Document 6bByq1DBRJY4prZQXLanaY4do
Department of the Navy (DON) Perfluorinated Compounds (PFCsVPer and Pol Him all vl. Substances (PFAS)
Comprehensive Strategy Road Map Version 2, 3JMaj 2016
BLUF: Perfluorinated cGompounds (PFCs) per and polydunralkyl -,ul>-,lance-. (PI AS-,) are a (suite of >i' ei 100 chemicals^^everaLofwhich are of emerging public health concern to the J /i`| Minn ni ttl iln Mas y (DON), U.S. Environmental Protection Agency (EPA), state regulators, public water systems, and the general public, primarily in drinking water systems. Iln li mi PI 1 will be used throughout this strategy as a surrogate for PFCs and PFASs...This strategy addresses PFCs in drinking water, the drinking water program, the environmental restoration program (on and off installation), and the acquisition, firefighting, and facilities ^management] programs. DON policies, positions, and messages are aligned throughout the Department and with the Office of the Secretary of Defense.
[Communications!: Need 1: DON repository of roiiiimimriiiioii plan, mid .upjxn mr> Frequently Asked Questions (FAQs), O&Asuestions and Answers (O&As). fact sheets, PAGsPublic Affairs Guides (PAGs). in '11,,i 11 p u l ' outreach material (internal and external [Environmental Protection Agency (EPA) and Agency for Toxic Substances and Disease Registry (ATSDRil). We need to be accurate, consistent, transparent, and efficient.
(Where to store this info?| Who maintains? (Who has access]?
Need 2: Standardized chain of command review/approval lines for media_andcpngressipnal inquiries. CODEL requests, and leadership briefings/testimony.
DASN (E) approval authority for policy decisions and new responses. Integrate into repository of FAQs, Q&As, etc. above to ensure everyone answers routine,
similar, repeat questions consistently and efficiently.
Existing Policies and Guidance: DASN(E): Perfluorinated Compounds (PFCs) - An Emerging Environmental Issue, 210CT14 USMC: Sampling and Testing for Perfluorinated Compounds (PFCs) in Drinking Water, 12DEC14 NAVFAC: Perfluorinated Compounds (PFCs) Interim Guidance/Frequently Asked Questions (FAQs), 29JAN15) OPNAV N45: Navy Drinking Water Sampling Policy for Perfluorochemicals Perfluorooctane Sulfonate and Perfluoroocatonoic Acid, 14SEP15 BUMED Mi mo A'Mi I M I; / I AIf.I ai IA? Testing for Periluorohemials Iv, Huo*if/,t|i`4 t t,it/poitii4 (PFCs) in Drinking Water, 24DEC15 DoDIs 4715.06, 4715.07 and 4715.18, DoDM 4715.20 [Air Force SAF|/IEE: (AFFF (Disposal and Replacement - Crash Response Vehicles, 9MAR16 ...................... .... UFC 4-211-01n "Aircraft Maintenance Hangars: Type I, Type II And Type III"
(----------------------------------------------------------------------_ - ' Comment [LN1]: NAVFAC EV: Do we want to
mention somewhere in this strategy that our sampling focus will only be on PFOA/PFOS or on those PFCs that have PHA levels? I think this is crucial to ensure that we don't open the door for sampling to be done of the full suite of PFCs Response: this is a very tricky issues and too complicated for this strategy since the answer depends. It depends on what the States establish as promulgated standards. It depends on what a states identify for DSMOA QC samples. It x depends on disposal of treated water. Etc.
Comment [WKCNMC2]: PFC issues are now affecting at least two land transfers --Melville Marina at Newport and a (BRAC?) site in CA. Suggest considering whether the strategy should x include recommendations regarding property transfer \ issues as well. x Response: PFCs are just one more contaminant v under DERP so there is nothing new here.
Comment [CJMCNAE3]: Recommend keeping a spreadsheet that includes: Date o f inquiry, name of person inquiring, affiliation of person inquiring, , recipient of inquiry, dateo f response. a Response: CHINFO has lead for how to manage x this information.
Comment [LN4]: NAVFAC EV: NAVFAC ( EXWC maintains the ERB Web Page, there is some \ info on PFCs located there already for use in this ' DON repository; the RITS has also had a PFC topic
x presentation from 2015 with case studies from \ BRAC sites. Navy also has an Environmental Portal \ which could be used as a data repository.
^ Response: CHINFO has lead for housing info.
Comment [djb5]: At a minimum, public affairs POCs should have access to the approved FAQs, so that response to media inquiries can be consistent and as painless as possible for RPM. Response: CHINFO will address this at implementation
Comment [djb6]: Not that I'm in favor o f it, nor does it say too much, but should the revised AF guidance & "press release" be included? Response: I do not think so Should the Navy be developing something similar? Response: That is what this strategy is all about and there will be additional policies and direction as a result of this strategy.
Comment [CJMCNAE7]: Also, if we are going to include AF information they have an interim policy from 2012 that we should include. Please send it to me and I will consider adding it as another reference.
US00007503
UFC 3-601-02 Operation and Maintenance: Inspection. Testing, and Maintenance of Fire Protection Systems
NFPA 412 Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Equipment. 2014
NFPA 11 Standard for Low-. Medium, and High-Expansion Foam. 2016
NawDON Drinking Water Program:! DON complied with the third Unregulated Contaminant Monitoring Rule (UCMR3) sampling requirements in the U.S. Under UCMR3, DON tested drinking water at |l9 Navy and seven USMC installation^ with no exceedance of the Provisional Flealth Advisory (PFIA) levels for j t i rIikiukh i inmi n i>j iPFOAt or j i irliioiooi I mu ulron i|i (PFOS l I oiu ollii i |'I < L, ,.uc aL,o levied nil'll i lln I If M l ' lio i ii linn mi no l'[) '
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DASN(E) policy required testing at additional locations in the U.S. if there was a known or suspected release of PFCs within about approximately a mile upgradient of the drinking; water source-wafefi Navy sampled 444-11 installations, with Naval Auxiliary Landing Field (NALF) Fentress wJiji li es approximate!;, _>() people, in Chesapeake, VA as the only installation with an exceedance of the PHA. USMC sampled one installation with no PFIA exceedances.
DASN(E) policy also required testing at all overseas locations. USMC completed testing at four locations with no PFIA exceedances. Navy sampling isjmderway. All compiled sample results expected by May 2016.
__DON policy is to utilize the PFIA values for drinking water as if they were a regulatory standard and provide alternative water to personnel on base for drinking and cooking if the PFIA is exceeded. When/if final health advisory (FLA) values or Safe Drinking Water Act (SDWA) regulatory standards (e.g. maximum contaminant levels (MCLs)) are established, these will replace the PIIAs asPPIA action levels. DON will is_also complying with any State standards that are properly promulgated and used within consistently across the |Statej pursuant to the State's delegated federal authority under the SDWA (e.gTPFNA in N J),
USMC will fund using local O&M/base operating funds, with support from higher HO as required. Navy will require funding by the drinking water system facility maintenance owner..
A looming question posed by DON leadership is "can we say now that all of our personnel on base are provided water without PFCs above an action level?" Since not every installation has sampled for PFCs under the SDWA, UCMR, or DON policy, the current answer has to be no. To determine the universe of sites where this question cannot be answered, ODASN(E) will-requested from Navy and USMC provide a list of installations under the following categories by 31 May: o DON'I in 4 water system sampled under UCMR o DON ' i in 11water system (including overseas) sampled under DON policy o_DON purchased water from off installation where public water system PWS sampled under UCMR
o I _<i in 11water system not sampled (non-public water systems, water systems that did not meet the policy criteria-)
Comment [SRGCNME8]: Do we need to address other routes of exposure that are currently being established that will ultimately create a riskspecifically eco (ingestion o f animals with PFCs since they bioaccumulate). Possibly add a sentence that says "as screening values are established for other routes o f exposure, new policy/guidance will be established". Response: This suggestion is true, but I am not \ i aware of any near Icrm actions (hat would result i in a need to add (his information a( (his time.
[ Comment [djb9]: Also for completeness, these installations should be listed here or in an attachment.
Repnne? th a t level o f d e ta il is too m u c h fo r an
i AS1N level strategy. Ihal info will he in the I'AO I lAQs and Q&As
Comment [SRGCNME10]: One clarification regarding the evaluation of testingof Navy water systems. Initially, only Navy public water systems (those serving more than 25 people) were evaluated fortesting. There are approximately 35 Navy water systems that serve less than 25 people. The strategy should clarify address whether we are also goingto evaluate testing at Navy Non-PWS. Cutler was a system that fell into this category. Response: The final bullet of this section is designed to gather that information so leadership i can decide whether to direct additional testing.
Comment [SRGCNME11]: Recommend that "source water" be changed to "Water supply source (e.g. lakes, reservoirs, wells) " Response: hdiled (o match I)ASIN(L) policy.
Comment [MSACCN12]: Has this pohev been properlv vetted and approved through DoD? Given the direction many states are going, this could be problematic. Response: This is common practice and OSD is aware of it.
US00007504
o DON purchased water from off installation where PWS not sampled
Environmental Restoration Program: __DON is following policy/guidance in DoDI 4715.07, DoDM 4715.20, DoDI 4715.18, and Navy Environmental Restoration Program (NERP) Manual to conduct Defense Environmental Restoration Program (DERP) response actions for PFCs, consistent with any other contaminant. No additional policy is required to address PFC releases under DERP, however DASN(E) f H*l r fh' If tohi `Ii vi I' ij nr51111| k 11is nMir5ills 1 i'ii i below t ni'iii `li I ill hi hi i Hi 4 Ho i li hi i to efficiently i (-inf k'k-i'li nhl , t ili'l i|i iii4 j 11' 11111/i a comprehensive I/I I'l' kill Mid /'.n i "I i <nii fin >' A '1 i inventory of potential release sites across DON.
f i t ' l l v l u l l ii ol i o v i ii >1 I s D l l ' f' i f ' estoration. i f e o n d - f t t k e d r e c n i i r e d at overseas installations mu I <mlI in i <1 In IU conducted in accordance with DoD Instruction 4715.08 and country-specific restoration guidance, if any, provided by DoD Lead Environmental Components pursuant to DoDI 4715.08.
NOTE: OSD responded to a reporter's question and in December 2015 released a list of 664 fire or crash training sites (DERP sites identified in KBCRS database) throughout DoD. This list was compiled by searching for certain terms fe.g., fire training) without any verification ol .111/ .I 1tus/applicability. Of the 664 sites, 143 are identified as DON sites. Fire and crash sites are just one category of potential PFC release sites, so this list is not complete or necessarily accurate for DON or DOD.
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Comment [LN13]: NAVFAC EV: For further identification o f known and suspected releaseses. j NAVSEA hosts a database identified as NOSC Net, i which would be a useful source of data for release sites. With respect to remote crash sites, many of these self-extinguish prior to responders arriving on scene. For hangar system releases, AFFF is often not contained because hangar doors are left open. Response: Gunarti, please track this down and incorporate into process as appropriate.
Comment [LN14]: 5090. ID does not currently require reporting of AFFF spills - We may want to consider changing Chapter 39 to require spill reporting (using the message format) which would be tracked in NOSC Net. Response: Concur.
Comment [LN15]: NAVFAC Washington: It is noted below that "preliminary assessments [are] costly and time consuming" and instead "DASN(E) will disseminate the existing lists o f DERP sites and PFC release categories to CNIC and USMC who will conduct facility-wide reviews to identify additional potential DERP sites to "assess"". Are these not essentially PAs? And if so, wouldn't it behoove the Navy to conduct the investigations as PAs such that our regulatory partners are satisfied that our "facility-wide reviews" are truly comprehensive? With the same considerations in mind, for those sites that the "facility-wide review" recommends further investigation, shouldn't follow-on sampling be conducted as an SI (or at least follow SI guidance) and have a UFP-SAP? Presumably for those sites that have now been sampled (as part of an SI or not) and have been identified as having PFCs in environmental media, new sites should be opened in NORM at Phase 2. And, regardless of what process was used in the past (PA/SI or other), the next phase would be an RI, which would follow CERCLA guidance like any other ER site. Is that the case? Response: Addressed in flowchart and business rules.
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|Completion of all |DERP response actions [will be a multi-year process similar to any
other contaminated site.
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Comment [SRGCNME17]: II is imperative that the RPM understands the entire CSM for the base, including possible source area, migration pathways, lithology, points of extraction, septic tank locations, treatment facilities (including disposal areas for same facilities), etc) Response: Agree, hul nul in this slrnlegv. ' ---------------------------------------------------------------------" Comment [LN18]: NAVFAC Washington: It does not sav anything about actually sampling the groundwater. Assuming this prioritization is to be done before sampling is to take place? Additionally, this section does not read as a prioritization hierarchy. The only true prioritization in the section are the sites with down-gradient drinking water wells within one mile. The rest of the paragraph are factors to consider for all other sites, but no direction as to which determine priority. Response: Addressed in flowchart and business rules.
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Comment [SRGCNME19]: Regulators as asking ; about where has the past disposal of possible PFC contaminated material has gone (sludges, filter backwash, e tc ). Past practice of spray application of material on land may have created an issue. Response: Gunarti, please ensure this is included as a potential release mechanism in the data call to CNIC and USMC.
Funding:
*\
3 Conduct all investigations, removal, and remedial [actions! using ER,N or BRAC funding.
3 Address all off-installation contaminant migrationj, including provision of alternative
\
water, where appropriate, using ER,N or BRAC funding.
3 Do not use ER,N flmding to provide alternative water on an installation (e.g., NALF
Fentress) or to install, operate, or test finished drinking water treatment systems. . These
on-installation drinking water systems must meet all SDWA and DON policy
requirements. USMC will fund using local O&M/base operating funds, with support
from higher EIQ as required. Navy will require flmding by the drinking water system
facility maintenance owner..
. Remediation conducted at overseas installations must be funded with Environmental
Compliance flmding, not ER,N flmding.
/Technology:!_________________________________________________________________ To support our drinking water and cleanup programs, we plan to consolidate information on the state of technology and research and development investments being made regarding:
Drinking water treatment technologies
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Comment [MSACCN21]: Technically providing \ alternate water or taking action to filter the water ' could be considered a removal/remedial action. If ^ this is done as part of a remedy selection then] [2]
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Comment [SRGCNME22]: Due to current level o f measurement requirements in parts per trillion, need to develop a consistent approach on how off base monitoring will proceed, if detections an) ['3]
?
Comment [SRGCNME23]: Midlant is currentlv planning to use our CNIC N4 utilities account as the funding source at Fentress Response: (hanks.
Comment [LN24]: EXWC Tech Review was completed in Feb 2016. Document will be forwarded under separate cover. Response: thanks.
US00007506
Groundwater treatment technology for both in-situ and ex-situ implementation Soil treatment technologies for on site Off-site disposal of soil or other contaminated media
Specific Installations: To date, two BRAC and two active installations have been at the forefront of the PFC issue due to PFC being detected in public and/or private drinking water wells on or near these installations. Each installation has generated a lot of material, fact sheets, PAGs, Q&As, etc. The four locations and their established web links are:
Warminster: http://www.bracpmo.navv.mil/brac bases/northeast/former warfare center warminster.h tml
Willow Grove: http://www.bracpmo.navy.mil/brac_bases/northeast/reserve_base_willow_grove.html
Health Studies: Many requests are being made to conduct health studies where there is contamination on site or in drinking water; however, (the desired outcomes of the requested studies are not always clear.|
Flealth studies cannot determine whether an individual's exposure to past PFC contaminated water has caused or will/may cause specific adverse health effects in the future. The public has been exposed to PFCs for many years as PFCs are in many consumer products (e.g., non-stick cookware, microwave popcorn bags, stain resistant carpet, etc.). There are also many other confounding factors (e.g., other chemical exposures, smoking, etc.) that cause similar adverse health effects and thus preclude the ability to determine a conclusive cause and effect for an individual.
DON is investing funds proactively to eliminate exposures from DON releases, as discussed above.
.BUMED policy .<*roro m n h iM m/pliim mPMlu >1I h,i>' i H i i l l l l i HI ] in K i l l lldllhl | l I I ' l l l l l I ' l l l l l l l l 'll iMid III " I i II l mn>I < I i
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, - ' Comment [WKCNMC25]: Suggest rephrasing this. Whose desired outcome? Phrase is too subjective. Suggest moving up the BUMED point here and saying something like "however, BUMED and other health agencies do not recommend them at this time." Response: this was meant to be general. The requests are all over the map and neither BUMED or ATSDR have definitively said no, y et We are working on this issue with our health professionals, OSD, and ATSDR.
o...BlppdTestingjbr^FOS^FOMsjipliriedkallyjiecessary...While blood tests can
measure the level of PFCs in person's body at the time of the test., the blood tests
cannot identify the source of the PFCs.
o...Providers shod
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person's living: and working environment., and that health studies have not
consistently found any specific health effects from exposure to PFCs.
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PFCs from a person's body other than to decrease total exposure and allow the
levels to decrease through natural elimination.
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....ATSDR has guidance on health studiesa_but_doesjiolJMke^eiiidii^ej^commendatinns
or^oHcy_jtatesiMisJiegardmg...the capabilities
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ATSDR
ATSDR toxgulde.pdf ATSDR ToxFAQ.pdf ATSDR Public Health ATSDR Blood PFC
pfcs_fact_sheet.pdf
Statement, August 2(Testlng and Health In
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Aqueous Film Forming Foam (AFFF): The DoD Emerging Contaminants Governance Council (ECGC) issued a policy memorandum on January 28, 2016 that specifies:
The Military Services will: o Issue Service-specific risk management procedures to prevent uncontrolled landbased releases of AFFF during maintenance, testing, and training activities. o Where and when practical to do so, remove and properly dispose of PFOS-based AFFF from the local stored supplies for non-shipboard use to prevent future environmental response action costs). Focus on removing and replacing known PFOS-based AFFF in unopened drums/can versus AFFF already loaded into systems tanks/bladders. PFOS-free AFFF is available on the DoD Qualified Products Fist.
|DFA will support the Services risk management actions to include AFFF procurement strategies and inventory assessment.)
The DoD Strategic Environmental Research and Development Program will issue a Statement of Need to initiate research to develop a fluorine-free AFFF.
Proposed elements for ASN(II ll&ll ! IlI ) policy to meet these DoD directions are:
Require Best Management Practices (BMPs)/containment for all AFFF storage and system applications. This includes HAZMAT/supply areas, mobile equipment, training locations, fixed flooding systems, etc.
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Minili i mi mii'liij" imi iI'equire replacement and proper disposal of all AFFF containing |PFOA or PFOSj, as follows: o All partial and frill containers of material on 111.I;111:111<ni. within 6 months and from ships within 12 months o All mobile firefighting and crash responseaircraft rescue and fire-fighting vehicles within 12 months o All fixed and training systems without complete containment and disposal BMPs in place within 18 months o All fixed and training systems without complete containment and disposal BMPs in place and_propalyjriaintainedand_operated_within 36 months
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- Comment [WKCNMC26]: Is this a new environmental liability cost that needs to be budgeted? How should that be done? Response: No. We do not budget for potential future releases.
(-------------------------------------------------------------Comment [LN27]: CNIC N3/N45-NAVFAC EV: Will DLA be able to provide assistance in the development a comprehensive disposal strategy in addition to ''support the Services risk management actions to include AFFF procurement strategies and inventory assessment"? Response; we are discussing this with DLA.
- ' Comment [mrp28]: Matches item 2 o f the 28 JAN 16 DoD ECGC guidance. Also, from the 5 APR 16 meeting, no confidence in availability o f "PFOA-free" AFFF. Even in the newest "C-6", "non C-8" or "Meets EPA 2015 Guidance" formulations, there might be trace amounts o f PFOA. If PFC-free AFFF becomes available, then initiate another program to replace and dispose of PFCcontaining AFFF. Response: We will address this in the future DON policy direction.
US00007508
o All shipboard systems during next availability, but no later than 66-72 month
[Analyze new C-6, non C-8 or Meets EPA 2015 Guidance AFFF formulations for other PFCs ofconcem.|
Require guidance/information be provided for purchasers and end users for ordering PFOA/PFOS-free AFFF products on QPL-24385 via NAVMSG, Advisory, other (advanced change notice to MIL-SPEC; applicable Tech. Manuals, etc.).
_Require cancellation of national stock numbers (NSNs) (or other) for all PFOA/PFOS containing AFFF products on the QPL-24385 by [future date certain],
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[Require all new purchase firefighting and crash response vehicles and ships with AFFF systems to only use C-6, non-C8, or Meets EPA 2015 Guidance AFFF.[
Continue R&D on PFC-free AFFF.
_ - ' Comment [mrp29]: All o f the remaining requirements, with the exception of R&D on PFCfree alternatives, should only be valid if new formulations of AFFF do not contain high levels of other PFCs o f concern. It does no good to simply swap PFOA for another PFC o f concern. Response: Agree
_ - ' Comment [mrp30]: This will need to be coordinated with ASN(RD&A). Response: Agree
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Page 4: [1] Comment [LN20]
Lindsay Nehm
5/3/2016 10:19:00 AM
Response: We should discuss furtehr. Is this a drinkign water or DERP question?
Page 4: [3] Comment [SRGCNME22] Schirmer, Robert G CIV NAVFAC MIDLANT, EV
5/3/2016 10:06:00 AM
Due to current level of measurement requirements in parts per trillion, need to develop a consistent approach on how off base monitoring will proceed, if detections are below PHA. Need to ensure that using 25% of PHA level for continued monitoring is the desired path forward
Response: Agree, but not included in this strategy.
US00007510