Drinking Water: Status of DOD Efforts to Address Drinking Water Contaminants Used in Firefighting Foam
Released: 2018-09-26T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: According to health experts, exposure to elevated levels of PFOS and PFOA could cause increased cancer risk and other health issues in humans. DOD has used firefighting foam containing PFOS, PFOA, and other PFAS since the 1970s to quickly extinguish fires and ensure they do not reignite. EPA has found elevated levels of PFOS and PFOA in drinking water across the United States, including in drinking water at or near DOD installations.

This statement provides information on 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 firefighting foam.

This statement is largely based on a GAO report issued in October 2017 ( GAO-18-78 ). To perform the review for that report, GAO 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 the four administrative orders issued by EPA and state regulators to DOD on addressing PFOS and PFOA in drinking water, visited seven installations, and interviewed DOD and EPA officials. This statement also includes updated information based on two 2018 DOD reports to Congress—one on PFOS and PFOA response and one on firefighting foam—as well as discussions with DOD officials.

section_title: What GAO Found
paragraphs: GAO reported in October 2017 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 per- and 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 PFOS 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 October 2017 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 PFAS. 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.

section_title: Letter
paragraphs: 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  environmental liabilities. 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). 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.

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 environmental liability 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 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 2018.

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 conclusions based on  our audit objectives.
subsections: section_title: Background
paragraphs: 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. EPA has issued such  regulations for approximately 90 drinking water contaminants. Public  water systems, including the DOD public water systems that provide  drinking water to about 3 million people living 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. Health 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. These advisories  set the recommended health advisory level for each contaminant—or  both contaminants combined—at 70 parts per trillion in drinking water.  According to DOD, the department also considers information in these  health advisories when determining the need for cleanup action at  installations with PFOS and PFOA contamination.

section_title: DOD Has Initiated Actions to Address Elevated Levels of PFOS and PFOA in Drinking Water and Concerns with Firefighting Foam
subsections: section_title: DOD Has Initiated Actions to Identify, Test, Address, and Respond to Orders from Regulators Regarding PFOS and PFOA in Drinking Water
paragraphs: 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. Since we issued our report, DOD has  updated that number to 401 active or closed installations, according to  August 2017 data provided in a March 2018 report to Congress on the  department’s response to PFOS and PFOA contamination.

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.

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. 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 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 health  advisories for drinking water for people (1) on 13 military installations and  (2) outside 22 military installations.

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.  For example, at Wright-Patterson 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 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 information becomes available. 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.

section_title: DOD Has Taken Steps to Address Health and Environmental Concerns with Its Firefighting Foam
paragraphs: In our October 2017 report, we found that DOD was taking steps to  address health and environmental concerns with its use of firefighting  foam that contains PFAS. These steps included restricting the use of  existing foams that contain PFAS, testing DOD’s current foams 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). 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.

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 Navy—which 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). 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. 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 PFAS-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.

section_title: GAO Contact and Staff Acknowledgments
paragraphs: 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  Gómez, (202) 512-3841 or gomezj@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, Amie Lesser, Summer Lingard-Smith,  Felicia Lopez, and Geoffrey Peck.

This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.

Fast facts: The firefighting foam DOD has used for decades contains chemicals that, at elevated exposure levels, can increase risks of cancer or other health issues. As a result, DOD:

spent about $200 million on investigations and response (as of December 2016)

identified 401 installations with known or potential releases of these chemicals

took actions, like providing alternative drinking water, at 32 locations (as of August 2017)

This testimony is largely based on our report on DOD's response to such contamination in drinking water, and is a part of our body of work on the federal government’s environmental liabilities, an issue on our High Risk list.

Question-summary annotations: questions: question: What did the GAO report on the DOD in 2017?
answer: GAO reported in October 2017 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.

question: What are PFOS and PFOA?
answer: PFOS and PFOA are part of a larger class of chemicals called per- and polyfluoroalkyl substances (PFAS), which can be found in firefighting foam used by DOD.
child_questions: question: What was EPA's response to the existence of those chemicals in drinking water?
answer: 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.

question: What did EPA's health advisories include?
answer: 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.

questions: question: What did the GAO report in about the DOD in 2017?
answer: 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 PFAS.

question: What has the DOD done to reduce  the amount of PFAS produced by them?
answer: 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.
child_questions: question: Has the DOD been successful up to date  in eliminating PFAS use?
answer: 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.

questions: question: What are the risks of exposure to PFOS and PFOA?
answer: According to health experts, exposure to elevated levels of PFOS and PFOA could cause increased cancer risk and other health issues in humans.
child_questions: question: What has the DOD done to address these risks?
answer: DOD has used firefighting foam containing PFOS, PFOA, and other PFAS since the 1970s to quickly extinguish fires and ensure they do not reignite.

question: What did EPA discover about PFOS and PFOA?
answer: EPA has found elevated levels of PFOS and PFOA in drinking water across the United States, including in drinking water at or near DOD installations.

questions: question: How was this statement created?
answer: This statement is largely based on a GAO report issued in October 2017 ( GAO-18-78 ).

question: What did the GAO do in order to prepare this report?
answer: To perform the review for that report, GAO 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 the four administrative orders issued by EPA and state regulators to DOD on addressing PFOS and PFOA in drinking water, visited seven installations, and interviewed DOD and EPA officials.
child_questions: question: What information was gathered about the DOD in this report and from what surces?
answer: This statement also includes updated information based on two 2018 DOD reports to Congress—one on PFOS and PFOA response and one on firefighting foam—as well as discussions with DOD officials.