The Environmental Pitfalls of the United States National Security: Permitting Widespread Per- and Polyfluoroalkyl Contamination
The assumption that tap water is safe has been upended in the last few years by a succession of well publicized health crises nationally. Although water contamination affects everyone, communities surrounding military bases and communities made up of working-class and minority groups are most adversely affected both by water scarcity and water contamination.
For example, the Agency for Toxic Substances and Disease Registry reports that North Carolina’s Marine Corps Base Camp Lejeune drinking water may have exposed as many as one million military personnel and families to life-threatening toxins. Furthermore, Camp Lejeune is not unique. More than 900 Superfund sites, areas in which it has been federally-mandated to clean up hazardous environmental contamination, are active or former military bases. Many of these bases, along with their surrounding communities, suffer from environmental contamination crises from known carcinogens, with some of the worst being trichloroethylene (TCE), perchloroethylene (PCE), and benzene. One of the most widespread and harmful groups of these contaminants is per- and polyfluoroalkyl substances, or PFAS.
To mitigate the public health impact of PFAS, it is imperative that the Department of Defense be held accountable for causing this environmental degradation and the resulting public health crisis. First and foremost, Congress must ensure that the contamination ends by passing legislation that ensures an increase in PFAS research. Such an effort would reduce and prevent further environmental degradation.
PFAS: A Definition
Exposure to PFAS increases risk of kidney or testicular cancer, birth defects, and weakened immune systems. Almost all humans have some measurable level of PFAS exposure because of the contaminant’s potency, rapid permeability into air and water, and permanence.
Any amount of exposure to PFAS is unsafe. The Environmental Protection Agency (EPA) regulates most contaminants using a maximum contaminant level in the parts per million; however, the two regulated PFAS compounds, PFOA and PFOS, are dangerous at even smaller amounts – with a standard in the parts per trillion (ppt). After public concern rose throughout the 2000s, the EPA lowered the exposure limit to near zero this year.
Moreover, even minimal amounts of PFAS continue to damage the environment. They can rapidly infiltrate and penetrate groundwater and air. This expedited release into the environment is exacerbated by the prevalence of PFAS in daily activities. The man-made toxin is historically crucial to the fabric and food-packaging industries, as it is used to create fluoropolymer coatings, thus preventing heat and grease. PFAS’ persistence combined with the toxin’s decades-long endurance has led to the widespread contamination of PFOA and PFOS in the environment and the human body.
A History of PFAS in the Military: Hiding the Damage
In 1966, the Navy granted a patent for the use of PFAS in aqueous film forming foam, which soon became the most common fire suppressant in the military. The foam – and thus PFAS – were used in all 5 departments of Defense to extinguish fires in burn pits, airport terminals, and on ships. In 1973, not long after the acceptance and widespread use of the extinguisher began, the Air Force reported its toxicity. However, the Defense Department kept internal studies and reports citing the harms of PFAS in the 1970s and 80s classified.
Although the military understood the effects of PFAS, they chose to ignore the studies indicating harm as well as disguise the contamination issue ostensibly because those at the decision levels could not have fully appreciated the harm done especially in the long term. Or, in the words of Secretary Leon Panetta, who served in the Army from 1964-1966, “the military is fundamentally interested in training soldiers and doing whatever that military base is about.” He went on, “[it] doesn’t spend a lot of time focusing on the health impacts whether it’s water or whether it’s the various Superfund sites that are there and the consequences of it. They usually wait for something to happen and then they try to address it.” (Panetta).
In 2011, nearly forty years after the Defense Department knew about the harm generated by PFAS, it finally publicized what it knew about these dangerous toxins. However, this did little, if nothing, to stop the military from further destroying the environment and poisoning soldiers and citizens, which is evidence that the health of its personnel and their families were of little concern to decision makers in the military establishment.
Even by 2016, after the EPA issued an update to the Safe Drinking Water Act recommending that the lifetime exposure levels of PFOS and PFOA be below 70 ppt, little was changed in military policy or practice with regard to the use of PFOS and PFOA. However, as a result of that updated report, the Assistant Secretary of Defense ordered the military to terminate the use of the PFAS-based fire suppressant. In response, the Department of Defense located on-base and nearby sites where the contaminants were found in military-run drinking water systems and provided bottled water to the impacted communities. This did not solve the problem; well water for other uses such as bathing or laundry still contained dangerous contaminants. Despite decades of awareness about the contaminant's prevalence and negative impact, this represented the first time the Defense Department warned military personnel about the potential dangers of PFAS contamination. Even more damning, according to Scott Faber, the Vice President of Government Affairs for the Environmental Working Group, the military only did so because Congressed ordered further action.
The military operates independently, and as a consequence it is exempt from the EPA’s oversight or regulations. Both active and former military bases are subject to the Superfund law, and are obligated to conduct an environmental cleanup required under the Comprehensive Environmental Response, Compensation, and Liability Act. However, recent exemptions have allowed a magnitude of military installations, especially those not on the EPA’s National Priorities List, to avoid compliance. The Defense Department argues that environmental cleanup would get in the way of effective military training even though no verifiable studies or evidence confirm their claim that environmental legislation impedes military service.
The Defense Department has either withheld information or conducted inadequate research about how many bases were affected by the contaminants. In 2018, the Department of Defense found that 24 out of 524 installations had drinking water systems with harmful levels of PFOA and PFOS. In the following year, the Environmental Working Group identified another 90 installations with dangerous concentrations, forcing the military to reinvestigate. In 2020, the Department of Defense disclosed more than 600 military sites with PFAS contamination. Today, it has acknowledged contamination on about 708 sites.
This series of events leaves open the question regarding the intentions of the Department of Defense, and portends that it will continue to fail those who serve our country if not held accountable for its pollution, and subsequent human and environmental impact.
The responsibility of the military is to protect the nation’s people, but, as evidenced through the narrative of PFAS, they fail to keep their own soldiers safe. Secretary Panetta reflected that, to achieve their mission of national security, the military operates independently from other federal agencies. This often comes at the expense of the soldiers and the community’s health. “It’s to their own people! It’s not just to the community, it’s to their own military people and families that try to fulfill the national security mission” (Panetta).
Current Remediation Efforts
With more knowledge surrounding PFAS contamination in the military, policymakers are aiming to terminate its use. In 2020, the National Defense Authorization Act ordered that the Department of Defense phase out the usage of aqueous film forming foam by 2024, with an immediate stop to the contaminant's application in training operations. The action sparked tensions between Congress and the military as demonstrated by Laura Macaluso's, the Acting Deputy Assistant Secretary for Force Safety and Occupational Health, testimony in a committee hearing. Macaluso stated that the cleanup efforts will take decades and that elevated blood levels of PFAS can also be attributed to other industries. Pushing blame elsewhere, the Defense Department refuses to accept responsibility and accountability for the poisoning of their veterans.
To appease the public, the Department of the Defense began testing military installations for PFAS but has yet to conduct any sufficient environmental cleanup efforts. The Defense Department is liable for implementing an environmental cleanup for each Superfund-designated military base. However, many if not most of these plans are left stagnant at the preliminary stage of discovering exact concentrations of PFAS and other military-related contaminants. These plans consistently miss deadlines and targets year after year, taking decades to complete. The Department of Defense’s failure to effectively and quickly clean up their contamination leaves soldiers and veterans forever at risk of exposure to PFAS.
Next Steps
The EPA must require and enforce the military to reduce overall pollution. If bills such as the COST of War Act of 2021, the Honoring our PACT Act of 2021, and the Veterans Exposed to Toxic PFAS Act of 2022 are enacted, the military will be held accountable for exposing their soldiers to PFAS and other contaminants. Yet, these contaminants bioaccumulate and can stay in the environment for decades. Only three treatment methods are effective at removal but are too costly to implement at scale. Therefore, to holistically address the issue, federal policy must require prevention of further contamination; Congress must prioritize relevant bills to ensure that the manufacturing and usage of militaristic carcinogens are discontinued.
In order for the military to stop contaminating their bases with PFAS, it is imperative they acknowledge their history. Instead of blaming other industries or withholding information, they must remediate the decades of pollution they knowingly discharged.