Drinking Water: DOD Has Acted on Some Emerging Contaminants but Should Improve Internal Reporting on Regulatory Compliance
Fast Facts
DOD and EPA have found chemicals in drinking water at or near military installations that may cause cancer and other health issues. Some of these chemicals can be found in firefighting foam and rocket propellants.
DOD has taken steps to limit individuals' exposure to some chemicals, including providing alternative drinking water supplies and installing water treatment systems. Still, DOD's incomplete internal reporting limits its ability to monitor installation compliance with safe drinking water regulations.
This report makes 5 recommendations to improve DOD's data, reporting, and oversight of drinking water regulations.
Military installations where DOD has started to address elevated levels of two chemicals found in installation drinking water: Perflourooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA), as of March 2017
Map of the United States showing 11 locations.
Highlights
What GAO Found
The Department of Defense (DOD) has not internally reported all data on compliance with health-based drinking water regulations or used available data to assess compliance. DOD data for fiscal years 2013-2015 indicate that DOD public water systems complied with Environmental Protection Agency (EPA) and state health-based drinking water regulations at levels comparable with other systems in the United States. However, the military departments did not report all violations to DOD, i.e., while 77 installations reported violations to DOD, GAO found that at least 16 additional installations did not. Until DOD takes steps to increase the clarity and understanding of its internal reporting requirements, it may not have the data it needs to fully oversee compliance. DOD also has not used its data to determine why its two types of systems—one that provides DOD-treated water and another that provides non-DOD-treated water—have different compliance rates. Specifically, DOD's data indicate that about 99 percent of the people who received non-DOD-treated drinking water were served by systems with no violations, while about 89 percent of the people who received DOD-treated drinking water were served by systems with no violations. Absent further analysis of its data, DOD may not be able to improve overall compliance.
DOD has initiated actions to address concerns with both its firefighting foam and also with elevated levels in drinking water of perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), and perchlorate, which are DOD-identified emerging contaminants. PFOS and PFOA can be found in DOD's firefighting foam. DOD has restricted its use of this foam and is funding efforts to develop a new foam that meets DOD performance requirements. Additionally, at 11 military installations (see fig.), DOD has shut down wells, provided alternate water sources, or installed water treatment systems to respond to elevated levels of PFOS and PFOA, at times in response to EPA and state orders.
Military Installations Where DOD Has Initiated Actions to Address Elevated Levels of PFOS and PFOA in Installation Drinking Water, as of March 2017
Why GAO Did This Study
According to DOD, about 3 million people in the United States receive drinking water from DOD public water systems, which are to comply with EPA and state health-based regulations. EPA and DOD have detected elevated levels of two unregulated, DOD-identified emerging contaminants found in firefighting foam—PFOS and PFOA—in drinking water at or near installations. Perchlorate, an unregulated chemical used by DOD in rocket fuel, can also be found in drinking water.
The Senate Report accompanying a bill for national defense authorization for fiscal year 2017 included a provision for GAO to review DOD management of drinking water contaminants. This report examines the extent to which DOD has (1) internally reported data on compliance with health-based drinking water regulations at military installations and used those data to assess compliance at its two types of public water systems, and (2) taken actions to address concerns with its firefighting foam and elevated levels of PFOS, PFOA, and perchlorate in drinking water at or near military installations. GAO reviewed DOD guidance and EPA drinking water regulations, advisories, and orders; analyzed DOD and EPA drinking water data; and visited seven installations from among those addressing emerging contaminants in drinking water.
Recommendations
GAO is making five recommendations to improve DOD's reporting and use of data on compliance with health-based drinking water regulations. DOD concurred with the recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Defense | The Assistant Secretary of Defense for Energy, Installations, and Environment, in consultation with the Secretaries of the military departments, should identify and implement any necessary changes to DOD's environmental compliance policy to clarify DOD's reporting requirements for violations of health-based drinking water regulations. (Recommendation 1) |
DOD concurred with this recommendation. In April 2019, the Deputy Assistant Secretary of Defense (Environment) issued a memorandum to the military departments that updated the requirements for reporting violations of health-based drinking water regulations. The memorandum describes, among other things, the types of drinking water systems for which violations should be reported, what types of violations should be reported, and how that information should be reported. According to the memorandum, these updated requirements are to go into effect in fiscal year 2019. As a result, DOD should have improved oversight of compliance with health-based drinking water regulations at its installations.
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| Department of Defense | The Secretary of the Army should identify and implement actions to increase understanding at Army installations and commands about DOD's reporting requirements for violations of health-based drinking water regulations. These actions may include improved communication to or additional training for personnel. (Recommendation 2) |
DOD concurred with this recommendation. In May 2019, the Army stated that it has provided training to commands and installations on DOD's drinking water reporting requirements. The Army also revised its quarterly environmental data call memorandum to emphasize the requirement for installations to report violations of drinking water regulations. As a result, Army installations and commands should have a better understanding of DOD's reporting requirements, and DOD should have improved information on compliance with drinking water regulations.
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| Department of Defense | The Secretary of the Navy should identify and implement actions to increase understanding at Navy installations and commands about DOD's reporting requirements for violations of health-based drinking water regulations. These actions may include improved communication to or additional training for personnel. (Recommendation 3) |
DOD concurred with this recommendation. In May 2019, the Navy and the Marine Corps reported that they had taken steps to implement this recommendation. For example, the Navy provided training on DOD's drinking water reporting requirements to its regional water subject matter experts and also updated the database it uses to collect drinking water data to clarify what qualifies as a health-based violation. Similarly, the Marine Corps revised its instructions to installations for reporting drinking water violations to clarify what types of water systems need to be included in compliance reports. The Marine Corps also briefed installation and regional environmental chiefs on the findings of our report. As a result, Navy and Marine Corps installations and commands should have a better understanding of DOD's reporting requirements, and DOD should have improved information on compliance with drinking water regulations.
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| Department of Defense | The Secretary of the Air Force should identify and implement actions to increase understanding at Air Force installations and commands about DOD's reporting requirements for violations of health-based drinking water regulations. These actions may include improved communication to or additional training for personnel. (Recommendation 4) |
DOD concurred with this recommendation. In May 2019, the Air Force reported that it had taken steps to implement this recommendation. For example, the Air Force revised the questionnaire used to collect compliance data from installations to clarify what types of water systems should report and to provide additional guidance on what constitutes a health-based violation. Additionally, the Air Force provided training to its installations in May 2019 on our report findings and DOD's reporting requirements for violations of health-based regulations. As a result, Air Force installations and commands should have a better understanding of DOD's reporting requirements, and DOD should have improved information on compliance with drinking water regulations.
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| Department of Defense | The Assistant Secretary of Defense for Energy, Installations, and Environment, in consultation with the Secretaries of the military departments, should (a) review reported compliance data to identify the reasons for any differences in the number of violations of health-based drinking water regulations between DOD's two types of public water systems and (b) identify and implement any actions needed to address the causes of any differences in the number of violations between DOD's two types of public water systems. (Recommendation 5) |
DOD concurred with recommendation 5, to figure out why there are differences in the number of health-based violations found between DOD's two types of water systems. They agreed to review their internal compliance records and figure out what was happening. In September 2020, DOD identified factors that contributed to the difference in compliance between the two types of systems. For example, DOD reported to us that several systems serving large DOD populations (e.g., Camp Pendleton, Fort Irwin, Fort Stewart) had infrastructure problems requiring repairs that took several years to complete. According to DOD, that period of non-compliance significantly contributed to DOD's lower performance, but completion of plant upgrades at those locations has reduced the number of violations and improved DOD's compliance rate. Additionally, DOD found that violations by some non-DOD systems were not always reported during the reporting period. In response, the military services have been using an improved compliance database from the Environmental Protection Agency to more effectively capture non-DOD system violations, according to DOD. As a result, DOD data shows that, in fiscal year 2019, the compliance rate for DOD systems in the United States was 97.7 percent and the compliance rate for non-DOD systems was 96.5 percent. As a result of DOD's actions, the department has identified reasons for why differences existed between the two types of public water systems and has taken actions that appear to have narrowed those differences, thus meeting the intent of our recommendation.
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