Updates & timeline for military bases contaminated with PFAS

According to a report from the Department of Defense and analysis from the Environmental Working Group, over 600,000 U.S. troops may have been exposed to PFAS on military bases. Exposure to these chemicals has a strong association with cancer, might cause harm to fetal development, and could reduce the effectiveness of vaccines.

The Department of Defense study found PFAS at 70 parts per trillion or more at 24 military bases across the country. Currently, there are 400 U.S. military installations in the states and overseas with known PFAS contamination and over 300 with suspected contamination.

Mark Favors, a nurse and activist who is originally from Colorado Springs, has seen many family members, including his grandmother, pass away from cancer. He believes her disease was caused by PFAS exposure from the nearby Peterson Air Force Base. Nevertheless, since trying to hold the Department of Defense accountable can be formidable due to a myriad of legal limitations, the man could not obtain justice in his case.

Some of the Favors' living relatives have signed on to multidistrict litigation against the companies that produced PFAS. However, he said that the legal difficulties associated with challenging the military in court and the very small changes doing so could result in have deterred him from suing the Department of Defense. "Say you could file a lawsuit - what could we really get that would prevent this from happening? I think it's so complex of an issue," Favors said. "To me, especially my grandma, there's really no financial amount that could compensate me for this, so I just don't see how it would be that beneficial," he added.

Nonetheless, Favors is frustrated that there is no method available to hold the Department of Defense responsible, stressing that "we need congressional accountability."

In the middle of September 2021, the Department of Defense sent letters to 2,063 agricultural operations within a mile of 95 military bases concerning PFAS contamination in the area they were living in. The average military installation sent 21 notices, and half of the bases sent 7 or fewer. In April 2021, the Environmental Working Group reported that PFAS were confirmed or suspected at 678 military installations.

Pentagon documents showed that at least 385 military installations across the U.S. are contaminated with PFAS, mostly from AFFF used by firefighters and during training exercises. Richard Kidd, deputy assistant secretary of defense for environment and energy resilience, said during a July public discussion on PFAS that it would take "years to fully define cleanup requirements the department faces, and probably decades before that cleanup is complete." The cleanup costs were estimated at $2 billion.

On July 14, 2021, the Department of Defense held a public outreach event detailing the roles and responsibilities, funding process, and actions taken as part of its cleanup endeavors regarding PFAS contamination of communities living near military installations. The presentation also detailed the future goals of the Department of Defense concerning public health outcomes, such as minimizing the future use of AFFF, monitoring the health of firefighters who have been exposed to PFAS, and expanding PFAS-related public outreach.

New Jersey sued the federal government, accusing it of contaminating the environment with PFAS on and around 3 military bases in the state by continuing to use AFFF. PFAS have polluted the Joint Base McGuire-Dix-Lakehurst and at two other bases at Trenton and Earle at levels that significantly exceed New Jersey's safe limit for human exposure. The federal government waived sovereign immunity by agreeing to follow the state's standards for the safe levels of PFAS but has "not addressed the imminent and substantial endangerment to the human health of New Jersey's residents."

In February 2021, the EPA deemed over 130 U.S. military installations Superfund sites. In addition to PFAS, there were other hazardous contaminants lurking on these military bases, such as cyanide, pesticides, chlorinated hydrocarbons, petroleum hydrocarbons, solvents, acids, chelating agents, asbestos, creosote, lead, thallium, antimony, and chromium.

The harmful fluorinated chemicals known as PFAS were confirmed or suspected at 678 military installations in America at the beginning of April 2020.

The Environmental Working Group compiled a top 100 list of the most contaminated military installations with PFAS in the U.S. At 13 sites in California, Florida, New York, Oklahoma, South Carolina, Texas, and Virginia, the PFAS contamination level was over 1 million ppt, when the safe limit is just 70 ppt. The military base with the highest PFAS detection was England Air Force Base in Louisiana, where there were roughly 20.7 million ppt PFAS.

The Department of Defense has begun battling environmental regulators in multiple states after the agencies tried to force the military to clean PFAS from military installations and sites. These endeavors mark the opening acts of what might turn into a nationwide war on legal liabilities, which the Pentagon estimated could reach billions of dollars.

Few manufacturers of PFAS face potential liabilities as great as the U.S. military, which has already spent over $200 million recently to start investigations of PFOS and PFOA at more than 400 military bases across the country. While there are a lot of chemicals in the PFAS group, PFOS, and PFOA are believed to be among the most dangerous.

The primary U.S. manufacturers voluntarily ceased the production of PFOS and PFOA in 2015. Furthermore, the Department of Defense updated the Military Specification for AFFF so that new supplies available for emergency firefighting responses would not contain detectable levels of PFOS or PFOA.

Nevertheless, AFFF is still used by the Department of Defense, but only to respond to emergency situations, and treats each use of AFFF as a spill to minimize the harmful environmental effects of PFAS. Fortunately, AFFF is no longer used for maintenance, testing, or training on military installations worldwide.

By 2001, PFOS and, in some formulations, PFOA became important ingredients in AFFF. The manufacturers of AFFF in the U.S. would sometimes use other PFAS than PFOS, but the existing stocks of PFOS-containing AFFF remained in use.

In the 1970s, every military installation in America was required to use AFFF as a firefighting agent to extinguish chemical fires or spills. However, AFFF was also employed during crash crew training exercises, hanger system operations and testing, and other emergency response actions. The Department of Defense would also use materials with PFAS in the vapor suppression systems at plating shops.

The formula of aqueous film-forming foam ? AFFF, for short ? was developed by the U.S. Navy together with the 3M company in 1966. Soon, all military vessels were required to carry AFFF to be used to extinguish a potential jet fuel or petroleum fire. AFFF is designed to put out Class B fires, which stem from flammable liquids or gases, such as petroleum greases, tars, oils, certain paints, solvents, and lacquers.