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Emerging Contaminants

Overview

The Department of Defense (DoD) protects readiness, people, and the environment by identifying and managing risks associated with emerging contaminants (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.


Click here to view the list of DoD 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 Public Health Center 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 4715.8 Emerging Contaminants (June 2009)
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, 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

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, 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, 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.

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).

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 Project 555: Demonstrating the Effectiveness of Novel Treatment Technologies for the Removal of PFAS from Groundwater
Demonstrates various PFAS adsorbent media through batch and column testing in comparison to granular activated carbon (GAC).

PFAS, Sampling

NESDI Project 534: Technology Evaluation and Sampling for Treatment of Perfluorochemicals
Studies how co-contaminants impact the degradation or persistence of PFAS in groundwater.

PFAS, Characterization

NESDI Project 527: Structure Function Relationship and Environmental Behavior of PFAS from AFFF
Gathers information on transport and exposure pathways for PFAS sites.

 

 

Topics

Title and Description

DON PFAS

ASN (Energy, Installations, & Environment) PFC/PFAS Web Page

NMCPHC

Navy Marine Corps Public Health Center (NMCPHC) Environmental Programs

Air Force

U.S. Air Force Emerging Issues and Emerging Contaminants Web Page

Air Force

U.S. Air Force PFAS Web Page

NAVFAC

NAVFAC PFAS Reading Room

DoD

DoD Chemical and Material Risk Management (CMRM) Program

DoD SERDP ESTCP

DoD SERDP-ESTCP Focus Area: PFAS and AFFF

EDQW

Environmental Data Quality Workgroup (EDQW)

ATSDR

Agency for Toxic Substances and Disease Registry (ATSDR) PFAS Information

EPA

EPA Emerging Contaminants and Federal Facility Contaminants of Concern Factsheets

EPA

EPA PFAS Web Page

ITRC

Interstate Technology and Regulatory Council (ITRC) PFAS Documents

NIEHS

National Institute of Environmental Health Sciences (NIEHS) PFAS Web Site

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