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Emerging Chemicals

Overview

The Department of Defense (DoD) protects readiness, people, and the environment by identifying and managing risks associated with emerging chemicals (ECs). Remedial Project Managers (RPMs) maintain awareness of ECs and their potential impact on the management of Department of the Navy (DON) Environmental Restoration (ER) sites.


Jump to Resources to access Policies & Guidance, Publications, Related Sites, and Tools

 

Process

The DoD defines an EC as “a chemical or material that is characterized by a perceived or real threat to human health or the environment with no published health standard, or an evolving standard.” These contaminants may be difficult to assess because many have insufficient or limited health and science data available. Since the standards, toxicity values, and/or science continually evolve, so does the list of chemicals currently considered ECs.


ECs that are commonly associated with DON past operations are: per- and poly-fluoroalkyl substances (PFAS), 1,4-dioxane, perchlorate, asbestos, and lead.  


The DoD EC Instruction (DoDI 4715.18) establishes policy for the identification, assessment, and risk management of ECs that have the potential to impact the DoD. Under this policy, the Chemical and Material Risk Management (CMRM) Program is responsible for early detection of ECs from the pool of chemicals and materials used by DoD. The CMRM uses the Scan-Watch-Action process to identify, evaluate, and mitigate risks associated with DoD ECs. This process also describes how DoD addresses associated ECs applicable to the DON ER Program. To assist RPMs with any tasks associated with ECs, subject matter experts from the NAVFAC EXWC and the Navy and Marine Corps Force Health Protection Command are also available for consultation regarding changes in toxicity values.


Although typically consensus has not been reached regarding the potential toxicity of many ECs, there may be situations where it is still possible or recommended to evaluate the nature and extent of a release, estimate potential risk, or even implement response actions in response to a release of an EC. In such situations, it is important to ensure the actions taken are consistent with existing DON guidance and policy on ECs. Please refer to Chapter 13.5 of the DON Environmental Restoration Program Manual for more information on managing sites with ECs.

RESOURCES

Topics Title and Description

ERP Manual

DON Environmental Restoration Program Manual: Chapter 13.5 Emerging Contaminants (February 2018)
Defines ECs and describes the guidance and policies available to RPMs to ensure appropriate actions are taken to address and manage ECs.

Identification and Assessment of ECs

DoD Policy Instruction 4715.18 Emerging Chemicals of Environmental Concern (February 9, 2024)
Establishes policy and responsibilities for the identification, assessment, and risk management of ECs that have the potential to impact the DoD.

Sampling in Clean Water Act Discharges

DON Policy for Sampling of Emerging Chemicals in Clean Water Act Discharges (July 2021)
Provides guidance to the Navy Clean Water Act compliance community to ensure consistency when sampling for emerging chemicals.

Per- and Polyfluoroalkyl Substances (PFAS)

PFAS DoD Policy

Assistant Secretary of Defense for Energy, Installations, and Environment (ASD[EI&E]) Memorandum on Investigating Per- and Polyfluoroalkyl Substances within the Department of Defense Cleanup Program (January 2025)

PFAS DoD Policy

ASD(EI&E) Memorandum on Prioritization of Department of Defense Cleanup Actions to Implement the Federal Drinking Water Standards for Per-and Polyfluoroalkyl Substances Under the Defense Environmental Restoration Program (September 2024)

PFAS DoD Policy

ASD(EI&E) Memorandum on Establishing a Consistent Methodology for the Analysis of Per- and Polyfluoroalkyl Substances in Matrices Other than Drinking Water (May  2024)

PFAS, Incineration

ASD(EI&E) Memorandum for Incineration Prohibition Policy Update (July 2023)

PFAS, Disposal

PFAS, Migration

ASD(EI&E) Memorandum for Taking Interim Actions to Address Per- and Polyfluoroalkyl Substances Migration from DoD Installations and National Guard Facilities (July 2023)

PFAS, Covered Area

Principal Deputy Assistant Secretary of Defense for Energy, Installations, and Environment (PDASD[EI&E]) Memorandum Public Disclosure of Department of Defense's Planned Testing of Per- and Polyfluoroalkyl Substances in Drinking Water Within a Covered Area (June 2022)

PFAS, BRAC

PDASD(EI&E) Memorandum Addressing Per- and Polyfluoroalkyl Substances at Base Realignment and Closure Locations (May 2022)

PFAS, Covered Area

PDASD(EI&E) Memorandum Public Disclosure of Department of Defense Testing Results of Per- and Polyfluoroalkyl Substances in Drinking Water Within a Covered Area (April 2022)

PFAS, State Standards

Assistant Secretary of Defense for Sustainment (ASD[S]) Memorandum Department of Defense Guidance on Using State PFAS Drinking Water Standards in Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Removal Actions (December 2021)

PFAS, Non-Drinking Water Testing

Update for Establishing a Consistent Methodology for the Analysis of Per- and Polyfluoroalkyl Substances in Media Other than Drinking Water, DoD Memo (December 2021)

Provides guidance on the use of Draft Method 1633 for the analysis of PFAS in matrices other than drinking water.

PFAS Navy Policy

Memorandum for CNIC on PFAS and Identification of Potential of Concern (AOCs) (2016)

DoN Strategy Policy that includes three enclosures: PFC/PFAS DERP Site and AOC Identification, Validation, Prioritization, and Response Process, DERP Sites with Potential PFC/PFAS Contamination and Potential PFC/PFAS AOCs list, and PFS/PFAS Release Mechanisms

PFAS, Risk, Regulatory Requirements

PFAS Site Guidance for NAVFAC RPMs (November 2020)

Assists RPMs with programmatic and technical issues related to PFAS including funding responsibilities, risk assessment, and regulatory requirements.
This Guidance supersedes and replaces previous Interim PFAS Site Guidance/FAQs issued on 28
September 2017.

PFAS Removal, Disposal

Aqueous Film Forming Foam (AFFF) Control, Removal, and Disposal Policy, DON Memo (June 2016)

Addresses the control, removal, and disposal of both legacy and uninstalled AFFF materials containing perfluorooctane sulfonate (PFOS)/perfluorooctanoic acid (PFOA). Policies are aimed to prevent routine uncontrolled environmental release of AFFF.

PFAS, Drinking Water Testing

Perfluorinated Compounds (PFCs) Drinking Water System Testing Requirement, DON Memo (June 2016)

DON policy highlighting the updated U.S. Environmental Protection Agency (EPA) healthy advisory for PFOA/PFOS and subsequent actions.

PFAS Site Identification; Release Mechanisms

PFC/PFAS – Identification of Potential Areas of Concern (AOCs), DON Memo (June 2016)

Provides policy on identifying, validating, prioritizing, and responding to PFAS-contaminated sites and AOCs.

PFAS, Drinking Water Testing

Testing DoD Drinking Water for PFOS and PFOA, DoD Memo (June 2016)

Requires testing of the finished drinking water for PFOS and PFOA at all installations where DoD is the water purveyor (including overseas).

PFAS, Drinking Water Testing

Testing for PFCs in Drinking Water, Bureau of Medicine (BUMED) Memo (December 2015)

DON policy for sampling and testing of PFOS/PFOA in drinking water and communicating results in coordination with regional and installation Drinking Water Managers and Navy Medicine Regions.

PFAS, Drinking Water Testing

Navy Drinking Water Sampling Policy for Perfluorochemicals, PFOS, and PFOA, OPNAV CNO N45 Memo (September 2015)

Establishes policy for the sampling and testing of PFOS/PFOA in drinking water at certain Navy installations worldwide.

PFAS, Drinking Water Testing

PFCs – An Emerging Environmental Issue, DON Memo (October 2014)

Summarizes PFOS/PFOA sampling requirements and the DON plan of action for the identification and remediation of contaminated drinking water sites.

Perchlorate

Perchlorate Release

Navy Perchlorate Release Management Policy (March 2010)

Updates Navy policy on management of perchlorate releases at DoD installations, including operational ranges and Government owned-contractor operated (GOCO) facilities, Base Realignment and Closure (BRAC) sites, and formerly used defense sites (FUDS) in the United States. 

Perchlorate Release

DoD Memorandum on Perchlorate Release Management Policy (April 2009)

Updates DoD policy on management of perchlorate releases at DoD installations, including operational ranges and GOCO facilities, BRAC sites, and FUDS in the United States.

Perchlorate Sampling; Quality

DoD Perchlorate Handbook (August 2007)

Ensures consistent approaches are used for sampling and testing activities involving perchlorate, so that collected data are of the quality necessary to support site decisions.

Perchlorate Sampling

Navy Perchlorate Sampling and Management Policy (May 2006)

Provides Navy policy for sampling and management of perchlorate sites, including defining a level of concern.

Other Emerging Contaminants

Lead

NAVFAC Guidance on Lead-Based Paint (January 2014)

Provides RPMs with direction on both programmatic and technical issues related to lead-based paint at ER sites, including funding, risk assessment methodology, and regulatory requirements.

Asbestos

NAVFAC Asbestos Guidance and Frequently Asked Questions (FAQs) (May 2012)

Provides direction on evaluating asbestos at ER sites including funding responsibilities, risk assessment methodology, other technical issues, and regulatory requirements. 

Topics

Title and Description

Leaching

Assessing PFAS Leaching from Soil to Groundwater (March 2025)
This fact sheet explains how different PFAS migrate through the vadose zone, how to estimate groundwater recharge rates, and how to estimate PFAS concentrations in porewater. In addition, awareness of new sensor-based methods for monitoring soil conditions may help in better understanding and managing PFAS leaching to groundwater.

Thermal Desorption

Thermal Desorption of PFAS from Soil (March 2025)
This fact sheet goes over thermal treatment as an approach to remove PFAS from soil. Two case studies and lessons learned are discussed. 

EDQW, Holding Times

DoD EDQW Memorandum: Recommendation to Address Shorter Holding Times for Specific PFAS When Using EPA Method 1633 for PFAS investigations (March 2025)

 

EDQW, ISM

DoD Environmental Data Quality Workgroup (EDQW) Memorandum: Issues with Applying the Incremental Sampling Methodology to PFAS Investigations (January 2025)

 

1,4-dioxane

DON 1,4-Dioxane Guidance/Frequently Asked Questions (FAQ) (September 2018)
Developed to assist with programmatic and technical issues related to 1,4-dioxane related to: investigation, sampling, regulatory standards, risk assessments, and remedy considerations.

ECs, Response Triggers

Initiation of ECs Characterization and Response Actions for Protection of Human Health Environmental Council of the States (ECOS)-DoD Sustainability Workgroup Issue Paper (September 2008)
Helps to inform decisions related to characterization and response actions for ECs and summarizes triggers for action, response selection, and funding.

ECs, Risk Communication

ECs Risk Communication Principles, ECOS-DoD Sustainability Workgroup – ECs Task Group (July 2007)
Provides specific principles of good risk communication and resources on EC issues.

ECs, Toxicity Values

Identification and Selection of Toxicity Values/Criteria for CERCLA and Hazardous Waste Site Risk Assessments in the Absence of Integrated Risk Information System (IRIS) Values, ECOS-DoD Sustainability Workgroup – ECs Task Group (April 2007)
Identifies approaches to the selection of toxicity values/criteria in the absence of an IRIS values.

EC Research

PFAS, ISTT

Environmental Security Technology Certification Program (ESTCP) ER20-5250 In Situ thermal Treatment (ISTT) of PFAS in the Vadose Zone
ISTT will be demonstrated for PFAS removal from unsaturated soil coupled with destruction of PFAS condensate using ultraviolet (UV)-sulfite and hydrothermal destruction technologies.

PFAS, Characterization

ESTCP ER24-8303 Sorbent On-site Testing Apparatus (SOTA) for Rapid Evaluation of Novel Sorbents
This project improves on the first version of the portable Sorbent Onsite Testing Apparatus (SOTA) developed at Naval Information Warfare Center Pacific and initially demonstrated under the Navy Environmental Sustainability Development to Integration (NESDI) program, which allows rapid and inexpensive on-site testing of sorbents. 

PFAS, Characterization 

SERDP ER24-4485 PFAS in Gaseous-phase Transport: Partitioning Mechanisms and Modeling
This project aims to provide an improved understanding of the potential occurrence and transport of semi-volatile PFAS in the vadose zone by (a) investigating the occurrence and migration of PFAS in the gaseous phase and (b) assessing the applicability of mathematical models to predict the potential for vapor transport.

PFAS, Treatment

ESTCP ER22-7338 Bench-Scale Evaluation of Supercritical Water Oxidation (SWCO) to Destroy PFAS in Aqueous Investigation-Derived Waster and Complex Waste Streams 
Demonstrates the destruction of PFAS in several aqueous-impacted media using a bench-scale SWCO system.

PFAS, Oxidation

ESTCP ER-201729: Field Demonstration to Enhance PFAS Degradation and Mass Removal using Thermally-Enhanced Low-pH Persulfate Oxidation Followed by Pump-and-Treat
Demonstrates a treatment-train approach using persulfate followed by extraction and activated carbon treatment.

PFAS, Characterization

ESTCP ER-201633: Characterization of the Nature and Extent of PFAS in Environmental Media at DoD Sites for Informed Decision Making
Determines the nature and extent of PFAS source areas and identifies factors such as soil characteristics and groundwater redox potential that affect PFAS transport.

PFAS, Treatment

NESDI 615: Ex-situ Concentration and Destruction of PFAS from Aqueous Wastes
Develops a paired treatment approach or set of approaches that can be rapidly implemented at Navy sites to preconcentrate and destroy PFAS in compliance-relevant, low-volume and complex waste streams where large-scale systems are not appropriate.

PFAS, Treatment

NESDI 608: Application of Supercritical Water Oxidation to Destroy Per and Polyfluoroalkyl Substance Impacted Waste Streams
Demonstrates the efficacy of a mobile SCWO system to destroy PFAS in aqueous PFAS-impacted media.

PFAS, Treatment

NESDI 606: XCPC Solar Thermal Evaporation for PFAS-Impacted Wastewater Minimization
Demonstrates and evaluates a solar thermal evaporation system comprised of commercial off-the-shelf (COTS) thermal evaporators combined with a solar thermal system for the purpose of minimizing PFAS found in wastewater at Department of Defense (DoD) facilities.

PFAS, Treatment

NESDI 602: Closed Loop, In Situ Soil Flushing at PFAS-Impacted Source Zones
Demonstrates in situ soil flushing, used in conjunction with sorption and destructive treatments as a viable method for the removal and subsequent destruction of PFAS in affected soil.

PFAS, Characterization

NESDI 601: Chronic Toxicity and Bioaccumulation Evaluation of Multiple PFAS for Benthic and Pelagic Species Relevant to Marine Ecological Risk Assessment
Produces acute and chronic toxicity and bioaccumulation data for 10 priority PFAS.

1,4-Dioxane, Biodegredation

NESDI Project 579: In Situ Biodegradation of 1,4-Dioxane and Chlorinated Solvent Mixtures in Dilute Plumes
Utilizes soluble food-grade substrates to promote the in situ cometabolic treatment of 1,4-dioxane and chlorinated VOCs.

PFAS, Treatment

NESDI 578: Mesocosm Field Testing of In situ PFAS Treatment Trains
Demonstrates an efficient method to evaluate promising in situ adsorptive amendment materials to treat PFAS in groundwater

PFAS, Treatment, Polymer

NESDI Project 577: Demonstrating the Use of a Novel, Hybrid Polyelectrolyte/Hydrophilic Polymer for In Situ PFAS Treatment Applications
Demonstrates control of a PFAS groundwater source zone by treating it with polydiallyldimethylammonium chloride (polyDADMAC).

PFAS, Treatment, CAC

Navy Environmental Sustainability Development to Integration (NESDI) Project 569: Field Demonstration of Colloidal Activated Carbon (CAC) for In situ Sequestration of PFAS
Demonstrates the field application of CAC for the in situ sequestration of PFAS in groundwater.

 

 

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