Synthetic carbon-fluorine chemistry, now classified as per- and poly- fluorinated compounds (PFAS), are coming into focus today as fuelling an unprecedented environmental crisis. After the briefest moment of practical utility, PFAS compounds come to haunt life with roving mobility, torpid toxicity, and a monstrous immortality. As we now know, exposure to trace amounts of these “
forever chemicals” is strongly linked to a host of cancers, developmental disorders, immune dysfunction, and infertility. Exposure has also been linked to aggravated Covid-19 infections and weakened vaccine efficacy.
In its initial survey of military bases in December 2016, the Armed Forces identified
393 sites of AFFF contamination in the United States, including 126 sites where PFAS compounds infiltrated public drinking water. (The Department of Defense has active remediation plans at a small fraction of those sites.) In 2019, DOD admitted those numbers were “ under-counted.” The Environmental Working Group’s popular map of PFAS contamination puts the current number of polluted military sites at 704, a number that continues to rise.
As does potential liability. While some states file suit against the manufactures of AFFF, the fingerprints of the US Armed Forces are all over the scene of the crime. When federal scientists moved to publish a comprehensive review of the toxic chemistry of AFFF in 2018, DOD officials called that science “
a public relations nightmare” and tried to suppress the findings.
Beyond damning internal emails, the military is still in possession of a tremendous amount of AFFF. As the EPA and states around the US begin to designate
AFFF a hazardous substance, the military’s stockpiles of AFFF are starting to add up to an astronomical liability on the military’s balance sheet. Perhaps thinking the Trump Administration presented an opportune moment, the Pentagon decided to torch their AFFF problem in 2016.
Despite AFFF’s extraordinary resistance to fire, incineration quietly became the military’s preferred method to handle AFFF. “
We knew that this would be a costly endeavor, since it meant we’d be burning something that was engineered to put out fires,” Steve Schneider, chief of Hazardous Disposal for the logistics wing of DOD, said in 2017 as the operation got underway.
Only one detail stood in the way of this grand plan: there is no evidence that incineration destroys the toxic chemistry of AFFF.
Noting the “strong flame inhibition effects” of the carbon-fluorine bond, a 2020 EPA report concluded, “
It is not well understood how effective high-temperature combustion is in completely destroying PFAS.”
In a 2019 technical guide for incinerators, the EPA wrote that our grasp of the “
thermal destructibility” of PFAS is sparse, thinly extrapolated, and currently inoperable. An influential interstate environmental council refused to endorse burning AFFF last year, noting incineration is still “ an active area of research.”
Nor was such hesitation restricted to environmental agencies. Even as it was sending tanker trucks of AFFF to incinerators in 2017, the military itself noted “
the high-temperature chemistry of PFOS […] has not been characterized” (PFOS is the major PFAS ingredient in AFFF), and “ many likely byproducts will also be environmentally unsatisfactory.”
But that hasn’t stopped the Pentagon from going ahead and quietly burning the chemical anyway. As the military was sending AFFF to incinerators around the country, the EPA, state regulators, and university scientists all warned that subjecting AFFF to extremely high temperatures would likely conjure up
a witches brew of fluorinated toxins, that existing smokestack technologies would be insufficient to monitor poisonous emissions let alone capture them, and that dangerous chemicals might rain down on surrounding neighborhoods. Weighing out its own liability against the health of these communities, the Pentagon struck the match.
Like so much else in the Trump Administration, the reckless rush to burn AFFF unfolded almost completely out of public view. The
intrepid reporting of Sharon Lerner at the Intercept and an Earth Justice lawsuit against DOD opened a window into this debacle in 2019. As information percolated back into communities near the incinerators, spirited advocacy helped push the crackpot logic of the entire operation further into unflattering visibility in Ohio and New York.
This winter, I partnered with
citizens groups and national advocates to compile and publish all available data on the incineration of AFFF. As my students and I gathered together scattered shipping manifests, tracked down details about incineration facilities and nearby communities, and started to get our head around the toxic fallout of the burning AFFF, this militarized operation gained a new definition: gross negligence.
Not only is burning AFFF extremely ill-advised, but the six hazardous waste incinerators contracted to do so are habitual violators of environmental law. Since 2017, two of the contracted incinerators were out of compliance with some environmental laws 100% of the time according to the EPA (Clean Harbors incinerator in
Nebraska, Clean Harbors Aragonite in Utah), two were out of compliance 75% of the time (Norlite incinerator in New York, Heritage WTI incinerator in Ohio), and the remaining two were out of compliance 50% of the time (Reynolds Metals incinerator in Arkansas, Clean Harbors incinerator in Arkansas). The EPA has issued a total of 65 enforcement actions against these six incinerators in the past five years alone.
Not that the military was expecting the best. Even as it shelled out millions of dollars to the hazardous waste industry to burn AFFF,
the military did not specify burn parameters nor emission controls. The military also withdrew typical documentation requirements of hazardous waste, noting in the contract that incinerators “ will not be required to provide Certificates of Disposal/Destruction.” When it came to burning AFFF, the Pentagon didn’t want to know what was really going on at these incinerators.
Mixing shoddy burn operations with fire-resistant toxicity, this multi-million-dollar debacle did not so much eradicate the military’s AFFF problem as redistribute it.
The WTI Heritage Incinerator, which burned at least 5m pounds of AFFF, is located in a working class Black neighborhood in East Liverpool, Ohio. When it was built in 1993, residents were told this mammoth
incineration could help stem the exodus of factory jobs. Instead of paychecks East Liverpool got some of the worst pollution in the US. The modest homes and nearby elementary school have become home to appallingly routine emissions of dioxins, furans, heavy metals, and now PFAS. Residents call it what it is: environmental racism.
“We didn’t get any answers,”
Alonzo Spencer told me. Residents started asking the WTI Heritage Incinerator about AFFF last year. Describing rising rates of cancer in his community and worried about the “close proximity of the facility to schools,” Spencer doesn’t understand why the military and the incinerator would try to burn AFFF, nor why they are so secretive about it. “They just don’t seem to have any incentive to be truthful about what they’re doing to this community,” he said.
Tucked into a scrappy working-class neighborhood in Cohoes, NY, the Norlite Hazardous Waste Incinerator burned at least 2.47m pounds of AFFF and 5.3 million pounds of AFFF wastewater, likely in violation of their operating permits. In the shadow of the smokestack lies the Saratoga Sites Public Housing, a squat brick complex where emissions routinely cloud the playground. Over the past four years, residents told me of paint peeling from their cars and waking some nights to searing pain in their eyes. Norlite, they said, “tear-gassed” them in their own homes. The potential byproducts of subjecting AFFF to extremely high temperatures include
the wartime ingredients of tear gas.
Places like East Liverpool and Cohoes are the destinations of AFFF that we can track. Some 5.5m pounds of AFFF, 40% of military’s stockpile, was sent to “fuel-blending” facilities where it was mixed into fuels for industrial use. It is not clear where the AFFF laden fuel went next, although the DOD contract stipulates incineration should be the endpoint. If you live in the United States, it’s possible it might have been burned in your community. And, because AFFF is a “forever chemical” that doesn’t break down, that pollution could likely plague communities for generations.
While much remains out of public view, there is good reason to think the military continues to burn AFFF. It is well past time to enact sensible national restrictions on the incineration of AFFF and to begin robust investigations into the communities where AFFF was burned.
The very name of the Department of Defense speaks to the military’s duty to defend, not harm, its own people. By all accounts, the Pentagon is endangering the lives of countless people through its reckless handling of AFFF. Communities witnessing this environmental catastrophe first-hand demand justice and accountability. When will their government hear them?