Defense Department officials testified about research efforts to replace PFAS, which is used in aqueous film-forming foam, or AFFF, and is very effective in extinguishing aircraft fuel fires. They also discussed cleanup efforts in areas contaminated with PFAS.
Maureen Sullivan, Assistant Deputy Secretary of Defense for the Environment; and Herbert Nelson, Director of the Strategic Environmental Research and Development Program and the Environmental Security Technology Certification Program, testified at the House Armed Services Committee Preparatory Subcommittee hearing.
PFAS refers to the entire class of perfluorinated and polyfluorinated alkyl substances, of which perfluorooctane sulfonate, or PFOS, and perfluorooctanic acid, or PFOA, are the most studied substances. These substances are also present in many industrial and consumer products because they increase a product’s resistance to heat, stains, water and grease.
On May 19, 2016, the Environmental Protection Agency issued Lifetime Health Advisories under the Safe Drinking Water Act and recommended action for drinking water systems containing individual or combined levels of PFOS and PFOA greater than 70 parts per trillion.
Sullivan said DOD is leading the way in combating these substances. Over the past four years, the ministry has committed substantial resources and taken steps to address concerns about PFAS.
In July 2019, the PFAS Working Group was established to ensure a “coordinated, aggressive and holistic approach to department-wide efforts to proactively address PFAS,” she said.
The federal cleanup act, known as the Comprehensive Environmental Response, Compensation and Liability Act of 1980, provides a consistent approach across the country to cleanup, which the DOD adheres to, Sullivan said.
The department prioritizes action sites using CERCLA risk-based processes to address sites that pose a greater potential risk to human health and the environment, she said. These sites are in various stages of investigation, assessment and clean-up.
There are currently around 200 airports across the department, which primarily use the AFFF, Sullivan said, noting that some of these airports are operated in conjunction with commercial aviation. The department is partnering with the Federal Aviation Administration to ensure that these airports maintain the current level of protection for passengers, crew and equipment.
“The priority of DOD is to quickly treat PFOS and PFOA in drinking water above the EPA lifetime health notice, where DOD is the known source,” she said. .
To prevent further releases to the environment, the DOD limits the use of AFFF to emergency event responses and it is no longer used for testing and ground training, she said. . In addition, the ministry treats each release of AFFF as a response to a chemical spill.
The current AFFF used by the department contains PFAS, but no more than 800 parts per billion, she said.
Unfortunately, none of the commercially available PFAS-free foams meet DOD’s stringent safety standards for quickly putting out fires, she said, adding that in addition to quickly extinguishing aircraft fires, the foams with PFAS are particularly effective in extinguishing large industrial or structural fires and overturned burning vehicles.
Nelson said DOD is researching the development of PFAS-free foams that meet DOD safety requirements, as well as the evaluation of any new commercial foam. He noted that the research is a collaborative effort that includes DOD’s own laboratories, other federal agencies, industry and universities.
The SERDP launched research shortly after the EPA released its 2009 interim health advisories for PFOS and PFOA, he said.
This research can be categorized into four parts, he said:
- Sampling and analysis;
- Understand how PFASs move and decompose in the environment in order to predict which sites may be of more likely concern;
- Understand how PFAS affects wildlife such as fish and birds; and
- Remedy sites impacted by PFAS.
When it comes to AFFF, there is also a four-pronged research effort, he said:
- Develop effective foams without PFAS;
- Demonstrate the performance of developed and commercially available foams in large scale trials;
- Study the ecotoxicology of any replacement compound; and
- Research into strategies for cleaning up firefighting equipment contaminated with AFFF.