Army Per- and Polyfluoroalkyl Substances

Army Response and Cleanup Process

Army Response and Cleanup ProgressThe Army continues to regularly test on-installation drinking water systems and coordinates with purveyors of drinking water to Army installations to ensure PFOS/PFOA levels do not exceed the EPA health advisory levels, or properly promulgated state safe drinking water standards, as a result of past Army activities. The Safe Drinking Water Act (SOWA) is a federal law designed to protect the quality of drinking water supplied to the American public. In 2016, the EPA issued SOWA lifetime HA levels for PFOS/PFOA in drinking water of 70 parts per trillion (ppt). While not an enforceable regulatory standard, a lifetime health advisory represents a concentration in drinking water that is not expected to produce adverse health effects if the water is consumed over an entire lifetime. Sampling of off-installation drinking water supplies is addressed under the cleanup program.

?	The Army continues to regularly test on-installation drinking water systems and coordinates with purveyors of drinking water to Army installations to ensure PFOS/PFOA levels do not exceed the Environmental Protection Agency health advisory levels, or properly promulgated state safe drinking water standards, as a result of past Army activities. The Safe Drinking Water Act is a federal law designed to protect the quality of drinking water supplied to the American public. In 2016, the Environmental Protection Agency issued Safe Drinking Water Act lifetime health advisory levels for PFOS/PFOA in drinking water of 70 parts per trillion.  While not an enforceable regulatory standard, a lifetime health advisory represents a concentration in drinking water that is not expected to produce adverse health effects if the water is consumed over an entire lifetime. Sampling of off-installation drinking water supplies is addressed under the cleanup program.
?	For context, 1 part per trillion is equivalent to: 1 inch in 16 million miles (600+ times around the Earth); 1 cent in 10 billion dollars; or 1 second in 320 centuries.
?	The Army follows the federal cleanup law known as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 (also known as ?Superfund?), and other long-standing Environmental Protection Agency regulations in its cleanup program, including to address PFAS. CERCLA is a complex, multi-phase process that provides a consistent, science-based approach across the nation for cleanup. The Army follows the process to investigate release and assess the appropriate cleanup actions based on risk.  
?	The Army prioritizes its cleanup response on a ?worst first? basis, meaning the Army will address sites that pose a greater potential risk to human health and the environment before sites posing a lesser risk.
?	The Comprehensive Environmental Response, Compensation, and Liability Act provides a consistent approach across the Nation for cleanup.  The Defense Environmental Restoration Program (DERP) statute provides authorities to the Department of Defense to perform and fund actions and requires they be carried out in accordance with CERCLA.  The figure on the page and the following information summarizes the major CERCLA phases and milestones Department of Defense uses to cleanup a site, although actual timing and scope of response actions will be tailored to site conditions and funding priorities.  
?	The timeframe of the Preliminary Assessment/ Site Inspection phase is approximately 1-3 years. The timeframe for the next phase, Remedial Investigation/ Feasibility Study, is approximately 3-6 years. The timeframe for the next phase, Remedial Design /Remedial Action Construction is 2-4 years. The timeframe for the next phase, Remedial Action-Operation, is 1-30+ years. The final phase is long term management, which takes 1-30+ years.
?	Within the CERCLA process, the Department of Defense can take short-term actions (e.g. provide bottled water, point of use filters) anytime during the process.

The Army follows the federal cleanup law known as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 (also known as “Superfund”), and other long-standing EPA regulations in its cleanup program, including to address PFAS. CERCLA is a complex, multi-phase process that provides a consistent, science-based approach across the nation for cleanup. The Army follows the process to investigate release and assess the appropriate                                                                               cleanup actions based on risk.

 

CERCLA Process graphic

 

?	In 2017, the Army began investigating areas with known or suspected releases of PFAS to the environment under the CERCLA framework, including sampling for PFAS in soil, sediment and groundwater. There are no PFAS thresholds or health advisory limits established for sediment, soil, or groundwater as there are for drinking water.  In the absence of regulatory direction, the Army has proactively been investigating for PFAS beyond drinking water to better understand potential impacts to the community and environment.
?	To protect surrounding communities, the Army uses data from investigating potential releases of firefighting foam to identify affected public water systems and private wells. While specific actions vary according to the unique circumstances at each location, the Army has taken, and will continue to take, swift action to address drinking water affected by Army activities.
?	During the Preliminary Assessment (PA), the Army reviews existing information and may conduct site visits to identify locations where Army activities may have caused a PFOS/PFOA release. The next step in the CERCLA process is to perform a Site Inspection (SI) on locations identified during the PA to confirm whether a PFOS/PFOA release occurred. Once the Army has information from the PA/SI, it can make informed decisions on which sites need to move to the next phase (i.e., Remedial Investigation (RI)/Feasibility Study (FS)). During the RI, the Army collects detailed information through field investigations to characterize site conditions, including the nature and extent of the PFOS/PFOA; assess actual and potential exposure pathways; and evaluate risks to human health. If PFOS/PFOA results in an unacceptable risk to human health and the environment based on EPA's risk assessment policies, the Army will conduct an FS to evaluate cleanup alternatives and work with regulators to select a permanent solution that is protective of human health and the environment.  
In 2017, the Army began investigating areas with known or suspected releases of PFAS to the environment under the CERCLA framework, including sampling for PFAS in soil, sediment and groundwater. There are no PFAS thresholds or health advisory limits established for sediment, soil, or groundwater as there are for drinking water. In the absence of regulatory direction, the Army has proactively been investigating for PFAS beyond drinking water to better understand potential impacts to the community and environment.

During the Preliminary Assessment (PA), the Army reviews existing information and may conduct site visits to identify locations where Army activities may have caused a PFOS/PFOA release. The next step in the CERCLA process is to perform a Site Inspection (SI) on locations identified during the PA to confirm whether a PFOS/PFOA release occurred. Once the Army has information from the PA/SI, it can make informed decisions on which sites need to move to the next phase (i.e., Remedial Investigation (Rl)/Feasibility Study (FS)). During the RI, the Army collects detailed information through field investigations to characterize site conditions, including the nature and extent of the PFOS/PFOA; assess actual and potential exposure pathways; and evaluate risks to human health. If PFOS/PFOA results in an unacceptable risk to human health and the environment based on EPA's risk assessment policies, the Army will conduct an FS to evaluate cleanup alternatives and work with regulators to select a permanent solution that is protective of human health and the environment.