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

Letter

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. 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.

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 Identify, 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. 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.

DOD Has Taken Steps to Address Health and Environmental Concerns with Its Firefighting Foam

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.

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 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.

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