JOINT BASE SAN ANTONIO-LACKLAND, Texas –
Armed with data from nearly 10 years of investigation and response to per- and polyfluoroalkyl substance, or PFAS, releases at its installations, the Department of the Air Force is rolling new regulatory standards into its ongoing plan to address PFAS risks.
“The key here is that we have a plan, and we will implement it,” said Jenni Dorsey-Spitz, an environmental technical advisor to the Deputy Assistant Secretary of the Air Force for Installations, Energy, and Environment. “We aren’t starting from scratch. The Department of the Air Force, without a regulatory standard, leaned forward to start addressing PFAS and we will continue leaning forward with the new standard.”
To date, DAF has spent more than $2.2 billion to identify and mitigate PFAS.
The Environmental Protection Agency finalized two rules in April to classify certain PFAS compounds as hazardous substances and formally establish drinking water standards, known as maximum contaminant levels for six PFAS compounds, including levels of four parts per trillion for PFOS and PFOA, two of the common PFAS chemicals found in aqueous film forming foam, or AFFF, previously used by the military services and civilian aviation to control petroleum fires.
Speaking at an Air Force Civil Engineer Center-sponsored environmental restoration summit between DAF environmental experts and state and federal regulators in early May, Dorsey-Spitz said the established levels will help the DAF support its ability to detect and treat PFAS by finally having standards for clean-up.
“The MCL provides clear guidance on what the regulatory community considers a reasonable standard for assessing risk to human health,” she said.
Since 2015, the DAF has conducted preliminary assessments and site inspections at 204 installations to determine whether AFFF may have been used or released into the environment. Of those, 191 had confirmed releases of PFAS. The DAF proactively took action to mitigate risk to human health by providing alternate drinking water to impacted private well owners, funding water purveyors to install filtration systems, and taking interim response actions such as installing pump and treat systems to prevent further migration of PFAS in groundwater.
AFCEC, a primary subordinate unit of the Air Force Installation and Mission Support Center at Joint Base San Antonio-Lackland, is leading the response effort under the Comprehensive Environmental Response, Compensation, and Liability Act to identify and mitigate PFAS impacts in the environment.
The new standards could mean more sampling of off-base drinking water supplies, Dorsey-Spitz said. Data from AFCEC’s remedial investigations will help environmental project managers revise plume maps and identify drinking water sources that could be affected by PFAS at lower levels than previous sampling efforts. If the DAF identifies drinking water wells with PFAS above the action level and attributable to DOD mission activities, it may implement a response action such as connecting the residence to municipal water supply or installing filtration systems.
The DAF will also conduct quarterly sampling and replace ion exchange or Granular Activated Carbon, or GAC, systems as needed to guarantee that delivered water remains below action levels.
“There’s a lot of technical work that goes on behind the scenes to make sure we have sufficient data and ensure what we put in the ground is actually going to be successful,” said Dr. Shannon Garcia, AFCEC Risk Assessment subject matter expert.
The Department is also looking at other possible sources of PFAS beyond AFFF releases by systematically evaluating non-AFFF sources of PFAS at active Air Force, Air National Guard, and Space Force bases and installations closed under Base Realignment and Closure action. The DAF is working with DOD to prioritize cleanup at locations that pose the greatest risk to human health and will continue to accelerate cleanup efforts in partnership with regulatory agencies and affected communities.
“DAF continues to make great progress in executing the CERCLA process, while at the same time taking appropriate interim response actions to mitigate risk while concurrently exploring the application of new PFAS (remediation) technologies,” said Dr. Mahalingam Ravichandran, AFCEC PFAS Integration Executive.
To date, DOD has invested more than $300 million to advance technologies to expedite PFAS cleanup and to test and develop fluorine-free foams. Part of this PFAS innovation involves the removal of PFAS-containing firefighting foams from the DOD inventory and replacing them with fluorine-free foams or water-only systems. The DAF is also hosting 55 technology demonstrations at 28 installations as part of its collaboration with DOD to develop and field innovative technologies to treat PFAS in soil, water and AFFF concentrate.