Document v14D1KqoGkK9LVxoQ1m5ZqQMm

USMC Perfluorinated Compound (PFC) Status August 2016 US00005059 Background Perfluorinated Compounds (PFCs) - A family of chemicals used in many commercial products. - Primary DoD use is in MILSPEC Aqueous Film Forming Foam (AFFF) for firefighting. - Has been found as a contaminant in drinking water wells and groundwater at DoD installations and in civilian communities.. PFC Health Advisories (HAs): - Not regulatory standards, but can be used to make drinking water and cleanup decisions - In May 2016, the Environmental Protection Agency significantly lowered HAs for the PFCs perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA). Increasing Congressional, media, and public interest/concern. To date, no USMC exceedances of PFC HAs identified. 2 US00005060 Policy Memos Drinking Water (MCICOM GF-5 Lead): - Testing DoD Drinking Water for Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA), June 10, 2016, ASD(EI&E). - Perfluorinated Compounds (PFCs) Drinking Water System Testing Requirement, June 14, 2016, DASN(E). Cleanup (MCICOM GF-5 Lead): - Perfluorinated Compounds/Perfluoroalkyl Substances (PFC/PFAS) - Identification of Potential Areas of Concern (AOCs), June 20, 2016, DASN(E). Operational Management and Use (? Lead): - Aqueous Film Forming Foam (AFFF) Control, Removal, and Disposal, June 17, 2016, DASN(E). 3 US00005061 Drinking Water - Sampling Requirement: - Sample finished drinking water for PFCs on all installations by 15 Nov 2016 where sampling has not previously been completed. - Sample results must be provided by 31 Dec 2016. Actions Completed to Date: - Reviewed results from sampling under Unregulated Contaminated Monitoring Rule 3 and previous DON policy (21 Oct 2014). - Information gathered on the additional systems required to be sampled under the recent policies. Planned Actions: - Installations to sample no later than 15 Nov 2016; installations to submit requests to MCICOM if funding required. - Installations acquire written confirmation from the provider that an effluent sample was collected from all treatment plants and/or wells that provide water to the installations Challenges to Implementation: - Potential FY16/FY17 funding challenges for sampling by deadline. 4 US00005062 Drinking Water - Detections Requirement: - If samples exceed EPA HA (70 parts per trillion combined for PFOA / PFOS), immediately secure the affected system and/or provide alternative water; promptly notify MCICOM, consumers, and state drinking water officials, as appropriate. Actions Completed to Date: - Reviewed results from previous sampling events to determine if action required. - No samples exceeded EPA HA Planned Actions: - Review upcoming additional sample analysis results - Take action as necessary based on analysis results Challenges to Full Implementation: - Determining affected consumers to be notified, if necessary - Providing alternative water, if necessary 5 US00005063 Drinking Water - Monitoring Requirement: - If sample results exceed the Method Reporting Limit (MRL) but are below the HA, installations must institute a quarterly monitoring program to ensure the levels remain below the HA level Actions Completed to Date: - Reviewed results from previous sampling events to determine if action required - One installation has detections above MRL, but below HA - MCB Camp Pendleton Planned Actions: - Review additional analysis results - Determine actions required for applicable installations Challenges to Full Implementation: - Locating the source of contamination and potentially isolating the source. 6 US00005064 Cleanup - Potential Areas of _____ Concern (AOCs)_____ Requirement: - DON to identify, prioritize, and evaluate locations where PFCs may have been released to the environment. - USMC to validate areas of concern (AOCs) - Identify any additional locations and provide those to the Navy for inclusion in the list of sites. Actions Completed to Date: - Data provided to DON in July/August 2016. Planned Actions: - No further action required. Challenges to Full Implementation: - None. 7 US00005065 Operational Management and Use AFFF Release Prevention Requirement: - Immediately cease uncontrolled environmental release of AFFF at USMC installations except for emergency responses. - Verify and ensure that appropriate controls are in place to prevent an environmental release. Actions Completed to Date: - DLA no longer distributes AFFF containing PFOS from active inventory. - Advised Fire Chiefs and ARFF OICs to cease testing and training fires that utilize AFFF. Planned Actions: - LP develops strategy so AFFF containing PFOS can no longer be purchased - Conduct inventory of current AFFF stocks. - Coordinate with DLA on Qualified Products List (QPL) for AFFF containing PFOA and other PFCs. Challenges to Full Implementation: - System improvements to facilities (i.e. hangars) with AFFF systems and no containment. 8 US00005066 Operational Management and Use Firefighting System Requirements Requirement: - Update and implement USMC firefighting system requirements, as needed, to ensure fire and emergency service vehicles and equipment are tested and certified to prevent AFFF releases. Actions Completed to Date: - Advised Fire Chiefs and ARFF OICs to develop/enforce SoPs that minimize AFFF contamination to the environment except for firefighting operations or where the AFFF can be contained. Planned Actions: - Investigate and procure foam testing equipment for vehicles that does not utilize foam or contains the foam in a closed system. - Investigate using less toxic AFFF where feasible. Challenges to Full Implementation: - Funding for new equipment and replacement of existing AFFF 9 US00005067 Operational Management and ______ Use - Disposal______ Requirement: - By the end of FY17, remove and dispose of uninstalled PFOScontaining AFFF in drums and cans from local stored supplies. Actions Completed to Date: - Advised Fire Chiefs to restrict usage of PFOS containing foam in drums and cans. Planned Actions: - Conduct inventory of current AFFF stocks to determine scope of AFFF issue. Challenges to Full Implementation: - Funding for AFFF disposal and replacement depending upon the amount required. 10 US00005068 US00005069 PFC Testing Conducted to Date Unregulated Contaminant Monitoring Rule 3 (UCMR 3) - EPA regulation that required large water systems (over 10,000 population) and certain smaller systems to test for 21 chemicals, including PFCs - Used to gather information to determine which contaminants potentially need future regulations. Deadline for testing: 31 Dec 2015 Department of the Navy PFC policy: - In addition to following UCMR 3, requires DON installations to test for PFCs where there is an identified or suspected PFC release upgradient and within approximately 1-mile of the drinking water source and at all overseas installations. Results to date: No USMC exceedances of PFC HAs identified. 12 US00005070 Aqueous Film-Forming Foam __________(AFFF)__________ A Qualified Product List (QPL) contains AFFF that are approved for use by Services (these products may still contain PFOA) - All AFFF containing PFOS has been removed from QPL; however, could still remain in inventory The AFFF manufactured by 3M prior to 2002 contained PFOS and is no longer available for purchase - GF-5 working with LP and DLA to ensure Marine Corps can no longer purchase and DLA no longer distributes from active inventory (recommend installations update AULs) QPL number for the MILSPEC foam is QPL-24385; National Stock Number for AFFF Concentrate is 4210-01-589-7074; DLA has performed stock screening of inventory at all DLA Depots to ensure that only QPL certified material is available for issue. The following NSNs are on the MIL-F-24385F QPL for 3% and 6% AFFF: 4210-01-139-4972, 4210-01-144-0291,4210-01-056 8343, 4210-01-056-0883 NAVSEA and Naval Research Lab are currently testing AFFF on QPL to determine levels of PFOA and try to identify most environmentally friendly - Testing is anticipated to be completed by end of first week in August - Once testing in complete, all Services will be brought in to assist in identifying a viable substitution US00005071