Per- and Polyfluoroalkyl Substances (PFAS) are a large class of chemicals found in many consumer products, as well as in industrial products such as certain firefighting foam called aqueous film forming foam (AFFF). PFAS is also found in essential use applications such as in microelectronics, batteries and medical equipment.
PFAS is found in everyday consumer items - from nonstick cookware to water-resistant clothing. PFAS is also found in essential use applications such as in microelectronics, batteries and medical equipment. Reports indicate most people in the United States have been exposed to PFAS and have PFAS in their blood. Health monitoring studies show PFAS is most prominently detected in workers associated with manufacturing activities and in communities with elevated levels of PFAS in their drinking water. Current scientific research suggests that exposure to high levels of certain PFAS may lead to adverse health outcomes such as reproductive effects (e.g., decreased fertility) and increased risk of some cancers, but it is unclear what health effects are associated with low levels of exposure to PFAS. Additional information regarding PFAS exposure can be found on the EPA website (https://www.epa.gov/pfas) and on the Centers for Disease Control and Prevention's Agency for Toxic Substances and Disease Registry website (https://www.atsdr.cdc.gov/pfas/). The science on PFAS is evolving. There is extensive research being done to determine where PFAS exist and what impact they have on human health and the environment.
In July 2019, the Secretary of Defense stood up a task force to ensure a coordinated approach on DoD-wide efforts to address per- and polyfluoroalkyl substances (PFAS). Section 2714 of title 10, United States Code codifies the Department of Defense’s (DoD’s) Per- and Polyfluoroalkyl Substances (PFAS) Task Force and identifies its members and goals. DoD’s PFAS Task Force is working to address PFAS issues in a cohesive, consistent manner while coordinating with other Federal agencies to ensure a consistent approach to this national issue. The PFAS Task Force will continue to identify and provide DoD with the tools needed to address the effects of its PFAS releases.
Protecting the health of our personnel, their families, and the communities in which we serve is a priority for the Department. In 2019, the Secretary of Defense established a PFAS Task Force to provide strategic leadership and direction and ensure a coordinated, aggressive, and holistic approach to DoD-wide efforts to address PFAS. The Task Force has issued numerous PFAS-related guidance documents to implement statutory requirements as well as ensure DoD is approaching PFAS in a consistent manner across the Military Departments. Under the guidance of the Task Force, the Department has made notable progress in addressing a range of PFAS issues. These include ensuring safe drinking water on installations, the development of an alternative to PFAS-containing firefighting foam, addressing PFAS releases related to past DoD activities under the federal cleanup law, substantial investment in research and development to support these efforts, and has expanded outreach and engagement with the public.
The Department of Defense (DoD) is taking a number of actions to address PFAS, such as researching an alternative to PFAS-containing firefighting foam, addressing PFAS releases related to past DoD activities under federal cleanup laws, investing in research and development to support these efforts, and engaging with the public on PFAS concerns. PFAS remains a complex national issue and many federal and state agencies are working together to address it. DoD frequently publishes reports and briefings to the DoD PFAS website to keep the public informed of its efforts to identify and address DoD’s PFAS releases.
DoD provides the status of its PFAS investigations across over 700 installations and National Guard facilities quarterly on the DoD PFAS website here. In addition, final testing results for PFAS or planned PFAS testing in off-base drinking water is available on the DoD PFAS website here.
Yes. DoD is now focusing on taking interim cleanup actions to prevent further PFAS migration off base. DoD will have initiated interim actions at over 40 installations by the end of 2024 and plans to take additional actions as more information becomes available from our ongoing investigations.
The Department posts PFAS drinking water results and planned sampling events within covered areas on DoD’s PFAS website and provides advanced notification of any sampling events to managers of public water systems, heads of the municipal government, and Restoration Advisory Board (RAB) community members, as applicable. In compliance with the federal cleanup law, DoD coordinates sampling plans with environmental regulators in affected communities.
DoD’s estimated cost to investigate and clean up per- and polyfluoroalkyl substances (PFAS) in Fiscal Year (FY) 2024 and beyond is $9.7 billion (estimate as of the end of FY 2023). This is a preliminary estimate that DoD expects will increase significantly as the ongoing investigations are completed and more information is known about the extent of the cleanup required. In general, the Department cannot estimate how long it will take or how much it will cost to completely address its PFAS releases until it knows the extent of those releases. The Department will be able to provide better estimates as the ongoing investigations are completed over the next few years.
Yes. DoD is identifying the best technologies to characterize, treat, and manage PFAS impacted sites. DoD has invested over $160M through Fiscal Year 2022 with another $60M planned through FY2025 and supports over 200 technology development and demonstration projects that advance the detection, investigation, cleanup, and destruction of PFAS. DoD will award 16 projects by Fall of 2023. DoD is committed to the continued advancement of these technologies and has several field demonstrations planned in FY23 to evaluate technologies. For more information on SERDP’s and ESTCP’s efforts on treatment methodologies, including a summary of the in situ and ex situ remedial approaches that are currently being developed click here.
DoD anticipates a significant number of private drinking water wells (potentially thousands of wells) will require interim actions that cannot all be completed at once. Establishing an initial prioritized action level at or above 3 times the PFAS MCLs (e.g., 12 ppt for PFOS or PFOA) enables DoD to take action now, as site specific background levels of PFAS are determined later during the remedial investigation process. While DoD considered several factors when developing its prioritized approach, this 3 times the PFAS MCL action level presumes that site-specific background levels for individual PFAS are below this amount. This approach allows DoD to address those locations where PFAS levels are highest, without having to wait to establish background levels for each site. Additionally, a prioritized approach to address the ‘worst first’ is consistent with long-standing EPA regulations. The September policy provides a pathway for prioritizing actions and establishes a comprehensive and holistic approach to addressing DoD’s PFAS releases.
To ensure cleanup begins as quickly as possible in locations with the highest known PFAS levels, DoD will initiate interim cleanup actions at private drinking water wells impacted by PFAS from DoD activities where concentrations are known to be at or above three times the levels established in EPA’s drinking water rule. For example, under this new DoD policy, DoD will prioritize taking interim action for PFOS and PFOA at 12 ppt in drinking water from DoD activities. This replaces the prior DoD interim action level of 70 ppt. Prioritizing action where PFAS levels from DoD releases are the highest, ensures a consistent “worst first” approach nationwide and across the Military Departments. Because DoD anticipates that a significant number of private drinking water wells will require action, a prioritized approach is necessary and consistent with the federal cleanup law and its regulations.
DoD will work to complete actions to address off-base drinking water at 55 installations with the highest known levels of PFAS (where DoD has previously taken action for wells with levels of PFOS and PFOA above 70 ppt), while at the same time, continuing to identify and address private drinking water wells with PFAS above three times the MCLs from DoD releases at additional locations. This approach prioritizes action where PFAS levels from DoD releases are the highest, rather than delay action at these locations while ongoing remedial investigations continue. DoD will also continue collecting additional sampling data to understand the extent of potential off-base impacts as well as site specific PFAS background levels.
The September 2024 DoD PFAS cleanup MCL policy identifies several methods, including some water treatment technologies, that can be used to address the action levels identified in this DoD policy and directs Military Departments to consider more sustainable solutions when examining alternatives. In prioritized order, the Department will consider: providing connections to municipal systems; installing whole house treatment systems; and providing point of use treatment systems. DoD will only provide bottled water – which is not currently regulated for PFAS – when more sustainable alternatives, such as drinking water treatment, are technically infeasible due to site-specific conditions.
The intent is for DoD Components to take immediate action to accelerate investigations, prioritize resources to identify impacted private drinking water wells that are at or above 3 times the MCL action levels, and implement interim actions per the policy and within the CERCLA framework. Site specific conditions and characteristics will impact individual implementation schedules, but there should be no delay in initiating implementation of the policy and DoD has already identified 55 locations with the highest levels of PFAS that should be considered a priority.
DoD also intends to expedite action at public water systems where authorized, prioritizing the most impacted sites for earlier action. For public water systems above the Maximum Contaminant Levels (MCLs) impacted by PFAS from DoD activities, DoD will work with those systems and regulators to address PFAS impacts. These actions will assist the public water systems as they work to meet the requirements for compliance with the PFAS National Primary Drinking Water Regulation as soon as possible but not later than April 2029.
When DoD identifies that it may need to sample a private drinking water well, the private homeowner where the well is located will receive a written notification. The notification provides information about next steps in the sampling process and includes information regarding: the possible presence of PFAS in their private drinking water well; DoD’s efforts to investigate and address PFAS impacts resulting from DoD activities; and the opportunity for the homeowner to have their private drinking water well tested for PFAS at no cost.
Once sampling and testing is completed, supplementary letters are provided back to private homeowners who consented to sampling. Letters contain information about the levels of PFAS detected in their private drinking water well, whether or not the level identified means alternative water or treatment will be provided, and information resources where homeowners can find the latest information on PFAS.
To expedite implementation of more enduring solutions, DoD will focus on sustainable solutions including providing connections to municipal systems; installing whole house treatment systems; and providing point of use treatment systems. The DoD will only provide bottled water when more sustainable alternatives, such as drinking water treatment, are technically infeasible due to site-specific conditions.
Background levels refer to chemicals (e.g., PFAS) that are not from releases at the cleanup site. For example, rainwater and residential septic systems have been shown to result in measurable levels of PFAS. DoD will work with EPA and state regulators, as appropriate, to evaluate background levels of PFAS during the detailed remedial investigation phase. Under the DoD policy, however, interim actions are taken at the prioritized action level (i.e., PFAS levels at or above 3 times the EPA MCLs) without an investigation of site-specific background levels.
DoD’s first priority is to address current human exposure to the highest levels of PFAS from DoD activities. DoD will follow the CERCLA process to develop remedial actions to cleanup groundwater used for drinking water. If there is groundwater that has a potential future use as drinking water at a location, it will be evaluated and addressed as part of the Department’s long term remedial actions and considered when establishing a site’s final cleanup goals. The policy directs focus on cleaning up PFAS off installations in surrounding communities where there is a current exposure to PFAS impacted drinking water.
Several years ago, DoD stopped using AFFF on its installations for testing or training unless it is fully contained and appropriately disposed. While AFFF continues to be used for emergency purposes, DoD is taking action to fully transition from AFFF to PFAS-free firefighting solutions for all land-based applications. As of October 2023, the Department stopped purchasing AFFF for land-based applications.
Over the last few years, the Department undertook a significant initiative to test and demonstrate fluorine-free foams (F3) to replace AFFF. The Department began the transition to F3 in September 2023 and F3 is already in use at some DoD installations. The Department plans to replace AFFF with F3 alternatives in more than 6,000 mobile assets and approximately 1,500 facilities. DoD is also evaluating available technologies, in addition to alternative F3 agents, to replace current AFFF systems in facilities. Based on the Military Department’s transition schedules for AFFF replacement, the Department will need to invoke the first of two one-year waivers to extend the current October 1, 2024 statutory deadline to cease AFFF use. Section 322(e)(1) of the National Defense Authorization Act for FY 2020 (Public Law 116-92) provides that the Secretary of Defense may extend the prohibition deadline by one year with respect to the use of fluorinated AFFF, pending the submission of a briefing and a written certification. The briefing was provided in June 2024, and on August 2, 2024, the Secretary of Defense provided Congress with certification of the waiver, after which the deadline for the prohibition of use of AFFF on military installations is extended to October 1, 2025. View the certification here.
Across the Department of Defense, we estimate the need to remove over 2 million gallons of AFFF concentrate - that is across all facilities (e.g., aircraft hangers) and mobile assets (e.g., firefighting trucks).
The new Fluorine Free Foams (F3) are engineered to put out large fuel fires without the use of PFOS, PFOA, or other PFAS compounds. DoD has invested considerable time, effort, and funding partnering with academia and industry on F3s, and independently reviewing the best available science to be sure that F3s meet performance needs, pose no known threat to human health, and are not persistent in the environment. While toxicity studies will evolve over time, we considered and screened F3s for hazards to people and the environment. The new F3s will allow us to protect our personnel and communities from fire threats without the human health and environmental concerns associated with PFAS.