Off-Base

The Military's Response to PFAS Contamination in Drinking Water

I last wrote about PFAS, or "Forever Chemicals" in drinking water in an October 2023 update, 'Forever chemicals' haven't gone away. That post contains an overview of PFAS and the regulatory history. You can catch up on all my previous PFAS posts here.

Now, as the anticipated release in the next few months of the new EPA Maximum Contaminant Levels for a number of PFAS compounds concentrates the minds of state and federal agencies, it's time for a progress report.

First, I'd like to say a word about sources. Alongside writing about these issues, I'm working on them. Doing so involves building relationships of trust with federal, state, and county agency staff, who are working hard on the public's behalf in what can be a challenging political environment and are not always free to speak on the record. Retaliation is a real thing. Some of my sources subscribe to this newsletter. They're not going to see their names in print here.

The assistance given to those drinking PFAS contaminated water is wildly inconsistent. One of the starkest divides is whether the source of the contamination is military or civilian, although there are further inconsistencies within each of those groups. We'll start in this post with a look at military facilities. The examples are from Washington State, but widely applicable. Washington's not a bad place to start. It's not so much that we're the canary in the coal mine, more that because of our number of small water systems and private wells, we have many more coal mines, and many more canaries.

Defensive

Military facilities have been major users of firefighting foam containing PFAS in training and practice following aircraft crashes and other accidents. Along with releases from manufacturing plants, firefighting foam is the origin of almost all PFAS contamination in drinking water, making the services major contaminators of drinking water around their bases.

There are a number of systemic issues with the military's PFAS response, the most glaring of which is the continued adherence to the 2016 EPA Lifetime Health Advisory (LHA) levels of 70 ppt--parts per trillion--of PFOS and PFOA, the two most problematic of the PFAS compounds, combined. They refuse to recognize Washington's lower State Action Levels of 10 ppt for PFOA and 15 ppt for PFOS, or to adequately prepare for the expected lower EPA Maximum Contaminant Levels of 4 ppt of either. Households testing above the LHA get bottled water and a pathway to a permanent solution. Those testing below do not.

A strong second place in the glaring issue stakes is the interaction with the public. Perhaps as a result of the post 9-11 hardening of military facilities, base personnel have less interaction with the surrounding community and can give the impression that they regard anything outside the facility, "off-base" in military parlance, as enemy territory. That lack of trust in the public is palpable and is, of course, reciprocated. It's present for example in public meetings of Restoration Advisory Boards (RABs) at contaminated sites, which are supposed to be military-community partnerships to facilitate communication about cleanup efforts. How this plays out varies with each service. Let's take a look at each one in turn.

Navy

I wrote in the October update that the Navy has done some good things around the facilities on Whidbey Island, including building a new treatment plant for the Town of Coupeville and working to connect more people to it, but the issues around PFAS limits and communication still apply, and I said as much in an interview with Department of Defense staff and contractors.

The Navy is expanding testing areas for drinking water wells around their facilities on the island and held a public Open House on February 1 to allow eligible well owners and water systems to sign up, as covered by the local paper. I attended. I was happy to learn that the new tests will be done using the current EPA test method, with detection limits low enough that retesting won't be needed to evaluate the results against the new limits. However, when I asked if wells originally tested with an older method that had much higher detection limits would be retested using the new method--there are many wells which tested below the LHAs, but could easily be above the new MCLs--the answer was a polite, but firm, no, not until the new limits become law.

The team that carried out the interviews about Navy communication last year was also present, incognito, at the Open House. Each team member separately came up to me, remembered my name, and thanked me for the clarity and forthrightness of my replies to the interview questions. Apparently they were getting similar answers from attendees at this and other RABs around the country, and are getting a good reception back at the Pentagon for some proposed changes. The team was warm to the possibility that I might attend the Fairchild Airforce Base RAB meeting and Open House the following week in Spokane and have an opportunity to compare notes.

Airforce

And so, I headed to Spokane last week. The West Plains, west of Spokane, lie partially between Fairchild Airforce Base and Spokane Airport, and both are contaminating drinking water. My friends at West Plains Water Coalition have done an outstanding job of rallying the community and bringing attention to this issue. Substack author

Timothy Connor

recently wrote about these folks in this post From Victims to Victories. Tim summarized his earlier posts on PFAS on the West Plains in this post from January, West Plains, 'forever chemicals'--to date.

The RAB meeting was in the afternoon, and had a large public presence. One positive I learned was that the Airforce, in contrast to the Navy, does appear to be offering quarterly retesting to residents whose wells had previously tested below the 70 ppt LHA, although I'm still awaiting confirmation.

RAB meetings are supposed to be venues for two-way communication between the military and community representatives. This one, however, like the meeting on Whidbey last year, was a presentation rather than a conversation, with both community and public comment curtailed by an artificially compressed timeframe. The facilitator treated comments from both community RAB members and the public abruptly and dismissively. An unnecessarily large number of Airforce personnel in dress uniform was interspersed with the public. In short, the atmosphere of mistrust between the Airforce and the public was even more palpable than between the Navy and the public in the RAB meeting at NAS Whidbey.

The DoD team was indeed there, and we had a chance to talk. They saw what I saw, and will be taking that message back to DC. They recognize that the communication that is happening now will be wholly inadequate as the scope of the problem balloons under the new EPA MCLs.

Army

Well, the Army makes the Airforce look good. The main Army base in Washington State is JBLM, Joint Base Lewis-McChord, comprised of the Airforce's McChord Field and the Army's Fort Lewis. This vast base has a total population of 210,000, making it the fourth largest military installation in the world. Firefighting foam used at the base has contaminated groundwater which supplies the cities of Dupont and Lakewood, as well as many smaller water systems and private wells. JBLM also runs the Yakima Training Center, where firefighting activities have contaminated wells in East Selah.

The Army's response has been woefully inadequate, while the communication style has bordered on hostile. State agencies have stepped up to pressure the Army to do more in East Selah. Under threat of an enforcement order from the Department of Ecology, the Army is now installing whole house filtration systems in homes on private wells. Under new county commissioners, the Yakima Health District has finally stepped up to take some responsibility for Group B water systems serving up to 15 connections, and the state Department of Health has offered free livestock testing.

The Army has so far refused to establish a RAB at either Yakima Training Center or JBLM. This may be a consequence of the joint nature of JBLM, with finger-pointing between the Army and Airforce. The DoD team is aware of the gap and is working on it.

What next?

It's taken relentless pressure from community groups and agency staff to achieve the results seen so far. Issues still exist, but I'm hopeful that the new regulatory limits and a focus on improved communication will bring safe drinking water to those affected by PFAS contamination from military installations, whether they're on a large water system or a private well.

Despite all the problems, these folks are better off than those whose PFAS contamination comes from a civilian source. We'll dive into that in the next post.

Thanks, as always, for reading or listening. Please share this post with anyone you feel might enjoy it.