Military’s Filthy 50 sites contaminated with ‘forever chemicals’ haven’t started cleanup

The military has not begun cleanups at any of the 50 Department of Defense sites Congress has identified as highly contaminated with the “forever chemicals” known as PFAS – and it could be years before cleanups are complete.

Congress set a May 2022 deadline for the DOD to report on the cleanup status of these bases, the Filthy 50, with extremely high levels of PFAS contamination. The Pentagon has not yet announced that it has completed the report.

EWG conducted its own analysis of DOD documents to assess the status of the cleanups. It finds that, in many cases, an average of six years have passed between the date contamination was first suspected at a base and when the Pentagon started even drafting cleanup plans.

The DOD has made some progress in addressing PFAS contamination at these highly contaminated sites, but it has been slow, and there is a long road ahead. All 50 sites have completed or are conducting preliminary assessments, or PAs, and site inspections, or SIs, and they have all launched remedial investigations, or RIs. None have started formal cleanups. 

Filthy 50 military base cleanup status summary^[1]

• The PA/SI has been completed and the RI is underway at 14 installations.
• The PA/SI and RI are underway at 22 installations.
• The PA/SI has been completed and the RI has been planned at 12 installations.

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^{Source: EWG, from Department of Defense Manual, March 2012}

The RI stage comes early in the cleanup process outlined in the Comprehensive Environmental Response, Compensation, and Liability Act, also known as the Superfund law. It’s when the extent of PFAS contamination is determined, setting the stage for cleanup.

It has been a long process even to get to the RI stage. As DOD officials have testified, it could be decades before cleanup at these sites is complete. 

A review of available documents from each site reveals that it has taken the DOD nearly three years, on average, to complete each of the two previous stages in the cleanup process.

The first stage – testing soil and water to see whether the site is contaminated with PFAS – took an average of nearly two years and 11 months to complete.

The DOD then took an average two years and 8 months for the next stage, starting to draft a plan for cleaning up PFAS contamination it identified.

If the Pentagon sticks to the same timeline for the third stage, the actual cleanup work, the typical Filthy 50 site will have had known contamination for at least 10 years, with little work done to clean it up. That leaves service members, their families and surrounding communities potentially exposed to these toxic forever chemicals for years and years.

PFAS have been confirmed in the ground or drinking water of nearly 400 military installations and are suspected to be present at hundreds of other sites. DOD installations are required to provide water filters or connect nearby residents with public water supplies if PFAS levels exceed the Environmental Protection Agency’s advisory level of 70 parts per trillion. As of spring 2022, the department is providing alternative water or filtration for private or public systems outside of 53 military installations.

PFAS contamination at DOD sites is caused mostly by the use of firefighting foam made with PFAS. In the 2020 National Defense Authorization Act, Congress directed the DOD to end the use of foam made with PFAS. DOD officials testified last month that a more effective, PFAS-free foam will soon be available.

Last year, Congress provided more than $200 million for PFAS cleanup efforts at military installations and directed the DOD to provide a cleanup schedule by the end of October.

The Environmental Protection Agency is expected to lower the advisory level for PFOA and PFOS – two of the most notorious PFAS – in the coming months, and to set advisory levels for two other PFAS commonly found on military installations. The EPA has also pledged to set a mandatory drinking water standard for PFOA and PFOS by the end of 2023.

After the EPA sets the new advisories, DOD officials have said the Pentagon must reassess bases across the country to determine their contamination status. If the EPA lowers the advisories, more funding will be needed to make sure that drinking water used by service members and surrounding communities is safe to drink.

_{^[1]PA/SI completed and RI underway}

_{The base actively working on developing a cleanup strategy.}

_{PA/SI and RI underway}              

_{The base is actively working on developing a cleanup strategy, while at the same time conducting a wider investigation into PFAS contamination on or around the base. Usually, bases with this status are conducting an "Expanded Site Investigation," meaning they realized the contamination has likely spread farther than initially believed.}

_{PA/SI completed and RI planned}

_{Investigations determined there is a need to continue with the cleanup process and develop a strategy for it.}