New DoD Policy for Testing for Per- and Polyfluoroalkyl Substances (PFAS)
In March 2020 the Secretary of Defense issued a policy requiring all DoD-owned water systems, where DoD is the purveyor (supplies drinking water to the installation), to test for PFAS, at installations world-wide, using the most recent U.S. Environmental Protection Agency (EPA) test method (537.1).
This new policy will require DoD-owned drinking water systems, which had previously been tested under the June 2016 Secretary of Defense and Assistant Secretary of the Navy (Energy, Installations and Environment) (ASN (EI&E)) policies, to be retested.
Under the new DoD 2020 policy, sites that report below the method reporting limit are to be retested every three years, while systems that exceed the reporting limit are to be sampled quarterly for one year, and once every two years until results are below the method reporting limit. Laboratory results for all samples collected will be provided on the installation’s consumer confidence reports.
PFAS substances are man-made chemicals persistent in the environment that are not absorbed well in soil and could travel to groundwater. PFAS substances have been used since the 1950s in a variety of products and substances because of their stain and water repellant properties; the most common historical Navy use of the substances has been in Aqueous Film-Forming Foam (AFFF), a fire extinguishing agent used on our installations. At this time PFAS substances are considered emerging contaminants for which there are no Safe Drinking Water Act (SDWA) regulatory standards. The EPA is working to improve its understanding of PFAS to determine if safe drinking water regulatory limits are needed. The Navy is following the EPA’s guideline for unregulated contaminate monitoring, including only using laboratories approved by EPA to perform the PFAS analysis.
To provide Americans, including the most sensitive populations, with a margin of protection from a lifetime of exposure to Perfluorooctanoic acid (PFOA) and Perfluorooctanesulfonic acid (PFOS)from drinking water, EPA issued a lifetime health advisory of 70 parts per trillion. Health advisories are non-enforceable and non-regulatory, but rather provide information to state agencies and public health officials which further inform actions that should be taken to reduce exposure. The EPA is currently studying PFAS to determine if national regulation is needed; however some states have begun to regulate individual PFAS compounds.
Chronology of Navy Policy
In 2014, the ASN (EI&E) issued a policy that required on-base drinking water sampling for PFOA and PFOS, for installations where groundwater was used as drinking water and PFAS could have been released nearby.
In June 2016, both Secretary of Defense and the ASN (EI&E) issued additional policies that required all Navy installations not previously tested under the 2014 policy or the EPA Unregulated Contaminant Monitoring Rule (UCMR3) to test drinking water regardless of the water source (installation or municipal) and regardless of proximity to a potential/known PFAS release to the environment.
Out of an abundance of caution, the Department of Defense PFAS testing and response goes beyond EPA Safe Drinking Water Act requirements. The Navy is working with local and state environmental and health agencies the EPA and the Agency for Toxic Substances and Disease Registry (ATSDR) as we move forward with testing of drinking water.
Additional information can be found:
EPA website: https://www.epa.gov/ground-water-and-drinking-water/drinking-water-health-advisories-pfoa-and-pfos
EPA website: https://www.epa.gov/pfas/epa-pfas-drinking-water-laboratory-methods
ATSDR website: https://www.atsdr.cdc.gov/pfas/index.html
U.S. Navy website: https://www.secnav.navy.mil/eie/Pages/PFAS_Home.aspx
U.S. Navy website: https://www.navfac.navy.mil/Business-Lines/Environmental/Products-and-Services/Environmental-Restoration/PFAS-Reading-Room/