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DOD Media Roundtable on the PFAS Task Force

ASSISTANT SECRETARY OF DEFENSE FOR SUSTAINMENT ROBERT H. MCMAHON:  Thank you.  Heather, thanks very much.  To all of you, thank you very much for taking the time to be here.  Quite frankly, from my perspective, this is important.  Everyone in this room knows that PFOS [perfluorooctanesulfonic acid] and PFOA [perfluorooctanesulfonic acid] is a very important topic, it’s an emotional topic and there’s a lot of interest in this topic.

And so what I would tell you is — and I think all of you know this — the secretary, literally on the first day that he was in office, signed out the task force letter, directing us to move forward with this, and we began to take a concerted, combined effort to the issue of PFOS and PFOA.

I think that’s indicative of his perspective and more importantly, the department’s perspective on what’s most important.  And for those that were here when he spoke on his first day, he talked about the fact that he was in adamant support of the National Defense Strategy that Secretary Mattis had built, three lines of effort there.

He added to that in discussion about taking care of our people.  And so this is an integral part of that conversation about taking care of our people, how we do that and on this specific issue.  One of the things, if I were to talk about what my priorities are, it would talk about, among other things, the fact that we are committed to ensuring that we have a safe place for our people and their families to live, work, play and pray.

And this is an integral part of that, along with a variety of other focus areas.  It’s equally as important, I think, for us to recognize that we have a responsibility for the communities that surround our installations.  I spent 34 years in uniform, and in that time, what I learned is, we can’t do what we do without support for our communities.

They have to support our military members, our civilian members, and their families on the installation, and we have an equal responsibility to be able to support them.  And so the things that I’ll talk about today — and I’ll spend a few minutes talking and then I want to get to your questions — what we’ll — I’ll talk about today is integral to the kind of things that I just talked about.

Let me, if I could, start a little bit broader than just PFOS/PFOA.  And — and so I think it’s important to put context to this.  When you look at what we do in the department, we spend just under $4 billion each year on environmental issues.  Of that, about $1.3 billion each year is spent on cleanup.  

And so as we look at that and — an element of that, as we move into the future with this emerging requirement, is going to be how we deal with PFOS and PFOA.  Now, we talk about the breadth of what that cleanup looks like.

You know, first of all it happens to be on active duty installations, it’s on BRAC [Base Realignment and Closure] installations and it goes back to what we call FUDS, or Formerly Used Defense Sites.  So we are looking at the plethora of both current and past defense sites as we talk about this.

How far back do we go?  We’re cleaning up munitions from the Civil War still.  And so the breadth of the cleanup responsibilities, the environmental responsibilities that we have within the department, are fairly significant.

But that doesn’t mean that as emerging requirements come up, which this is, that we don’t add that into this process.  So let me get a little bit more specific and talk a little bit about PFOS/PFOA from my perspective.  First, what I’ve learned since we’ve begun this conversation, this is a national issue.  It’s not a — just a Department of Defense issue, it is a national issue and has to have a national solution.

When we talk about what — what the causes of PFOS and PFOA are, we talk obviously within the Department of Defense about AFFF [aqueous film-forming foam], the firefighting foam that we use — and I’ll talk a little bit about that — a little bit more about that here in just a minute.

The reality, though, as you all know, PFAS [per- and polyfuoroalkyl substances] compounds are used in a myriad of things.  I’m looking around the room, everybody in this room has something on that has a PFAS compound associated with it, whether it’s your shoes, my tie, which hopefully is stain resistant.  Whatever the case might be, it’s an integral part of what we do.

We’ll go home tonight and we’ll cook on non-stick cookware.  What’s an — what’s an integral element of that?  PFAS compounds.  So this is a national issue and we’ve got to deal with it in a national way.  That’s not to undermine the responsibilities that we have in the Department of Defense, but it’s simply to say we have to take a holistic look at what it is that we’re doing.

And so when the Secretary of Defense signed out his letter with regards — his directive — with regards to this, an integral part of that is ensuring that we had to be an integral part of the interagency solution to this thing called PFOS and PFOA.

And so it’s not just the department, but it’s working collectively with the other elements of the government to be able to figure out what we ought to go do.  So, within PFOS/PFOA, where we are today — well we talk a little bit about the — the task force first.  

Secretary, on the 23rd of July, his first day, he signed out the — assigned out the task force letter, I have the opportunity to be the chairman of the task force and my role of the — among other things, the responsibility for environmental issues for the Department of Defense.

I’m excited about that because it goes back, as I said, the fact that an important element is taking care of our people.  And 34 years in uniform, I came to the realization very quickly that we can’t do what we need to do without our people.  And so I have a responsibility to do that.

But we also talked about the health issues associated with people.  We’ve got to make sure we understand what those health issues are; we’ve got to understand and put in context what issues we have out there in terms of where there is concentrations of PFAS and PFOA that are our — our responsibility, how do we deal with that responsibly, how do we find, for example — and an integral part of what we have to do is not only find a fluorine-free replacement for a – AFFF — for firefighting foam, but we’ve got to do that, in my words, more aggressively and — than what — what the schedule was before.

In some cases, this may take new science, but are we doing all that we can to determine that new science; figure out how we do this effectively; and still be able to ensure that we have an effective firefighting capability for both our sea-based and land-based capabilities; and — so part of the conversations says, do we have to look at this and bifurcate the issue, instead of just talking about firefighting; do we do it in two different ways? One focused on sea-based, which would be one standard.  One might be on land-based. And so that’s part of what we look through at this, and as I mentioned previously what we want to do is assure that we’re an integral, effective and aggressive member of interagency focus on this issue.

That’s really the guidance that we got from the secretary. We’ve moved forward.  Some numbers that you’re already familiar with.  When we talk about the fact that this became an apparent issue, we looked at 524 different installations across the Department of Defense to understand and to characterize the drinking water systems that we’re responsible for.  Of those, the numbers that you’ve seen, 24 of those were above the lifetime health advisory put out by the EPA [Environmental Protection Agency] of 70 parts per trillion; I’ll come back to that in a second.  In addition, at the time, as we’ve gone through an initial blush, we identified 401 different installations where it appeared there was some level of PFOS/PFOA contamination that was generated by the Department of Defense.

So those would be some of the key numbers.  One of my key talking points is that as of today, there are no military members, there’s no one drinking water that’s above the lifetime health advisory where the Department of Defense is the purveyor of the water.  That’s important to us because that really is the most important measure – “go, no-go” position from my perspective.  Are we taking care of our people?  Are we taking care of those that are reliant on our actions where we were the purveyor of the drinking water? And so from that, then we get into the discussion about what does cleanup look like?  Where are we in the midst of preliminary analysis, how do we move forward from there as we get into creating some solutions?

So that gives you a flavor.  Let me go back to AFFF for just a second.  I talked about that.  I grew up on flight lines in the Air Force.  I been around it all my whole life.  I share that with you to say this isn’t — I’m not only the sustainment guy for the department. I’ve lived around this and so I’m pretty darn interested as well in understanding what impact this might have, because I’ve lived on installations nine different times in my life, my family has and I lived in this and around this environment my entire life. So this isn’t just my job, it’s a personal interest for me.

I go through all of that to say I’ve spent a whole lot of time and whole lot of different flight lines watching our firefighters shoot this foam out there as part of their training.  We know that they did that, and we never thought anything about it until we came to the realization that the AFFF had something harmful in it.  And so what we’ve done since 2016, I think was the year, we began to understand what the impact was.  We don’t use AFFF in training anymore.  The only time it’s used is in an actual emergency and when it is, we treat that site as a spill and treat it as spill contamination, much like we do a variety of other chemicals.

So one of the things I’ve asked for that we’re trying to put together, I ought to be able to look over the last decade in terms of utilization and consumption of AFFF, and since 2016, I ought to be able to see a significant reduction in that.  It doesn’t undo what we’ve done, but what it does is ensure that we don’t contribute anymore to the contamination that’s taken place.  I don’t know what that number is.  I will tell you that I’ll share what that graph looks like when we figure out what that data is.

And to that point, an integral part, and hopefully you’ve seen this from Secretary Esper, which I fully support, we went for a long period of time without any interactions with the press in terms of him having his press conferences.  He believes an important part of what we do is communicate freely with you on a regular basis.  My commitment to this group and to those that are interested in is that what this task force stood up, we will continue to come back to you, be as transparent as we can, share with you because part of this, and I know many of you have had the opportunity to read most of your articles.  I didn’t not realize there were that many articles until I started reading through this.  You all are really prolific writers.  I’ve come to that realization.

But part of this is I have a sense of where you are on the issue and on some things we’ll agree, some things we won’t, but you’re also an integral part of my communication to the installations writ large.  So it’s important that if I don’t give you information, you’re going to go take the information that you  have or wherever you have it from, and in many cases I don’t believe it’s very accurate, so I would rather have this conversation with you all, share with you my perspective; you could obviously document where we agree and where we disagree, but from that be able to draw conclusions and make sure that I’m communicating through you because you’re communicating to a much larger audience than just what I touch.

So let me see if there’s anything that I missed that I wanted to mention and then we’ll get into some questions.  Maureen, did I miss anything that I was supposed to say that I didn’t say?

DEPUTY ASSISTANT SECRETARY OF DEFENSE FOR ENVIRONMENT MAUREEN SULLIVAN:  I think you got it, Sir.

MR. MCMAHON:  OK, and I will tell you, I’ve asked Maureen to join me.  Maureen has forgotten more about this issue than I will ever know.  

MS. SULLIVAN:  The pressure is on.

MR. MCMAHON:  And so there’ll be some things that I won’t give you, I won’t know the answer to that I may not be able to give it to you. There may be some things that I don’t know the answer to that I’ll defer to Maureen, but together hopefully we’ll provide for you at least a meaningful dialogue here that we can move forward from.  So Heather, who should I — who am I supposed to choose first that I don’t insult or — what was the lady that used to sit in all the White House briefings that always got the first question?

STAFF:  Helen Thomas.

MR. MCMAHON:  Helen Thomas, that’s right.  Who is the Helen Thomas of this group?  All right, let’s do it that way.

Q:  Suzanne Yohannan, Inside EPA. It’s kind of a long question, but…

MR. MCMAHON:  Sure.

Q:  … so one of the focus areas that you guys laid out in your task force is cleanup standards and science-backed standards for exposure and cleanup.  So at the House hearing this past Tuesday, some lawmakers and witnesses said there is scientific consensus that PFAS, especially PFOA and PFOS, the two that you guys are kind of grappling with, are harmful to human health.  So they’re saying there is scientific consensus.  Your focus areas on cleanup standards and science-backed standards; I’m just wondering how does your plan fit with this statement, like with them saying, “Hey, it’s already there.  It’s already clear.”

MR. MCMAHON:  So like you, I’ve read and I’ve heard the discussion that says — science-based — that there is an impact on human health.  I’ve listened and saw where a variety of those factors are.  That’s interesting, but it’s not the level of detail that I need.  As I think you all know, we’ve begun to work and then we’ve actually funded with AST — ATSDR (Agency for Toxic Substances and Disease Registry) for — I get those two letters mixed up, I apologize — ATSDR for a series of studies, a minimum of eight that we can actually begin to go out and collect information around — in this case interestingly enough — eight Air Force installations, so that we can become data rich in terms of the determinations that we’re going to go make.  

I think that will begin to tell us about some of the health studies.  In addition, internal to the Department of Defense, what we want to be able to do is begin to collect effective data on our firefighting force, which has been most — obviously the most exposed to that.  It begins with blood testing, which came out, as you know, out of the ’19 NDAA [National Defense Authorization Act].  What we also want to do, and as recent as this morning we talked about, is creating a larger health analysis of our firefighters so we can — we can understand holistically of where they are.  So it’s a matter of collecting data, of being able to look at the data and draw meaningful conclusions by the professionals who do this for a living, being able to look at specifically those folks that we know are most affected by this, which are firefighters. 

And then from that, make determinations that allow us to move forward in I think a meaningful, thoughtful way that allows us to go attack this the way that we should.  Follow up on that, or are you good? 

Q:  Yes, I’m good.  

MR. MCMAHON:  OK. 

Q:  I — have some other questions.  So the timing of this conversation is fortuitous, given that negotiations over the 2020 NDAA are in play.  Obviously a lot of PFAS provisions are part of that conversation.  We know that the Trump administration isn’t thrilled with a lot of them.  Couple of the more controversial ones come out, firefighting foam, where you started, which might suggest to me that that — 

MR. MCMAHON:  Sure. 

Q:  — is one of your priorities.  CERCLA [Comprehensive Environmental Response, Compensation and Liability Act] designation for PFOA, PFOS, a whole category that’s, you know, in flux at the moment, and agricultural water delivered at the EPA health advisory level, another one that the administration has pushed back on.  Wondering if you could tell us a little bit your thinking on those and in particular, what you would see the consequences being for DOD if those provisions as written move forward?  

MR. MCMAHON:  Sure.  And I — what I’m about to share with you I’ve also shared with our staffers on the big four for us, so nothing that will be a surprise.  With — let me start with firefighting foam.  There is nobody that wants to find a meaningful solution that’s fluorine-free for firefighting foam more than I.  But what I don’t want to do is drive myself into a position that, if the science doesn’t support a product that I need that allows me to effectively protect life and limb on land-based fires, I don’t want to have to make a determination that I’m either going to support people, or eliminate this product and have to go with something that is less successful, less viable as a product. 

And so what I’ve tried to communicate is, if you give me an artificial date, I’m not sure that’s in our collective best interest.  We’ve done what we can today to minimize — and I alluded to this before — the amount of firefighting foam that — AFFF foam — that’s being expended where it’s simply down to emergencies only, and then secondly treated as a spill.  So I’ve mitigated some large percentage of that and I — I don’t want to give you a number until I actually can measure it, and then I’ll give you that number.  From that perspective, let me work aggressively.  I’ll tell you how much I’m spending, I’ll you what I’m doing, I — all the different things, but just don’t give me a date I can’t live with if the science doesn’t support it.  So that’s issue one. 

PFAS, as — and you all know this better than I, because you’ve been doing this a whole lot longer than I in this area.  There’s what — 5,000-plus different compounds that fall in this PFAS.  If — the unintended consequences if we say PFAS — P-F-A-S writ-large, we have no idea what the unintended consequences of that are, for not just DOD but for our nation.  And we — we’ve got to understand that.  So I think it’s important for us to deal with compound by compound.  We know that there’s an impact from PFOS and PFOA.  Let’s go deal with that, let’s go manage that collectively, but let’s not take broad swathes without understanding what that means — I don’t know that that’s in our collective best interest. 

And then on your — on the ag [agriculture] question that you gave, I’m going to defer that to my — to Secretary Perdue and the — and the folks over in — in agriculture to figure out how they best want to answer that part of the question.  But what I will tell you is, those kind of questions have to be part of the interagency process where we’re all sitting around together with EPA talking about how we move forward. 

Q:  So follow up question on the regulating as a class versus individual.  For your purposes — you know, this is all kind of tracing back to firefighting foam for the most part — 

MR. MCMAHON:  It is. 

Q:  — and my understanding is that there was often a brew of different PFAS’s that were in — in the foam.  So I wonder from a — from a — like a CERCLA designation standpoint if it really makes that big of a difference whether it’s done individually or as a group, given that it’s all — they were all going to be found together.  Now, I get that some are more transportable than others, and so if you’re doing groundwater cleanup and one has traveled further, that could make a difference, but I’m just wondering from like a DOD, kind of, cleanup cost perspective, if it really makes a difference. 

MR. MCMAHON:  The short answer is I don’t know, because we have obviously been focused predominantly on AFFF and — and we know what’s in AFFF.  What I don’t know, when I look at the other 5,000 compounds without doing the analysis, and saying what am I driving and what’s my return on that, to understand what that impact is.  And so I — I’d rather us focus on specifics, individual compounds rather than classes.  I think at the end of the day, we end up with a better understanding of what the impact of that is, not only on cost for cleanup, impact on people, but on the broader sense what’s the impact on — on us being able to do the mission.  You’ll come back to me on that, I can tell.  Go ahead. 

MS. SULLIVAN:  Could I supplement somewhat? 

MR. MCMAHON:  Sure. 

MS. SULLIVAN:   You know, I think your question — twofold part of your question.  One is — you’re probably right that cleanup costs won’t be that different because we’ll address all of them, but we have to respect the integrity of the process.  So what is the criteria for something becoming a hazardous substance.  Because we don’t know a lot of the science behind many of the other PFAS compounds, are we compromising the — the — the process itself?  I don’t — I don’t know.  

MR. MCMAHON:  I’m going to build on that a little bit, if I could.  So I apologize, but you’ll get to another question in a minute.  I started with the broader context of the environmental cleanup challenges that we face.  The question becomes, for every dollar that I have that I put into cleanup — and I need to continue to do that — I don’t want — I don’t want to clean up something over here when it should have been over here.  And so, part of this is contextually: how do I move forward?  If I say every PFAS  — the class, I go from that instead of that. And so, am I spending money on something that — that I can defer for some period of time, because there’s minimal impact versus something that I ought to be focused on today?

And the broader the context, the more challenging that becomes for us.  And so that becomes part of the conversation, as well.  Are you OK with that?

Q:  Yes.

Q:  Can I just ask a quick clarification.  So hearing you push back on designating compounds other than PFOA and PFAS, does that mean you’re OK with designating PFOA and PFAS as hazardous under CERCLA?  

MS. SULLIVAN:  We have said that we respect the — we respect the EPA going through the hazardous substance designation process under CERCLA.

MR. MCMAHON:  And if it came out as a …

STAFF:  Hazardous.

MR. MCMAHON:  As a hazardous substance, we would appropriately deal with it.

Q:  So it has to be done by EPA rather than Congress?

MR. MCMAHON:  I think that would be the appropriate place for it to be done.

Q:  I’m Rebecca with the Hill.  I was wondering what are your guidelines at this point for determining when DOD is responsible for a cleanup versus when it isn’t.  And kind of like, what’s that dividing line between, all right, this is DOD’s responsibility versus a nearby farmer or a nearby community that has their own, sort of, municipal water supply.

MR. MCMAHON: So the clearest way to articulate that is, when you look at all of our installations, if you think about — first of all, on-the-installation responsibilities, what’s the source of the water? Is the source of the water wells and supporting that? Is the source of the water wells and supporting the local community?  If — if in fact, it is and it’s clear that there was a contamination caused internal to the installation that effects not only the installation but the community, clearly that’s my responsibility.

In some cases there are multiple sources out there feeding a well system for communities.  So the challenge has become delineating responsibility in those installations.  The other part of this conversation where — and this is why the preliminary analysis and — beginning to understand aquifers, understanding the flow of plumes, all those things become tremendously important.

It’s — one, it drives behavior, but also helps us articulate what responsibilities we have.  So upfront where we know we were the — we’re the purveyor of water, not only for the installation but for the community and well system, we know we have a responsibility ultimately to clean that up.

And whether that’s at one part per trillion going through the process, or a one million parts per trillion, ultimately through the CERCLA process we have responsibility for cleaning up.  The other part though, is — where is — what’s the other source of water if — or source of the water for the community and the installation?

If it’s all piped in from a community location, X number or hundreds of miles away.  I know that isn’t my responsibility.  You go back to that source.  So I think …

Q:  I guess, how do you handle gray areas though is what I’m wondering.  I mean there are multiple sources …

MR. MCMAHON:  Give me an example in your mind where there’s a gray area.

Q:  You just mentioned, like if there’s perhaps multiple sources of that you’d have to delineate.  I’m just curious, like how you’d approach that.

MS. SULLIVAN:  That’s pretty standard in CERCLA investigations.  So — I mean there’s all sorts of — this happens with all sorts of other compounds.  So — they do water flow studies to see how flumes of water move, flow patterns of the ground water, so you can pinpoint where the water moves, and how the chemicals move in that water, which all chemicals move differently in water.

So there are very complex studies that take a lot of time.  So — but it’s pretty standard in a — in a CERCLA cleanup process.

MR. MCMAHON:  But it’s also why this is a much more complex conversation, is understanding the nuances of the science of this ,and whether it’s the science of cleaning up or whether it’s the science of managing the flow that — it’s not — I don’t know that — I think part of our responsibility is to communicate exactly that point, that there is a level of complexity to both the analysis and then the execution of whatever that remediation might be.

MS. SULLIVAN:  Drilling lots of wells.

Q:  Hi. Tara Copp, McClatchy. I have a couple of — I want to — first I want to get back to the firefighters.  Is DOD looking at all at making a recommendation to VA to establish — to ease establishing service connection for an MOS [military occupational specialty] or for a specialty code, under the assumption that a lot of these firefighters have been exposed to foam over the years, and as they develop cancers — if they develop cancers — making it an easier path to them to get the health care they need through the VA system?

MR. MCMAHON:  I’m not sure that I’m ready to answer the question in that depth.  What I am — would tell, is there an integral part of the task force is the assistant secretary of defense for health matters, his team — many of the actions that we’re taking — and I should have said this earlier — there are probably, at this point, roughly 40 different actions we generated for ourselves.  Some are near-term, some are midterm, some are long-term that focus on what actions that task force out to take in place — take to get to where we want to be.  

An integral part of that on the health side is the interaction between the department and the Veterans Affairs folks to be able to understand what that relationship ought to be.  What is it that we can push?  What are those standards and — and how do we, not only for our firefighters, but in a broader sense for the folks that may be impacted to work — make sure that we’re working off a common set of standards there.

Q: OK.  So potentially to — not only for firefighters, but beyond that to help them get established service connectivity if they need to.  

MR. MCMAHON:  In the broader context, the answer is yes.  

Q:  OK.

MS. SULLIVAN: For example, we’re recording all of the drinking water data in the health system.  So it’s — we have the record.

Q:  And then to go back to the AFFF, it appears the Navy is still using it both for training and emergency response on its carriers and on the amphibs [amphibious ships].  And you can — you can pull up current photographs of sailors on deck without protective gear training with this foam.  

I’m just wondering has that been — message received by the Navy, or is it just that there’s no other option on amphibs and on the carriers right now as a replacement foam?

MR. MCMAHON:  I’ll be honest, I don’t know the answer to that question.  

MS. SULLIVAN:  The policy only — the policy to stop using it for test and training was only for land-based.

MR. MCMAHON:  But in terms of protective equipment, I don’t know the answer to that — that question.  That’s a great question, and let me take it and I’ll do it as a follow up for you.

Q:  OK.  Think I have one more for you.  

Oh, so, I’m sure you have seen, you know, the Environmental Working Group has been pretty aggressive in continuing to add to the original baseline you guys set with your 2018 study.  Are there any thoughts about updating and getting, you know, a current DOD count, DOD-wide of the bases, BRACs, former bases that have drinking water issues, or did?  

MR. MCMAHON:  So let me start wider and then work down to your specific question.  Part of the thing — one of the things that we want to do as part of this task force is establish and improve, as I said before, the transparency we have.  So you’re about to see a website come up.  It’s up in its infancy, but the ability to put data out there so that it’s easily accessible not only to all of you who are writing a story, but if I’m at what — pick an installation anywhere in the Department of Defense, they can see what that impact is as part of a communication.  

So much of the information that we have will be readily available on that site.  We talked to the accuracy of the data, this is going to only improve over time.  And that’s part of what I would tell you upfront we know that there is probably holes in the data.  We had the release this week, the FOIA [Freedom of Information Act] on the Army.  You’ll see something similar coming from both the Air Force, the Navy not too far down the road this fall.  

So the 401 number that I used earlier, I would expect to see some growth in that as we begin to get a better understanding and better characterization of where we are.  So part of that I actually see that as a good news story is the information becomes more accurate, what it does is better develop, better articulate, word is that we ought to be focused in the actions that we ought to take. 

So the short answer is, yes, you will continue to see additional data being made available, and it’s not just for all of you, it’s so that if I am at a base or an installation, I understand what that is as well.  Good question.

Q:  So this website will have like all installations and kind of have account of what’s –

MS. SULLIVAN: Eventually.

Q: OK.  

(CROSSTALK)

MR. MCMAHON:  That’s what we’re trying to work.  Go ahead.  Please.  

Q:  Oh, me.  

OK.  Actually, I was hoping, could I clarify two things that you guys just said…

MR. MCMAHON:  Sure.  

Q:  … to them before I ask the question?  What…

MR. MCMAHON:  So you’re going to be doing multi-multi-question.  

Q:  Well, I’m trying not to, but…

MR. MCMAHON:  That’s OK.  

(CROSSTALK)

Q:  … you said that you’re recording all of the drinking water data in the health system.  What — can you — I don’t quite understand what…

(CROSSTALK)

MS. SULLIVAN:  Oh, so we have a system where we record occupational — for OSHA [Occupational Safety and Health Administration] purposes.  And we have a — Health Affairs has DOEHRS (Defense Occupational and Environmental Health Readiness System) — don’t ask me to define that acronym, I apologize.  So, you know, it records where we use chemicals in our processes and all of that.  So when a service member says I was at base A doing these functions, and we know that there was these chemicals when that service member is.  

So now we’ll be adding this drinking water data to that.  And so it brings together where the drinking water was to match up with the service members’ records.  

Q:  And that would be for PFOA and PFOS?  

MS. SULLIVAN:  Right.  We are actually loading all of the drinking water data that we tested.  So when we test the drinking water, we went in through the standard EPA test method.  So it’s going to produce results for up to 18 different PFAS compounds.  And so we’re recording all of that, even though then we’re focusing on making sure the water meets the EPA’s health advisory for the PFOS and PFOA.  But we’ll have the record for all of the sample results.  

Q:  I’ll then minimize what I think the other questions, although I’d like to know more about that site when we’re…

MR. MCMAHON:  Sure.  

Q:  But I’m just curious, if EPA does proceed to this PFOA and PFAS under CERCLA, are there any exemptions you all would need?  I have heard some water utilities voicing concern about carbon filters and wanting an exception for carbon filters.  

MS. SULLIVAN:  We’ve never asked for…

(CROSSTALK)

MR. MCMAHON:  I was going to say.  

MS. SULLIVAN:  Yes — no.  Never even contemplated.  

MR. MCMAHON:  Please.  

Q:  I just — I guess my question really — I’m trying to make sure I understand what you said earlier.  You said — across the board — U.S. military installations right now drinking water.  Are you saying that nobody has to worry about anything right now with the drinking water, that it meets the standards?  I’m just…

MR. MCMAHON:  So let me try it again.  There is nowhere [where] the Department of Defense is the purveyor of drinking water — no one is drinking water that is above the lifetime health advisory of 70 parts per trillion.  And that has been our initial focus since day one as we began in this direction, ensuring we’re taking care of our people, their families and the communities around their bases.  

So your characterization was a lot broader than that.  And so we — I want to be very specific as how we define it.  That is within our control.  

OK.  Back row, please.  Either one.  

Q:  Oh, sorry.  I just had a quick question about training.  

MR. MCMAHON:  Sure.  

Q:  Now that they’re not using PFAS on land, has that degraded their training or are they just using water?  And can you get the same effects in training to be effective?  

MR. MCMAHON:  I have not seen anything that suggests in as recent as this morning with the three services, their assistant secretaries for energy installations environment, who own the civil engineering process, the firefighting process, I have seen nothing to suggest that their training has gone down hill.  

I can take — I’d be happy to take that as action and go back and talk to the fire chiefs.  But there is nothing that indicates to me that that’s the — that has happened.  

In fact, Heather, let me take that as a for-action question, just to confirm it, because I don’t want to do it in absentia.   

Please.  

Q:  What percent of military housing or bases are served by DOD-controlled water?  And, like, what percent would be — because you said, DOD purveyor.  The DOD purveyors, wherever you’re supplying water, nobody is drinking it.  But that, to me, sounds like that means there are other military personnel or civilians that are in the DOD system that are consuming water by other sources?  

MR. MCMAHON:  For example, an installation is hooked up to a city water system.

Q:  Correct.  

MR. MCMAHON:  That keeps us from being — the department being purveyor.  Do you know what the percentage is?  

STAFF:  No, I don’t.  

MR. MCMAHON:  Let me take that — I don’t want to guess it —

Q:  Your testing though — your testing those systems though, too, correct?  Or —

MS. SULLIVAN:  The Army and Navy made a decision to test. We asked all of three military departments to work with the local purveyors, and I think our 2018 report talks about some of the off-base systems where we’re buying from, and what they were doing.  

Q:  And to follow-up with that, there’s a lot of concern in communities — neighboring communities — at old bases, Willow Grove, those kind of areas, about exposure.  What do you say to them about, you know, their concerns and how you all are planning to address former bases, and communities around former bases?  

MR. MCMAHON:  When you — excuse me. When you look at the installations, again where we were the purveyor of water — I mean, go ahead —

MS. SULLIVAN:  So I want to — I want to segregate.  So a lot of what Mr. McMahon was talking about has been about the drinking water on our system, on our bases.  But at the same time we went and looked where we really had confidence that we had added these compounds to the water and it impacted off-base that we are — we have already worked out with them to provide bottled water in some cases, hook people up from their private wells to the local community system, to install treatment at the local — so when you hear the numbers of how much we spent, most of it is to address those off-base drinking water sources.  

Q:  And my understanding is the data goes back to 2016, right?  Are you all ever going to like — do you have, like ability to look further past and see exposure for vets — people that have lived on these bases and dealt with this for —

MS. SULLIVAN:  That’s the work with ATSDR, that’s who it would — they’re the ones that are doing that —

MR. MCMAHON:  That would look at the impacts, that’s right.

MS. SULLIVAN:  Yeah.  

Q:  Thanks.  

STAFF:  So sir, we are at time, do you want to take one more question?  

Q:  I just had one follow-up, if that’s ok?  

MR. MCMAHON:  All right, we’ll take two more follow-ups, do the first two hands.  

Q:  So my question’s for Ms. Sullivan.  At a House hearing earlier this year you cited a $2 billion, kind of back of the envelop estimate for the potential cleanup costs, and I’m wondering if you can tell us what factors you were looking at in that. For instance, the cleanup level, we’re talking about groundwater is a crucial element of that.  

It’s no secret the DOD has pushed for a higher number than 70 parts per trillion that’s in the draft guidance —

MR. MCMAHON:  I’m going to push back on that statement, but — ask the question then I’ll push back.  

Q:  And so the question is, what cleanup level were you looking at?  And to this question of DOD’s responsibility for areas where they are not necessarily the only one contributing to the problem, were you looking at sites beyond the ones where DOD has been the known source of contamination?

MS. SULLIVAN:  You have done now more analysis on that number than I did in creating that number.  So that was really a wild guess on my part, you know?  

MR. MCMAHON:  Our boss asked her for a wild guess to figure out, put a mark on it.  

MS. SULLIVAN:  You know, the kind of — it kind of is, we’ve spent about $200 million a year over 10 years, that would be $2 billion.  So —

MR. MCMAHON:  Do I think it’s going to be bigger than that?  The answer is yes.  

MS. SULLIVAN:  Yes.  Really, it — there was no factoring in of cleanup levels, no factoring in of technologies, it was just a general — you know, it’s going to be somewhere in that vicinity, given our history of the cleanup liability.  

Right now I’m sitting on $27 billion worth of cleanup without PFOS and PFOA, so that it would be a little less than 1 percent potentially — you know, 10 percent potentially that’s about the level of analysis that went in.  We’re really not going to know until we have much more analysis, much more investigation into the sites to see the scope of the problem, to fully understand all of the water flows and therefore what are the possible solution sets.

MR. MCMAHON:  So let me go back to your comment where I pushed back.  We are in alignment with EPA, we’re working with EPA.  We’re an integral part of the conversation with EPA.  When all of — when the story broke very simply, and I’ll put it in my terms — the only comment that we made is we want to use — we wanted to use a standardized, risk-based system to get what that — to what that number ought to be when we talk about ground water.  

That was the message that we communicated at the time.  It didn’t say that we weren’t fully supportive of the standard process that we’ve been using literally for decades.  I think that evolved in to a story that I don’t think was accurate at the time.  

I don’t want to push back, but what I do want to say is that we’re in alignment with EPA, that we believe we ought to use standardized EPA processes and that we’re fully supportive, an integral part of the process with them today.  

Q:  So I just want to follow up on the question about, or the issue of communities that — where DOD is one of potentially many contributors.  I just want to know what you would sort of say to those communities in the meantime as you’re going through the process for figuring out what part of the problem DOD contributed to it?  

So I’m thinking of communities like Ayer near Fort Devens; EPA ended up, like, moving towards a compliance order with DOD before DOD stepped in and helped fund it was a very — my understanding is it’s a very poor community that wasn’t going to have the bandwidth to treat the water —

MS. SULLIVAN:  You’re talking about my home now.  My sister lives just a couple miles from there, sorry.  You know, actually the truth on the Ayer is that it was in fact the research into — it was the investigation that the Army was able to say OK, these are in fact the sources, and this is in fact how the water’s moving and therefore how — what the interim solution should be.  

So it was really based on the Army’s investigation of the water that resulted in, now they’re working with the town on how to add additional treatment systems because they were able to figure out the water flow.  

I would admit these are very complicated questions that — but we need to make sure that we fully understand how the water is flowing, and where — and how the chemicals are moving in to the water, so that we make the right decision upfront, that we’re not making a shorthand decision that may actually compromise other things.  

MR. MCMAHON:  And the only think I would add to that is, it’s a matter of transparent communication with those communities, with the regional EPA and having a collaborative conversation that says this is what we’re looking at.  What do you see, what do we see, how do we talk about that in a way that is again meaningful.  That goes back to this idea that this is beyond a DOD issue, it’s a national issue in the way that we go approach it.

Q: If I could ask just two related …

MR. MCMAHON:  Hang on, I’ve got…

Q: You mentioned that you’ve got about 40 working directives or do outs that your task force is working on.  Can you give us kind of an estimated timeline of when we’ll start to see rollouts of these directives, and maybe one or two other examples of what you’re working on?

MR. MCMAHON:  What I would tell you is – and I’ve not shown them — the secretary has not seen the list yet so I don’t want to get out in front of my headlights, quite frankly, without giving you — but whether it’s focused on health issues, whether it’s focused on methodology, whether it’s focused on funding, how do I look at all the critical elements that are necessary for us to achieve the things that we’re attempting to do; and the guidance I talked about earlier, you can characterize it in some broad buckets that then allow us to get to where we need to be.  And so I feel most comfortable leaving it probably there.  We’ll give, as we get the chance and I have the chance to actually show it to the secretary first, I think we’ll share to a greater extent with you and give you a sense of what that is, but for now, picture whatever you think those broad buckets — five or six broad buckets were and the actions within each of those.

Q: And the timeframe?

MR. MCMAHON:  I think if I were to look at the secretary’s original letter, 180 days for the task force.  Some of these things will be near term in the next 60 to 90 days.  Some of it will be a little bit longer to the end of the calendar year.  Some of it will take obviously much longer period of time to execute the things we need to go do.

Q:  Just curious, do you have a sense of how much AFFF is still on shelves in various bases and have any kind of take back program?  

MR. MCMAHON: Part of — one of the questions that again that I want to do is get my arms around the whole supply chain on this.  As you all know, that there are multiple types of AFFF.  We went from a — there are no fluorine-free FFFs today — but there are some that had a level of fluorine up there that have come down.  So to characterize it — go ahead.

MS. SULLIVAN:  So over the last two years, each has — so there’s an older version that was in our warehouses with PFOS still in it.  All three military departments have gone through and gotten rid of the old so what’s on the warehouse — in the warehouses is — it’s the new, and each of the military departments are stepping through to do those replacements in the equipment.  So — so they’re all on a schedule and I’m sorry I don’t know it off the top of my head but that’s — but that’s — so there’s the less PFOS — there’s no PFOS and there’s less PFOA in it. So we are working on what the supply situation is.

MR. MCMAHON:  So they can speculate and characterization where we started.  You know when we were essentially before we understood what the impact was and were using it for training as well and using PFOS.  So you go from PFOS down to PFOA and then you change the rules and what you can do and only use it in emergencies.  We ought to be able to see a fairly significant trend line and then when you do use it, you treat it as a spill and clean it up again.  It helps us for the future; it doesn’t take care of the problems we had in the past.  

Heather?

Q:  Do you have any last remarks?

MR. MCMAHON:  I’ll go back to what I started with, and that’s very simply that our most important resource are our people.  It’s our families; it’s the communities that surround us.  We have a responsibility to work with them and to take care of them, the folks on the installation and work with the communities outside of it.  We understand that responsibility that starts with the Secretary of Defense.  He is serious about taking care of our people.  This is an integral part of that, and we’re going to push hard to make sure we do that.

He’s also serious about open and transparent communication.  We’re going to continue to do that, so my commitment to all of you is that we’ll continue to have those conversations on a regular basis, keep you updated on what we’re doing, what we find, how things change, and then finally, with regards to the website  — that’s so you don’t have to talk to me.  You don’t have to talk to Maureen. Much of this you can see on your own and validate it; that again is part of that transparency that we want to drive.

And I appreciate your time, tremendously important to us, so thank you all very much.

Q:  Thank you.  

Q:  Thank you.

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