Document Rprmw3E2p655nnX46d0nbKVyv
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
(Draft CNIC PAO)
DRINKING WATER SAMPLING AND TESTING FOR PFCs (perfluorochemicals)
Background: All Navy public water systems (PWSs) in the U.S. that produce drinking water from installation sources where perfluorinated compounds (PFCs) are known or suspected to have been released within ~ 1-mile up-gradient to the drinking water source must be sampled for PFCs in finished drinking water. PFCs are man-made chemicals persistent in the environment that are not absorbed well in soil and could migrate to groundwater. On 21 October 2014 DASN policy required drinking water sampling and testing for PFCs be done at Navy installations world-wide. Regional commanders were informed of this requirement and then on 14 September 2015 OPNAV N45 policy issued detailed testing requirements and clarified direction contained in the DASN policy instructions. PFCs have been used in a variety of products and substances, the most common historical Navy use of the substances has been as a fire extinguishing surfactant in Aqueous Film-Forming Foam (AFFF). At this time PFCs are considered to be emerging contaminants for which there are no Safe Drinking Water Act (SDWA) regulatory standards. The testing is being done to comply with DOD Policy on emerging contaminants (DoDI 4715.18 of June 11, 2009 - Emerging Contaminants).
Precautionary measures are being developed to sample off-base private drinking water wells if PFCs are detected within the [insert location] and/or groundwater samples. Measures include project planning, coordination with [insert locality] and internal and external public health stakeholders, as well as community outreach, in order to be prepared to execute off-base private drinking water well sampling.
Timeline:
08 January 2009: EPA's Office of Water released a Provisional Health Advisory (PHA) establishing health-based concentrations above which action should be taken to reduce exposure for PFCs.
21 October 2014: DASN policy required drinking water sampling and testing for PFCs be done at Navy installations world-wide.
14 September 2015: OPNAV N45 policy issued detailed testing requirements and clarified direction contained in the DASN policy instructions.
*31 December 2015: Sampling at identified CONUS U.S. Navy installation locations is completed. *an extension for this completion by 30 days was authorized by policy 18 Dec 2015.
15 February 2016: Results from CONUS sampling due. 15 March 2016: Sampling in OCONUS to be completed. 15 May 2016: Results from OCONUS sampling due.
Communication goal: Inform stakeholders --in accordance with identified timelines --of water testing prior to, during and following completion of the testing.
Stakeholders: Primary - internal publics (all military and civilian employees of commands where testing will be done - both CONUS and OCONUS) and their families; Secondary external publics (i.e. outside installation fence-lines of relevant Navy installations, DON leadership, members of Congress and host nation partners, as appropriate).
US00004828
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
(Draft CNIC PAO)
PA Posture: Active
Objectives: Commit to and engage in consistent, timely and accurate updates on the testing before during and after testing with internal and external stakeholders. Maintain transparency with all stakeholders. Maximize the use of all communication tools available to reach internal and external publics. Ensure appropriate subject matter experts (SMEs) are available to support Q&A with stakeholders, including news media.
Key messages The health and well-being of personnel remains a top priority. Maintaining quality control of water testing plays an important role in base operations. The water-testing program is a comprehensive program conducted by subject matter experts and in accordance with guidance set forth by Navy leadership. o Testing drinking water is done on a [frequency] basis, and additional testing for other elements as directed. o Testing for PFCs is a new requirement directed by OPNAV N45 should EPA set new regulatory health standards for this particular emerging contaminant. Subject matter experts and media resources are available for personnel who have questions (insert link to water testing page on website; all base/region websites should link to the CNIC HQ waterpage; regions should include a page that lists what installations in their A OR are included in this particular testing cycle).
Statement: (if asked) In accordance with the Department o f the Navy's environmental programs, testing of drinking water will be conducted to identify baseline sampling at Navy installations world-wide that produce drinking waterfrom sources where perfluorinated chemicals are known or suspected to have been released within one mile up-gradient o f drinking water sources. For installations in the U.S., sampling is to be completed by 31 December and results reported by 15 February 2016. For locations overseas, sampling should be completed by 31 March 2015 and reported by 15 May 2016. Information about the testing will be shared with stakeholders throughout the entire process, informingpersonnel prior to, during and upon completion of the testing.
Talking points: We will be/are/ (have been) conducting sampling of drinking water at the direction of OPNAV N45. o As required by OPNAV N45, all Navy public water supplies in the United States that produce drinking water from on-installation sources where perfluorochemicals are known or suspected to have been released within approximately 1-mile up-gradient to the drinking water source must be sampled. We will keep personnel informed every step of the way informing them prior to the testing, during the testing and upon completion including details of the results.
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US00004829
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
(Draft CNIC PAO)
We will use a variety of resources to keep all stakeholders informed, including, but not limited to local base newspapers, social media, letters to residents (where applicable), All Hands calls, and meetings with community partners (as applicable).
Subject matter experts will be available to answer questions and provide information to those who may be interested, and will make available FAQs, which will be posted on our public website (insert weblink).
TACTICS
DATE
By 24 Dec.
W eek o f (TB D )
EVENT
D raft/approve Public A ffairs G uidance (PA G )
POC
CN IC PA O
D istribute P A G to region PA O s C reate and approve stakeholder letters and FA Q page Inform IN T E R N A L stakeholders o f testing (P R IO R to / during and after testing)
CNIC PAO C N IC PA O /N 4 (tem plate for regions/bases) C N IC /R egion/B ase leadership
W hen it has been determ ined that outside the fenceline te stin g is required, inform E X T E R N A L stakeholders o f testing (P R IO R to/during and after testing)
COM M UNICATING W ITH EXTERNAL PUBLICS
Base leadership with key influencers
NOTES
In coordination w ith N 4/B U M E D ; C N IC approves (share com pleted P A G w ith CH IN FO )
C oordination w ith B U M E D /N M C PH SM Es L eadership inform s staffs through social m edia, staff m eetings, A ll H ands calls, C hiefs m ess, com m unity leader engagem ents (in accordance w ith approved PAG)
L eadership inform s identified external com m unity stakeholders in accordance w ith the plans; invites m em bers to the base for Q & A w ith SM Es (T ow n H all forum option)
L eadership is highly encouraged to connect w ith local officials and key influencers w here im pact and attention w ill be placed from testin g B E F O R E the testing is to occur; a subject m atter expert should attend w ith leadership if com m unication is done in person and/or on a call w ith leadership if done by phone; key influencers in the com m unity affected by the testing should also be encouraged to attend a to w n hall forum , and be provided inform ation on the base w ebsite (i.e. F A Q s) as a p p ro p ria te
Public Affairs POCs: CNIC (lead): CAPT Wendy Snyder, wendv.snyder@navv.mil / (202) 685-0867 NAVFAC: Anthony Cooper, anthonv.cooper4@navv.mil / (202) 685-1423 BUMED: CAPT Dora Lockwood, dora.u.lockwood.mil@mail.mil / (703) 681-9069 Region/Installation (insert appropriate info)
3 US00004830
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
QUESTIONS and ANSWERS
(Draft CNIC PAO)
Q: Why is drinking water being tested? A: Testing for Perfluorinated compounds (PFCs) is being done in accordance with OPNAV policy direction. As required hy OPNAV N45 Policy signed on 14 SEP 15, all Navy Public Water Systems (PWS) in the United States that produce drinking water from on-installation sources where PFCs are known or suspected to have been released within approximately 1-mile up-gradient to the drinking water source must sample for PFOS/PFOA in finished drinking water.
Q: What is a PFC? A: Perfluorinated compounds (PFCs) include perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA). PFCs are man-made chemicals which are very stable and persistent in the environment and not absorbed well in soil, and therefore can migrate to groundwater.
Q: What are PFOS and PFOA? A: PFOS and PFOA are organic chemicals used in repellants for stains, water, oil, and grease. Commercial and consumer products containing or degrading to these compounds were first introduced in the 1950s. They have been used in a variety of products such as the fabric of upholstered furniture, carpets, nonstick cookware, floor wax, and the lining of microwave popcorn bags. Firefighting foams also contain these chemicals. Over time, both chemicals became widely distributed in the environment and have been detected in the blood of humans, wildlife, and fish.
Q: Are you working with the [insert locality; i.e. city, town, county, etc.] federal, state and/or local officials on this issue of PFOS/PFOA potentially in their drinking water? A: [Insert local information]
Q: Can I drink the water while the testing is taking place? A: [Insert local information following discussion with local medical SME]
Q: When will the testing begin? A: Sampling will take place at [location] and be completed hy [timeline]
Q: How long will the testing take? A: [Insert local information]
Q: How many locations are being tested? A: [Insert local information]
Q: Has the [insert locality; i.e. city, town, county, etc.] water been affected by PFOS/PFOA? A: [Insert local information]
Q: Can I continue to drink the public water?
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US00004831
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
(Draft CNIC PAO)
CHOOSE APPLICABLE ANSWER A.l: Yes. There was no PFOS or PFOA detected in drinking water testing results from samples collected at [insert location], therefore the water is considered safe for consumption and further testing is no longer required.
A.2: Yes. While PFOS and PFOA were detected in the drinking water testing results from samples collected at [insert location], the amounts detected were below the PHA, therefore the water is considered safe for consumption and further testing is no longer required.
A.3: No, testing results from samples collected at [insert location] had PFOS and/or PFOA levels exceeding the PHA health-based screening levels. Alternative drinking water (e.g. water that has been tested for PFCs and deemed safe for consumption) will be provided until levels are reduced below the PHAs. Note: It can 7 be assumed that bottled water has been tested. It does not have to meet all the SDWA standards as waterfrom a PWS does. FDA regulates bottled water as afood and cannot require certified lab testing or violation reporting. My understanding is that FDA does not require bottled water companies to disclose to consumers where the water camefrom, how it has been treated or what contaminants it contains. OCONUS VETCOM does approve bottled water companies.
Q: How long have I been exposed to PFOS and PFOA in my drinking water? A: There is no way to determine how long this chemical has been present in the water supply. The drinking water production wells, where PFOS and PFOA were detected at or above the PHAs, have been taken offline to prevent further exposure.
Q: What are the potential health effects from being exposed to PFOS and PFOA at levels above the PHA? A: More research is needed to determine the health effects of PFOS and PFOA on humans, but the most consistent findings from laboratory studies indicate elevated blood serum total cholesterol levels among exposed populations and some limited findings related to low infant birth weights. The Navy is testing for PFCs at all installations both in the United States and overseas where PFCs may have been used so corrective actions can be implemented if anything is found.
Q: What are Provisional Health Advisory Levels (PHAs)? A: In 2009, EPA issued provisional PHAs for PFOS and PFOA. The PHAs are intended to ensure protection of public health, with a margin of safety built-in, following ingestion of PFOS and PFOA in drinking water. The provisional PHA is 0.2 ppb for PFOS and 0.4 ppb for PFOA. While EPA continues its research on these chemicals, it's important to note that PHAs are conservative with a margin of safety to account for uncertainties related to toxicity and other sources of exposure.
Q: Do PFOS and PFOA cause cancer in humans? A: At this time, there is not enough information to determine if cancers and in humans are caused by PFOS and PFOA. Whether cancer studies in laboratory rodents are relevant for predicting human cancers is a current topic of debate in the scientific community. EPA's PHAs do not evaluate cancer as the effect of concern.
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US00004832
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
(Draft CNIC PAO)
Q: What can I do to protect my family? A: We do know that studies show that nearly all people have some level of PFCs in their blood, regardless of age. People may be exposed to PFCs through food, water, or from using certain commercial products such as non-stick cookware, and repellants for stains, water, oil, and grease. Simple steps that can help reduce your exposures to PFOS and PFOA in drinking water include:
a) Avoid ingesting (including drinking and cooking with) tap water contaminated with PFOS and PFOA above the provisional PHAs.
b) Check with your local water provider if you aren't sure about PFCs in the water supply. c) Discuss your health concerns with your health care provider. Please see the contacts
listed at the bottom of the page to answer questions.
Q: Can I prepare baby formula with water contaminated with PFOS/PFOA above the PHA? A: To reduce potential exposure to infants, caregivers should use pre-mixed baby formula or reconstitute formula using alternative water sources not containing PFOS and/or PFOA above the PHA.
Q: Should I be concerned about the other PFCs listed on the drinking water results? A: At this time, not much is known regarding the toxicity of the other PFCs. Most toxicity studies involving PFCs have focused on PFOS and PFOA.
Q: Can I use the drinking water to water my vegetable garden? A: From a health perspective, the ingestion of PFOS and PFOA in food and drinking water, above the provisional PHAs, are the primary exposure pathways of concern. As a prudent public health action for all produce regardless of source, vegetables and/or fruits should be washed thoroughly with water that is not contaminated with PHOS and PHOA prior to consumption.
Q: Can PFOS and PFOA be taken up by the roots of plants or vegetables grown using water containing PFCs and would the plants be safe to eat? A: While the evidence suggests that uptake is a possibility, there are too many variables, data gaps and uncertainties requiring further investigation to give a one size fits all answer.
Q: Can I use the drinking water for showering/ bathing? A: It is recommended that you consult Navy and Marine Corps Public Health Center before using the water for bathing if it has been determined that the PFC levels exceed the PHA.
Q: What Navy installations are potentially affected by PFOS and PFOA in the drinking water? A: [Insert local testing site(s)]
OFF-BASE SAMPLING
EPA'S UNREGULATED CONTAMINANT MONITORING RULE (UCMR)
Q: What is the Unregulated Contaminant Monitoring Rule (UCMR)?
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US00004833
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
(Draft CNIC PAO)
A: The EPA's UCMR program is used to collect data for selected contaminants, suspected to be present in drinking water, to determine how frequently and at what level they occur. These contaminants do not have health-based standards under the SDWA.
Q: How often does EPA look for new contaminants? A: Every five years, EPA develops a Contaminant Candidate List to evaluate new chemicals not currently tested for in public water systems. From this list and other sources of information, EPA identifies a smaller group of contaminants (30 or less) for monitoring. The next list of chemicals to be monitored under the UCMR is due in 2016. PFCs, including PFOS and PFOA, are part of the third list of contaminants to be investigated therefore it is referred to as UCMR3. Of the chemical contaminants, only six are PFCs and only two of the PFC's have provisional health advisory levels at this time (PFOS and PFOA).
Q: Do all water systems have to sample for UCMR contaminants? A: No. Only those public water systems serving more than 10,000 people are required to sample for UCMR contaminants. In addition, approximately 800 small water systems are randomly selected to be included in the sampling program. As required by OPNAV N45 Policy signed on 14 SEP 15, all Navy Public Water Systems (PWS) in the United States that produce drinking water from on installation sources where PFCs are known or suspected to have been released within approximately 1-mile up-gradient to the drinking water source must sample for PFOS/PFOA in finished drinking water. [Insert location] met this testing requirement condition.
Q: If PFCs are found in the drinking water, what then? CHOOSE APPLICABLE ANSWER A.l: While PFOS and PFOA were detected in the drinking water testing results from samples collected at [insert location], the amounts detected were below the PHA, therefore the water is considered safe for consumption and further testing is no longer required.
A.2: While detected at less than the U. S. Environmental Protection Agency Provisional Health Advisory (PHA), we have detected PFOA and/or PFOS at concentrations greater than 25% of the PHA. The Navy will continue to monitor the drinking water from [base drinking water facility] for a period of one year. All base personnel will be notified prior to future sample events and notified of the results.
A.3: Testing results from samples collected at [insert location] had PFOS and/or PFOA levels exceeding the PHA health-based screening levels. Alternative drinking water (e.g. bottled water or water that has been tested for PFCs and deemed safe for consumption) is being provided until levels are reduced below the PHAs.
Q: If I have concerns about PFCs or what this means to me, with whom should I consult? A: [Insert local health POCs]
ADDITIONAL INFORMATION For locations where testing is being conducted and to coordinate with the appropriate local SME contact: Dr. Paul Gillooly
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US00004834
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
Environmental Programs NMCPHC Paul.b.gillooly.civ@mail.mil Office: (757) 953-0664 Blackberry: (757) 274-5480
(Draft CNIC PAO)
Q. What installations throughout the Navy have used firefighting foam and have well water. A. Per EPA Unregulated Contaminant Monitoring Rule (UCMR) 3 requirements, Navy was required to sample at 19 installations within the United States. Navy policy further required sampling at installations where there was a known or suspected release of PFCs with a potential to impact drinking water sources. This equated to nine additional installations.
Q. What are thel9 installations within the United States? A. Nineteen U.S. systems were required to sample by EPA under UCMR3. None of these systems exceeded the Public Health Advisory (PHA) for PFOS and PFOA:
1. Joint Base Pearl Harbor-Hickam, Hawaii 2. Naval Support Activity (NSA) Andersen, Guam 3. Naval Support Activity (NSA) Norfolk Naval Shipyard, Virginia 4. Naval Station (NAVSTA) Norfolk, Virginia 5. Naval Station (NAVSTA) Great Lakes - Illinois 6. Joint Expeditionary Base (JEB) Little Creek Fort Story West, Virginia 7. Naval Support Activity (NSA) Crane, Indiana 8. NAWC-Air Detachment (AD) Patuxent River PAX --Maryland 9. Washington Navy Yard, DC 10. Naval Air Warfare Center Aircraft Division (NAWCAD) Patuxent River (Solomons),
Maryland 11. Naval Air Warfare Center Aircraft Division (NAWCAD) Patuxent River (Webster),
Maryland 12. Naval Base Kitsap - Bangor, Washington 13. Naval Base Kitsap - Bremerton, Washington 14. Naval Air Station (NAS) Whidbey Island, Washington 15. Naval Air Station (NAS) Jacksonville, Florida 16. Naval Air Station (NAS) Pensacola, Florida 17. Naval Station (NAVSTA) Mayport, Florida 18. Naval Air Station (NAS) Lemoore, California 19. Naval Construction Battalion Center (NCBC) Port Hueneme, California (a part of Naval
Base Ventura County (NBVC))
Q. Where can the results be found? The individual results can be found on EPAs website: http://www.epa.gov/dwucmr/occurrence-data-unregulated-contaminant-monitoring-rule
Q. What are the nine additional U.S. locations required to sample under Navy policy. A. Nine additional U.S. systems were required to sample under Navy policy. They are:
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US00004835
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
1. Navy Alternative Landing Facility (NALF) Fentress - VA 2. WMPSTA Earle Colts Neck - NJ (MSC Fire School) 3. NAVUNSEAWARCENDIV Keyport - WA 4. NAVSUPPACT MID-SOUTH - TN 5. NAS Kingsville (NALF Orange Grove) - TX 6. NAS Whiting Field, Milton - FL 7. NAS Whiting Field (NOLF Choctaw) Milton - FL 8. NCBC Gulfport - MS 9. NAA Culter - ME
(Draft CNIC PAO)
Q. Is the Navy testing water at the nine additional sites? A. Only NALF Fentress had PFC detected above the PHA in drinking water. Earle Colts Neck (MSC Fire School) had PFC detected in ground water monitoring wells associated with environmental restoration site, but not in the Navy drinking water supply.
Q. Is there any potential danger to public health? A. In 2009, EPA issued provisional PHAs for PFOS and PFOA. The PHAs are intended to ensure protection of public health. The provisional PHAs are 0.2 ppb for PFOS and 0.4 ppb for PFOA. PHAs are not regulatory standards like maximum contaminant levels (MCLs); they are interim values that are used to protect public health until enough information is available to develop MCLs. Navy is using the PHAs as a precautionary measure to protect public health.
Q. For each installation where there's testing, how many people are served by those wells? A. To date, the only location with PFC detection above the PHA serves 40 individuals; NALF Fentress. Those installation employees were immediately provided bottled water upon detections above the PHA.
Q. Is there a possibility that wells for the communities outside the bases, such as Fentress, could be contaminated and if so, where, and how is the Navy addressing that? A. The potential for contamination outside of the Fentress boundary, additional investigation is preceding off-base as described below: All off-base drinking water wells located within 0.5 mile of the potential PFC source area and in the direction of the groundwater flow away from the source area are being identified to be tested to document any off-site migration. Wells with the highest possibility of containing PFCs related to historical Navy operations will be sampled first. Additional wells may be sampled in the future if the results from this initial round of sampling indicate wells further away from the source may be impacted.
TEMPLATE LETTER - PFCs SAMPLING ANNOUNCEMENT Date
Dear [insert target audience] :
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US00004836
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
(Draft CNIC PAO)
The safety and health of our military and civilian personnel on this base are a top priority; and therefore, as Commanding Officer, I would like to inform you of plans to conduct some additional testing of our drinking water.
The Navy has proactively developed a requirement to sample the finished drinking water at [insert location] and other select installations for perfluorinated compounds (PFCs). PFCs are unregulated or "emerging" contaminants, which have no Safe Drinking Water Act regulatory standards or routine water quality testing requirements. PFCs are currently being studied by the U.S. Environmental Protection Agency (EPA) to determine if regulation is needed. Until a decision on regulating PFCs is made, the Navy has developed a policy to determine whether on-base drinking water contains PFC contamination at installations where there has been a nearby known or suspected release of PFCs to the environment. [Location] met this testing requirement condition because a commonly used fire-fighting foam, Aqueous Film-Forming Foam (AFFF), containing PFCs was released to the ground surface during training exercises in years past. AFFF containing PFCs is no longer used at [location].
Because the health and well-being of our personnel and surrounding communities is of primary importance to the Navy, this testing is being done out of an abundance of caution to determine if wells have been impacted by Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA), which are considered by the EPA to be emerging contaminants and were contained in the AFFF used at the site. The testing will help us determine if additional actions are needed to protect human health and the environment.
As explained above, there currently are no regulatory standards governing safe concentrations of PFCs in drinking water. However, the EPA has developed a Provisional Health Advisory (PHA) establishing health-based concentrations above which action should be taken to reduce exposure to certain PFCs, in particular PFOS and PFOA. These PHAs are very conservative values developed with a sufficient margin of safety included so that we would not reasonably expect health effects to occur. The EPA advisory language states, "The selection of children's exposure parameters will help to ensure that this Provisional Health Advisory is protective of sensitive populations potentially exposed." We will be comparing our sampling results to these PHAs to determine if any actions are needed.
As we proceed:
We will be testing the drinking water produced by the Navy-owned [local installation water system],
We will inform you of the results once testing is complete and we will keep you informed of any actions we are taking to minimize exposure to PFCs in drinking water.
If the results show exceedance of the PHAs, then the Navy will provide an alternate source of drinking water.
If you have any immediate concerns, please contact us at (telephone) or (email address). [Enter PAO and Medical SME contact information].
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US00004837
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
(Draft CNIC PAO)
We are committed to keeping you informed every step of the way as we complete the testing process at your facility.
Sincerely,
Name [Rank], United States Navy
(TEMPLATE LETTER - PFCs SAMPLING: NONDETECT - 25% of PHA) DATE:
Dear [insert target audience]:
The safety and health of our [location stakeholder group] at [location] are our top priority. In my earlier letter, I announced that we would be performing perfluorinated compound (PFC) sampling of the drinking water produced by the Navy-owned Water Treatment Plant at [location],
I am pleased to report that drinking water testing results for Perfluoroctanoic acid (PFOA) and Perfluoroctanoic sulfate (PFOS), which are PFCs associated with the historic use and releases of Aqueous Film-Forming Foam (AFFF) on the [location at installation], were not detected or were below the levels set by the U. S Environmental Protection Agency Provisional Health Advisory (PHA).
While PFCs are considered "emerging contaminants" for which there are no Safe Drinking Water Act (SDWA) regulatory standards, Navy policy requires this testing in an effort to ensure the safety and health of all our military and civilian personnel. Based upon the sampling results, no additional monitoring of drinking water is warranted at this time.
If you have any immediate concerns, please contact [Enter PAO contact information] at (telephone) or (email address).
Sincerely,
[Name] [Rank], United States Navy
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US00004838
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
Commanding Officer
(Draft CNIC PAO)
DATE:
(TEMPLATE LETTER - PFCs SAMPLING: ABOVE 25% OF PHA)
Dear [insert target audience]:
The safety and health of our [location stakeholder group] at [location] are our top priority. In my earlier letter, I announced that we would be performing perfluorinated compound (PFC) sampling of the drinking water produced by the Navy-owned Water Treatment Plant at [location].
By this letter, I am informing you of the testing results for Perfluoroctanoic acid (PFOA) and Perfluoroctanoic sulfate (PFOS), which are PFCs associated with the historic use and releases of Aqueous Film-Forming Foam (AFFF) on the [location at installation]. While detected below the actionable levels of concentration established by the U. S. Environmental Protection Agency Provisional Health Advisory, we have detected PFOA and/or PFOS in the water. The Navy will continue to monitor the drinking water from [base drinking water facility] for a period of one year. All base personnel will be notified prior to future sample events and notified of the results.
While PFCs are considered "emerging contaminants" for which there are no Safe Drinking Water Act (SDWA) regulatory standards, Navy policy requires this testing program in an effort to ensure the safety and health of all our military and civilian personnel.
If you have any immediate concerns, please contact [Enter PAO contact information] at (telephone) or (email address).
Sincerely,
[Name] [Rank], United States Navy Commanding Officer
(TEMPLATE LETTER - PFCs SAMPLING: ABOVE PHA) Date
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US00004839
PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
(Draft CNIC PAO)
Dear [insert target audience]:
The safety and health of [location stakeholder group] at [location] are our top priority. In my earlier letter, I announced that we would be performing perfluorinated compound (PFC) sampling of the drinking water produced by the [location].
By this letter, I am informing you of the results of the drinking water testing associated with the use and releases of Aqueous Film-Forming Foam (AFFF) on the [location name]. Of these results, X X parameter(s) tested higher than XX parts per billion (ppb) level of [enter PFOA or PFOS, or both as applicable], which is above the U. S. Environmental Protection Agency (EPA) Provisional Health Advisory (PHA), the health based concentrations above which action should be taken to reduce exposure to PFOA and PFOS. While EPA does not enforce PHA levels, in an abundance of caution, Navy policy requires taking action with additional testing and corrective measures if a PFC sample exceeds the PHA in Navy drinking water systems. As our first immediate response, we will be providing alternative drinking water (e.g. bottled water) until these levels can be reduced below the PHAs.
I know this issue will generate more questions than this letter can answer. As such, I invite you to attend an informational forum that I will host at the [enter location/date/time]. This will he an opportunity for you to speak with local medical and NAVFAC Environmental Program representatives to have your questions addressed and to voice your concerns.
Below is a link to the EPA Emerging Contaminants Fact Sheet - PFOS and PFOA - March 2014 - that provides some additional resources you may find informative:
http ://www2,epa. gov/sites/production/files/201404/documents/factsheet_contaminant_pfos_pfoa_march2014.pdf
If you have any health questions or concerns, I encourage you to contact your health care provider or our medical representative [enter local health care SME],
Rest assured that my team and I will work to find a way to address PFCs in drinking water, but in the interim we will continue to supply an alternate drinking water source. I am committed to the safety and health of all personnel using our facilities and will keep you updated on this issue.
Sincerely,
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PUBLIC AFFAIRS GUIDANCE (drinking water testing / PFCs) As of March 11, 2016
[Name] [Rank], United States Navy Commanding Officer
(Draft CNIC PAO)
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