Snell & Wilmer

On April 27, 2021 Governor Doug Ducey sent a letter to Secretary of Defense Lloyd Austin requesting the Department of Defense (DOD) identify and treat water in Arizona contaminated in the areas surrounding four defense installations and prevent additional human exposure to per- and polyfluoroalkyl substances (PFAS) from other DOD facilities in Arizona.

The four installations with known impacts to groundwater—Luke Air Force Base, Davis-Monthan Air Force Base, Morris Air National Guard Base and the former Williams Air Force Base—are located in the two most populous metropolitan areas in Arizona, and each is surrounded by businesses and residential communities where thousands of Arizonans live, work and rely on clean groundwater for drinking.

Governor Ducey specifically requested that the DOD:

  1. Share PFAS data related to Arizona installations to help determine the extent of PFAS impacts.
  2. Develop a preliminary conceptual site model for each DOD facility based on available groundwater, geological and facility data.
  3. Estimate a preliminary time range for when DOD-related PFAS plumes may reach public drinking water systems.
  4. Conduct accelerated remedial investigations with the primary purpose of designing early response actions to stop the PFAS plumes.
  5. Design and install early response actions to protect public drinking water systems at risk from DOD-related PFAS.

PFAS, sometimes identified as “forever chemicals”  have been in existence for approximately 80 years but are nevertheless still considered “emerging contaminants.”  They are typically utilized in the manufacture of products such as nonstick cookware, grease-resistant food packaging, stain repellents, and firefighting foams. PFAS can migrate into soil and groundwater during the manufacture and use of related products. PFAS contamination is increasingly being linked to military bases and airport locations where firefighting foams containing the forever chemicals are used in training exercises. Given the prevalence of PFAS, it is commonly believed that most Americans have been exposed to these chemicals at some point during their lifetimes. Human health impacts of PFAS exposure, if any, remain under scrutiny. Governor Ducey’s request to DOD is evidence of just that as concerns over PFAS in drinking water supplies escalate.

In his letter, Governor Ducey specifically noted that “the [PFAS] situation in Arizona deserves attention. Arizona, through the Arizona Department of Environmental Quality, is acting to contain the spread of PFAS now, and I ask [DOD] to make a similar commitment . . . for prompt remedial actions to address the DOD-related PFAS contamination of groundwater throughout Arizona and protect the health and safety of Arizonans.”

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