Army closes PFAS investigations at 8 bases in Hawaii claiming facilities are not contaminated
Evidence suggests otherwise.
By Pat Elder
December 2, 2023
The Army says all future investigations and testing for PFAS have been called off at these facilities in Hawaii.
The Army is not being honest with the Hawaiian people about PFAS while they’ve contaminated the Hawaiian landscape with the deadly carcinogens that last forever. The Army has demonstrated no intention to clean up anything. They have examined their spotty historical record and say they can’t verify the use of aqueous film-forming foam (AFFF) at any of these bases.
The Army has stopped investigating PFAS at these installations:
USAG HI – U.S. Army Garrison
(1) USAG HI - Dillingham Military Reservation
(2) USAG HI - Kahuku Training Area
(3) USAG HI - Kipapa Ammunition Storage (4) USAG HI - Kunia Field Station
(5) USAG HI - Makua Military Reservation
(6) USAG HI - Waikakalaua Ammunition Storage Tunnels
(7) National Guard Fort Ruger
(8) National Guard Hilo AASF #2
The Army says historical documentation of PFAS use was not required “because PFAS were considered benign. Therefore, records were not typically kept by the facility or available during the Preliminary Assessment on the use of PFAS in training, firefighting, or other non-traditional activities, or on its disposition.”
The Army is not telling us the truth. As far back as the 1970s, studies conducted by the Department of Defense showed that the firefighting foams containing PFAS used on military bases were toxic.
Well-intentioned, yet unenforced congressional directives call for a thorough accounting of all uses of the toxins. The Army has been allowed to proceed with slipshod investigations of these facilities concentrating only on the use of PFAS in firefighting foams. They’ve only addressed 3 of the more than 15,000 PFAS compounds known to exist.
They can also shirk their responsibilities because Hawaiian officials let them. After all, The Hawaii Army National Guard is an organized state militia force and a federal military reserve force of the United States Army. It serves under the President of the U.S. and the Governor of Hawaii. Both entities bear responsibility here.
The Army wants us to believe the carcinogenic foams were never used in multiple accidents involving the crashes of aircraft, including eight at Hilo International Airport alone. They want us to believe that airport hangars were outfitted with PFAS-laden foams everywhere across the country except for Hawaii. They say tunnels where ammunition is kept were never fitted with foams containing PFAS. The Army in Hawaii ignores sewer plants as a receptacle for PFAS and they deny that the pesticides they use contain a drop of PFAS.
The Army has brazenly used a template across the country to fill in blanks with lies.
These same words are used at more than three dozen Army installations across the country to eliminate areas from further investigation, or to exit the CERCLA process altogether: “Documentation specific to AFFF may have been limited (e.g., each AFFF use, procurement records, documentation of AFFF used during crash responses or fire training activities) due to lack of recordkeeping requirements for the full timeline of common AFFF practices.”
Because the Army claims it kept lousy records it will assume there was no use of PFAS to close the books on these facilities.
This entire “investigative” charade avoids an examination of the use of PFAS in a host of military applications like wire coating, chrome plating, degreasing, and wash racks. Hawaii is poisoned by the Army and so are its living creatures.
We’ll examine the Army’s sketchy record at these bases.
The Army is far behind the other military branches in addressing the threat to public health posed by its use of PFAS. Just recently, the Army created a page with links to all CERCLA-related files for bases in every state. See ARMY PER- AND POLYFLUOROALKYL SUBSTANCES (PFAS) STATUS
All of the military branches are required to follow the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), a law known as the Superfund, passed by Congress in 1980. The first step in the CERCLA process is the publication of the Preliminary Assessment which involves an exhaustive report by 3rd-party engineers who provide reviews of the historical record and conduct field visits to determine the likelihood of PFAS contamination at an installation. Until this year the Army had not published a single preliminary assessment for any installations in Hawaii aside from Fort Ruger, although many of the newly arrived reports appear to be back dated.
Section 315 of the National Defense Authorization Act (NDAA) of 2019 calls on the DOD to “assess any contamination at Department of Defense installations and surrounding communities that may have occurred from PFAS usage by the Department of Defense.” The legislation, along with successive NDAA’s, refers to PFAS, whether it is contained in a host of military applications - or if it is found in the fire-fighting foams.
Regardless, the Army is severely limiting most of its investigations by only pursuing PFAS contained in the fire-fighting foams.
The recent publication of numerous Army reports addressing PFAS contamination are all titled the same way: “Final Preliminary Assessment of Per- and Polyfluoroalkyl Substances.” This suggests an investigation of all PFAS compounds in all applications on their installations, but the Army is only focusing on three PFAS compounds: PFOS, PFOA, and PFBS.
In 2018 the Army published Guidance for Addressing Releases of Per-and Polyfluoroalkyl Substances (Army 2018). This directive defines the suite of chemicals to include, but not be limited to the following: PFOS, PFOA, PFBS, PFDA, PFDoA, PFHpA, PFHxS, PFHxA, PFNA, PFTA, PFTrDA, PFUnA, PFDS, PFBA, PFOSA, PFPeA, NEtFOSAA, NMeFOSAA.
The 2018 guidance identifies environmental releases of PFAS in the use of mist suppressants for chrome plating operations, landfills, and wastewater treatment plants. These sources of contamination are generally ignored by the Army while their bases are being systematically eliminated from the CERCLA process.
We’ll first examine the Dillingham Military Reservation Army Garrison, an installation the Army says requires no further CERCLA action. Dillingham is included in the Preliminary Assessment for Per- and Poly Fluoroalkyl Substances (April, 2022) with five other facilities: Kahuku Training Area, Kipapa Ammunition Storage Site, Kunia Field Station, Makua Military Reservation, or the Waikakalaua Ammunition Storage Tunnels. The Army reports that no “areas of potential interest” were identified so all future investigations and testing for PFAS have been called off.
The Dillingham Military Reservation consists of three training areas; aircraft hangers; a joint-use civilian/military airfield with a runway with associated critical infrastructure. Dillingham Airfield is owned by the U.S. Army and managed by the Hawaii Department of Transportation Airports Division (HDOTA) under authority of a revocable lease. The field is a joint-use airfield with the Army having first priority for air-land operations and helicopter night-vision training.
In the 1970’s the Department of Defense began using AFFF to fight fuel fires at all military installations. Still, the Army claims Dillingham, Kahuku Training Area, Kipapa Ammunition Storage Site, Kunia Field Station, Makua Military Reservation, and the Waikakalaua Ammunition Storage Tunnels are the exceptions.
Army airfields are believed to be outfitted with firefighting equipment using aqueous film-forming foam, (AFFF). Hangars are typically equipped with suppression systems that use the carcinogenic foams. Until recently, firetrucks routinely practiced with the materials.
The Hawaii Department of Transportation says the use of AFFF is necessary for firefighting at airports due to the nature of aircraft fuel fires.
The Hawaii Fire Code Chapter 21 – Airports and Heliports mandates the use of AFFF foams which contain PFAS. “21.3.4.6.1.2 - The foam discharge rate for the fire-extinguishing system shall be 0.10 gpm/ft2 (4.1 L/min•m2) for aqueous film forming foam (AFFF).”
The Army says it examined the historical record and can’t verify the use of AFFF at any of the six bases. The preliminary assessment for Dillingham says, “Available data indicated there was formerly a fire station, as well as a pick-up truck with a skid mount on the back and a 500-pound dry chem extinguisher system, at Dillingham Military Reservation. However, USAG-HI, Honolulu Airport Fire Rescue, and Dillingham Airfield personnel noted there were no known or documented AFFF storage locations, locations where AFFF was used (including fire response sites), or AFFF disposal locations at the fire station or elsewhere on the installation. They claim there were also no known or documented areas where AFFF was used (including at fire response sites), stored, or disposed at Dillingham.”
It may be true that at some point in the history of the Dillingham Military Reservation a firetruck was mounted with a 500-pound dry chem fire extinguisher and it may also be true that interviews with a few unnamed individuals in the chain of command could not recall specific instances of the use of AFFF.
A retired civil engineer with a lifelong knowledge of the Army’s environmental record said, “The Army will get away with whatever it says here. They pissed this stuff in their sleep.” We’ll examine evidence pointing to the use of AFFF at the other facilities.
Pesticide use
The Army denies the use of pesticides that are known to contain high levels of PFAS. They write, “Following document research, personnel interviews, and site reconnaissance at USAG-HI Subinstallations: Dillingham Military Reservation, Kahuku Training Area, Kipapa Ammunition Storage Site, Kunia Field Station, Makua Military Reservation, or the Waikakalaua Ammunition Storage Tunnels, other potential PFAS source types were either not identified at the installations or did not prompt further research or constitute categorization as areas of potential interest.”
At face value this statement is true. They’re not saying pesticides containing PFAS were not used. Instead, they’re saying they simply didn’t care to investigate it.
From the preliminary assessment: “It was noted during a discussion with a U.S. Army Environmental Command (USAEC) Pest Management Consultant that the larger group of pesticides are generally not of PFAS concern. Specifically, products containing Sulfluramid (i.e., associated with insecticides) may have contained PFAS and were phased out in 1996. The USAEC Pest Management Consultant has records of pesticides used and stored at Installation Management Command installations and did not identify DMR, KTA, KASS, KFS, MMR, or WAST as installations ever containing PFAS-containing pesticides/insecticides.”
These words are being repeated verbatim in preliminary assessments by the Army across the country. Here are a few examples:
The National Training Center and Fort Irwin, California
New Century Aviation Support Facility (ASF), Kansas
Fort Knox, Kentucky
Rock Island, Illinois
Carlisle Barracks, Pennsylvania
Fort Hamiliton, New York
Presidio of Monterey and Ord Military Community
Natick Soldier Systems Center, Massachusetts
Pueblo Chemical Depot, Colorado
McAlester Army Ammunition Plant, Oklahoma
Aberdeen Proving Ground, Maryland
Letterkenny Army Depot, Pennsylvania
United States Army Garrison- West Point, New York
This land is your land. This land is my land - from California to the New York Island.
Although each of these reports are dated at different months in 2022, 2023 they don’t appear to have been made public until very recently. Huge chunks of text are repeated word for word in reports on bases nationwide. The Army apparently created a template and filled in the blanks to create the impression of conducting thorough and legitimate investigations.
The DOD’s use of dangerous pesticides is clearly documented. Throughout DOD installations, Abamectin has been widely used for ants and cockroaches. Imidacloprid has been used for flea control, and Malathion for mosquitoes. See, also DOD Contingency Pesticides.
These pesticides are heavily laden with PFOS, according to a study in the Journal of Hazardous Materials Letters PFOS, which bioaccumulates in fish, was found in 6 out of 10 tested insecticides at incredibly high levels, ranging from 3,920,000 to 17,800,000 parts-per-trillion (ppt) in pesticides used on military bases.
The toxins are also being taken up into the roots and shoots of plants, which means that they are entering our food supply through contaminated soils.
PFOS (mg/kg)
Abamectin 3.92 ± 0.51 (3,920,000 ppt ± 510,000 ppt)
Imidacloprid 13.3 ± 1.4 (13,300,000 ppt ± 1,400,000 ppt)
Malathion 17.8 ± 0.7 (17,800,000 ppt ± 700,000 ppt)
But what do we really know about the pesticides without investigatory powers and access to these facilities?
It’s a Catch - 22.
Waste disposal
The preliminary assessment includes a discussion of the sewer system at the Dillingham Military Reservation, but does not point to the sewer as a potential location of PFAS contamination. Instead, the report leaves it alone and proceeds to claim there were no known or documented areas where AFFF was used at the Dillingham Military Reservation. They’re deceiving the public into thinking that AFFF is the only source of PFAS on their installations.
We see it clearly in the Helemano Military Reservation Final Preliminary Assessment, (Sept. 2023). This report documents the use and spillage of PFAS at the fire station. However, the preliminary assessment discounts the possibility of PFAS being discarded at the former sewage treatment plant because, they argue, the sewage treatment plant did not receive wastewater from the fire station. Certainly, the AFFF at the fire station is not the only potential source of PFAS on the installation. Wastewater treatment plants function as grand central stations for PFAS.
The Elusive Appendix E
The Preliminary Assessment for Dillingham includes this memorable line, “A comprehensive well survey was not completed as part of this Preliminary Assessment; therefore, the information reviewed regarding off-post wells is limited to what is contained in the EDR well search results (Appendix E).”
There was no Appendix E to be found in the report or any of the reports on the installations shown below. EDR is Environmental Data Resources, Inc., a for-profit entity that generates environmental reports from a variety of state, city, and other publicly available databases for a referenced property. There’s a serious paywall involved in accessing the data.
All of this is deeply ironic because commercially available and extraordinarily reliable PFAS water test kits can be purchased for $79. If the Army invested a few hundred dollars it could ascertain the presence of PFAS in wells on and off the Dillingham base. In this sense, the Army is abusing the CERCLA process. If there is a shadow of doubt regarding the presence of PFAS in groundwater wells it would be a snap to conduct a cursory evaluation. It’s also pretty simple to test surface waters draining from these bases. Instead, the Army is closing the books.
Keeping in line with its preference for creating one-size-fits-all templates, the Army’s preliminary assessments for PFAS at the following installations contain the exact same lines, citing the elusive Exhibit E.
Military Ocean Terminal Concord, California
Pueblo Chemical Depot, Colorado
New Century Aviation Support Facility (ASF), Kansas
Carlisle Barracks, Pennsylvania
Aberdeen Proving Ground, Maryland
Fort Lee, Virginia
Presidio of Monterey and Ord Military Community, California
Joint Systems Manufacturing Center, Ohio
Anniston Army Depot, Alabama
Former Jefferson Proving Ground, Indiana
Lake City Army Ammunition Plant, Missouri
Natick Soldier Systems Center, Massachusetts
United States Army Garrison- West Point, New York
This land is your land. This land is my land -
from California to the New York Island.
There was a big, high wall there that tried to stop me.
A sign was painted said "Private Property."
But on the backside, it didn't say nothing.
This land was made for you and me.
Woody Guthrie - This Land is Your Land
Of the eight facilities identified by the Army for no further action in Hawaii, six were described in the Final Preliminary Assessment of Per-and Polyfluoroalkyl Substances, April, 2022. They are, (abbreviated): Dillingham, Kakuku, Kipapa, Kunia, Makua, and Waikakalaua. The Army, insisting that its charge is to identify the presence or use of AFFF, claims there are no available records to indicate the foams were used, stored, or disposed of at these installations so they are not moving ahead to test these facilities for the presence of the toxins.
A closer examination of the record raises serious issues.
Kahuku Training Area The Army says the Kahuku Training Area warrants no further action regarding the use of PFAS although reading thorough the narrative suggests the use of PFAS in the wash rack and in the firefighting foams. The carcinogens are often used in wash racks on bases.
From p. 33 – “KTA has a septic tank for the wash rack, which was installed circa 2013. Detergents and waxes are not used at the wash rack and no fire truck has been used (or deployed AFFF) at KTA since the new wash rack became operational.” This statement leaves open the likelihood that was used PFAS prior to 2013.
p. 34 – “Two Black Hawk helicopters collided at KTA during a night training exercise on 12 February 2001. Honolulu County Fire Department personnel confirmed that, since 2000, they have not responded to any calls at KTA in which AFFF was used."
This leaves open the possibility that PFAS may have been used in crashes prior to 2000. The Army claims there were no known or documented areas where AFFF was used (including at fire response sites), stored, or disposed of at KTA.
Kipapa Ammunition Storage Site (KASS) Army Garrison
P. 34 – “KASS, which consists of 80 underground storage tunnels, was constructed during World War II for storing incendiaries and high explosives, was later used to store insecticides and chemical agents, and was subsequently put out of service in the early 1960s and 1970s (USAG-HI 2016a). According to FFD personnel, there may have been a fire station (Fire Station 6) at KASS that was closed in the early 1990s; however, they could not confirm whether or not there was a fire station at KASS or if the fire station was in a different location. There are no available records to indicate AFFF was used, stored, or disposed of at the installation.”
We’ve seen how the Red Hill Bulk Fuel Storage Facility was fitted with an extensive overhead fire suppression system loaded with foams containing PFAS. Throughout the military fuel and munitions facilities were typically outfitted with firefighting foams containing PFAS beginning in the early 1970’s.
Kunia Field Station The Army says there’s no reason to suspect the use of PFAS in or around the Kunia Field Station Army Garrison although high levels of carcinogen PFAS were found in the drinking water at nearby Kunia Village in 2022. The chemicals were found to be thousands of times over EPA health advisories. The state downplayed the threat to public health and suggested that concerned residents in the low income residential area use home filtration systems to reduce the PFAS levels in their drinking water.
The PFAS in Kunia’s water likely comes from five Army installations in the immediate vicinity that send their wastewater to the privately owned Schofield Barracks Wastewater Treatment Plant. The tainted waters are re-used for agricultural purposes, potentially causing groundwater and surface water contamination. The Schofield Barracks Wastewater Treatment Plant provides treatment for wastewater received from Schofield Barracks, Wheeler Army Airfield, Camp Stover, Kunia Military Reservation, and Helemano Military Reservation.
The preliminary assessment says there were no known or documented areas where AFFF was used at Kunia Field Station.
Makua Military Reservation Likewise, the Army has closed the books on the Makua Military Reservation. On P. 34, the Preliminary Assessment says, “Makua Military Reservation has designated helicopter landing pads (CEMML 2010). Helicopters were required to be on the installation for firefighting purposes when live-fire training occurred (CEMML 2010). Live-fire training ceased at MMR in 2004 and, in 2011, the Army announced that live-fire training would not be resumed at MMR (GSL 2015). Based on available electronic records dating as far back as 2000, Honolulu County Fire Department personnel confirmed that, since 2000, they have not responded to any calls at MMR in which AFFF was used. There are no available records to indicate AFFF was used, stored, or disposed of, and no interviewees had knowledge of AFFF use, storage, or disposal, at helipads on the installation.”
The Army is not saying AFFF was not used historically, and it is not saying the carcinogens are not being used today.
P 36 - “Documentation specific to AFFF may have been limited (e.g., each AFFF use, procurement records, documentation of AFFF used during crash responses or fire training activities) due to lack of recordkeeping requirements for the full timeline of common AFFF practices.”
Because the Army claims it kept lousy records it will assume there was no use of PFAS to close the books on this facility. It’s another Catch-22.
This same rationale and the exact same words are used at more than three dozen Army installations across the country to eliminate areas from further investigation or to exit the CERCLA process altogether.
The PFAS report for Makua Military Reservation, contains additional boilerplate language: “Anecdotal accounts of AFFF use (and therefore likely PFOS, PFOA, and PFBS use) were limited to available installation personnel, whose knowledge of AFFF use may have been restricted by their time spent at the installation or previous roles held that limited their relevant knowledge of potential AFFF (or other PFAS-containing material) use.”
Now, we get a little closer to the truth. There is anecdotal evidence of the use of AFFF at the Makua Military Reservation. The report concludes like the others,
“There were also no known or documented areas where AFFF was used (including at fire response sites), stored, or disposed of at Makua Military Reservation.”
The Army also claims the Waikakalaua Ammunition Storage Tunnels never used PFAS. We saw the same claim with the Kipapa Ammunition Storage Site.
Engineers who track these things for the Army will explain how difficult it is to believe that AFFF have never been used or stored since the 1970’s in the ammunition storage tunnels, the hangars, the wash racks, the firetrucks, fire training areas, or used during emergency situations at any of these six installations.
It’s a stretch.
The Army has identified two additional bases in Hawaii where no further action on PFAS is warranted: Fort Ruger, and Hilo Army Aviation Support Facility.
Fort Ruger’s Preliminary Assessment in September 2020: “There is no potential for exposure to PFAS contamination in soil, groundwater, surface water, and sediment.” Considering the history of the base, this may be true, but we don’t know and we don’t trust them. The public knows Fort Ruger as the Diamond Head State Monument.
Hilo Army Aviation Support Facility #2 The Preliminary Assessment Report of the Hilo Army Aviation Support Facility #2 claims the base has not contaminated the soil, groundwater, surface water, or sediment at the facility with PFAS.
The Army says the “use and storage of AFFF at the Hilo International Airport are unknown. Eight major air incidents have occurred at the airport, but the response actions, location, and extinguishing agents used (if any) are unknown for each incident (Hawaii.gov, 2020).”
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“If the DOD says all Army installations have used PFAS in firefighting foams, especially in major air accidents, and the state actually mandated its use, how can the Army say the use of AFFF at Hilo is unknown?”
“It’s a Catch-22!”
“They don't have to tell us the truth? Why not?”
"The law says they don't have to."
"What law says they don't have to?"
"Catch-22."
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The Army is continuing to conduct very limited investigations at the following bases. In Part 2 we will look at the work the Army has done to justify eliminating potentially toxic sites from cleanup at these 8 installations:
(1) Active USAG HI - Fort Shafter/Tripler Army Medical Center
(2) Active USAG HI - Hawaii - Wheeler Army Airfield
(3) Active USAG HI - Helemano RAD REC Station
(4) Active USAG HI - Kilauea Military Reservation
(5) Active USAG HI - Pohakuloa Training Center
(6) Active USAG HI - Oahu - Schofield Barracks
(7) National Guard Kalaoloa Facility (Former Barbers Point NAS)
(8) National Guard Waiawa Unit Training Equipment Site
Sources:
Final Preliminary Assessment of Per- and Polyfluoroalkyl Substances’ - U.S. Army Garrison-Hawaii Sub-installations - Dillingham Military Reservation, Kahuku Training Area, Kipapa Ammunition Storage Site, Kunia Field Station, Makua Military Reservation, and Waikakalaua Ammunition Storage Tunnels
Prepared For: U.S. Army Corps of Engineers, Baltimore District 2 Hopkins Plaza Baltimore, Maryland 21201 April 2022 Arcadis. https://aec.army.mil/application/files/9816/7701/1471/USAG-HI_PFAS-PA.pdf
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Final Preliminary Assessment Report Fort Ruger, Oʻahu, Hawaiʻi Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic acid (PFOA) at Impacted Sites ARNG Installations, Nationwide September 2020 Prepared for: Army National Guard Bureau 111 S. George Mason Drive Arlington, VA 22204 AECOM https://www.nationalguard.mil/Leadership/Joint-Staff/Personal-Staff/Public-Affairs/Community-Relations/Environmental/PFAS-Library/Hawaii/FileId/287827/
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FINAL Preliminary Assessment Report Hilo Army Aviation Support Facility #2, Hawai‘i, Hawai‘i Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic acid (PFOA) at Impacted Sites ARNG Installations, Nationwide September 2020 Prepared for: Army National Guard Bureau 111 S. George Mason Drive Arlington, VA 22204 AECOM
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Spreadsheet of Installations where DOD Performing Assessment of PFAS Use or Potential Release September 30, 2019
https://www.documentcloud.org/documents/6816961-SPREADSHEET-of-INSTALLATIONS-WHERE-DOD
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Installations Where DoD is Performing an Assessment of PFAS Use or Potential Release March 17, 2020
https://media.defense.gov/2020/Mar/17/2002265607/-1/-1/1/SPREADSHEET_OF_INSTALLATIONS_WHERE_DOD_PERFORMING_ASSESSMENT_OF_PFAS_USE_OR_POTENTIAL_RELEASE.PDF
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Per- and Polyfluoroalkyl Substances at Base Realignment and Closure Locations Office of the Under Secretary of Defense for Acquisition and Sustainment January, 2023
https://www.acq.osd.mil/eie/eer/ecc/pfas/docs/reports/PFAS-at-Base-Realignment-and-Closure-Locations.pdf
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Report on Department of Defense’s Per- and Polyfluoroalkyl Substances Task Force Activities Office of the Assistant Secretary of Defense for Energy, Installations, and Environment January, 2023
https://www.acq.osd.mil/eie/eer/ecc/pfas/docs/reports/PFAS-Task-Force-Qtrly-RTC-FY22-Q3-Q4.pdf
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