particularly for private well owners. 

Private wells pose unique challenges in detecting contamination because there are no 

requirements for well owners to routinely test their water. Federal funding for technical 

assistance programs to conduct well owner outreach and financial support for water testing 

must be prioritized, particularly in rural areas. 

• While PFAS in drinking water is a challenge, it is not a challenge without a solution. Like all 

contaminants in drinking water, treatment options are available to ensure drinking water 

remains safe and reliable. Funding should be made available for point-of-use devices to treat 

contaminated drinking water. 

NGWA and its members look forward to continuing to serve as a resource for the committee. Our 

members stand ready to volunteer their expertise, as solutions and assistance are developed. 

NGWA also produced a comprehensive guidance document on the state of knowledge and practice 

surrounding groundwater and PFAS. Please contact Lauren Schapker, NGWA government affairs 

director, if you would like a copy of this resource or with any questions at t;chajlker@ngwa.org or 

702.888.9151. 

We look forward to working with the committee on this important issue. 

Sincerely, 

Terry S. Morse, CIC 

Chief Executive Officer 

National Ground Water Association 
167 

The State of New Hampshire 

Department of Environmental Services 

Robert R. Scott, Commissioner 

September 25, 2018 

U.S. Senator Rand Paul 

Chairman, U.S. Senate Subcommittee on Federal 

Spending, Oversight & Emergency Management 

340 Dirksen Senate Office Building 

Washington, DC 20510 

Dear Chairman Paul and Members of the Subcommittee: 

Thank you for this opportunity to provide the perspective and requests of the New Hampshire 

Department of Environmental Services. New Hampshire has been dealing directly with Per- and 

Polyfluoroalkyl Substance (PFAS) contamination since 2014 when contamination of a public drinking 

water well was discovered associated with the former Pease Air Force Base. We have since found 

multiple other sites associated with PFAS contamination. 

One of the biggest challenges with this family of emerging contaminants is determining and 

implementing protective and enforceable drinking water standards. Due to a lack of federal standards, 

ctotc, have been forced to create their own standards. This results in a patchwork of conflicting 

standards throughout the nation that causes confusion and unnecessary stress to the affected 

communities and families, as well as the regulated entities, as they are unsure of what standards are 

safe. The creation of national safe drinking water standards will allow states to focus their efforts on 

communication, implementation and compliance assurance- the appropriate roles considering states' 

funding and staffing constraints. 

cc: NH Governor Christopher T. Sununu 

U.S. Senator Jeanne Shaheen 

U.S. Senator Maggie Hassan 

~a- Robert R. Scott 

Commissioner 

www.des.nh.gov 

29 Hazen Drive • PO Box 95 • Concord, NH 03302-0095 

(603) 271-3503 • Fax: 271-2867 TDD Access: Relay NH 1-800-735-2964 
168 

A Formal Request from Oscoda-Wurtsmith Airport Authority 

S~e~:ng Indemnification Protection and Additional Environmental Restoration Response 

Support at the Former Wurtsmith Air Force Base, Oscoda Michigan 

In response to the discovery of United States Air Force (or Air Force) having released Poly- and 

Perfluoroalkyl Substances (PFAS) in soils, groundwater and residential water supply wells - -

securing additional commitments from the United States Government (or Government) is now 

critically important. Oscoda-Wurtsmith Airport Authority and its' constituent municipalities, 

along with all successors in operation of former Wurtsmith Air Force Base (Wurtsmith A.F.B.) 

properties, respectfully seek indemnification protection as well as additional and more timely 

environmental restoration response activities from the United States Government. 

A. Indemnification Protection 

1. When closing Wurtsmith A.F.B., the United States Government executed a Public Benefit 

Transfer (PBT) Agreement with Oscodil-Wurtsmith Airport Authority (dated December 19, 

1994). The PBT Agreement establishes each party's obligations and commitments during 

future reutilization of the former military properties. It cites the Comprehensive 

Environmental Response and Liability Act (CERCLA) Sections 120(h)(3) and 120{h)(4) - -

which establishes the Government's obligation to clean up Air Force generated 

contamination even after the completion of land trJnsfer transactions. 

2. PFAS contamination at Wurtsmith A.F.B. has been discovered subsequent to base closure 

and the related land transfer conveyance documents. Therefore, neither the 1994 PBT 

Agreement, land transfer documents nor the cited CERCLA laws specificillly envision and 

address the Government's clean up obligations in response to Air Force generated PFAS 

contamination. Of Significant concern is the need to protect the Local Redevelopment 

Authority in response to any claims associated with personal injury or property damages 

that might result from the Air Force generated environmental contamination. 

Oscoda-Wurtsmith Airport Authority respectfully seeks to secure a firm obligation and 

commitment from the United States Government to immediately hold harmless, defend and 

indemnify in full - - Oscoda-Wurtsmith Airport Authority, its' constituent municipalities and 

~~~ >uccessors in operation of former Wurtsmith A.F.B. properties, in response to any claims 
169 

of personal injury or property damage - - resulting from, or which is predicated upon, the 

release or threatened release of any and all forms of environmental contamination resulting 

from Air Force activities at the former Wurtsmith Air Force Base. 

B. Additional and Timely Environmental Restoration Response Activities 

As stated above, the Comprehensive Environmental Response and Liability Act (CERCLA) sets 

forth the Government's obligation to cleanup Government generated environmental 

contamination from former Department of Defense sites. CERCLA does not specifically include 

provisions for Local Redevelopment Authority's to participate when establishing response 

priorities for the Government's site investigations or cleanup. Therefore, Local Redevelopment 

Authorities and potential developers face months or even years while waiting for the 

Government to investigate and I or restore contaminated property. 

hinder and can derail important local redevelopment projects. 

A current example is described below. 

Such circumstances 

An existing tenant at Oscoda-Wurtsmith Airport is expressing significant interest in developing 

at least one, and perhaps two, very large aircraft maintenance hangars. Each aircraft 

maintenance hangar is expected to create 150 new jobs. Therefore, the envisioned project is a 

very high priority for the local community. In response to the discovery of potential PFAS 

contamination and related issues, the developer is now reticent to implement this important 

project at Oscoda-Wurtsmith Airport. As a result, they are now also looking for development 

sites at other airports. 

The actual environmental condition of the Oscoda development site is unknown. Therefore, 

timely performance of an Environmental Site Assessment is necessary in order to retain the 

developer's interest. The Government's current environmental response work at OscodaWurtsmith Airport primarily involves intercepting PFAS in contaminated groundwater. It is our 

understanding that project funding limitations and other resource restraints currently preclude 

the Government's environmental response team from also performing full environmental site 

asse<>~Ments, Therefore the needed full Environmental Site Assessment is being commissioned 

and funded by state and local agencies. In other words, state and local agencies are assuming 

costs associated with performing site investigations that really should be the Government's 

responsibility. The estimated cost for completing this single site investigation and developing a 

responsive 'Due Care Plan' is $60,000. 

Oscoda-Wurtsmith Airport Authority is seeking to establish provisions which empower the 

local Development Authority to establish priorities and otherwise direct the Government's 

environmental site assessments and cleanup response initiatives. 
170 

Alternatively, the Government will provide the Airport Authority with access to a source of 

federal Government funding that will pay for environmental site investigations and 

establishing 'due care' plans that are directly commissioned by Oscoda-Wurtsmith Airport 

Authority. 

Thank you for considering these important requests. If there are questions or additional 

information is needed, please contact me or our Airport Manager - Mr. Gary Kellan, by calling 

••••• .,r via email at········· 

Sincerely, 

Kevin Boy at, Chairman 

Oscoda-Wurtsmith Airport Authority 
171 

Southern 

Environmental 

Law Center 

October 2, 2018 

The Honorable Rand Paul 

122 (: .Stnx! N\'V', \uit<.' YJO 

\\',,~hin~wn, DC 20001-.: 10~ 

202-~28-H.\82 

Ln. 202-:)4'7-(,041 

Sout ht:rl\ En 1·iron men t .org 

Chatrman, Subcommittee on Federal Spending Oversight and Emergency Management 

United States Senate 

439 Hart Senate Office Building 

Washington, DC 20510 

The Honorable Gary Peters 

Ranking Member, Subcommittee on Federal Spending Oversight and Emergency Management 

United States Senate 

432 Hart Senate Office Building 

Washington, DC 20510 

Dear Chairman Paul and Ranking Member Peters: 

Southern Environmental Law Center (SELC) thanks the U.S. Senate Committee on Homeland 

Security and Government Affairs, Subcommittee on Federal Spending Oversight and Emergency 

Management for holding a hearing on the Federal Role in the Toxic PFAS Chemical Crisis, 

Communities across the country, including communities in North Carolina, have been harmed by 

PF t\S pollution over the past century. The federal government is now aware of the extent of destmction 

that PFAS can cause to our bodies and the environment. The federal government must act immediately to 

combat this class of harmful chemicals. 

SELC respectfully requests to submit the attached comments to the record for the hearing entitled 

'"The Federal Role in the Toxic PFAS Chemical Crisis'" before the Subcommittee on Federal Spending 

Oversight and Emergency Management held on September 26, 20 !8. SELC originally wrote these 

comments for the Environmental Protection Agency's Docket EPA-HQ-OW-2018-0270 on PFAS 

contamination, however they may provide valuable information to the subcommittee as it continues to 

investigate the PF AS chemical crisis. 

Sincerely, 

Navis A. Bcunudez 

Federal Legislative Director 

(:h.Jrluutwilk • Ch.1pd fli!l '":\d.mt.l • .\>h~·vi!k • Hirnun):lwn ~ ("!l.llk•.,wn • :'--.'.!'-11\·i!k ~ RkhnwnJ • \\.",hhingron, [)C 

j(){Ji'o !l'<)"<'ialj!tl/h'!" 
172 

SOUTI-IERN ENVIRON1v1ENTAL LAW CENTER 

GOl WEST POSCV1i\~Y Sl RtU. Sl:IH- //0 

Andrew Wheeler 

Acting Administrator 

Environmental Protection Agency 

1200 Pennsylvania Avenue. ?--J.W. 

Washington, DC 20460 

Eric Burneson 

CHAPEL HIU. NC 235!..\ 

September 28. 20 !8 

Director, Standards and Risk Management Division 

Oftlce of Ground Water and Drinking Water 

Environmental Protection Agency 

1 ?Of) Penn,syivania Avenue, N. W. 

\\'ashington, DC 20460 

Facsm111e 919-929-9421 

RE: Comments on EPA Response to Per- and Polyfluoroalkyl Substances (PFAS), 

Docket II) No. EPA-HQ-OW-2018-0270 

Dear Acting Administrator Wheeler and Director Burncson: 

The Southern Environmental Law Center offers the following comments on actions that 

the Environmental Protection Agency must take to address the presence of per- and 

polyfluoroalkyl substances (PFAS) in the nation's drinking water. surface and groundwaters. air, 

and soil. These comments are submitted on behalf of Cape Fear River Watch, North Carolina 

Conservation Network, North Carolina Coastal Federation. Sound Rivers. Haw River Assembly, 

Catawba Riverkecper Foundation, and the French Broad Riverkeeper. 

For nearly four decades, E.!. duPont de "icmours and Company ("DuPont") and the 

Chemours Company FC, LLC ("Chcmours") knowingly contaminated the air, water, and soil in 

southeastern North Carolina. including the drinking water supply of more than 250,000 Nmih 

Carolinians. The people of North Carolina are worried that the years of drinking. lishing from. 

and swimming in the companies' polluted waters have permanently harmed the health of 

themselves and their families. And they arc furious that companies like DuPont have historically 

polluted other communities with the same compounds and were simply permitted to continue 

their toxic pollution in new places. 

As EPA has witnessed at its Community Engagement events throughout the country. 

North Carolina is not the only state that has been intentionally used as a dumping ground for 

PFAS chemicals-pollution that will persist for years in people's bodies and the environment. 

There must be immediate action on PFAS. But EPA's current proposed actions are entirely 

inadequate. Most importantly, (I) they only consider two of the thousands of existing PFAS, 

allowing companies to continue using the regulatory loopholes that they have used for decades. 

Charlottesville • Cl'\arel Hi!l ~ Mi.3nla. • Asheviltr> • Bummgham • Cl1corteston • i~astw1lle • R•chmond • Wasl1mgton, DC 
173 

and (2) they do nothing to stop additional toxic PFAS from spewing into our air, soil, and water, 

and remaining there tor decades. 

A. PFAS arc toxic and bioaccumulativc, and they persist in the environment and in our 

bodies. 

It is well established that PFAS arc a threat to the health and safety of the public. Two of 

the commonly studied PFAS. pcriluorooctanoic acid ("PFOA") and perfluorooctyl sulfonate 

(''PFOS"), have been found to cause developmental cJTccts to fetuses and infants, kidney and 

testicular cancer. liver malfunction, hypothyroidism. high cholesterol, ulcerative colitis, lower 

birth weight and size, obesity, decreased immune response to vaccines, reduced hormone levels 

and delayed puberty. 1 Epidemiological studies suggest that many of these same health outcomes 

result from exposure to other PF AS. 2 PFAS have been found in the air and dust. surface water 

and groundwater, and soil and sediment. 3 They arc extremely resistant to breaking down in the 

environment. can travel long distances. and have even been found in the Arctic and in the open 

ocean4 They take years to leave the human body, and instead slowly accumulate over time-' 

Concerned about the extensive health effects ofPFOA and PFOS, in 2016. EPA 

established a lifetime health advisory of 70 parts per trillion ('"ppf') tor the combined 

concentrations of PFOA and PFOS in drinking water6 Since then, in June 2018. the Agency for 

Toxic Substances and Disease Registry released an updated Draft Toxicological Prolilc for 

PFOA, PFOS. and other PFAS. The report suggested that many of the chemicals arc much more 

harmfi.li than previously thought. For instance, the minimum risk levels, or the amount of a 

chemical a person can cat. drink, or breathe each day without a detectable risk to health, was 

determined to be only ll ppt for PFOA. and 7 ppt for PFOS7 

Within the past several decades, companies like DuPont and Chcmours have replaced 

PFOA with "short-chain .. PF AS. which have fewer carbons 8 In :vtay of 2015. two hundred 

researchers and scientists warned government officials, manufacturers, and the public not to 

1 Arlene Blum, et al., ''The Madrid Staternent on Poly- and Pcrfluoroa!kyl Substances (PFASs),'' 123 Environ. 

Health 5. A 107 (May 2015) (hereinafter "The Madrid U.S. Environmental Protection 

Fact Sheet on PFOA & PFOS Drinking Water Health 2, availah!e at 

Dep't ofllealth and Human 

Toxicological Pro tile for Perfluoroalkyls, 2 4 /r/· ahu EPA, Technical Fact Sheet~ ver·!luorc•OClane 

(Nov.2017); The Madrid Statement at A 107. 5 A TSDR. Toxicological Profile for Pertluoroalkyls, Draft for Public Comment, at 3 (Aug. 20 15). 

~EPA, Fact Sheet on PFOA & PFOS Drinking Water Health Advisories at 2. 

'CFPt !A Statement on Recently Released DHIIS Report, June 21, 2018, available at 

sec also Draft 2018 Toxicological Profile for Perfluoroalkyls. 

Melisa ct a!., the toxic potency in vivo oflong-chain pcdluoroalkyl acids and fluorinated 

alternatives,'' 113 Environ. International 1 (20 18) (hereinafter ·'Gomis 2018 ~tudy''), included as Attachment 2 

2 
174 

underestimate the danger of short-chain PFAS alternatives." Yet EPA has done exactly that, 

stating that short-chain PFAS "arc generally less toxic and less bioaccumulative in wildlife and 

humans.'' 10 The California Department of Toxic Substances Control reviewed recent scicntitlc 

literature on PFAS compounds. including short-chain PFAS alternatives and, in February 2018. 

released a draft report highlighting the danger of short-chain PFAS: 

Shorter-chain PF ASs arc marketed as less toxic compared to the longer-chains, 

mainly because they appear to bioaccumulate less and to be more readily 

eliminated ti·mn some organisms. Nevertheless, they are equally persistent and 

more mobile in the environment than the chemicals they are replacing, and also 

show potential for toxicity. 11 

Citing a 2018 study which compared short and long-chain PFAS compounds, the 

report ultimately l(mnd that the short-chain alternatives could be more toxic than the 

compounds they arc replacing: 

PFECAs and shorter-chain PFAAs may have similar or higher roxie potency than 

the longer-chain PFAAs they arc replacing. Using a toxicokinetic model and 

existing toxicity data sets, a recent study found that PFBA. PFHxA, and PFOA 

have the same potency to induce increased liver weight whereas GenX is more 

potent. The authors concluded that previous findings of lower toxicity of 

fluorinated alternatives in rats were primarily due to the faster elimination rates 

and lower distribution to the liYcr compared to PFOA and other longer-chain 

PFAAs. 12 

Short-chain alternatives only appeared to be less toxic than long-chain PFAS, such as PFOA, 

because it was leaving the bodies of animal test subjects more readily than long-chain 

compounds. For humans, however, short-chain PFAS ·'could likely be intrinsically as potent as 

their prcdecessors.'' 13 As explained by the 2018 study cited by the California Department of 

Toxic Substances ControL "short-chain PFASs that are rapidly excreted in a species such as the 

rat m"v not reach internal concentrations sufficient to result in toxic e!Tccts that it could in other 

specie; with a longer half-life, such as hmnans.'' 14 Therefore, short-chain PFAS arc likely to stay 

in the human bodies long enough to cause severe toxic effects. Short-chain PFAS created to 

replace PFOA and PFOS could be as harm till, if not more harmfi.1l, than the compounds they 

<)The Madrid Statement at A 107: see also Schcringcr ct a!., Hc!singor Statement on poly~ and pcrtluorinatcd alkyl 

(PFASs) I 14 Chemosphere 337 (2014). 

EPA, Risk Management for Per- and Po!yfluoroalky! Substances (PFASs) under TSCA. available at 

https://www.epa.gov/assessing-and-managing-chcmicals-under-tsca/risk-managcmcnt-and-polyfluoroalkylsubstances-pfass (last visited Sept 19. 2018). 11 California Department of Toxic Substances Control, ·'Product-· Chcmkal Profile for Pcrfluoroalkyl and 

PolyOuoroalkyl Substances (PrASs) in Carpets and Rugs" 6 (2018) (hereinafter "CDTSC 2018 Report"). included 

as Attachment 3, 

I:' Id at 29 (citation omitted). 1

" Gomis 2018 studv at 7·8. H /d. ~ 

,) 
175 

·::ere ueatcd to replacc. 15 Additionally, because some short-chain PFAS arc less effective, larger 

quantities of short-chain PFAS may be used in manufacturing processes. 16 

B. For decades, chemical companies have freelv contaminated our environment with 

PFAS, 

In North Carolina, for nearly four decades, DuPont knowingly contaminated the air, 

water. and groundwater at its Fayetteville Works Facility, and the Cape Fear River-the drinking 

water supply for more than 250,000 North Carolinians. After DuPont created Chemours. 17 and 

passed responsibility for its pollution to its then-subsidiary, the fi1cility continued to quietly 

release hundreds of thousands of pounds of toxic PFAS. 

This was not the first time DuPont contaminated a community and its drinking water. 

Before DuPont polluted the air and water in southeastern North Carolina, the company 

devastated communities in \Vest Virginia with its pollution containing PFOA. 18 DuPont knew 

about the dangers of PFOA beginning in the early 1960s, after the company conducted studies 

that showed the chemical caused liver damage, was resistant to degradation, and could cause 

birth defccts. 19 By 1981, DuPont found PFOA in the umbilical cord of a pregnant employee, 

demonstrating that the chemical's toxic effects could reach fetuscs. 20 By 1982, DuPont knew 

that PFOA emissions from its facility's stacks in West Virginia traveled beyond the boundaries 

vf ;,, \vest Virginia facility and was warned by its own medical director that surrounding 

communities were likely being exposed to the company's poisonous dust 21 By 1987, DuPont 

found the chemical in drinking water around its West Virginia facility, yet told no one outside 

the company.22 

Nevertheless, when DuPont lost its supply of PFOA from the 3M Company in 2000, it 

decided to begin making PFOA in North Carolina, starting a new legacy of pervasive 

environmental pollution in a new place. 2

·' Y cars later, plagued by thousands of civil lawsuits 

from its PFOA pollution in West Virginia; scientilic evidence showing that PFOA causes birth 

!S S'ee also Gomis 20! 8 study; Gloria Post ct aL ''Key scientific issues in developing drinking water guidelines for 

perfluoroalky·! acids: Contaminants concern," 15 PLoS Bioi c~002855 (20 17); Melissa Gomis. "From 

emission sources to human tissues: exposure to per- and polyfluoroalkyl substances,'· (20 J 7); Nan 

Sheng eta!., ··cytotoxicity of nove! alternatives to long chain," 92 An.:hive;;,· ofToxicol. 359 (2017); 

Melisa Gomis et aL, "A modeling assessment ofth~ physicochemical and environmental fl1te of emerging 

and novel per- and polytluoroalkyl substances," 505 S'ci. of the Total 981 (20!4); J.M. Rae et al., 

"Evaluation of chronic toxicity and carcinogenicity of ammonium 2.3,3,3-tetratluoro-2-(heptafluoropropoxy)-

in SpragueDavdey rats," 2 Toxiu;/. Ret). 939 (2015). 

Madrid Statement at A 107. 17 E. I. duPont de Nemours and Company owned and operated the fayetteville Works from the 1970s until 

the fOrmed Chcmours Company FC, LLC, and transfcn'Cd mvncrship to Chcmours 2015. 

Rich, "The La\vyer Who Became DuPont's Worst Nightmare;' lv'.Y. Times, Jan. 6, 2016, available 

].0 /d. 

11 ld; see also Motion fOr Partial Summary Judgment, Exhibit 7, Little 

& Co., 91 F. Supp. 3d 940,962 (S.D. Ohio ]015), included as 

(last 

Motion for Partial Summary Judgment, Exhibit 12, Little ffockinK f'Vater A.n'n, Inc. v. EJ duPont ,Vemours 

& Co, 91 F. Supp. 3d 940. 962 (S.D. Ohio 20 15), included as Attachment 5. 2

'

1

1'\athanicl Rich, "The Lawyer Who Became DuPont's \\.'orst Nightman.~," NV. Times, Jan. 6, 2016. 

4 
176 

defects, cancer, and other severe health effects; and pressure from the public and EPA, DuPont 

was compelled to stop making PFOA2

' And, it replaced it with the equally ham1ful OenX. 

DuPont studied OenX, its new toxic PFAS substitute, beginning as early as 1963, 

discovering over time that OenX produced toxic effects in laboratory animals similar to that of 

PFOA, including cancers in the liver, pancreas, and testicles?' Still, the company began quietly 

releasing the chemical into a North Carolina drinking water supply, the Cape Fear River, in the 

early 1980s, as a result of its many manufacturing processes."' DuPont also began emitting 

hunrlreds of millions of pounds of GcnX and other PFAS into the air each year, and allowing the 

chemicals to leak from its open pits, ditches, and pipes into the aquifers that supply the drinking 

water wells lor hundreds of families. 27 

Three decades later, when DuPont began making GenX as a replacement for PFOA at the 

Fayetteville Works Facility in North Carolina, 28 the company did not disclose to the North 

Carolina Department of Environmental Quality or to the public that GenX has harmful health 

effects similar to those of PFOA, or that DuPont had already been dumping the chemical into the 

Cape Fear River for nearly three dccadcs. 29 

DuPont created a new company, Chemours. to bear the weight of its hundreds of million 

dollars' worth oflegalliabilitics t!·om its PFOA contamination. When Chemours took ownership 

of the Fayetteville Works Facility in 2015, it simply continued DuPont's tradition of toxic 

pollution.30 Hundreds of thousands of people in North Carolina have been devastated by DuPont 

and Chcmours' decades ofPFAS contamination. Until PFAS arc strictly regulated, millions 

more throughout the country will be harmed by these companies' blatant disregard for 

communities near their facilities. 

C. EPA must regulate I'FAS as a class of compounds, 

. There arc over 3,000 PFAS in circulation on the global market,31 and possibly 5,000 to 

10,000 in total 32 EPA has a proposed a regulatory process which addresses one PFAS at a time. 

This will not protect the health of the public and the environment. 

>t /d. 

''DuPont and Chcmours' TSCA tiling to EPA. "SEHQ-06, 1643 6. 8EHQ-06- 16478." Jan. 8, 2013, included as 

Attachment 6. 6 Amended Complaint, NC Dept 

DEQ Amended Complaint""), as 

Exhibit 22 ofNC DEQ Amended Complaint,· Focused Feasibility Study Report- PFAS 

as Attachment 8. 

NC Amended Complaint at 18. 

at 14.20-21. 

5 
177 

EPA made the mistake years ago offailing to address the entire class ofPFAS. In 2006, 

EPA asked companies, including DuPont, to voluntarily phase out their use of PFOA, and gave 

the companies nearly a decade to do so33 DuPont then took advantage of the lack of regulation 

on PFAS and simply shifted to using GcnX. a structurally similar compound, to replace PFOA. 

Despite DuPont's own studies of GenX showing that the chemical had health effects in 

laboratory animals consistent with the effects of PFOA, DuPont and later. Chemours, 

intentionally pumped GenX and numerous other PFAS into the drinking water for over 250,000 

people in southeastern North Carolina for decades. 

EPA is poised to make the same mistake. The agency's proposed response fails to 

address the entire class of PFAS. and will again allow companies like DuPont and Chemours to 

avoid regulation of their PFAS pollution. EPA has proposed: 

"evaluatfing] the need for a maximum containment level (MCL) for PFOA and PFOS," 

• "beginning J ... J to propose designating PFOA and PrOS as 'hazardous substances' 

through one of the available statutory mechanisms,'' 

''developing groundwater cleanup recommendations for PFOA and PFOS at 

contaminated sites," and 

• "taking action J ... 1 to develop toxicity values for GcnX and PfBS.''34 

Each of EPA's proposed actions is limited to only two PF AS out of thousands of existing Pf AS. 

Moreover, EPA only proposes enforceable regulations for PFOA and PFOS-legaey PF AS that 

companies like DuPont and Chemours have already switched out for new PF AS alternatives, 

such as GenX. 

In addition to holding PFAS manufacturing companies accountable tor their pollution, 

EPA's regulation ofPFAS as a class will ensure that the agency considers the cumulative c!Iects 

ofPFAS mixtures on humans and the environment. As evidenced by the situation in North 

Carolina, these compounds are not released one at a Dozens. if not hundreds. of different 

PF AS are released together into the air. water. and soil. Therefore, people and the environment 

arc exposed not only to PFOA or PFOS, but toxic mixtures that can cause greater harm than a 

single PFAS wouldy, Any regulatory action, therefore, must consider the cumulative cfl'ects of 

exposure to numerous different PFAS over an entire lifetime. 

EPA cannot wait for health studies to be conducted on each individual PFAS bclorc it 

acts. In l'vlay 2009, the Agency for Toxic Substances and Disease Registry released its first dratt 

Toxicological Pro tile ior Perf1uoroalkyls for public commcnt37 Over 9 years later, EPA is still 

releasing draft versions of this report lor public comment· the latest version of which discusses 

Attachment 9, 

l{, Wang Ting ct aL ·'Hydrophobicity-dependent QSARs to predict the toxicity ofpertluorinated carboxylic acids 

their mixtures,'' 32 Environ Toxicol flharmaco! 2 (2011 ). 

Draft 20!8 Toxicological Profile for Perfluoroalkyls at iv. 

6 
178 

only 14 PFAS out of the thousands of existing PFAS3 ' Still, the public has not seen any 

enforceable regulations on PFOA, which has been in production for over 60 years,39 and has long 

been known to cause developmental effects to fetuses and infants, kidney and testicular cancer. 

liver malfunction, hypothyroidism, high cholesterol, ulcerative colitis, lower birth weight and 

size, obesity, decreased immune response to vaccines, reduced hormone levels, and delayed 

pubcrty, 40 

States and other countries have recognized the need lor PF AS to be regulated together, 

For instance, Vermont has issued a drinking water health advisory for the sum of five different 

PFAS, Vermont has determined that the combined levels ofPFOA, PFOS, perfluorohexanc 

sulfonic acid ("PFHxS"), perfluoroheptanoic acid ("PFHpA''), and perfluorononanoic acid 

("PFN A'') should not exceed 20 ppt" Massachusetts has similarly issued a public health 

guideline for the combined levels ofPFOA, PFOS, PFNA, PFI!xS and PF!lpA, stating that 

public ~vater supplies sh?uld "take steps e:p,cditiously'' to lower the combined level: ?f the Eve 

PI' AS· to below 70 ppt lor all consumers, • Other states that have addressed PFAS m addition 

to PFOA and PFOS include Connecticut, Minnesota, and New Jcrsey"3 Sweden and Germany 

have proposed that the European Union restrict the manufacture of about 200 PFAS, 44 

EPA must use existing environmental statutes, as discussed in Section F, to regulate the 

entire class of PFAS in order ( 1) to prevent companies from creating new PFAS to avoid 

regulation as they have done in the past, and (2) to account for exposure to toxic PFAS mixtures 

that already exist in our air soiL and water, Anything less will not protect communities like 

those in southeastern North Carolina from future harm, 

D. EPA must prevent PFAS at the source. 

EPA's current proposed actions do nothing to stop PFAS tl'0111 entering the environment 

in the first place, Instead, EPA plans to put the burden on public water supplies, their customers, 

and others to filter and clean up PFAS that have been already allowed to permeate throughout 

drinking water supplies, rivers and Jakes, and soiL EPA's strategy is not feasible, Both site 

remediation and drinking water treatment for PFAS are extremely costly and difficult, and 

!d. at L 

N Andrew Lindstrom, et aL, "Polytluorinated Compounds: Past Present, and Future,'' 45 Environ Sci. Techno!. 19 

I), 

The Madrid Statement at A 107: lJ.S. Environmental Protection Agency ('"EPA"). Fact Sheet on PFOA & PFOS 

Water Health Advisories, 2. 

ofl leal!h, "Drinking \:\/atcr Health Advisory for Five PFAS (per~ and polyfluorinated alkyl 

! 0. 2018. availablu at 

DWPF AS_ I JealthAdvisory.pdf(last visited 

Water,'' avai/ahle at 

eo,;/llles,'docurncrrts/20 1/pfas,in-dw,fsO.pdf (last visited Sept 19, 2018). 

RegulatOJ)' Council, PFAS Fact Sheets, Section 4 Tables, available at https: /pfasl.itrC\veb.org/fact-sheets1 (last visited Sept. 19. 2018). 44 KEMI, Swedish Chemicals Proposal to ban 200 highly tluorinated substances, Dec. 20,2017. available 

"' substances/ (last visited Sept. 19, 2018): Public Consultation. 

KC':itnction On C9~Cl4 Perlluorocarboxylic Acids (PFCAS), Their 

included as Attachment 10. 

7 
179 

conventional techniques arc often ineffective.·" Because EPA docs not plan to combat PFAS 

pollution at its source, the agency's plan will not protect human health and the environment. 

As evidenced by the presentations EPA gave in its Community Engagement Event in 

Fayetteville, North Carolina. EPA knows what the sources of PFAS are_46 They include PFASmanufaeturiug facilities and facilities that PFAS as part of their industrial processes, 

wastewater treatment plants, and landfills. Once PFAS enters the environment, it moves 

aggressively. The chemicals "end up virtually everywhere, including air, dust, wastewater 

treatment plant (WWTP) effluent. biosolids. soil, inland and ocean waters, drinking water, and 

food,[ ... j in the deep ocean, and in underground aquifers, in rainwater and snow, and in pristine 

Arctic lakes, far from any point sourcc.''45 

The North Carolina Department of Environmental Quality has spent the last 14 months 

trying to determine how far DuPont and Chemours' PFAS contamination has spread from their 

Fayetteville Works Facility, consuming significant staff resources. GenX has now been found in 

private wells up to 5.5 miles away from the facility's border. in levels as high as 4,000 

ppt. Robeson County's health director has stated that the presence of GenX in Robeson County 

likely indicates that Chemours' contamination has spread into the Lumber River basin and even 

the Pee Dee River in South Carolina50 The North Carolina Department of Environmental 

Quality has found the chemical in rainwater at levels as high as 810 ppt five miles from the 

facility, and as far as 7 miles from the facility. 51 Scientists hom the University of North Carolina 

Wilmington have measured GenX in the rainwater as far as Wilmington-nearly 80 miles ti·om 

the facility-in concentrations higher than 500 ppt. 52 Last December, GenX was even found in 

local honey at 2,070 ppt. 51 Nmih Carolina has witnessed the ability ofPFAS to invade every 

facet of the world we live in. 

EPA states that it will ''evaluate the need f()l' a maximum containment level (:'v1CL) for 

PFOA and PFOS.''54 While the promulgation of maximum contaminant levels under the Safe 

Drinking Water Act is important for protecting the public's drinking water supply, it is 

Combined Presentations from EPA PFAS Comnnur>itv En>w~.ement 

2018. m:ailable at httiDS:J'Iwww·.ec>a.".ov.1sit•csit,mdm:tionl1iiles/20 8-C>8/clocuments/r4 

19, 

Combmed Presentations from NC, slide 28, Aug. 14,2018. 7 ld 

18 CDTSC 2018 Report at 19. 49 1\C DEQ Amended Complaint at 27. 50 Steve DeVane, ·'Robeson County Pauls,'' !he Fayetteville Obsr:rver, Feb. 2, 20 J 8, 

available at (last visited 

19, 

DEQ Amended Complaint at 2. 

Ralph Mead, UNCW, Presentation for the Cape Fear River Assembly, "'Environmental Mass Spectrometry," slide 

14, \!lay 23, 2018, included as Attachment ll. 

"'Adam ''Hov .. -did GcnX end up in a jar 

National Summit available at httiJS:;'/w·ww·.erc•a.eov,'sit>es/t)fO•duct 

08/documcntslpfas-meeting-summary. final .. _508.pdf (last 

8 
180 

extraordinarily dinicult and expensive to remove PFAS from water. Relying exclusively on 

maximum containment levels to clean up drinking water puts the entire burden on local water 

utilities and their customers. As evidenced by the situation in North Carolina, this is not fair, 

feasible, or effective. 

The Cape Fear Public Utility Authority, which services 200,000 customers in North 

Carolina, discovered in the summer of2017 that PFAS from Chcmours' Fayetteville Works 

Facility was in its finished water. One of the PFAS, GcnX. reached levels of up to 1,100 ppt in 

the treated drinking water. 55 In September 2017, Chemours agreed to stop pumping its PF AScontaminated wastewater directly into the Cape Fear River 5 6 llowcver, PFAS levels in the Cape 

Fear River and in the utility's tinished drinking water have persisted fi·om contamination in the 

soil and groundwater at the facility, 57 sediment in the Cape Fear River and its tributaries, 5

8 and 

possibly even bacteria that coat the inside of pipes which pump treated drinking water59 

The Cape Fear Public Utility Authority has now spent S 1.8 million addressing Chemours' 

PF AS pollution, and is planning to install advanced treatment technology that could have a lifecycle cost of $196 million through 2055. 60 It projects that its customers, who have already been 

harmed by Chemours' pollution for decades, will face a 14 percent increase in their water bills 

because of the actions the utility must now take to combat PFAS. 61 During its presentation to the 

House Select Committee on North Carolina River Quality on April26. 2018, the Cape Fear 

Public Utility Authority emphasized that even its upgraded treatment system will not eliminate 

PFAS in finished drinking water, and that the only way to effectively address the contamination 

is by controlling the source of the compounds. 

Communities that have been injured by the intentional pollution fl·om large chemical 

companies should not be the ones to bear tbe heavy financial burden of cleaning up their own 

drinking water. EPA must prevent additional PFAS tfom being pumped into our air, water and 

soil. None of EPA's current proposals will do so, and they fail to protect communities from the 

harm su!Tered by those in southeastern North Carolina. 

E. EPA's failure to control PFAS has resulted in longstanding contamination across 

the countrv, which EPA must uow confront. 

The number of PFAS-contaminated sites continues to grow. Initially, PFAS pollution 

was thought to be somewhat limited to PFAS manufacturing fi1cilities, but it is now understood 

June ! 9 to Ju!v 25, 2017 GcnX Surtace \Vater Results, included as Attachment 12. 

f:m,iro,nmcnta!Qua/ityv. Chcmours, !7 CVS 580 (KC. Super. 2018), 56 Partial Consc~t Order. A'. C Dept 

included as Attachment 13. 7 Exhibit 22 of NC DEQ Amended Complaint, ·•focused Feasibility Study Report- PFAS Remediation,'' 

)l:\ to the Environmental Review Commission from the of North Carolina at Wilmington 

the Implementation of Section 20(a)(2) of House Bill 56 (S.l.. '"included as Attachment 14. 

"What's GenX still in the water downstream of a Chcmours Plant," c&en, Feb. 12,2018, 

at 

plant.html (last vbited Sept. 20!8). 

uv Combined Presentations from EPA PFAS Community Engagement in Fayetteville, NC, slide 78, Aug. 14,2018, 

availahle at https://\-vww .epa.gov/sites/production/filcs/20 18-08/documents r4~" combined ~presentations __ pdf (last 

visited Sept. I 9. 20 I 8). 

"'tJ. 

9 
181 

that the contamination is widespread. PF AS contamination exists not only at PF AS 

manufacturing facilities and facilities that use PFAS as part of their industrial processes, but also 

at military bases; lire-fighting foam application, training. storage. and disposal 

sites; manufacturing sites of fire-retardant materials; landfills; wastewater treatment plants; 

airports; and many other locations. 62 PFAS contamination is a national problem, and EPA must 

act. 

Many sites potentially contaminated with PFAS have yet to be characterized, added to the 

National Priorities List (the list of contaminated sites eligible for cleanup and financed under the 

federal Superfund program), or cleaned up. As of May 2017, EPA estimated there were over 

1,000 sites potentially contaminated by PFAS (including 315 Department of Defense sites with 

fire training areas, 535 airports, and hundreds ofPFAS manufacturing facilities) 63 Against this 

artificially low estimate,"" there were less than 90 Superfund sites with known PFAS impacts 65 

Bcc"'!oe PFAS do not degrade in the environmcnt,66 PFAS-contaminated sites require aclive 

clean up to eliminate the harm to human health and the environment. EPA must therefore 

identify and characterize the sources ofPFAS, add any known contaminated sites to the 

Superfund National Priorities List, and prioritize those sites f(lr cleanup. 

So that responsible oftlcials and parties know how best to reduce the risks of PFAS 

contamination and exposure, EPA must also develop and publicize PFAS test methods for all 

environmentalmcdia. It must evaluate and identify effective treatment technologies for 

remediating PF AS-contaminated soils, sediments, and waters. These must include methods tor 

preventing PFAS-polluted groundwater from entering surface waters. And EPA must develop 

tools, data, and guidance tor remedy selection, remedial action, and performance monitoring. 

ln many cases, the costs associated with environmental contamination are unfairly borne 

by state and federal governments, public and private utilities, and members of the public. EPA 

must instead hold the polluters financially responsible lor these costs-including the costs tor 

remediation on and otT site, effective filtration systems at an individual and utility scale where 

drinking water supplies arc polluted with PFAS. human health studies, environmental sampling, 

and ongoing monitoring. Finally, EPA should implement an aggressive enforcement strategy 

against companies that have knowingly and intentionally released PFAS into the environment, 

such as DuPont and Chemours. 

.final. pdf (last visited Sept. I 9, 20 I 8). 

contaminated by PF AS is mtitlcially !ov,· 

considering Michigan alone has confirmed the state has sites PFAS contamination. Sel! Michigan 

Department of Environmental Quality, Confirmed PfAS Sites (Sept. 12, available at 

https: 1

/W\Vw.michigan.gov/documcnts/deq/deq·map-confirmedPFASsites 61 visited Sept. 20, w1n - "'EPA PFAS Superfund Sites at 6. 66 Interstate Technology Regulatory Council, Environmental Fate and Transport for Per- and Polyfiuoroalkyl 

Substances Fact Sheet, at I (Mar. I 6, 20 18) (hercinatler .. ITRC Fate Fact Sheet .. ), included as Attachment I 5. 

10 
182 

EPA has stated that it will "begin[] the necessary steps to propose designating PFOA and 

PFOS as 'hazardous substances,"' specifically under Section I 02 of Comprehensive 

Environmental Response, Compensation, and Liability Act ("'CERCLA')67 While it is 

important for polluted sites to be cleaned up, designating PFAS as "hazardous substances" under 

CERCLA does not prevent industrial facilities and others from creating hazardous waste sites in 

the first instance. Therefore, in order for EPA to protect human health and the environment, it 

must utilize its entire arsenal of environmental statutes, as discussed more fully in the next 

Section. 

F. EPA must use its statutory tools to control PFAS at the source, protect public and 

environmental health, and require polluters to bear the costs associated with their 

PFAS use. 

Despite their known risks to human health and the environment, little federal regulation 

applies to PFAS~~ ~leaving state governments, owners and customers of public water systems, and 

individuals to pay for the costs associated with PFAS contamination, or to resort to post-injury 

legal claims against the polluting companies that have damaged their health and well~being. As 

discussed in Section D, the public and environmental health threat must be controlled and 

eliminated before harm occurs. EPA has a legal and moral obligation to require industry to 

install technology that prevents PF AS Jrom entering the environment, ensure that the public is 

informed about risks ofPFAS already in the environment, limit the use and distribution ofPFAS, 

and hold polluters responsible. In order to do this. EPA must take the following actions. 

1. Designate all PFAS as "hazardous air pollutants" under the Clean Air Act and 

promulgate national emissions standards. 

PF AS arc found in ambient air, with elevated concentrations observed ncar emission 

sources. such as manufacturing facilities, wastewater treatment plants, fire training facilities, and 

landfills 68 Short-range atmospheric transport and deposition results in PFAS contamination in 

soiL sediment, surface water. groundwater (including drinking water supplies), and other media 

near emission points, as well as several miles away. 69 Long-range atmospheric transport 

processes are responsible for the widespread distribution ofPFAS. including in remote areas 

with no direct emission sources."' 

The Clean Air Act was enacted to ··protect and enhance the quality of the Nation's air 

resources so as to promote the public health and welfare." 42 U.S. C.§ 7401(b). To fully protect 

against PFAS contamination ±rom emissions sources, EPA must designate PFAS as hazardous 

air pollutants. 

('

7 EPA, PFAS National Leadership Summit, availahle 

0.8fdocumcnts/pfas-mecting-summary~final 508.pdf (last 

M\ ITRC Fate Fact Sheet. 

(l<J See id 70 /d.: see also EPA, Contaminated Site Clean-up lnfonnation, Per- and Polyfluoroalkyl Substances (PFASs), 

Environmental Distribution and Accumulation (2018) (hereinafter, "PFAS Environmental Occurrence''), available 

.~:· h~tp:../ 1 c I u -in. org/contam inantfixus/ def au lL focus/ sec/Perand_Polyfluoroalkyl_Substances_(PF ASs)lcat/Occurrcnce/ (last visited Sept. 19, 20 18)~ 

II 
183 

"Hazardous air pollutants'' are those pollutants that arc known or suspected to cause 

cancer or other ''adverse health effects." such as reproductive effects or birth defects, or ·'adverse 

environmental c!lects.'' 42 U.S. C.§ 7412(b)(2). EPA must periodically review the list of 

hazardous air pollutants and add pollutants "which present. or may present'' such risks. !d. , 

Because PFAS are known toxins which cause serious adverse health and environmental effects." 

EPA must (I) list all PFAS as hazardous air pollutants; and (2) promulgate national emission 

standards for all major sources and area sources ofPFAS. 42 U.S.C. § 7412(b)(2), (d). 

2. J)csignatc all PFAS as "hazardous substances" and "toxic pollutants" under the 

Clean Water Act, and affirm that the Act prohibits the discharge of pollutantsincluding PFAS-to surface water via hydrologically connected groundwater. 

PFAS arc released into surface waters by industrial facilities. wastewater treatment 

pl<inis, fire fighting foam activities, and land application ofbiosolids (i.e., sewage sludgc)72 

Once released into surface water. PF AS remain in the water, causing harm to people who fish 

and swim in-·· or whose drinking water comes from--polluted waters. 73 PFAS in surface water 

can also contaminate groundwater through groundwater recharge or he transported to the oceans 

where they are then transported globally by ocean eurrents 74 And, PF AS discharged to 

groundwater can result in large plumes and discharges to surface water75 Because the Clean 

Water Act is the primary tool tor restoring and maintaining the nation's waters, 33 U.S.C. 

§ l25l(a), PFAS must be regulated as "hazardous substances·' and "toxic pollutants•· under the 

Act. EPA must also affirm that the unpermitted discharge of pollutants--including PFASthrough hydrologically connected groundwater is prohihited. 

a. PFAS are hazardous substances. 

Section 311 of the Clean Water Act requires EPA to designate as hazardous substances 

those substances which, when discharged in any quantity into surface waters, present an 

'·imminent and substantial danger to public health or welfare, including, but not limited to, fish, 

shcll£ish, wildlife. shorelines, and beaches." 33 U.S.C. § l321(b)(2)(A). The Clean Water Act 

then prohibits discharges of hazardous substances in quantities that may be "harmful to the 

public health or welfare or the environment." !d.§ 132l(b)(3), (4). PFAS easily satisfies the 

dciinition of'hazardous substance'' because PFAS arc persistent. bioaccumulative, and toxic to 

both humans and animals. 76 EPA must designate them as ''hazardous substances." 

b. PFAS are toxic pollutants. 

PF AS must similarly be designated as "toxic pollutants" under section 307 of Clean 

Water Act. 33 U.S.C. § 1317. "Toxic pollutants'' are "those pollutants, or combinations of 

pollutants, including disease-causing agents, which after discharge and upon exposure, ingestion, 

inhalation or assimilation into any organism .... cause death, disease. behavioral abnormalities, 

'

1 See Section A, 

Draft 2018 Profile for Pertluoroalkyls a! 552-554. 

JTRC Fate Fact Sheet at 13. 

ld 

"ld at 12. 76 S'ee Section A, supra. 

12 
184 

cancer, genetic mutations, physiological malfunctions (including malli.mctions in reproduction) 

or physical deformations, in such organisms or their otT spring." 33 li,S.C. § 1362, 

Designation as a toxic pollutant appropriately results in enhanced measures to protect 

human health and the environment from the dangers posed by the pollutant, including, for 

example, more stringent disclosure requirements in the NPDES permitting process (40 C.F.R. 

§ 122.21 ), eflluent limitations in NPDES pennits (33 U.S. C. § 1317(a)). pretreatment standards 

(33 U.S.C. § 1317(b)). water quality criteria to control concentration levels for the pollutants (33 

U.S.C. § 1314), guidance to states for establishing protective water quality standards (33 U.S. C. 

§ 1313), and prohibitions on the disposal of pollutant-containing sludge 

(33 U.S.C. § 1345). These enhanced protective measures should apply to all PFAS because 

PFAS arc toxic pollutants. As EPA develops analytical test methods for specific PFAS, those 

compounds should also be added to the Priority Pollutant List so that water quality criteria and 

effluent limitations guidelines can be developed more quickly 77 

c. Unpermitted discharges of l'FAS through ltydrologica/ly connected 

groundwater are prohibited under the Clean Water Act. 

As explained more fully in our comments on ''Clean Water Act Coverage of Discharges 

of Pollutants via a Direct llydrologic Connection to Surface Water" (Docket ID No. EPA-HQOW-2018-0063),78 the purpose and plain language of the Clean Water Act requires EPA to 

protect the nation's waters from unpermitted discharges to surface waters through hydrologically 

connected groundwater. 79 An overwhelming majority of federal courts have held the same. S(J 

J\.1oreover, people who rely on the nation's waters for fishing, swimming and other recreation. 

and as sources of drinking water, benetit from these types of groundwater discharges being 

monitored, controlled in keeping with leading industry practices, and limited in a way that 

ensures water quality will not be further degraded. ''Because the CWA's goal is to protect the 

quality of surface waters, the NPDES permit system regulates any pollutants that enter such 

waters either directly or through groundwatcr.'' 81 EPA should aflirm that rule of law. 

77 At EPA's August 2018 PFAS National Leadership Summit in Fayetteville. NC, the agency indicated it ''is 

beginning the to designating PFOA and PFOS as ·hazardous substances' through one of the 

availabie statutory potentially CERCLA Section 1 02.'' By designating PF AS as ·'hazardous 

substances'' or ''toxic pollutants," EPA would automatically adJ PFAS to CERCLA 's Section 102 Hazardous 

Substances List, 42 U.S.C 9601(14) (defining hazardous substance), thereby applying the more expansive cleanup 

reporting requirements under that la\v ami the Clean Water Act. 

FPA llcckct Folder for ·'Clean Water Act Coverage of Discharges of Pollutants via a Direct Hydrologic 

Connection to Surface Water'', Docket ID No. EPA-HQ- 0Ww201 8-0063, availabl~? at 

https:/iwww.regulations.gov/documcnt?D"'""EPA-HQ-OW-20!8-0063-000I (last visited Sept. 19. :?:018). 79 St!.e general(v Ltr. from F. llol!cman to S. Wilson re: Comment on ''Pollution of Surface Waters by Pollution 

Transmitted From a Point Source through Ground\vater with a Direct llydro!ogical Connection to the Surface 

(Docket ID No. EPA-IIQ-OW-201 8-0063) (Apr. 18. 2018), included as Attachment 16. 

ld at 9-15. 

lll IVi/l!am,r.,' P1jJe Line Co. v. Bayer Corp .. 964 F.Supp. 1300. 1320 (S.D. lmva 1997). 

13 
185 

3. Designate and regulate PFAS-containing waste as a "hazardous waste." 

Industrial facilities may also release PFAS to the environment via on- and oft~site 

disposal of wastes. 82 EPA must ensure that PFAS-hazardous wastes are carefully managed and 

disposed. 

"Ilazardous waste" is waste with properties that makes it dangerous or capable of having 

a harmful cJTect on human health or the environment. See 42 C.S.C. § 6903(5). EPA has 

developed a comprehensive program to ensure that hazardous waste is managed safely from the 

moment it is generated to its final disposal (cradle-to-grave). See 400 CFR parts 260 through 

273. To ensure the safe management and disposal of PFAS-containing wastes, EPA must list 

!'rAS as a '·hazardous waste" under42 U.S.C. 9 6921. 

4. List PFAS as toxic chemicals under the Toxic Release Inventory. 

The Emergency Planning & Community Right-To-Know Act's Taxies Release Inventory 

requires industrial and federal facilities to disclose information to the public about toxic chemical 

releases and pollution prevention activities. See 42 U.S.C. § 11023. EPA may add chemicals to 

the Toxics Release lnventory list where there is sufficient evidence that a chemical causes or is 

"reasonably anticipated to cause" human health effects, such as cancer or serious reproductive 

issues. !d. at II 023( d)(2). EPA may also add a chemical that-because of its toxicity or toxicity 

and persistence. or toxicity and tendency to bioaccumulate-is known to cause or is ''reasonably 

anticipated to cause" a ''significant adverse effect on the environment.'' !d. So that the public 

can be informed about toxic PF/\S releases in their communities. EPA must add all PFAS to the 

list of toxic chemicals. 

5, Utilize the Toxic Substances Control Act to require disclosure of PFAS risks and 

limit the manufacture, processing, and use of harmful PFAS. 

In enacting the Toxic Substance Control Act (TSCA). Congress found that "among the 

many chemica! substances and mixtures which are constantly being developed and produced, 

there are some [that] may present an unreasonable risk of injury to health or the environment." 

15 U.S.C. § 260l(a). For these chemicals, pre-manufacture data must be developed to identify 

the effects of the chemical substances and regulation must be implemented to protect against the 

risks. !d. § 2601 (b). PFAS presents unreasonable risks to human health and the environment. 33 

and EPA must utilize its authority under TSCA to protect against those risks. 

As an initial matter, EPA must enforce its TSCJ\ section S(e) orders, including the Order 

the agency entered into with DuPont and Chemours-'·l For decades, the companies have violated 

EPA's Order, EPA has failed take enforcement actions against them. and now. Chemours 

ITRC Fate Fact Sheet at 3 

s.l See Section A. supra. 

"EPA, Consent Order and Determinations Supporting Consent Order for PMN Substances P-08-509 (2009) 

(hereinafter ''TSCA Order''), included as Attachment 17. In order for DuPont to manufacture GcnX and related 

chemicals. the EPA issued the Order to DuPont under TSCA in 2009. When DuPont transferred ownership of the 

Fayetteville Works facility to Chcmours in 2015, Chemours became responsible for complying with the order. 

14 
186 

''""~i:oue> those violations85 The companies have released nearly 100,000 pounds of PFAS 

compounds from its stack emissions each year, including GenX compounds at a rate of2,758 

pounds per year86 Chemours' emissions arc contaminating surface water, groundwater, and 

drinking water sources with PFAS, despite that Chemours was required to ·'recover and capture 

(destroy) or recycle the [PFASJ substances at an overall efficiency of99% from all the effluent 

process streams and the air emissions."87 Based on EPA's determinations that preceded the 

Order, EPA's issuance of the Order was mandatory, and so is its enforcement. See 15 U.S. C. 

§ 2604(e). 

To broadly address the manufacturing of PFAS as a class. EPA should exercise its 

authority under TSC A Section 4 to require PFAS manufacturers and processors to conduct 

toxicity testing of all PF AS and disclose the results, as well as all currently available data, to 

EPA. 15 U.S.C. § 2603. Similarly, EPA should require reporting ofPFAS production, including 

PF AS byproduct production at very low thresholds under the revised Chemical Data Reporting 

Rule. See 15\J.S.C. § 2607; 40 C.F.R. Part 711. 

EPA must also take action under 15 U.S.C. § 2604 to protect against the unreasonable 

risks posed by PFAS. Where a "chemical substance ... presents an unreasonable risk of injury to 

health or the environment,'' EPA is requircd-''without consideration of costs or other nonrisk 

factors"-to protect against those unreasonable risks, including by issuing an order limiting or 

prilh1biting the manufacture, processing, or distribution of the substance'' 15 U.S. C. 

§ 2604(a)(3)(A); 15 U.S.C. § 2604({). It is indisputable that PFAS as a class poses serious risks 

to health and safety of the public and the environment; therefore, EPA should ban the 

development of new PFAS and strictly limit the manul~lcture, processing. and distribution into 

commerce of existing PFAS. EPA should also halt the usc of all PFAS in Aqueous Film 

Forming Foam and llrefighting gear for military and civilian usc, and require industry to find 

safe alternatives for these and other uses. 

Finally, EPA should issue a Significant New Cse Rule for all PE4S. and should prohibit 

new uses of PFAS, including their usc in "articles.'' See 15 U.S.C. § 2604(a); 40 C.F.R. 

720.3(c). Although EPA has proposed a Significant New Usc Rule for PFOA and related 

chemicals, the rule covers only long-chain PFAS88 Short-chain PFAS can, however. be even 

more toxic89 Therefore, Significant New Usc Rules regarding PFAS should apply to all 

PFAS-short-chain and long-chain- -including their usc in articles (such as nonstick cookware 

or water resistant clothing). 

s:- Southern Environmental Law Center Notice of Intent to sue Chcmours under the Toxic Substances Control Act, 

May 7, 2018, included as Attachment 18. 6 fd; Sec Combined PFAS well samples around FaycHevi!lc Works Facility and air emission estimates, included as 

Attachment 9. 87 TSCA Order (Attachment 17) at 36; Southern Environmental Law Center Notice of Intent to sue Chemours under 

the Toxic Substances Control Act, Ma\ 7, 2018. 88 EPA "Risk Management for Per- a~d Polyfluoroalkyl Substances (PI·"ASs) under TSCA," availahle at 

https://w\vw.cpa.gov/asscssing-and-managing-chemicals-undcr-tsca/risk-managemcnt-anJ-polyfluoroalkylsubstances-ptass (last visited Sept. 119. 2018). 

ll'> See Section A, supra. 

15 
187 

G. Conclusion 

Far too many communities like those in North Carolina have been harmed by PFAS 

pollution throughout the country in the past century. EPA is now fully aware of the extent of 

destruction that PF AS can cause to our bodies and the environment. The agency must use its 

statutory tools to combat this class of chemicals that has infected every facet of our daily lives. 

Its cun·ent proposal docs nothing to protect future communities, and EPA has a legal and moral 

obligation to do more. 

Thank you for considering these comments. Please contact us at ggisler@selnc.org or 

919-967-1450 if you have any questions regarding this letter. 

Sincerclv, 

iJArz~ Geoffrey R. Gisler 

16 
188 

SIERRA 

CLUB 

The Honorable Rand Paul, Chairman 

Senate Committee on Homeland Security and Governmental Affairs, 

Subcommittee on Federal Spending Oversight and Emergency Management 

439 Hart Senate Office Building 

Washington, DC 20510-6250 

The Honorable Gary Peters, Ranking Member 

Senate Committee on Homeland Security and Governmental Aftairs, 

Subcommittee on Federal Spending Oversight and Emergency Management 

439 Hart Senate Office Building 

Washington, DC 20510-6250 

Dear Chairman Paul and Ranking Member Peters, 

September 26, 2018 

The Sierra Club is extremely concerned about the issues we all face with the recently identified 

problems related to the family of organofluorine chemicals known as PFAS. These chemicals 

have contaminated water resources across the country and are widely found in many consumer 

products. Widespread human exposure to these dangerous chemicals has occurred globally. 

Sadly, these chemicals are extremely persistent in the environment and have contaminated even 

the remotest regions of the planet. 

As a society, we face the pressing issue of ending exposure to these chemicals, which are so 

pervasive now that exposure is hard to avoid. We also face the issue of banning the production of 

t:.ese chemicals, and an extensive clean up effort, similar to the eflort we have undertaken with 

PCBs. As well, we have the daunting task of destroying these chemicals, which is no small feat, 

given that they are some of the most persistent and difficult to destroy chemicals ever made. 

Municipal waste incinerators are not designed to bum hot enough to destroy these chemicals and 

few other pmctical combustion options exist. Experts reviewing the military's SERDP research 

program highlighted research into safe disposal as a "1-Titical need" and disposal as a "continuing 

liability" for the Department of Defense. 1 As there arc no regulations for the safe management or 

methods documenting the effective destruction of these chemicab, xf take-back programs are 

1 SERDP. 2017. Summary Report: SERDP and ESTCP Workshop on Research and Demonstrotion Needs for 

Mana~cmenl of AFFF-Impacted Sites. September ~017. 
189 

SIERRA 

CLUB 

initiated, these highly persistent, toxic chemicals will most likely go to the cheapest disposal 

option available- either a landfill or a municipal incinerator. If you bury PFAS chemicals, they 

will eventually reach groundwater. Poorly controlled incineration leads to a~r emissions ofPFAS. 

One recent study of a modem municipal waste incinerator in the Netherlands, found incomplete 

removal of PFOA during normal operation.' 

In light of these pressing facts, we ask this committee to direct federal agencies to address the 

PFAS crisis: 

Require military bases, airports, fire departments and other locations where PFAS are 

used to store existing stocks of chemicals safely, until safe, effective destruction 

technologies are identified and required. 

Direct the National Academy of Sciences to determine which technologies will 

completely destroy all PFAS chemicals so that additional releases will not pollute our air 

and waters. 

Work with Department of Defense, Department of Energy, and the states to identify and 

require the use of analytical test methods that will identify and quantify the entire class of 

PF AS chemicals. 

Require PFAS testing methodologies sensitive enough to detect and regulate PF AS 

chemicals at exposure levels linked to toxic outcomes for use in identifying and 

regulating all PF AS congeners. 

Require both regulation of PFAS emissions to the environment and reporting of any 

(exempted) production, use, and disposal of PF AS chemicals under Emergency Planning 

and Community Right-to-know Act, Comprehensive Environmental Response, 

Compensation and Liability Act, Resource Conservation and Recovery Act, Clean Water 

Act, Clean Air Act and Safe Drinking Water Act so that mdustrial producers, users, 

Stateo, and affected communities can effectively deal with these chemicals in 

environmental media. 

2 Abel Arkenbout, 2018. Lon g-lenn samplmg emission or PFOS •nd PFOA of a Wasle-to·Energy incmerator. DOl: 

lO. 131401RG.2.2.142S 1.19046 
190 

SIERRA 

CLUB 

Utilize existing international scientific information about effective replacements for 

AFFF fire fighting foam with fluorine free alternatives to enable the alternatives to 

comply with the military specification {MILSPEC) for fire-fighting foams for use in 

liquid fuel fires. 

States are the best resource the federal government has for developing some of the important 

exposure information regarding PF AS chemicals. To encourage further research, Congressional 

funding should be earmarked to allow states to test their drinking water sources with the best test 

methodologies available. These testing methods must identity the largest number ofPFAS 

chemicals at the lowest detection limit available. Laboratories tasked with this work need to 

coordinate with federal agencies so the quality assurances and quality controls ensure 

consistency and accuracy. 

We thank you for your diligence in addressing this vexing problem ofPFAS chemical exposure 

and look forward to hearing back from you on how you plan to resolve the problem of the lack of 

exposure data from drinking water, the lack of a robust and complete test method for drinking 

water, and the lack of safe, effective disposal methods for these chemicals. 

Cc: 

James Lankford, (R) OK: 

Michael B. Enzi (R) WY: 

John Hoeven (R) ND, 

Kamala Harris (D) CA; 

Doug Jones, (D) AL: 

Sincerely, 

Debbie Sease 

Legislative Director 

Sierra Club 

Washington, DC 

Susana Reyes Vice-President Conservution Sierra Club Board of Directors; 

Jane Williams, Chair, Sierra Club Air Committee, 

Eric Urarn, Chair. Sierra Club Toxics Committee; 
191 

My Story: Eric J. Tobin 

My story starts before I was born. My mother was an airmen's wife stationed at Wurtsmith Air Force 

Base from 1973-1978, and so my mother was drinking the water in Oscoda from conception, through my 

development, and my birth at the base Hospital. My sister and I were breastfeed by our mother, so 

whatever bad things were in the water were concentrated and delivered into us as infants. As toddlers 

we also drank the water and bathed in it. When I was born I was severely jaundice. So our exposure to 

the chemicals that were in the water was for about 4 years of our most vulnerable time in our lives and 

our development. As a child I was prone to chronic respiratory illnesses and was even diagnosed as 

being allergic to the cold. Going up I was shy and in elementary I was put into special Ed. As I grew up I 

was able to rejoin normal classes and got good grades, but I always had a problem with reading and 

writing. 

At 17 I developed a severe case of Gilberts Disease which caused my liver and spleen to enlarge, put me 

in the hospital with a temp close to 104, and quarantined me. They thought I had mono complicated by 

hepatitis according to what it said on my medical notes of the time. At this time, I met a fantastic girl at 

that time and I married her in 1994. It was our hope that we would have a decent size family with 4 

kids. We soon discovered that both my wife and I had fertility issues. I was found to have a low sperm 

count and low motility. After trying for seven years with fertility treatments we had almost given up 

when my wife got pregnant. Our excitement was short lived due to finding out that there was no 

heartbeat. We tried again and eventually she was able to become pregnant with our son. Without any 

prevention, we have not been able to get pregnant since. 

At about the time my son was born (2000) I developed what they only termed as complex migraine. It 

was a migraine that did not have a headache, but would basically shut down my body, limiting my 

mobility, speech, and cognitive function for about 20 mins to an hour, after which, I would be extremely 

tired and want to lay down. To date the doctors have not been able to explain this, but have decided to 

treat it with medications used for epilepsy or anxiety. After a lot of trial and error it seems like they 

discovered medications that limited the events to only once a twice a year instead of three times a day. 

They also came to the conclusion that the events were brought on by my eyesight and/or Stress. This 

was also part of the reason that I do not like reading. 

After 2008 I started getting weak and began getting cramps that first were in my legs and later 

progressed to all most everywhere in my body. As time went on it became worst, muscles started 

twitching for no known reason, and at times I can barely walk. I continually pushed my doctors for 

answers. They ordered tests to try an answer those questions. In 2013 they found that I had very low 

levels of Testosterone and vitamin D. With more tests they could not give a reason why my 

Testosterone levels were low while not by being caused by a testicular problem or a pituitary tumor. 

The doctors figured that is why I am feeling so weak and said I needed hormone replacement therapy or 

I would start to experience muscle loss and worse symptoms. Our first attempts to correct the problem 

failed and I am now on once a week injections. The doctors have attributed the cramps to Benign 

Cramp Fasciculation Syndrome and treated me with Gabapentin and Carbamazepine. 
192 

At about this same time they discovered a monoclonal protein in my blood, which means I have 

monoclonal gammopathy of unknown significance (MGUS) and that I would have to be seen by oncology 

for the rest of my life. MGUS is the pre cancer for Multiple Myeloma, a terminal blood and bone cancer. 

All of my labs and risk factors put me in the moderate to high risk of it turning into the cancer with the 

~ext 20 years'. So far my condition is stable. 

Today I feel like I have the body of an 80 year old. The issues I have, I have been told are uncommon for 

someone in their 40's. All of my life I have baffled and mystified doctors on my combinations of 

conditions and their effects on my quality of life. Last year I was in the doctor's office or hospital at least 

once a week for various things. I have had countless tests, procedures and have seen almost every type 

of specialist there is with very few answers. Within the last few years I discovered that it is very likely 

that I have been exposed to TCE and PFAs by my beginning of life at Wurtsmith AFB. It saddens me to 

think that the organization that was meant to protect me, may lead to my untimely death and the part 

of the reason why my wife and I could not have the family size we wanted. I would hope that the 

powers to be and our government would step up and get the bottom of the problems and take care of 

what they have caused. Take care of the Veterans, their families, and anyone else affected by the 

contamination, it is your duty. 
193 

Water Quality Association 

Statement for the Record 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

Re: Hearing entitled "The Federal Role in the Toxic PFAS Chemical Crisis" 

September 26, 2018 

I am writing to the committee on behalf of the Water Quality Association (WQA)- a not-for-profit 

association for the residential, commercial and industrial water treatment industry- to communicate 

our continued support for implementing measures to understand the impact of per- and polyfluoroalkyl 

substances (PFASs) on human health and to urge support of point-of-use (POU) and point-of-entry (POE) 

-at the tap or whole house- water treatment technologies to battle these contaminants. 

I would also like to thank the committee for holding this hearing and for its focus on PFASs 

contamination. Our association was encouraged by the FY18 National Defense Authorization Act's 

(NDAA) inclusion of a national study through the Department of Defense on human health implications 

of PFASs in drinking water, ground water, and any other sources of water and relevant exposure 

pathways. This will be the first ever nationwide study on the human health impacts of PFASs which will 

help Federal agencies and states communicate the risks of PFAS contamination. 

Though several options are available to treat water and prevent PFAS exposure, using centralized 

treatment facilities would be extremely expensive, as it would require upgrading drinking water 

treatment plants not currently designed to remove these chemicals. Many economically challenged 

communities already struggle to fund necessary maintenance and upgrades to their existing 

infrastructure for roads, bridges and drinking water pipes. Asking these communities to pay for 

additional upgrades to their drinking water treatment plant would only increase that burden. 

Research shows POU and POE technologies can be used to successfully treat for these contaminants at 

the home or in a building. 1 They cost only a fraction of the price our society would need to bear to 

upgrade our drinking water treatment plants for PFAS removal. Furthermore, Department of Defense 

expenditures on PFAS investigations and cleanup reached nearly $200 million by the end of 2016.2 POU 

and POE technologies offer a cost-effective alternative that could reduce the federal monetary burden 

for current and future PFAS related expenditures. 

These POU and POE technologies include Reverse Osmosis, Carbon Filtration and Anion Exchange. 

Reverse Osmosis products have been independently tested through WQA in collaboration with the 

Minnesota Department of Public Health3• Carbon Filters have been independently tested by NSF 

International. And Anion Exchange products have been independently tested through the Water 

Research Foundation. The testing has shown each of these technologies, with the right design 

1 http://www. health.state. mn. us/ divs/ eh/hazardo us/topics/pies/ 

' https:/ /www .den ix.osd. mil/ derp/home/ docu ments/aq ueou s-fi 1m-forming-foam-report -to-congress/ 

' http://www. health.state mn. us/ divs/ eh/we lls/waterquality /po udevicefi na lsu m mary.pdf 

4151 Napo?rvilie Road 

li$1<.\ li!hlOIS 60532-3696 US.ll, 

PhOIW 630·':>05 0160 

50S 9637 

www.wqo.org 
194 

parameters and configuration, can be used as a successful final barrier in the home to protect people 

from the harmful effects caused by the presence of these chemicals in our drinking water. These tests 

help the Federal agencies, states, and the public learn how to prevent unhealthy exposures. 

In May 2016, The Federal EPA published a lifetime Health Advisory of 70 parts per trillion for the sum of 

PFOS and PFOA in drinking water. PFOS and PFOA are two of the more than 3,000-4,000 PFAS chemicals. 

Manufacturers voluntarily phased out use of PFOS in 2000-2002 and PFOA in 2010-2015. This health 

advisory is not legally enforceable under EPA regulations or the Safe Drinking Water Act but may be 

given weight in state regulation. 

So far, twenty states have established their own health advisory levels, action levels, drinking water 

criteria, or state standards for PFASs in ground water, surface water, or drinking water. Attached with 

this letter is a <ummary of state actions to address PFASs. Through legislation and agency activities, 

states are continuing to look for crucial information on the identification, characterization, and 

monitoring of PFASs and the impacts to human health. There remain gaps in research on PFASs. 

WQA staff participated in the Federal EPA summit on per- and polyfluoroalkyl substances (PFASs), in 

May 2018, and continue to be a resource on PFAS treatment options as communities and legislators try 

to learn more about the widespread occurrence of PFASs from many sources and how POU and POE 

treatment can serve as an inexpensive and immediate solution to protect public health. 

WQA represents more than 2,500-member companies, including equipment manufacturers, supplier, 

dealers and distributors of water quality improvement products and services. WQA also operates a 

product certification program attesting to the safety and efficacy of a variety of water treatment 

products; and provides training to water treatment specialists through its professional certification 

programs. 

We appreciate the committee's continued focus on PFAS, and WQA stands ready to serve as a resource 

as Congress works to find sensible, cost-effective solutions to these nationwide problems. If you need 

any additional information, please contact David Loveday, WQA's Director of Government Affairs, at 

glgveday@wqa.o!£ or by phone at (630) 505-0609. 

Sincerely, 

~?~ Pauli Undesser 

Water Quality Association 

Executive Director 

pundesser@wqa.org 

630-929-2514 
195 

The Honorable Rand Paul 

Chairman 

Subcommittee on Federal Spending Oversight 

and Emergency Management (FSO) 

United States Senate 

167 Russell Senate Office Building 

Washington DC, 20510 

The Honorable James Lankford 

vniied States Senate 

316 Hart Senate Office Building 

Washington, D.C. 20510 

The Honorable Michael B. Enzi 

United States Senate 

379A Russell Senate Office Building 

Washington, DC 20510 

The Honorable John Hoeven 

United States Senate 

338 Russell Senate Office Building. 

Washington, D.C. 20510 

October 5, 2018 

The Honorable Gary C. Peters 

Ranking Member 

Subcommittee on Federal Spending Oversight 

and Emergency Management (FSO) 

United States Senate 

724 Hart Senate Office Building 

Washington, DC 20510 

The Honorable Kamala Harris 

United States Senate 

112 Hart Senate Office Building 

Washington, D.C. 20510 

The Honorable Doug Jones 

United States Senate 

326 Russell Senate Office Building 

Washington, DC 20510 

Dear Chairman Paul, Ranking Member Peters, and Committee Members, 

I am writing to request action be taken by the United States Federal government to clean up the 

PFAS contamination and secure a clean water source for the area in and around the former 

Wurtsmith AFB. 

As a native of Oscoda, Michigan I was born and raised drinking, swimming and recreating in the 

waters of Oscoda including Van Etten Lake, Lake Huron, Oscoda Area School swimming pool 

and the Au Sable River. As a competitive swimmer and daughter to the local swim coaches, our 

family revolved our lives around water. Upon turning 18 years old I became a civilian employee 

of the USAF at the Base beach lifeguarding on a body of water the USAF has contaminated 

with PFAS. By age 28, I had developed breast cancer and severe Rheumatoid Arthritis despite 

my healthy lifestyle guided by my knowledge as a Registered Dietitian. 

As years passed, my friends and family also developed cancers and immunological diseases 

including kidney cancer, liver cancer, lupus, increased cholesterol and thyroid diseases. Some 

continue to struggle with the effects of these diseases but unfortunately many have passed 

away including my neighbors Jerry- and Nancy···· 
196 

Our community is angry and struggling. We now have a decommissioned base that our 

community is attempting to utilize to enhance our economic base, but the entire property is 

highly contaminated and the contamination bleeding into the surrounding community and 

waterways. We live in fear that the pump and treat system that has been pumping groundwater 

into a river and on to Lake Huron with levels of PFAS over 1 ,000 ppt is approaching our 

municipal water supply. Recently significant foam events were identified by community 

members just one mile from our municipal water supply intake and in the Saginaw Bay 

threatening many other water supplies. In addition, foam that is characteristic of PFAS foam is 

covering the shores of many of our inland lakes which the Michigan DEQ has admitted they do 

not understand. 

As a co-leader of the NOW Need Our Water group formed to address the PFAS contamination, 

I personally am furious. Furious that the time I used to spend taking care of my health through 

quality family time, exercise, proper self-care and community volunteering is now spent 

navigating the roadblocks, secrets, technical language and excuses both the State of Michigan 

and the US government has created for this crisis. This approach is embarrassing to me as 

someone that travels throughout Michigan, the U.S. and the world and speaks with others that 

live in places that govern from the basis of what government was created, to protect the people. 

This is a water crisis I Funds must be directed to address this widespread contamination and 

prov1de clean drinking water to those affected. We cannot wait any longer for these silent, toxic 

chemicals to be removed from the source .... the former Wurtsmith USAF base in Oscoda 

Michigan. Municipal water lines to residents in the areas of concern and the eighteen additional 

GAC filtration systems must be installed immediately to ensure the health and welfare of the 

citizens and environment of Northern Michigan. Our government must act NOWI 

I respectfully request submission of this letter into the record for the hearing. Thank you for your 

consideration, time and effort to hold this very important hearing. 

Cathy Wusterbarth 

Co-Leader NOW Need Our Water 
197 

oc;o:cmuer 24, 2018 

Senator Gary Peters 

724 Hart Senate Office Building 

Washington, DC 20510 

Dear Senator Peters, 

My name is Sandy Wynn-Stelt. My husband and I moved into our home in 1992, in what we thought was the 

perfect location. It was a quiet and rural neighborhood, which was just what we wanted. My husband worked 

as a Protective Services worker and I worked in mental health. We loved the idea of a home that was our 

sanctuary, peaceful, full of nature and away from others. We did not know that the Christmas tree farm directly 

across the street was actually a previous dump site which Wolverine World Wide used to dispose their tannery 

waste. In March of 2016, my husband was diagnosed with stage 4liver cancer. He died just three weeks later. A 

year later, in 2017, !learned that my well water has been contaminated with PFAS and related compounds. My 

drinking water has tested at levels of 27,000; 38,000 and most recently 71,000 ppt, significantly higher than the 

lifetime health advisory of 70 ppt set by the EPA. 

Losing my husband Joel is hard to measure in dollars. Joel and I were married for almost 25 years, and we lived 

together four years before that. We completed each other. We were a couple that both complimented and 

cr1ai1enged the other person to be better and do better. We did not have a day that we didn't laugh together, 

not a giggle but laughing until it hurt. We could read each other's minds and could finish each other's 

sentences. We would drive everywhere on vacations simply because we loved to be together to talk. He retired 

from the state, and then came to my business every day to 'work', which really was an excuse for us to spend 

time together. The house is so quiet without him. 

Without him here, it is truly like a part of me is missing. I don't have someone to hold my hand and reassure me 

that everything will be fine. I don't have someone to lay in bed and listen to me be scared about the future. I 

don't have someone to eat dinner with and talk about our day, or politics, or baseball. I don't have someone to 

be with me when my parents die, when my nephews graduate, and when I accomplish something-anything. I 

don't have someone to grow old with, travel the world with, or laugh with. I've lost my travel buddy. Our 

friends are wonderful, but I'm now the 'third wheel'. I avoid going with them so that we don't feel 

uncomfortable looking at the empty chair that Joel would be in. They avoid inviting me so that I won't be 

reminded of fun things we did before. Life becomes very lonely when your husband is gone. 

The hardest thing for people to understand is that when you become a widow, your life literally stops. But 

gradually, over time, you do heal. I started to feel some joy, look forward to some things, find new activities and 

interests. I started to connect with things. In 2017 I signed up to volunteer for the American Red Cross and was 

supposed to do Hurricane Relief. I had decided that I could put my passion for mental health to good use and 

Tnere was a desperate need for mental health professionals throughout the summer. Literally the week I was to 

be deployed all of the contamination issue became consuming. I had to turn down the deployment to Houston, 

to Florida and to Puerto Rico. I couldn't leave because this became such a nightmare. 

And now, because the entire situation is at a standstill, I am forced to simply continue to grieve without closure. 

Every time I meet with the media, meet with lawyers, answer em ails and texts about this, talk to consultants, or 

answer questions from strangers I'm brought back to the fact that my husband died suddenly and painfully due 

to water contamination for decades that progressively damaged his liver. Its like a bad dream that you can't 

wake from, and you are forced to stay grieving day after day after day. 
198 

I never used to have to worry about levels of chemicals in my blood_ My blood levels have tested at 5,000,000 

ppt_ No one can tell me what this will do to me, though it is in all probability what will end my lik Now that I 

know that I have some of the highest recorded levels of PFAS in my blood, the anxiety is overwhelming_ I have no 

idea what this may cause in the future_ I lay awake contemplating the potential reality that one day I will have to 

drive to chemotherapy alone, without my husband to be there for support_ 

Joel and I worked very hard to pay off our mortgage as early as possible_ We believed that it was the best way to 

invest our money_ We even bought the lot next door to us for the same reasoning, believing that a real estate 

investment strategy would pay off Additionally, we assumed that Wolverine's property (which we did not know 

was Wolverine's or a landfill) was going to be developed_ We had sunk a ton of money into our property for those 

'P'"'='"o ~cd more_ Now, I'm left with a property that is essentially valueless given my location and the levels of 

contamination; my husband is certainly rolling in his grave_ Everything we worked for now seems to have been 

for nothing_ 

The future of my business is in jeopardy_ Initially, my business partner and I were hoping to expand_ Now, she 

does not feel as comfortable accepting new risks because my body is overloaded with PFAS_ The risk that I may 

not be around to ensure the business will succeed is too high_ 

My family is also struggling with this, which bothers me extensively_ My mother-in-law is 89 years old and is 

constantly worried that I will die like her son did - an outcome that is very reaL My husband was the patriarch 

of the family, and his sudden death has left me to fill that role_ My sister-in-law calls crying, and my nephew 

struggles to grasp this situation_ I used to entertain family and friends every weekend, now they hardly come 

over_ Part of it is because people are nervous_ I recently had cousins come over for the weekend_ I had to explain 

why there was bottled water in the bathroom, why things now had to be done a certain way_ 

In the past ten years, my neighborhood has grown_ At last count, we have more than 15 kids within a quarter mile 

of the recently found dump site, many of them under the age of six_ I cannot imagine the anxiety that their parents 

feeL We all have water systems in our homes and have to carry 48-pound jugs of water into the home and load 

them into a water dispenser_ In the winter, my neighbors and I have to store these several of these water jugs in 

the house, or they will freeze_ We have become a neighborhood that does not borrow a cup of sugar, but instead 

will call to borrow a jug of water if we are caught short Children in the neighborhood cannot play in the sprinkler, 

fill thp.ir ~c:0!s, or drink from the hose outside. We cannot garden and harvest food. 

Contamination from PFAS and related compounds that had been disposed nearby have devastated my 

neighborhood and community_ This is a 'forever' chemical that cannot be seen, smelled, or tasted_ There was 

no way for any of us to know_ It will not evaporate, dissolve, burn or dissipate_ It is a secret contamination and 

is much more prevalent that was initially believed_ This contaminate can no longer be ignored_ We need to 

have funding for not only discovering where this has been discarded, but also funding for further testing in the 

health affects of these chemicals_ Standards need to be established based on scientific research that is relevant 

to medical findings after research has occurred, not based on the minimal amount of research that has been 

published_ And we need to be proactive in the future, not allowing chemicals to be discarded without 

researching the affects that can occur_ 

My dream home is no longer worth anything, and in fact is probably a liability_ The investment in property is 

gone_ I have lost my husband_ I will eventually probably succumb to something related to this contamination_ 

But despite this I am hopeful that our representatives can use my story, and the story of my neighbors to 

prevent this from happening to others_ 

Sandy Wynn-Stelt 

Belmont, Ml 
199 

Post-Hearing Questions for the Record 

Submitted to Peter C. Grevatt, Ph.D. 

Office of Ground Water and Drinking Water 

Office of Water 

U.S. Environmental Protection Agency 

Senate Committee on Homeland Security and Governmental Affairs 

Subcommittee on Federal Spending Oversight and Emergency Management 

"The Federal Role in the Toxic J>FAS Chemical Crisis"- September 26, 2018 

The Honorable Garv C. Peters 

1. What steps is FPA taking to establish the methods for measuring PFAS in soil and groundwater'' 

What is the expected timctrame for these methods to be established and agreed upon nationally" 

The EPA validated and published its original method (Method 53 7) for monitoring 14 P FAS in drinking 

water (including drinking water ohtainedfi"om groundwater sources) in 2009. This method was 

expanded in November 2018 (published as J;/ethod 537.1 J and can now measure 18 diflerent P J.~4S 1f1e 

EPA is ll'orking to derelop additional drinking 1\'ater ana/yticalmethr"l'fiH other PFAS as well as two 

different methodsfilr quantifj·ing 24 PFAS in surji.1ce water. groundwater, and wastewater matrices 

(non-drinking water) and solids (e.g, soil and sediment). The EPA amicipates completing these new 

methods in 2019. 71wse new methods will include multi lab validations to document repeatability and 

will he added ro the FPA 's l!a~urdous Waste Test :\.1ethod~ SW-8-16. The EPA has developed and 

continues Jo conduct research to develop new analytical methods which can be used to mea5ture a 1-t:ide 

variety of 1' FAS in diffi:rent media. 

2. As recently as tive years ago, EPA had to rely upon industry provided records to understand what 

PF/\S chemicals were manufactured or utilized. The Agency's Significant New Usc Rule authority 

provided by the recent TSC/\ reauthorization was intended to help the agency better understand what 

chemicals are being produced or used here in the United States. Can you elaborate on EPA "s use of 

the "'Significant New Usc Rule"" authority to potentially understand new uses ofPFAS chemicals 

before they are commercialized" Specifically. will the Significant "Jew Use Rule help EPA better 

understand the implications of PFAS chemicals as a class, or does EPA interpret the authority 

provided by Congress to be more narrowly tailored to assess the two specific chemicals, PFOA and 

PFOS'' 

The FI'A has published several SSURs under TSC'!to manu(i1cturers (including importers) and 

processors ofsome PJ,:4S chemicals lo notify the EPA at 90 days hefi!re sturling or resuming new 

uses of these chemicals. The EPA action prohibits new uses of PFAS chemicals until notice is submitted. 

EPA revieH'S, and make.v a determination regarding unreasonable risk posed by the new U5/e. The EPA is 

required to lake action, as appropriate, to address uny unreasonable risk. The S'NURs apply 10 all PFAS 

chemicals included in the SNURs, notjust PFOA and PFOS. 

Relemntto understanding which PFAS chemicals on the TSCA Inventory are active in US commerce. 

the EPA will soon be publishing an updated version oft he 7:'\C-1/nventory !hat will include all 

suhstances designated as either aclh'e overt he past I 0 years or inacfive per reporting under the 'f~~'CA 

lnventm~v Xotification (Acti,·e!Jnactive)jramework rule. 
200 

The Honorable Margaret \Vood Hassan 

1. How many Americans are known or expected to have been exposed to PFAS in their drinking water'' 

Is this estimate you provide for people on public water supplies or docs it include people on private 

drinking water wells? 

The EPA worked with slates and public water systems (PWSs) to character ice the occurrence of six 

!'FAS in the nation's drinking water sen·ed by public water systems (PWSs) hy including six !'!'AS in 

the third Unregulated Contaminant ivfonitoring Rule (UCMR) under the Safe Drinking Water Act 

ISDWA) (UCMR does not sample private wells). From 2013-2015, drinking water samples were 

mllecled and analyzedfiH· six PJ;:,tS in nearly 5,000 PWSs across the nation, accountingfiJr 

approximately 1!0 percent of the US. population served by PW5:, (approximate(v 250 million people). 

7he El'Afinmd 4J! percent of!'WSs ( 198 out of.+, 920 system.s) reported resultsfiJr which one or more 

o{the six PFAS (PFOA, PFOS. per(luorononanoic acid (i'FNA}, perfluorohexane sulfimic acid 

(l'FlfxS). (perjluoroheptanoic acid) PFHpA, or perfluorobutane sul/imate (PFBS')) was measured at or 

above the minimum reporting limit during one or more sampling cPents at one or more sampling 

lour lions. The minimum reporting limit is lower than EPA's lifetime HA. l1!e (/CMR data are the bestuvmtable data on thefi'equenq and level of occurrence of' these PFAS in public water .1ystems 

nationally, hut/hey do no/ provide infimnalion on the occurrence in private wells. 

2. ]-low many Americans have been exposed to levels of PFOA and PFOS that exceed the EPA 

drinking water guideline'' 

To provide Americans, including the most sensitiw populations, with a margin of'prolectionfi·om a 

lifetime o(exposure to PFOA and PFOS(i'om drinking water. the EPA has established the health 

advismy levels a/ 70 parts per trillion When both PFOA and PFO.'i arefimnd in drinking water, the 

combined concentrations ofPFOA and PFOS should be compared tvith the 70 parts per trillion health 

advisory level. This health advisoty level o{/i!rs a margin ofprotection/iJr all Americans throughout 

their lifefi·om adverse health effects resullingfi·om exposure to PFOA and PFOS in drinking water. The 

health advisory value is derived based upon peer-re1·iewed studies of the effects ofP FOA and P FOS on 

lahoralor:v animals (rodenr.1) demonstraling the potcnlialjiJr developmental effects. Under the third 

Unregulated Contwninanl j\1oniloring Rule, discussed in the ru;ponse to the preceding question, the 

El'AfiJund that 1.3 percent oft he participating PffXI' (63 out of{ 920 PWSs reporting) had at/east one 

sample that measured PFOA aml1or l'FOS at concenrrations greater than 7() ppi. The EPA believes the 

L'C;VfR3 data provide the best-available data regarding thefi·equency and level of contaminant 

occurrence in puhlic l,J'ater ,\ysrems. lloH'C\'er, the EPA. has not developed e.Ylirnates r~f'the national 

."";"'!c::ic;, served hy puh/ic 11·ater .1ystems at levels greater than the Jlealth Advisory. The EPA also 

does not have nationally representalil'e data on PFOA and PFOS levels associated with private wells. 

3. When did the EPA begin developing its drinking water guideline for PFOA and PFOS? 

The FPA initiated its health assessrnentsfor l'FOA and PFOS in 2009. Dra/i llealth Effects Support 

DocwnentsfiJr P FOS and!' FOA were releasedfin· public comment in February 2014. The final Health 

Effects Support Documents and Lifetime Health ;ldl'isories were published in Afay 2016 See Health 

Rjfects Support Documents and Health AdvisoriesjiJr PFOA and PFOS at 
201 

4. When were the guidelines publicly available'' 

The non-regulatory Lifetime Health Advisorv levelsfi!r the sum ofPFOA and PFOS concentrations was 

released in A!ay 2016. 

5. When were the data documenting the presence ofPFAS under the Safe Drinking Water Act"s 

Unregulated Contaminant Monitoring Rule analyzed'' When were they made publicly available0 

The UCi'v!R 3 data were col!ectedfi·om 2013-2016 and were analyzed thereafter. The EPA published 

UCAfR 3 data approximately quarterly throughout the monitoring programfiJI/owing review. The data 

summary was puhlished in January 2017. available at 

The EPA continues to assess the data. 

6. I low many years have passed since the EPA has known that PFAS - including PFOJ\ and PFOS arc 

present in public drinking water supplies'? 

The EPA conducted a narionwide survey a/drinking water systems under !he third [inregulated 

Contaminam Monitoring Rule. which began sampling drinking water in 2013. 

7. What is the difference between a guideline and a standard? 

Standardv, such as maximum contaminamlcvels set under the Sa{i! Drinking Water Acr (SDW:4;. are 

enfi>rceable requirements !hal drinking water systems must follow. Guidelines, such as the EPA's Health 

Advisories, are non-enfhn:eable and non-regulaiOIJ'. They are intended to provide technical information 

to slate agencies and of her public health officials on potential health effects. analytical methodologies, 

and trP-:!!n~ent technologies associated ll'ith drinking water contamination. The health adl'ism~v le\'elfor 

PFOA and PFOS were calculated to offer a margin ofprotectionfinferuses during pregnancy and 

hreasl/ed in/imts as well as fin· all Americans throughout/heir life. 

8. If an EP/1. standard is dc\'cloped. are all states required to meet the standard0 

Yes. when the EPA establishes a standard under SDWA. stales. territories. and tribes are required /o 

meet/hat standort/. In addition. stales, territories, ond tribes that have been delegated primary 

enfi>rcemen/ re.1ponsihility (primae:\) IIlllS I adopl standanl1 that are no less slringenllhan the EPA 's 

regulations. 

9. I fan EPA standard is developed, are DoD facilities required to meet the very same standard(s)? Why 

or why not0 

DoD/(Icilities !hat are public water systems and are located within the United Swtes (including 

territories) are required to meet SDW1 requirements, including meeting any applicable drinking water 

slandards. 

I 0. The Centers for Disease Control Agency for Toxic Substances and Disease Registry released its 

Toxicity Profile for PF AS this summer. The A TSDR guidelines for PFOA and PFOS are almost I 0 

tu11cs less than the EP J\ drinking water guidelines. Why is this'7 

3 
202 

On June 20, 2018, ATSDR released a drafi Toxicological Profile/or per/luoroa/kylsfi>r public 

com men/. 7his documenl includes Minimal Risk Levels (MRLs)fiJrfiJW' PFAS · Pelfluorooctanoic acid 

(PFOAJ, Perfluorooclane sulfonic acid (PFOS}, Perfluorononanoic acid (PFNA), and Peljluorohexane 

m/fimic acid (PFflxS). An'DR released the drafi Toxicological Profile afier working co/laborative/y 

ll'ith the EPA, the Food and Drug Administration. the National Institutes ofHealth (including the 

National Institute ofEnvironmental Health Sciences), the i\'ationa/ Toxicology Program, the US 

Geological Survey, and the Department ofDeji:nse (DoD) . 

. n:'iDR 's MRLs and the EPA's Health Advisories (HAs) are two di(ferenttoo/s that are used in different 

situations. Drinking Water HAs provide information on contaminants that can cause human health 

effects and are known or anticipated to occur in drinking water. They are a concentration in drinking 

water that is not expected to cause any adrerse human health ef!ec/s orcr an exposure period (e.g Iday, I 0-day lifetime). The EPA's health advisories are non-enfhrceahle and non-regulatory and provide 

rechnical infimuation to slates agencies and other public health officials on health ej/i!Cis, analytical 

methodolozies and treatment technologies associaled with drinking 11'/lter contamination Drinking 

wafer HAs are calculated incorporating toxicity (i.e., reference doses or RfDs) and exposure parameters 

(i.e., drinking water intake. hody weight. and other potential sources of exposure), 

ATSDR 's MRLs are toxicity mlues that are intended to be used to help public health professionals 

determine areas and populations potentially at riskfor health effeC!sfi'om exposure to a particular 

chemical. MRLs do no/take into account .1peci[ic exposures like a drinking water f!A. MRLs are 

intended only to serre as a screening too/to help puh/ic health professionals decide where to look more 

closely: they are not intended to indicate a maximum safe exposure level. Drinking water HAs provide 

non-en/iJrceahle tee/mica/ guidance to state agencies and other public health officials who have the 

primary responsibilityfi>r orerseeing drinking water systems. The health ad1•ismy /eve/fin· PFOA and 

PFOS offer a margin of'protectionforjetuses during pregnann· and breastfed infimts as well asfilr all 

Americans throughout their life. 

A7:<:;DR 's :'v!RLsfi>r PFOA and PFOS differ hy an order of'magnitudefi·om the toxicity values that were 

derived by EPA in development of' the drinking water HAs due to rhjferences in the critical study 

selected (I'FOA) and uncertain(vfactors applied (PFOSJ, Other health agencies may issue diflerent 

values based on their mvn anafp,es, including rnore strinf{ent t:a/ues that may reflect rnore convervative 

assumptions. The EPA supports !he effilrts ojotherfi:deral partners, including A7SDR, ro develop 

infbrmalion related to PFAS. 1he EPA continue:.,, to take concrete steps, in cooperation -..vith ourfederal 

and state partners, to address l'FAS and ensure all Americans have access to clean and safe drinking 

water lhe EPA will continue to carefiillr review the drafi A 1:'iDR Toxicological I'rofile and will 

consider any infimnation that may infimn our approach to PFOA, PF05i, and other PFAS 

11. In your opinion, do the EP/\ guidelines meaningfully reduce risk to human health? 

The EPA's health adPisories are non-enti>rceah/e and non-regulatory and prol'ide technical information 

to states agencies and other puh/ic health o[(icia/s on health effects, ana(vtical methodologies, and 

/rea/men/technologies associated with drinking water contamination The EPA's health advismy level 

for PFOA and PFOS offers a margin o(protectionfi>r all Americans throughout/heir lifi:fi'om adPerse 

health effects resu/ringji·om exposure to P FOA and P FOS in drinking water. 

4 
203 

12. Based on the scientific evidence. do you think that the EPA guidelines set for PFOA and PFOS are 

health protective? Are they specifically protecting infants who are bottle fed with water from their 

contaminated home source or those who arc breast fed where moms arc drinking contaminated 

vvatcr? 

Based on the available scientific evidence. rhe EPA believes the Health Advisory levels for PFOA and 

l'FOS are protective o{human health These levels include margins ofsafety and consider sensitive 

individuals. inc/udingfetuses during pregnancy and breastfed and bottle,fed infrmts. 

13. Do you think that the EPA drinking water guidelines should be developed lor the suite of chemicals 

measured in the UCMR and not just tor PFOA and PFOS? 

The EPA will work with ourfederal, state, tribal, and local partners on response actions and research 

info rhe health and environmenral impacts o{lhese l'FAS substances. The lc'f'A is continuing to 1rork to 

dnclop a PI· AS Managemem 1'/onrhat H'i/1 o111fine rhe Agency's opproach to addressing the f'F>IS 

challenge. 

14. The last drinking water standard EPA developed was way back in the 1990s and in fact was only a 

lowering of the arsenic standard. Docs EPA have the person power and technical abilities to develop 

PFi\S federal drinking water standards'/ 

The EPA 's teclmical experts are dedicated to assuring that National Primmy Drinking Water 

regulations assure public health protection in accordance with SDWA. The EPA has promulgated a 

numher '?ldrinking H'ater regulations that strengthen public health protection .r-;ince the 1996 

amendrnenl.Y to SDrVA. These regulations. including those designed to reduce risks.fl-om arsenic, 

disinf'ection h}producL>. radionuc/ides, and microbial palhogens that can comefi'om a varier)' o{source.1 

including 5nn:f(Ice lrater, ground H·ater and airplane drinking H··ater ,\y.,·tems, were developed in 

consultation with states. !he EPA's National Drinking Water Advisory Council. the Science Advisory 

Board ancPor other interested stakeholders. 

Addi!ionally, SDWA requires the EPA to rexularlv assess and evaluate unregulated conlaminants. The 

loP ;1 has publishedfiJur Contaminant Candidate Lists. promulgated and implementedfiJur Unregulated 

Conraminant Monitoring Regulations, and made regula101y determinalionsjiJr 25 contaminants in 

accordance H'ith SDJVA. 'i11e l: . .'PA mu5;/ also reviel·1' each nalional primary drinking H'ater regulation at 

lea•;t once eve!)' six years and re,·ise them. {/appropriate. As part oft he "Six-Year RevieH', n the EPA 

evaluates any new()' available data. infimnation and lechnologies to de/ermine if any regulatory 

revisions are needed Revisions must maintain or strenglhen public health protection The EPA's third 

Six-Year Review emluated thousand1· ofjJeer revieH·ed studies and millions ofdata poinrsfrom drinking 

1mter trearment syslems and was puhlished in January 2017 The results of that review identified rules 

the EPA can emluate whether to nwdifi' to s/rengthen public health protection infitture years. This 

revieH· ensures that existing rules are offering the maximum public health benejitfeasible. 

For more h?fbrmation abou!The lime/ines under which drinking 1vater regulations ·were promulgated, 

piease .vee ~l) I 
204 

15. lf so, how long would it take to develop and promulgate a standard" 

Under the SDWA-mandated regula!O!J' delerminalion process, the EPA mus/ consider three crileria 

1vhen making a determh1ation to rexulate a contaminant· 

The contaminanlmay have an adverse effect on the healih ofpersons 

The contaminant is known to occur or there is a high chance that/he contaminant will occur in 

public water sys/ems ofien enough and a/levels ofpublic health concern 

In the sole judgment o(tlze !ldministrator. regulation of"the contaminant presents a meaningji1l 

opportuni(vfiJr health risk reductions for persons served by public water .\)'Stems 

rvhen making a determination, the EPA .firs/ puh/ishes a preliminary re[;ulatory determination in/he 

Federal Register (FR) and provides an opportunityfiir public comment. Aller review and consideration 

-~f;:::l:!ic , ommenls. the EPA would puhlish a final FR nolice wilh the regulatory determination 

decisions. ff'the EPA ·were to make a .final determination to regulate a particular contaminant, the 

Agency would start/he rule making process to establish the National l'rimwy Drinking Water 

Regulation (:Vl'DWR). The SDTT·~t requires that the FPA propose" regulation within 24 months of 

making a determination to regulate a contaminanl, and to promulgate a regulation within I 8 months ol 

proposal !with an OfJiion of' extending rhis timefi'ame hy up to 9 monrhs), 

77-le EPA helieves the timefi'wne a/lolled fi;r promulgaling drinking water regulations is appropriate 

because of' the steps required under SDWA. As part of' this process, the EPA reviews health e[ji?cts data 

that the Agency would use to set a maximum contaminant level goal iJICLG). 77-le MCLG is the 

tnaximurn level qla contwninant in drinking H-·ater at which no knoH'fl or anticipated adverse e.fTect on 

!he health of'persons would occur, allowing an adequate margin of'sa(ety. ;\ICLGs are non-enforceable 

puhlic health goals. Once the MCUi is determined, the EPA sets an enj(Jrceable standard, which is 

established as eilher a maximum contaminant level (A1CL) or a "treatmentlechnique. "The !v!CL is the 

maximum allowed Jerel qla contarninant in water which is delivered to any user r?f a public H'ater 

system. 

The EPA must consider feasibility of' treatment and monitoring when selecting an enfiJrceable limit. 

SDWA also requires the EPA to prepare a health risk reduction and cost ana(vsis in support o( any 

NPDWR. The EPA must analyze the quantifiahle and non-quantifiable costs and benefits that are likely 

to occur as the result of compliance with rhc proposed standard 7he FPA must determine i(the benefits 

o("the regulationjustijj; or do no/justify the costs. Finally, the EPA must consult wirh experts and 

stakeholders including the Nalional Drinking Water Advisory Council and the Science Advisory Board 

7/u:se analyses and consultations can take sign{ficant titne but assure that state and local resources are 

ji1cused upon the most important puhlic health priorities. 

16. How many people's health will be harmed in the time it takes to develop a national standard? 

Protecting public health is the EPA ·s primmy mission. The EPA will continue to carry out the 

requirements r;:(SDVVA in order to t!nsure that citizens across the [Jnited States continue to have sqle 

and clet.Hl drinking water. 

6 
205 

17. When we know that very small amounts of PFAS can negatively affect health, why is EPA treating 

results below the UCMR minimum reporting levels (MRLs) [20 ppt PFOA; 40 ppt PFOS] as "zero'"' 

Are they zero or arc they levels that we need to he concerned about? 

The HAjbr PFOS and PFOA is 70 ppl. 

The EPA set 1he /v!RLsjiJr UCMR 3 after looking at the per/imnance o(mulliple laboratories !hal 

conducted studies 10 determine how low they could reliably measure the concentra/ion ofcomaminants. 

To establish these levels. the EPA veiled those MRLs through the no/ice-and-comment UClv/R 3 

rulemaking The EPA set/he UCMR 3 MRLs such that we would have high confidence that a capahle 

ana/ys/1/aboratmy could meet those levels and report numeric resulls. Per the rule, no results he/ow 

that lnel were reported 

The EPA is aware that some laboratories are ahle to reliably measure PFAS in drinking water at/ower 

le~•els. The fPA advises states or others who may be leading the collection of'PFAS data since the 

UCMR to consider establishing lower ;'v!RLs to meet any projecHpeci/ic data quality objectives. 

provided the laboratories can demonstrate acceptable per/(mnance at the specified concentrations of 

interest. 

18. The PF ASs have been in commerce for tens of years. Can the Lauten berg Amendment to the Toxics 

Substances Control Act he used to require pre-market testing of all of the PFASs'' What is 

preventing this from happening'' 

The EPA's new chemicals review program revieH1S all new PF'A,"' chemicals intendedf(n· 7:\~CA uses 

before they are allowed to cmnmercialize and must make a determination regarding unreasonable risk 

ofinjwy lo health or the environment. The EPA reviews nell' substances to identify whether the range of 

toxicity, fate, and bioaccumulation issues that have caused pas/ concerns with long-chain PFAS may be 

present, a.v well as any concerns that may he rai.ved hy new chemistries, in order to rnake an affirmative 

safety determinmion. In addition to heing able to require testing under TSCA section 5(e}. the EPA will 

also restrict uses pending development o/additional infimnation related to the chemical (e.g testing), 

where appropriate. Whether and what t)pe olfesting may he necessary depends on a numher of/ctctors 

such as the .lpecific uses of'the new chemical. and the similarities or dif(erences of the nell' chemical 

relative to other PFAS chemicals Many of'the Pl·ILS on the active TSCA inventory have been through 

the new chemical rerie-l-1' described ah(H'e. PF,fS' that were in to the enactment ofT:';C'A 1-n~re 

not subject 10 such a review Approximatelv 200 oft he P FAS that been through EPA 's new 

chemicalr.,' program have an associated consent order. A1ost of those orders contain a_ requirement for 

resting if' certain conditions are mer. 0/'these approximately I .f() have commenced production. 

19. Filtration is the currently feasible technology to remove PFAS from water. The filters that contain 

the PFAS are then disposed of Where are they disposed of' Arc these toxic'' Docs this mean that 

PFAS should be listed as Superfund chemicals and disposed of in hazardous waste facilities 0 

Currently available methodsfi>r removing certain PFASfi'om drinking water include granular or 

pml'dered activated carbon, anion exchange. or high-pressure membrane separation techniques 

including reverse osmosis or nanofiltralion These method1· may generate PFAS-contaminated waste, 

;rhich should be managed consistent with state, tribal, and local requirements and in a manner that will 

minimize I he potentialf(Jr enrironmental releases. 

7 
206 

The Resource ( 'onsermlion and Recorery Act (RCRA! regulales hazardous was/e disposal. The 

Comprehensive Environmental Re.1ponse, Compcnsalion and Liabilily Acl (CERCLA, aka Superjimd) 

regulates the cleanup of' hazardous substances released to the environmenl. All chemicals designated as 

RCRA hazardous waste are CERCLA hazardous substances, though not all chemicals designared as 

CF:RCLA hazardous suhslances arc RCRA hazardous waste. The F:PA is currently evaluating all 

statutory mechanisms availa/Jle to mldress PFOA and PFOS. 

20. PFASs arc measured in waste water and in sewage sludge. Does this mean that PFASs are now in 

our rivers. streams and lakes'? Arc our fish contaminated'? If yes, why is EPA not regulating 

discharge to waterways'' 

PFAS are very persistent and mobile in environmental media, including wastewater and sludge. Some 

evidence shows thai certain PFAS have been accumulating in !he environmenl and in wildlife (including 

.fish). The EPA and states regulate chscharges ofpollutants to Waters of" the United States under the 

.Vational Pollution Discharge Elimination ,~:V,Hem. The EPA and states are evaluating approaches to 

ensure that PF4S discharges to the enviromnent are minimi~ed 

21. What is EPA· s plan to further engage with the community in NH and get direct input from Granite 

Staters about PF/\S contamination in their waters'' 

The EPA held a community engagement meeting in Exeter, NH in June 2018. l71e EPA received input 

_ti-om community members at/his meeting as 1rell as through a public docket, which closed on September 

28, 2018. The El'.-1 is co/1/inuing to rmrk to derelo1? a l'FAS Management Plant hal will outline !he 

.·(~·en(1' ·.,.approach to addressing the PF·1S' clwllenge. 77JC Agency i<.: 1rorking to releaJe the plan us 

soon (e·: possible. 

8 
207 

Post-Hearing Questions for the Record 

Submitted to Maureen Sullivan 

Deputy Assistant Secretary of Defense, Environment, Safety & Occupational Health 

Office of the Assistant Secretary of Defense, Energy, Installations & Environment 

U.S. J)epartment of Defense 

Fmm Senator Gary C. Peters 

"The Federal Role in the Toxic PF AS Chemical Crisis" 

September 26, 2018 

Question 1: Your testimony noted that since PFOS is no longer manufactured in the United 

States, U.S. firefi.ghting foams should not contain PFOS, though some legacy stocks still remain. 

Please provide a list of the f1uorinatcd foams that arc currently scheduled for purchase by the 

Department. Has the Department either performed. or contracted to be perfi.wm, any health 

based studies on the newer formulations of foams? 

Answer: The Department purchases fi·om various manufacturers which are listed on the 

Departments Qualified Products List (QPL). The Defense Logistic Agency ASSIST website 

allows users to access specifications, standards. and products on-line: 

h.tt;:;:;://dssist.dla.mil/online/start/. Attached is the QPL for Aqueous Film Forming Foam To date, 

the Department has not conducted studies regarding the safety of substitute chemicals. As part of 

our research and development proposals we arc requiring the investigators to include an 

assessment of the human health and environmental impacts of proposed substitutes and 

byproducts. 

Question 2: GAO noted that DOD had identified 391 active and closed installations with known 

or suspected releases of PFOS and PFOA, and had reported spending almost $200 million on 

environmental investigations and mitigation actions at or near 263 of those installations. Can 

you estimate the total cost the Department will incur for testing and remediating PFAS 

contamination? 

Answer: DoD cannot estimate the total cost the Department will incur for testing and 

remediating PFAS contamination at this time. As of July 2018, DoD has identi lied 401 active 

and Base Realignment and Closure installations with one or more areas where there is a known 

or suspected release ofPFOS andior PFOA. Now that DoD has an initial list of known and 

suspected release areas, the DoD Components are !(J!lowing the Comprehensive Environmental 

Response, Compensation and Liability Act process to investigate these areas to confirm if a 

release occurred. The DoD Components will continue collecting in!(Jrmation on the nature and 

extent of the releases to determine if cleanup actions are necessary. 

Question 3: Your testimony noted that DOD policy is to remove and properly dispose of local 

warehouse supplies of aqueous !ire-f!ghting foams containing PFOS (other than for shipboard 

use) where feasible. Can you describe "proper disposal" in more detail? How are the foams 
208 

disposed of~ given their unique chemical composition and the environmental challenges 

associated with them? 

Answer: The Army and Air Force will dispose of the C8 aqueous fire-fighting foams (AFFF) 

and other AFFF-related waste by incineration. The Navy policy requires that AFFF be disposed 

of by incineration, while the AFFF-contaminatcd water can be treated using granular activated 

carbon treatment (preferred method) or disposed of via solidification/landfill, incineration, or 

another equally protective disposal technology. 

Question 4: Michiganders are concerned with an unnatural foam that has heen appearing near 

known contamination sites. This unnatural foam is known to have high concentrations ofPFAS, 

and is washing up on the shores of water bodies, including Van Etten Lake in Oscoda. PFAS 

contaminated foam is likely due to the plume entering the lake !rom the contaminated source at 

the former Wurtsmith Air Force Base. What actions are being taken by DOD to address and 

rcmcdiatc this unnatural foam that is occurring on waterways adjacent to the military bases, 

including the former Wurtsmith Air Force Base? 

Answer: DoD has not taken actions to address loam on waterways adjacent to military bases in 

Michigan. The Environmental Protection Agency Lifetime Health Advisory applies to drinking 

water only, and the Michigan Department of Human and Health Services (MDHHS) issued a 

statement that said "incidental swallowing of PFAS-containing lake water or foam is not 

expected to harm human health". 
209 

Post-Hearing Questions for the Record 

Submitted to Maureen Sullivan 

Deputy Assistant Secretary of Defense, Environment, Safety & Occupational Health 

Office of the Assistant Secretary of Defense, Energy, Installations & Environment 

U.S. Department of Defense 

From Senator Margaret Wood Hassan 

"The Federal Role in the Toxic PFAS Chemical Crisis" 

September 26,2018 

Question I: When did DoD first test for PFAS in water used for drinking on military bases? 

Answer: DoD has not taken actions to address foam on waterways adjacent to military bases in 

Michigan. The Environmental Protection Agency Lifetime Health Advisory applies to drinking 

water only, and the Michigan Department of Human and Health Services (MDHJ-IS) issued a 

statement that said "incidental swallowing ofPFAS-containing Jake water or foam is not 

expected to harm human health". 

Question 2: Did those tests only test for PFOA and PFOS? 

Answer: No, under the UCMR3 drinking water purveyors were required to test for the following 

six PFAS: PFOS, PFOA. PFNA, PFHxS, PFBpA, and PFBS. 

Question 3: Were the results shared with the public and if so. when? 

Answer: During the active sampling period of 2013-2015, EPA posted results of the UCMR3 

testing online via its National Drinking Water Contaminant Occurrence Database: 

https:l/w\vw.epa.gov/dwucmr/occurrcnce-data-unrcgulatcd-contaminant-monitoring-rulc#3. The 

final results were posted in January 2017. In addition. UCMR3 Community Water System 

participants were required to publish any detections of unregulated contaminants in their annual 

consumer confidence reports by 1 July each year." 

Question 4: The concentrations made publicly available arc, in some cases 100 times higher 

than the EPA guidelines. How do you know that people drinking this water (now or in the past) 

are not harmed by the water they are drinking'? Is DoD conducting clinical screenings? 1s DoD 

testing the blood levels of the Pf AS in the service people and people who work and reside on 

these bases? 

Answer: DoD has expeditiously taken action to find and eliminate exposure to drinking water 

with PFOS/PFOA above EPA's LHA on DoD installations. DoD owns and operates 524 drinking 

water systems worldwide on its installations. Of the 524 DoD-owned drinking water systems, 

DoD identified 24 that tested above the EPA LHA levels and has taken appropriate action to 
210 

reduce PFOS/PFOA below the EPA LHA levels. Where DoD is not the drinking water supplier 

for its installations. 12 systems tested above the LHA level. DoD worked with the drinking water 

supplier to determine appropriate actions consistent with the EPA recommended actions. DoD is 

not currently conducting clinical screenings or testing the blood levels of PFAS in service people 

or people who work and reside on our bases. llowever, as specified in the Section 315(c) of the 

National Defense Authorization Act of Fiscal Year 2019. DoD will conduct an assessment of the 

human health implications of PF AS exposure for individuals who served as members of the 

Armed Forces and were exposed to PF AS at military installations. 

Question 5: Does DoD only test for PFOS and PFOA on bases and installations? 

Answer: No, ail drinking water sample results include all 14 PFAS that are listed in the cunent 

drinking water analytical method (i.e .. EPA Method 537. Rev.l.l ). 

Question 6: Does DoD only test for multiple PFAS chemicals in water on bases or installations 

when required by a state -such as in NJ or in Nl-P 

Answer: No. all drinking water sample results include all 14 PFAS that arc listed in the current 

drinking water analytical method (i.e .. EPA Method 537, Rcv.l.l ). 

Question 7: When DoD finds PFAS (PFOA, PFOS and multiple others now at least 14 others) 

in groundwater on military installations. arc the data made available in a timely manner (within a 

month or so) to people living on base AND o!Tbase') And if not. why not0 

Answer: Throughout the cleanup process. DoD works in concert with regulatory agencies and 

communities, and shares information in an open and transparent manner. When elevated levels 

of PFOS and PFOA are detected that may pose an unacceptable risk to human health, DoD uses 

a proactive outreach strategy to promptly notify potentially affected community members. 

Outreach cfTorts may include: • Communicating to potentially affected communities (e.g., 

notifying the residents of his or her personal drinking water results. fact sheets on installation 

web sites): • Partnering with local regulatory and governmental organizations to reach 

stakeholders: • Ilosting public meetings (e.g., Restoration Advisory Board meetings); • Alerting 

and engaging with the media; • Messaging through community social media: and • Updating 

community leaders. 

Question 8: !las DoD educated its clinicians about the damaging health effects of PFAS on 

military personnel'' 

Answer: Yes, the Military Departments have provided information to educate clinicians at the 

Military Treatment Facilities on PFAS exposures and potential health effects. The Military 

Department public health organizations are a central source of health risk communication, health 
211 

effects, and other health-related information for exposures of concern, including PFAS, to our 

Service members, their families and other residing and working on the installations. 

Question 9: When DoD detects Pf AS on its property, does it test downgradicnt drinking water 

or rivers, lakes or streams or does it ONLY test on its property'' 

Answer: The DoD Components will collect information on the nature and extent of the releases 

both on and off installations to determine if cleanup actions are necessary. The Department 

considers the EPA's health advisory toxicity inf(Jrmation when assessing risk to human health 

under its cleanup program consistent with EPA risk assessment guidance. Throughout the 

CERCLA process, DoD works in concert with regulatory agencies and communities and shares 

information in an open and transparent manner. 

Question 10: Has the DoD ever provided an alternative water supply lor residents on base or 

issued health advisories due to concerns over PFAS contamination~ 

Answer: Yes, lor DoD-owned drinking water systems that tested above the EPA's Ll-IA for 

PFOS and PFOA, we are following EPA's LilA recommended actions to ensure no one is 

drinking water with elevated levels of PFOS and/or PFO/\, These actions include, but are not 

limited to: providing bottled water, and adding treatment systems, such as granular activated 

carbon filter, to remove PfOS/PFOA Where DoD is not the drinking water supplier, 

installations were encouraged to ask if their drinking water suppliers if it had tested the drinking 

water and if the results were below the EPA LHAs. for the 12 suppliers where the drinking 

water tested above the LHA level, the installations reached out to the drinking water supplier to 

understand what actions the purveyor is taking to reduce the levels ofPFOSiPFOA. DoD has not 

issued a health advisory, we are following EPA's LHA and recommendations. 

Question 11: In the annual dctense bill signed into law earlier this month, there's a clause urging 

the DoD to develop fluorine-free firctighting foams. Any updates on starting this process? What 

are the challenges or setbacks that need to be addressed, so that we can achieve this goal in the 

future? 

Answer: DoD is funding research on Ouorine-fi·ee substitutes for AFFF which can meet the 

mi]ib_r;·'s stringent performance requirements. ln FY 2019, DoD will initiate demonstrations of 

existing replacement AFFF formulations at DoD facilities to determine if their performance can 

meet DoD's needs. We are committed to tinding a f1uorinc-trec substitute for AFFF that meets 

the military's stringent performance criteria while protecting human health, When these 

demonstration projects are completed we will have a better understanding of the capability and 

environmental impacts of several tluorine free foams. 

Question 12: Is DoD using the same methods as EPA lor detection of all 14 PFAS chemicals in 

water'? 
212 

Answer: Yes, DoD uses the EPA Method 53 7. revision 1.1. for detection of all 14 PFAS 

chemicals in drinking water. 

Question 13: If not, why not') 

Answer: Not applicable. 

Question 14: If a federal drinking water standard is set, will DoD comply with it? Will DoD 

clean up all contaminated drinking waters to a standard(s) set by EPA? 

Answer: As part of our compliance with the SDWA, for DoD drinking water systems we 

comply with federal drinking water standards, i.e., maximum contaminant level- MCL. As part 

of the CERCLA process DoD performs a risk assessment to determine if there is an unacceptable 

risk to human health or the environment. If an unacceptable risk is found, then DoD needs to 

take a cleanup action. To determine the site-specific cleanup standard, CERCLA identifies 

specific criteria which must be met in order for a standard to be designated as an applicable or 

relevant and appropriate requirement (ARAR). A federal drinking water standard (i.e., MCL) 

under the SDWA is an example of an ARAR. 

Question 15: DoD falls back on the excuse of "military readiness" as a rationale for not 

complying with health and environmental protections how will DoD treat PFAS contaminated 

waters 0 

Answer: DoD follows the CERCLA process, which provides a consistent risk-based approach to 

address on-base and off~ base migration of PFOS and PFOA releases. As a first step, the Military 

Departments identified installations where DoD stored or used AFFF containing PFOS or PFOA 

and suspect there was a release. The Military Departments then determined whether there is 

exposure through drinking water and if the source is from DoD activities. The DoD works with 

the communities and private individuals to break the drinking water exposure pathway. Then the 

Military Departments are prioritizing sites for further actions using the normal CERLCA riskbased process. 
213 

Post-Hearing Questions for the Record 

Submitted to Linda S. Birnbaum, Ph.D., D.A.B.T., A.T.S. 

Director 

National Institute of Environmental Health Sciences and National Toxicology Program 

National Institutes of Health 

U.S. Department of Health and Human Services 

From Senator Margaret Wood Hassan 

"The Federal Role in the Toxic PFAS Chemical Crisis" 

September 26, 2018 

Question I. You've provided us with the latest scientific evidence on the adverse health 

outcomes caused by or associated with a subset of the PFAS chemicals. Is there sufficient 

science to tell us that multiple PFASs and not only PFOA and PFOS should be limited or 

removed from drinking water'! 

Answer of Dr. Birnbaum: Regarding safe drinking water levels, several states, relying on the 

best available science, have elected to establish their own guidance for PFAS in drinking water. 

These states include Connecticut, New Hampshire, New Jersey, Vermont, and Minnesota, and 

their guidance covers multiple PF AS, including PFOA, PFOS, PFNA, PFHxS, and PFHpA. 1 

Additionally, federal agencies have released draft toxicity assessments on some PFAS other than 

PFOA and PFOS, including GcnX chemicals and PFBS2 These assessments arc expected to be 

finalized in 2019. As the latest science becomes available, public health officials at both the 

federal and state level are better positioned to make informed decisions in establishing guidance 

and/or regulatory limits for drinking water and other exposure media as may be appropriate. 

NIEHS-supported research helps create a scientific basis for such decisions. 

Question 2. Everyday there are new scientific studies demonstrating that people arc exposed to 

PFAS from their water, dust in their homes. food, and air. Wbat is known about the exposures 

ti·om sources other than water? Should we be conccrncd0 

Answer of Dr. Birnbaum: Humans are exposed to PFAS through a myriad of pathways, 

practices, and products. While much attention is placed on ingestion of drinking water, science 

shows other pathways can have relevance for human exposure. For example, carpets and 

clothing containing stain-repellant PFAS can shed microparticles that adsorb to household dust 

and ar<>, in turn, incidentally ingested by children and adults. Packaging materials--such as 

pizza boxes, beverage containers, and food wrappers-can also contain Pf AS that can migrate to 

foods. Certain PF AS in municipal water may be dermally absorbed via swimming, bathing, or 

1 Several states have established guidance to date relating to the presence in drinking water of multiple per- and 

polyfluoroalkyl substances, including for perfluorooctanoic acid (PFOA); perfluorooctanc sulfonate (PFOS); 

perfluorononanoic acid (PFNA); perfluorohcxanesulfonic acid (PFI!xS); and pertluoroheptanoic acid (PFHpA). 2 PFBS means perfluorobutancsu!fonic acid (Pti3S). 
214 

dish washing and research in this area continues. The practice of land farming-a process of 

composting waste products on agricultural land--can result in uptake of PF AS by plants and 

animals in the food chain. Ongoing research in the area of exposure can help inform regulators 

in making sound decisions to protect public health. On an individual basis, multiple actions can 

be taken to minimize such exposures. If an individual is concerned about their drinking water 

containing PFOA andior PFOS, they can contact their drinking water provider, consider using an 

alternative or treated water source, and consult their local and state health departments for 

gu.irb\"!GC about steps they can take to reduce their exposure. Citizens who are concerned about 

their drinking water should consider contacting their local water utility to understand what 

contaminants may be found in their drinking water. 

Question 3. If we should not be concerned, should the drinking water guidelines reflect multiple 

sources of PF AS of exposure? And if they should, would this result in a lower or higher 

allowable concentration ofPFAS in water'7 

Answer of Dr. Birnbaum: N!EHS subject matter experts continue to collaborate with, and share 

technical information with, EPA and other regulatory agency scientists responsible for 

developing drinking water health advisories and guidelines. Federal interagency collaboration is 

occurring on a range of individual chemicals within the PFAS class. Also, notably, EPA 

commonly uses a relative source contribution (RSC) factor in calculations leading to regulatory 

limits in drinking water. The RSC assumes that exposures occur in pathways other than 

ingestion of drinking water. 

Question 4. The EPA is taking small steps to phase out the production and use oflong-chain 

PFAS- including PFOA and PFOS. Is there evidence that short-chain alternatives are less toxic, 

persistent and bioaccumulative? 

Answer of Dr. Birnbaum: Current evidence indicates there are difTerences in toxic potency--the 

exposure level at which toxic e!Tects occur- ,and persistence among the many PFAS chemicals. 

Our understanding has not yet developed sutliciently to enable broad generalizations regarding 

whether short-chain alternatives are less toxic and less persistent than the longer-chain chemicals 

within the PFAS class. The National Toxicology Program Division at NIEJ-IS has conducted 

studies in rats to evaluate toxicokinetics of seven individual PFAS-PFBS, PFJ-IxS, PFOS, 

PFHxA, PFOA, PFDA, and 8:2 FTOJ-I 3 These animal studies are designed to help us better 

understand how these PFAS are handled within, and eliminated fl·om, the body. 

'The seven individual PFAS for which the National Toxicology Program Division at NIEHS has conducted 

toxicokinetic studies are: perfluorobutanesulfonic acid (PFBS): perfluorohcxancsulfonic acid (PFHxS): 

pert1uorooctane sulfonate (PFOS): pcrfluorohcxanoic acid (PFHxA): perfluorooctanoic acid (PFOA): 

perfluorodecanoic acid (PFDA): and 8:2 fluorotclomcr alcohol (8:2 FTOH). 

2 
215 

Question 5. Does NIEIIS or the National Toxicology Program have the technical tools it needs to 

test PFASs using high throughput screening methods~ If not, what is needed? If yes, why are 

these chemicals not tested? 

Answer of Dr. Birnbaum: NTEHS and the National Toxicology Program are well-positioned to 

both understand, and advance scientific knowledge about, human health effects associated with 

exposure to PFAS and health effects in rodent models induced by PF AS. NIEHS and NTP are 

actively contributing to this growing knowledge base using existing resources. For high 

throughput screening, advanced equipment, techniques, and computing power are needed that 

allow teams of researchers to more rapidly map biochemical pathways associated with adverse 

health effects than they would if they approached their research using traditional methods. 

However, cost and access to these nascent high throughput technologies---namely robotic 

laboratory architecture and big data capacity~can be limiting factors. Currently, NIEHS 

possesses medium throughput screening capability. and conducts high throughput screening 

through partnerships with NIH's National Center for Advancing Translational Sciences 

(NCA TS) and EPA's National Center for Computational Toxicology (NCCT). NIEHS is using 

all these new technologies, as appropriate, in its studies of PFAS under the NTP Responsive 

Evaluation and Assessment of Chemical Toxicity (REACT) Program as was summarized in my 

writ!en testimony. The greatest needs for advancing PFAS toxicity research relate to chemistry. 

We now recognize there are hundreds ofPFAS to which people may be exposed and thousands 

of PF AS have been identi tied. Most everything we understand about potential health effects is 

from studies of a handfi.ll of compounds. When the number of chemicals of interest is so large, 

inevitably a major limiting factor relates to chemistry~that is. our ability to obtain, synthesize, 

and measure all of these chemicals. Once obtained and identity-verified, NIEHS has many tools 

at our disposal to test a library of compounds against a wide array of biological targets. Ideally 

resources are created either through private sector investment or in the public sector such that a 

large number ofPFAS chemicals can be procured by any interested scientific research team. 

Likewise, robust analytical methods would need to become available to measure a larger number 

of PFAS chemicals either in experimental settings or in the environment. In addition. since 1999 

the Centers for Disease Control and Prevention's (CDC) National Biomonitoring Program has 

regularly assessed the U.S. population's exposure to certain PFAS including PFOA, PFOS, 

PFNA. and PFHxS4 CDC"s laboratory methods for PFAS arc designed to evaluate population 

exposures and were recently updated to include additional PFAS such as GcnX and other shortcholn ~lterncttivcs. 

1 Cet1ain PFAS included in the CDC's National Biomonitoring Program include: perfluorooctanoic acid (PFOA): 

pcrtluorooctane sulf(mate (PFOS): perfluorononanoic acid (PFNA): and perfluorohexanesulfonic acid (PFHxS). 

3 
216 

Post-Hearing Questions for the Record 

Submitted to Linda S. Birnbaum, Ph.D., D.A.B.T., A.T.S. 

Director 

National Institute of Environmental Health Sciences and National Toxicology Program 

N ationallnstitutes of Health 

U.S. Department of Health and Human Services 

From Senator Gary C. Peters 

"The Federal Role in the Toxic PFAS Chemical Crisis" 

September 26, 2018 

Question I: Are there any life stages that are not thought to be implicated or affected by PFAS? 

Answer of Dr. Birnbaum: As l mentioned in my testimony, we only have knowledge regarding a 

small percentage of PFAS compounds. In most cases, we are drawing primarily on data ti·om 

animal studies. These data suggest that for some of the chemicals studied, the same exposure 

may affect children and adolescents as well as pregnant mothers and their offspring to a greater 

degree than persons at other stages in life. This principle also holds true t(Jr exposure to other 

chemicals. 

4 
217 

Post-Hearing Questions for the Record 

Submitted to Brian J. Lepore 

Director 

Defense Capabilities and Management 

U.S. Government Accountability Office 

J;'rom Senator Gary C. Peters 

"The Federal Role in the Toxic PFAS Chemical Crisis" 

September 26, 2018 

1. Has GAO done any prior work on DOD's environmental liability for contaminants, 

including the costs of limiting future exposure or cleaning up prior exposure? If so, 

what were some of the recommendations GAO made? Has GAO faced specific push 

back in discussions with non that may indicate non disagrees with the 

foundational challenges related to contaminants? 

In 2016, we reviewed the extent to which the Department of Defense (DOD) has made progress in 

capturing and reporting environmental cleanup costs at installations closed under the base realignment 

and closure (BRAC) process. DOD is obligated to ensure that former installation property closed under 

BRAC is cleaned up to a level that is protective of human health and the environment before such 

property can be transferred to other federal and nonfederal parties. We issued a report on this work in 

January 2017 (GA0-17-151- Military Base Realignments and Closures: DOD Has Improved 

Environmental Cleanup Reporting but Should Obtain and Share More Information). 

Our 2017 report included a recommendation for DOD to provide Congress with better visibility over the 

costs for the environmental cleanup of properties closed under BRAC. Specifically, we recommended 

that DOD disclose in its annual reports to Congress on environmental cleanup costs that those costs will 

increase due to the costs of cleaning up the contamination left by per- and polyfluoroalkyl substances 

(PFAS) anrl other emerging contaminants. We also recommended that future reports to Congress 

include the best estimates of these costs as additional information becomes available. DOD agreed with 

us and, in its environmental cleanup report issued to Congress in Jun.e 2018 (the fiscal year 2016 annual 

report), DOD stated that it expected that environmental cleanup costs would increase due to the 

investigation and cleanup of two particular types of PFAS (perfluorooctane sulfonate, or PFOS, and 

perfluorooctanoic acid, or PFOA). DOD also reported that, as additional information became available on 

environmental cleanup costs, it would include a best estimate of those costs in its reports to Congress. 

DOD further stated that as of December 31, 2016, it had spent about $202 million on sampling, analysis, 

and response actions to address PFOS and PFOA. 

Our 2017 report also recommended that DOD more effectively share information and address 

environmental cleanups and transfers by creating a repository or method to record and share lessons 

learned about how various locations have successfully addressed cleanup challenges. DOD agreed with 

this recommendation and stated that it would develop a process to record and share lessons learned in 

conjunction with its fiscal year 2017 annual report to Congress. In July 2017, DOD issued a memorandum 

to the services directing them to collect BRAC success stories to be posted on the DOD Environment, 

Safety, and Occupational Health Network and Information Exchange. In September 2018, DOD posted 

these success stories on the website. 

Page 1 of 2 
218 

Æ 

uAO has not experienced push back from DOD on recommendations made in our last two relevant 

reports. DOD concurred with all five recommendations we made in GA0-18-78- Drinking Water: DOD 

Has Acted on Some Emerging Contaminants but Should Improve Internal Reporting on Regulatory 

Compliance. This report was the basis for our testimony at this hearing. DOD also concurred with both 

recommendations we made in GA0-17-151, which are discussed above. 

Additional GAO work with implications for DOD environmental liabilities: 

Agent Orange: Actions Needed to Improve Accuracy and Communication of Information on 

Testing and Storage Locations, h~tr>:LLvL~\I\A/J'.~Q.£Q\fLflrQQtJC_1s/_§i\Q_:12.:2:1, November 2018 

Defense infrastructure: DOD Con Improve Its Response to Environmental Exposures an Military 

Installations, May 2012 

Superfund: Interagency Agreements and Improved Project Management Needed to Achieve 

Cleanup Progress at Key Defense Installations, llt1p~L/'·\/'-'c\\I.S,,(),g.Q'L/h''C2tJi'CtsfC,A.QlD. 

2010 

Superfund: Greater EPA Enforcement and Reporting Are Needed to Enhance Cleanup at DOD 

Sites, March 2009 

July 

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