Commentary on the minutes of the Pearl Harbor-Hickam-Kalaeloe Restoration Advisory Board (RAB) Meeting of September 25, 2024
By Pat Elder
December 11, 2024
Adit 6
My comments on bold.
The following segments pertain to the use of AFFF and/or PFAS.
Ms. Tamashiro from NAVFAC “explained that the Environmental Restoration Program is responsible for addressing historic releases of contaminants to the environment. The program does not address any releases from current facilities that are in operation, such as the Red Hill Drinking Water issues. Ms. Tamashiro described the time allotted for questions after the presentations.”
The key difference between the DOD Environmental Restoration Program (ERP) and Naval Facilities Engineering Systems Command NAVFAC regarding PFAS is that while the ERP sets the overall policy and framework for cleaning up PFAS contamination across all Department of Defense installations, NAVFAC is specifically responsible for implementing those cleanup actions at Navy and Marine Corps facilities, managing the environmental restoration process on those bases, including PFAS remediation, based on the broader DOD guidelines.
This is an important distinction because NAVFAC has neglected to publish a PFAS Site Inspection for JBPHH. This is a crucially important document that often exceeds a thousand pages for a facility this size and may include hundreds of sets of analytical data of PFAS is a host of environmental media like soil, subsurface soil, ground water, surface water, and sediment. We are proceeding blindly on PFAS without this important documentation.
NAVFAC follows the CERCLA process that is the Comprehensive Environmental Response, Compensation, and Liability Act, or Superfund. That process begins with a Preliminary Assessment, then follows with a Site Inspection. We cannot have a remedial investigation on AFFF without having the roadmap provided by the Site Inspection. That roadmap is initially prepared by the Preliminary Assessment. The Preliminary Assessment, released earlier this year, has already closed the door on future PFAS investigation and or remediation at many sites throughout JBPHH.
Q4: (Mr. Curtis) Have you done any PFAS analysis on the sediment?
A4: (Ms. Markillie – Navy, ERP) We have not done any PFAS analysis as part of the Pearl Harbor Sediment project. However, we are going to be looking at PFAS in sediment as part of Jan Kotoshirodo’s project, (ERP) and she will be discussing that in the next presentation.
Q7: (Mr. Huber) Is the inventory of AFFF [aqueous film-forming foam] from our past history with Navy and concurrent inventory of the AFFF available for us to see? As well as any of the plating that has been done in the past or plating that is concurrently been done available so that we can see the amount and make a determination of where that inventory is going and what the uses are for.
C11: (Ms. Markillie) I cannot speak to that, but can anyone on our team speak to that? Or we can get back to you on that.
The Preliminary Assessment for AFFF has addressed part of this.
A7: (Ms. Tamashiro, NAVFAC) The list of facilities that may have used PFAS-containing products, if they are operational facilities, then, as the military, we are not allowed to disclose which facilities they are. We can say a building number, but we cannot specify what that building is used for. And it would be considered controlled unclassified information.
See the Report on Critical Per- and Polyfluoroalkyl Substance Uses August 2023 Office of the Assistant Secretary of Defense for Energy, Installations, and Environment Office of the Assistant Secretary of Defense for Industrial Base Policy
https://www.acq.osd.mil/eie/eer/ecc/pfas/docs/reports/Report-on-Critical-PFAS-Substance-Uses.pdf
This report specifically identifies a host of products and applications for PFAS that the DOD considers to be indispensable. It does not identify specific uses at JBPHH.
C12: (Mr. Huber) But just the amount of what is being used and the questions that could arise from the usage wherever it is being sourced from or to. We just want to be able to make a determination of why it’s being used. And the amount of inventory in the past and the future and concurrently.
Huge quantities of PFAS are used in routine chrome plating applications. In chrome plating, hexavalent chromium (Cr VI – the passion of Erin Brockovich) is the primary chemical used to create the chromium coating on a metal surface, while PFAS are used as a fume suppressant in the chrome plating process. PFAS is added to the plating bath to minimize the release of deadly chromium mist into the air.
A key question is what happens to these chemicals at the end of the day.
C13: (Ms. Tamashiro) The project managers are saying that we did not assess past usage or volumes or quantities. That information is not available to us. We did not dig that deeply into finding that specific type of information. We were just looking at facilities themselves that may have used PFAS-containing products.
We did not quantify anything.
This is reprehensible. The Preliminary Assessment recommended in its “Group C” that the use of PFAS be evaluated in the yet-to-be-released Site Inspection. Generally, Site Inspections for Navy bases were released nationwide in 2017-2019.
Q11: (Ms. Espiritu)
I’m mind blown that your statement that 92% of the harbor meets our remediation action objectives, when at the same time we have Department of Health warnings. So just some questions on who is setting those standards, where can we find that, how do I reconcile that when you’re telling us we cannot eat the fish but it has hit your remedial action objectives and so we’re going to step off and don’t need to do anything more.
A11: (Ms. Markillie – DOD ERP) That’s an excellent question. Let me address that part first. Although sediment is safe, and that’s what is indicated by the green, the levels of PCBs in fish samples that we collected in some of these areas were still above the Department of Health’s criteria for issuing that fish advisory. That fish advisory is on the Department of Health’s website, and we’re going to continue to work with EPA and DOH to monitor fish tissue levels. And hopefully at some point through natural recovery from clean sediment coming in from the watershed, those fish tissue levels will improve and they will reach levels where DOH can lift that fish advisory. I don’t have a timeline on that, but it’s the sediment levels that meet the criteria, which obviously, those fish interact with the sediment. It’s kind of a lapsed thing. We remediate the sediment; it’s going to take a while for the natural environment to recover.
The representative of the DOD’s ERP says the sediment is safe.
The Navy has reported Mercury, Polychlorinated biphenyls (PCBs), Polybrominated diphenyl ethers (PBDEs), Dioxins-furans, Chlorinated pesticides, Arsenic, Cadmium, and Lead in the sediment at its bases across the country. These toxins also contaminate fish.
However, our focus here is with PFAS. We must demand a robust fish-testing regime for PFAS in Pearl Harbor, along with an analysis of the other deadly toxins in the sediment, the invertebrates, and the entire food chain.
Q13: (Mr. Lau) You mentioned earlier that the harbor is dredged on a regular basis because ships need to pass. I know that sediments build up over time and it has to be deep enough for the draft of the ships so they do not run aground. Where does the dredge material get disposed of? Does it go to PVT? Where does it go? And did you do a NEPA [National Environmental Policy Act] process for that action?
A13: (Ms. Markillie) That’s not part of my program. So, I can’t really speak to that.
C24: (Mr. Lau) Maybe the captain for the Joint Base could answer that question.
C25: (Captain White) I’ll have to get back to you on that. Does anybody have an answer on where that dredging material goes?
Follow-up response: Dredged material that is not located within a CERCLA remediation footprint and that is not suspected of containing munitions, may be tested for ocean disposal in accordance with the Marine Protection, Research, and Sanctuaries Act. Following a very specific evaluation and testing protocol to ensure that the material will not adversely affect human health and the marine environment, this material may qualify for ocean disposal and permitted by the EPA and the US Army Corps of Engineers to be taken to a designated ocean disposal site. Material that does not qualify for ocean disposal, must be taken to the Confined Disposal Facility on Waipio Peninsula, allowed to dry out, then characterized for upland disposal using incremental sampling methodology in accordance with the State of Hawaii Department of Health Guidance for Soil Stockpile
As noted above, ocean dumping of dredged material is permitted by the Corps with EPA’s case-by-case concurrence, and only at ocean dump sites designated by EPA through rulemaking or, if use of such sites is infeasible, at an alternative site selected by the Corps and subject to EPA concurrence. Use of such alternative sites is limited to five years (with an optional five-year extension contingent on three statutory conditions).
It does not appear that PFAS are specifically regulated under the Ocean Dumping Act, or Marine Protection, Research and Sanctuaries Act.
Ms. Tamashiro (NAVFAC) provided a brief overview of presentation topics along with an outline of the CERCLA process on Slide 2.
The main source of PFAS on Department of Defense installations is aqueous film-forming foam (AFFF), used for fire suppression.
Now that routine fire training practice using AFFF is no longer held at JBPHH, this may likely not be true.
Slide 5 presented the seven current PFAS remedial investigations.
How are these remedial investigations being carried out pursuant to the CERCLA process in the absence of the publication of a Site Inspection?
Ms. Tamashiro presented the four locations included in the RI: Building 1871 Former Industrial Waste Treatment Plant (IWTP), Building 1526, Building 1665, and Shipyard Fire Training Area. PFAS investigations at the former IWTP began in 2018 and the goal for the RI is to delineate the extent of PFAS contamination in soil and groundwater. The contract was awarded in July 2024 to continue the ongoing RI at IWTP and begin PFAS investigations at the other three sites due to their proximity to the former IWTP, as presented on slides 6 and 7.
The Former Pearl City Fuel Annex, presented on slide 8 and 9, had a potential release of PFAS from using AFFF to extinguish a 1985 fuel tank fire, and PFAS was detected in waste characterization soil samples during the 2015 Non-Time Critical Removal Action. During the 2021 RI Addendum, PFAS in soil and groundwater samples were above 2021 EPA regional screening levels (RSLs). The contract to continue the work for the 2021 RI Addendum was awarded in March 2023.
Why weren’t these releases mentioned in the DOD Inspector General’s 11/8/24 report on the Navy’s handling of incidents involving aqueous film forming foam, (AFFF) at various locations on Joint Base Pearl Harbor–Hickam? The very brief and heavily redacted 42-page report was issued on November 8, 2024.
Ms. Rangel introduced herself and presented the Red Hill Fuel Bulk Storage Facility.
Site inspection (SI) samples for surface and subsurface soil were above the project screening levels based on the November 2023 EPA RSLs.
Why doesn’t the public have access to the Site Inspection?
Ms. Griswold introduced herself and presented Building 67 Former Plating Facility on Slide 12. Site-specific SI was conducted to evaluate whether contamination was present due to a potential release of processed wastewater from the former plating tank sump at Building 67, which operated from 1981 to 2004. Soil and groundwater samples were collected. Results from soil samples identified the presence metals, specifically chromium, which exceeded the project screening levels. Groundwater results indicated the presence of chromium and cyanide, which also exceeded the project screening levels.
PFAS in groundwater samples were below the 2023 EPA screening levels. Soil samples were not collected and will be evaluated in the upcoming RI. The RI was awarded in April 2024, and the Draft Work Plan is being developed.
How about PFAS levels at the wastewater treatment plant in the liquid effluent and the solid sludge?
Ms. Kotoshirodo presented two locations on Slide 14: the Former Richardson Fire Fighting Training Area and the 2019 Barge Fire at the boat house. SI samples for soil and groundwater were above screening levels at the Former Fire Fighting Training Area. Samples have not been collected at the 2019 Barge Fire location.
Why weren’t these locations included on the DOD IG’s report?
(Ms. Kotoshirodo DOD ERP) PFAS is an emerging contaminant, that is new, and we are evaluating and assessing.
The Navy has known that the PFAS in firefighting foams is a danger to human health for 50 years.
Q4: (Mr. Curtis) You had a power plant on base, and all ships are required to have AFFF. Is any of that being analyzed?
A4: (Ms. Kotoshirodo) For our preliminary assessment, we did not assess the ships or anything on the ships.
Q5: (Mr. Kajihiro) First a comment. I just feel kind of depressed at the extent of this contamination and knowing that it’s going to continue to unfold and emerge. It’s good to know other sampling is going on, but it seems like the compartmentalization is the problem. Correct me if I’m wrong, but is there a formal way that you coordinate your investigations for PFAS or is it just informally sharing data?
PFAS Preliminary Assessment and Site Inspection
Additional Questions for tonight’s RAB:
1) Should the public be alarmed by the release of data by ERP that shows 2.88 million parts per trillion of PFAS in groundwater on JBPHH?
2) What role did the Navy play when the DOH relaxed its Environmental Action Levels (EAL) for many of the compounds shown above?
3) Will the Navy release groundwater testing results throughout JBPHH that show the depths that were tested?
4) Why was the DOD IG report so heavily redacted?
5) Has the Navy conspired to muzzle the free speech of members of the CRI?
6) Is the Navy opposed to the creation of a robust PFAS fish testing program in Pearl Harbor?
7) Is the Navy actively enforcing the regulation against taking and consuming fish from Pearl Harbor?
8) Will the Navy or the EPA or the DOH test the air or dust for PFAS?
9) The DoD OIG Report has requested that the office of the Assistant Secretary of the Navy (Energy, Installations, and Environment), to provide comments December 8, 2024. Have these comments been made available?
10) What role, if any, does the EPA play in any of this?
This summer I’d like to return to Hawaii, and then to Japan with Rachel Clark and Veterans for Peace. We must raise funds now to know what we're doing next year. The airfare, hotels, and transportation are very expensive. It is a struggle. I'd rather be home with Nellie on the poisoned banks of St. Inigoes Creek.
I want to purchase water and blood test kits to document the harm caused by the US military's use of PFAS in routine fire-fighting training exercises and everyday operations. The water test kits are $70 each, while the Empower DX pin prick tests are $249. Blood testing is politically explosive activism, but it is expensive. Please help me raise hell and $20,000.
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Mahalo for your support. Pat