Document YjgewYEvpnZJLJ9YrE6dEjzZK

Department of the Navy (DON) Perfluorinated Compounds (PFCsVPer and Polyfluoralkyl Substances (PFAS) Comprehensive Strategy Road Man Version 2, 3 May 2016 BLUF: Perfluorinated cGompounds (PFCsVper and polyfluoralkyl substances (PFASs) are a (suite of over 100 chemicals, several of which are (of emerging public health concern to the Department of the Navy (DON). U.S. Environmental Protection Agency (EPA), state regulators, public water systems, and the general public, primarily in drinking water systems. The_termPFC will be used throughout this strategy, as a surrogate tor PFCs and PFASs. This strategy addresses PFCs in hi oil ni 'l' i lii' hi nl n ' ih i imi inn the environmental restoration program (on and off installation), mil hi' acquisition, firefighting, and facilities management | m> i,un . DON policies, positions, and messages are aligned throughout the Department and with the Office of the Secretary of Defense. [Communications!: Need 1: DONreposrtory ofh orninuiiji ation phiiMandsupportiiig Fi qu mil I dMu I ni (I-AQsi, Qi' m l ni Mid n 'i 'it i, fact sheets, i1 < Dull I llDui luul ip M i malia a j on i outreach materral (tntemal and external [> it u utin ill d Pi ii >nil it ii jEPAi and ' ii' l u l l ' nil I ir Mill) I' i u ATSDRjj). We need to be accurate, consrstent, transparent, and efficrent. [Where to store tilts into7] Who maintains? Who has access? Need 2: Standardized chain of command review/approval lines for media and congressional inquiriesTCfODED-FeqHests^jmd leadership brieflngs/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: Memo 6280 Ser M3B7/15UM30462, Testing for Perfluorochemicals Perfluorinated Compounds (PFCs) in Drinking Water, 24DEC15 DoDIs 4715.06, 4715.07 and 4715.18, DoDM 4715.20 _[Air Force SAF[TEE: [AFFF [Disposal and Replacement - Crash Response Vehicles, 9MAR16 M....II]ii=14:i2il:iQi!LflAirerafLM - Comment [LN i]: 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 states identify for DSMOA QC samples. It i depends on disposal of Ircalcd water. IClc. 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 include recommendations regarding property transfer \ issues as well. ? Response: IM'C s are just one more contaminant v ?-u-n-d-e-r-D-L-R--P-s-o-t-he1-r-e-is--n-o-th-i-n-g-n-e-w-h-e-r-e.-----Comment [CJMCNAE3]: Recommend keeping a spreadsheet that includes: Date o f inquiry, name of person inquiring, affiliation of person inquiring, recipient of inquiry, date o f response. 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 ^ 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 Em 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 V_a_s _an_o_th_er_r_e_fe_re_nc_e_. ________________ US00005352 .MairiteraneeJInspeA^^ Protection Systems NFPa. 41z Standard For 1Evaluating Aircraft Rescue and Fire-Fighting Foam 1Equipment, ..... 2014............................................... .............................................. ........ ................'...'........... ENawDON [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 Health Advisory (PHA) levels for perfluorooctanoic acid (PFOA) or perfliiorooetane sulfonate fPFOS). Four other PPCs were also tested under the UCMR. however, there are no PHA levels or other criteria for these PPCs. DASN(E) policy required testing at [additional locations [in the U.S. if there was a known or suspected release of PFCs within 0 ................ I a mile upgradient of the drinking water [source-waterj. Navy sampled 40-1 1installations, with Naval Auxiliary Landing Field (NALF) Fentress, which serves approximately 50 people, in Chesapeake, VA as the only installation with an exceedance of the PHA. USMC sampled one installation with no PHA exceedances. DASN(E) policy also required testing at all overseas locations. USMC completed testing at four locations with no PHA exceedances. Navy sampling is_underway. All compiled sample results expected by May 2016. _ D O N policy is to utilize the PHA 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 PHA is exceeded. When/if final health advisory (HA) values or Safe Drinking Water Act (SDWA) regulatory standards (e.g. maximum contaminant levels (MCLs)) are established, these will replace the PHAs asPHA action levels. DON will is_also i 111,1111 iii" with any State standards that are properly promulgated and used within consistently across the |Statej pin umiiuilu ' i ib fti ft w ft ft ft'i ft mill uI uiift' i Hi' iiJ Wa (e.g.. PFNA in NEC 1 I M 1, |l ' 11 111Hu 1 II ' I I " I H 11 11 A M l I ' Ip ' l 11-II 111Hi I ' '111 ll p p n i I li Mil ||> !l' i I I < ) i 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) wfiTrequested frim-i-Navy and USMC provide a list of installations under the following categories by 31 May: o DON owned water system sampled under UCMR o DON owned water system (including overseas) sampled under DON policy o...DON purchased water from off installation where public water system (PWS) sampled under UCMR o DON owned water system not sampledJnqryrubluLwaler^ystems^^yateLsy^enis 11il [11' I I III' pi ftiC ' Cl'iI' rein Comment [SRGCNME11]: Recommend that "source water" be changed to "Water supply source (e.g. lakes, reservoirs, wells) " Response: Edited to match DASN(E) policy. Comment [MSACCN12]: Has this policy been properly 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. US00005353 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) plans to issue the directionis developing/implementing the 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 1 sites. With respect to remote crash sites, many of 1 these self-extinguish prior to responders arriving on i scene. For hangar system releases, AFFF is often i not contained because hangar doors are left open. 1 Response: Gunarti, please track this down and j incorporate into process as appropriate. process belowJfnqredetaihijnjnsMedjlqwchart) to efficiently eemplete-identify* validate, and prioritize a comprehensive DERP Site and Area of concern (AOC) inventory of potential release sites across DON. N u l l V, lule not i ou-red I/) D1 RP rR I n H m)_if fromiH+te-dreijiiired >1 ' u ' i (' Comment [LN14]: 5090. ID does not currently i require reporting of AFFF spills - We may want to 1 consider changing Chapter 39 to require spill 1 i reporting (using the message format) which would i 1 be tracked in NOSC Net. i j Response: Concur. n I ill H si nn+4\\onld need to lie i uiiilm h il a) iiind ill ' ' In I ) 4 ) In hm I ni i j Comment [LN15]: NAVFAC Washington: It is I I >i mil - ii11h 1 - I - n l i, n ni n <1He I ui pi i T 4 I 1J 4 J I < ul I n i nun' nl il 1 iin][ni' nl pm n ml I i H 4 'I I 1<i 1 ( noted below that "preliminary assessments [are] ! i costly and time consuming" and instead "DASN(E) i 1 i will disseminate the existing lists o f DERP sites and NOTE: OSD responded to a reporter's question andin December 2015released a list of 664 fire or crash training sites (DERP sites identified in KBCRS database) throughout 1! i PFC release categories to CNIC and USMC who will | i 1 conduct facility-wide reviews to identify additional , i ( potential DERP sites to "assess"", DoD. This list was compiled by searching for certain terms (e.g., fire training) without any verification of site status/applieability. Of the 664 sites, 143 are identified as DON i 1 i Are these not essentially PAs? And if so, wouldn't it , 1 behoove the Navy to conduct the investigations as i j PAs such that our regulatory partners are satisfied 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. 1 ( that our "facility-wide reviews" are truly I / comprehensive? i 1 With the same considerations in mind, for those sites DON is identifying existing DERP sites/AOCs. validating them as potential PFC sites. filling data gaps, and prioritizing further actions in a risk based, approach. Until a ( that the "facility-wide review" recommends further i investigation, shouldn't follow-on sampling be i conducted as an SI (or at least follow SI guidance) validated list of sites is determined, the site counts will not be included in this strategy or other documentation. The attached flowchart,outlines in detail and, with schedule 1 and have a UFP-SAP? ( Presumably for those sites that have now been i sampled (as part of an SI or not) and have been milestones, the process being implemented by DASN (E). NAVFAC (ER.N and. BRACT <1 identified as having PFCs in environmental media, new sites should be opened in NORM at Phase 2. CMC, and. USMC. The major steps include: ) And, regardless of what process was used in the past o Key word, search of existing databases to generate initial list of potent ial -where PFC DERI' Sites/AOCs. niay4iayM3eennas-ed/FMdnMeas-edv ji (PA/SI or other), the next phase would be an RI, which would follow CERCLA guidance like any 11 other ER site. Is that the case? o Validate initial list. 11 Response: Addressed in flowchart and business rules. o Provide validated, list and potential PFC release mechanisms to CNICand USMC (' to fill site/AOC gaps, in coordination with NAVFAC RPMs. j< e--Need to further identify additional known or suspected releases of PFCs on active j > 4HsteHatieH-aH4BRAG4eeatieHs|^-Siee-6eHdtjetiHg-GERtA^FdiHiHiary j! assessHieHis4s-eesily-ftHd-tHHe-eessfflHigr|BASN(E)-wiH-be49sHig-lieeiieH4e quickly and cost effectively identify all (- 95-99% solution) known or suspected I PFG^elase-sifesMMSN(E)-wilWisseHHHafe-the-eKisffflg4isto-eBERP-sifes-afil , reviey^skeNdeHtifVMtdditi^mkpefeHtidrTDINkPMfeskeMtssessNlPrioritize sites J' based, on risk to drinking water/receptors. 1 o Prioritization--a All known or suspected PFC release sites will need to be i assessed to determine whether they require further DERP response actions. |The i number one objective is to identify sites with likely/potential direct exposure i via DON-caused contamination reaching public or private drinking water supplies so that the unacceptable exposure can be eliminated. [ , Flowchart: ( Formatted: Font: Bold, Underline US00005354 "J 16-05-03 PFC DERP |Slte and A0C Flowch'Oju -rt 1-f4 o-t Hrti-nti-rtl frti'-'f ^ kno-wn [tin- fi>tb>vnu.< prioriti/alion hn*f * < - h v - s h < m W - e r f + 4 site-SfH-^tk >+/ HHWtriJU "f e --(Eask-kistellafieF^feaH-yeBiyytsew-eF-saspeeleit-PFG-Felease-sitesIr-deieiHHe !0oe -04itelry^pxw fikateF#ew -H ;eefie7-afil4eafify^pet^^ exposure pathways (e.g., public or private drinking water wells) within apprexiamtolrY-T-fflTe-d6WB-ia!ayr8Bfr--[lT4fa<HBB^^ 77 afpx>p4ateAtsfeS'ea^ ar-~fa~e*WRfewi^ ^ effipeifrfiea~fifid~4eigaatoHirVXHy^btrt-fiffii^^ Biaflagerr^a4esx^Hte4rraaek m efeies4 iIk 4 "Fegteter)T4isea>xpSH pa4krtfiy`kdrifMyw84ef"9eaK r'SteH 4e~w ^ feresbeM s-fer& r-RH A 4wri^M diM Bafi^fae"ex p ^ ^ aJ4raa4sve~water)r Formatted: Indent: Left: 0.5", No bullets or numbering Field Code Changed Comment [SRGCNME17]: It 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, but not in this strategy. Comment [LN18]: NAVFAC Washington: It does not say 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. t4iriaed<W )4H~eeiiifieH~wtfth#M M Teai^>4ea~iet~ea^^ te-eefiifretep-aKX *-- GHdw8TeiHles|pMiiefi")ri}rgr~bea-eMaf~^^ -----P rep erty x m srersb ip ^ ^ ^ g rriX ^ am sre-er^^ ---- PeteetkJ-expesBFe-patkways-etkeF-tbaa-elHBkiag-watef *-- F^RAGr4ime&6HfrBf-6Hti^ate^rtHfe^eperty4fftHsiefs *-- IfetefffiaTfeM friep-peteHfr^^ [Completion of all [DERP response actions [will be a multi-year process similar to any other contaminated sitej. Formatted: Font: +Body (Times New Roman), 7 1 11 pt, Not Bold, No underline Comment [SRGCNME19]: Regulators as asking t ' 7 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. / x Funding: ___ ___ ___ ____ -*\ Conduct all investigations, removal, and remedial |actions| using ER,N or BRAC flmding. y \ \ . Address all ^>ff-installation contaminant migration], including provision of alternative water, where appropriate, using ER,N or BRAC flmding. . 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. N ^Formatted: Normal, No bullets or numbering j Formatted: Font: (Default) Times New Roman, 12 pt 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 ] ( Formatted_______ 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 arf [~3 ~| 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 Comment [SRGCNME23]: Midlant is currently planning to use our CNIC N4 utilities account as the funding source at Fentress Response: thanks. Comment [LN24]: EXWC Tech Review was completed in Feb 2016. Document will be forwarded under separate cover. Response: thanks. US00005355  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/s policy feeejBmerals-BefHsampfiafrfaivittuafe-kieeris: o Healthcare providers should perform routine diagnostic or screening tests as medically indicated, based on their patients' history, physical examination, and assessment, and not based on PFOS/PFOA levels. o_Blood testing for PFOS/PFOA is not medically necessary. 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.should person's living and, working environment, and, that health studies have not consistently found, any specific health effects from exposure to PFCs. AlsoJhatthere_arejiojnedica]]y_agprovedPTreatments/l^oiiethqds_tojemqve PFCs from a person's body other than to decrease total exposure and, allow the levels to decrease through natural elimination. 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. US00005356 _ATSDR has guidance on health studies, but does not make definitive recommendations or poliu statements regarding tlte capabilities and limitations of such studies. Here is some of their materi alWiH-wa TT ATSDR ATSDR toxguide.pdf ATSDR ToxFAQ.pdf ATSDR Public Health ATSDR Blood PFC pfcs_fact_sheet.pdf Statement, August 2(Testlng and Health In ^feed-te-develepHarWHiied-BQNj/BeB-pesifieHT-ptaiirSiaieHieatreieT-te-addFess-itiis a-iattervDON is working with OSD and the Pol) Components to address these concerns. OSD is initiating discussions with ATSDR. More to foltow._ 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 friture 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 ASNtFI1 f FIE) 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. Require assessment of the availability of PPOA/PPOS-free AFFF products on QPL- 24385. DON policy will be needed to define PPOA/PPOS-free. Identify/secure funding and rRequire replacement and proper disposal of all AFFF containing ^FOA or PFOS|, as follows: o All partial and full containers of material onjnstaUations_within 6 months and from ships within 1.2 months o All mobile firefighting anderash-respenseainn^if jidjiredlghting 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 properly maintained and operated within 36 months - -f Formatted: Normal, No bullets or numbering J t Field Code Changed J : Field Code Changed [ Field Code Changed J i Field Code Changed J Field Code Changed ' Formatted: Font: (Default) Times New Roman, 12 pt____________________________ ^(FonTiatti^ ] "(Fonriatti^ ) Comment [WKCNMC26]: Is iliis ;i nTM 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. US00005357 o All shipboard systems during next availability, but no later than 60-72 month (Analyzejiew_C^Jj!P!LC=8j)rMeetsjsPA^2M5_Guidancej^PEFJpnnuMii!QsJprothCT n i.s 01 eoneern.i 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], -ReqtHFe-tke-deelepHieai-eaii-eHie{geHe-fespeHse-ptei-(FeeieH/HisiailaiieH)-ifeai-effli4je *`uHv> ted on bane jh-whuhT Plan 4tall have an a n tfi>w44nndnu.> vi* eo rdentdi-ed |Require_a]Jjie^purhaseJireilghting_andrashj5sponsejyehiks_an4^ips_wdth_AF^ C8,, or Meets EPA. 201.5 Guidance A.FFF..1 Continue R&D on Pl-C-lree AFFF. Comment [mrp29]: All o f the remaining requirements, with the exception of R&D on PFCffee 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 US00005358 Page 4: [1] Comment [LN20] Lindsay Nehm 5/3/2016 10:19:00 AM 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. US00005359