DOD Inspector General issues incomplete report on use of AFFF and PFAS at Joint Base Pearl Harbor-Hickam
A separate unheralded study by the Navy Environmental Restoration Program reports total PFAS of 2.88 million parts per trillion in groundwater.
Meanwhile, the EPA, Navy, and the Defense Logistics Agency have conspired to muzzle the officially established Community Representation Initiative.
By Pat Elder
December 4, 2024
The DOD’s Inspector General has issued a spotty 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. Aqueous film-forming foam, (AFFF) contains carcinogenic PFAS chemicals.
The report demonstrates how the DOD manages to regulate itself by publishing studies that purport to be independent in nature. The Inspector General’s Report (IG Report) is an inside job.
We should not grant them the legitimacy they crave.
First, we’ll briefly examine a set of seven analytical results of PFAS in groundwater on Joint Base Pearl Harbor-Hickam (JBPHH) and naval installations throughout Oahu. The data was produced by the Navy’s Environmental Restoration Program. (ERP).
Next, we’ll analyze the deficient IG Report on AFFF, followed by a discussion of the Navy’s castration of the Community Representation Initiative, (CRI).
The Navy’s limited reporting describes an environmental train wreck.
The Navy has failed to publish an AFFF Site Inspection for JBPHH pursuant to the congressionally mandated Comprehensive Environmental Response, Compensation, and Liability Act, (CERCLA). These reports were made public across the country years ago, but not in the Aloha State. It’s a big deal because site inspections include robust data showing the concentrations of these carcinogens in a host of environmental media. The fear is that the Navy will cut corners in their testing regime if they ever publish it.
There is an even greater fear that the incoming administration in Washington will shut down the remaining vestiges of transparency and community involvement.
I must raise money to be more effective. Nellie does not want me to spend any more of our retirement funds. We'll both turn 70 this year.
This summer I’d like to return to the U.K., Germany, and 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. If I can't raise the money I won't go. What the hell.
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.
Please support my work! World Beyond War is my fiscal sponsor. I serve on WBW’s Board. Love and hope, Pat
Joint Base Pearl Harbor-Hickam
PFAS Groundwater Sampling Results
The tables below show sampling results for PFAS constituents in groundwater at seven installations on Oahu as of June 30, 2023.
Results are in parts per trillion. The EPA’s enforceable limit for drinking water is 4 parts per trillion for PFOS and PFOA. The limit for PFHxS, PFNA, and HFPO-DA is 10 parts per trillion. They ought to have limits on all of these chemicals! Human beings aren’t supposed to be consuming PFAS. The compounds terrorize the thyroid.
The Navy is reporting PFOS concentrations in groundwater that exceed 2.62 million parts per trillion. Only three bases have higher levels worldwide:
· Naval Air Weapons Station China Lake, California 8,000,000 (PFOS+PFOA)
· Patrick Space Force Base, Florida 4,338,000 (PFOS+PFOA+ PFBS)
· Myrtle Beach Air Force Base, South Carolina 2,640,000 (PFOS + PFOA)
We must demand truly independent testing, considering the ridiculously low levels reported for Barbers Point, a hell hole of chemical waste.
The Navy says the evaluation of the groundwater sample results shown above will be considered “final” when the Site Inspection report is completed. When completed, the final report outlining the evaluation of the data will be available online at the Navy’s installation administrative record.
There are no federal cleanup standards for PFAS in groundwater while the EPA and the state of Hawaii are spectators that occasionally provide insightful commentary.
The DOD’s Inspector General’s Report identified 4 incidents involving AFFF while leaving out additional releases of AFFF and routine releases of PFAS.
Navy Lt. Cmdr. Shannon Bencs is a former fuels director at Red Hill. An after-incident report indicated she was the last remaining person with fuel expertise after the massive fuel leak on November 29, 2021 before the Navy removed her from the position. She told Hawaii Public Radio, “What didnʻt come out of the (DOD IG) report was accountability — who would be held responsible for the mismanagement, the non-maintenance, the inadequate training, and more.
The I.G. Report identified 4 incidents involving AFFF. These accidents occurred on:
· December 7, 2019,
· September 29, 2020,
· October 26, 2021, and
· November 29, 2022.
The Navy also identified two additional AFFF incidents for which they say the dates were unknown. These incidents were not included in the IG report.
However, the Final Preliminary Assessment of Potential Per- and Polyfluoroalkyl Substances National Priorities List Sites - Joint Base Pearl Harbor-Hickam Oahu, HI., December, 2023 briefly mentions the release of AFFF during a large fuel fire in the 1980’s at the Aboveground Fuel Storage Tank One. It also refers to the accidental release of AFFF at Warehouse 1526 in the late 1990’s. These incidents may have resulted in the release of more AFFF than the well documented AFFF accident that occurred at Adit 6 on November 29, 2022 when 1,300 gallons of AFFF concentrate were released.
We don’t know anything more about the releases at Warehouse 1526 or Aboveground Fuel Storage Tank One because the Naval command and the Inspector General have decided to keep them secret, like all of the redacted information throughout the selective IG Report.
The Navy has created a narrative about PFAS in Hawaii by waging a sophisticated campaign orchestrated to blindside the public while closing the books on huge swaths of perpetually contaminated land and water. The Preliminary Assessment cited above was released to the public in mid-March, 2024 even though the State of Hawaii Department of Health reviewed the document in 2021. The document removes substantial areas from further scrutiny or “clean up.”
We also saw the Army do the same thing in Hawaii this year when it closed off eight bases from further PFAS scrutiny despite evidence of PFAS to the contrary.
The Site Inspection is the second step in the CERCLA process.
Site Inspections are accompanied by analytical data showing PFAS concentrations in a host of environmental media, including soil, groundwater, and surface water.
· December 7, 2019,
· September 29, 2020,
· October 26, 2021, and
· November 2022.
December 7, 2019
We didn’t know anything about the December 7, 2019 AFFF incident at Naval Station Pearl Harbor until this IG Report. The skimpy AFFF Preliminary Assessment left it out. We still don’t know much about the incident, the way the Navy/IG tell it. Navy documentation on this accident says there was a release of approximately 1,500 gallons of AFFF concentrate and water mixture onto the ground. We don’t know the exact mixture. Foam is made up of 3% concentrate and 97% water so it is important to know the makeup of the mixture.
See Figure 1 above, used to describe the exact location of the December 2019 incident. Also see a sample of redacted information to the left,
All we know is that the Navy failed to describe any cleanup actions and Navy officials neglected to issue public notifications about the incident.
These are not isolated releases
These environmental calamities have occurred almost everywhere you’ll find Navy or the Marine Corps bases. For instance, on December 5, 2019, just two days before the 1,500-gallon release at Pearl Harbor, Hangar 507 on Marine Corps Air Station Futenma in Okinawa experienced an accidental 10,000-gallon leak of AFFF.
Four months later, at the same base, Marines in Hangar 539 lit a barbeque in front of the open hangar. (There were no grownups in the room.) The fire suppression system went off when the charcoal was ignited. The fire suppression system ran for 28 minutes resulting in the release of an estimated 41,200 gallons of a mixture consisting of 97% water and 3% AFFF. The release contained 1,236 gallons of concentrate, about the same as the infamous Red Hill Adit 6 leak. The Marines didn’t know how to turn off the prolific carcinogenic bubbler. Not a big deal for the Navy. After all, this was in Okinawa where the Japanese government washes its hands of American environmental crimes. When pressed to comment, the commander of Futenma, said, “If it rains, it will subside.”
Unlike officials in Hawaii, the Okinawans have documented highly contaminated fish around the island containing more than 100,000 parts per trillion (ppt) of PFOS in their fillets. (ng/g = parts per billion.)
What about fishing in Pearl Harbor?
In 1998, the State of Hawaii Department of Health issued a health advisory stating that fish and shellfish from Pearl Harbor should not be eaten because the fish and shellfish may contain chemicals that can be hazardous based on the animals' uptake of pollutants and contaminants. As of 2024, this advisory remains in effect.
According to the Navy, “Fishing in the Pearl Harbor Naval Defensive Sea Area (PHNDSA) and from the shorelines surrounding the PHNDSA is authorized only in certain areas and only on a "catch-and-release," with zero bag limit, and utilizing pole and line gear. JBPHH Security Forces are responsible for patrolling and enforcing the requirements in applicable recreational fishing instructions as well as enforcing state and federal regulations applicable to fishing on JBPHH.”
Wayne Tanaka, Chapter Director of the Sierra Club of Hawaiʻi, is concerned about the potential health impacts on those who consume fish from Pearl Harbor. Tanaka said, "I know with 100% certainty that people catch, eat, and sell fish and crabs from Puʻuloa, which has some of the only accessible and fishable shoreline for much of South Oʻahu. Social media is replete with posts of people catching and consuming and sometimes offering for sale fish from West and Middle Loch.”
People were fishing on the west side of the canal opposite Kalaeloa Airport when we collected a water sample on 3/26/22 showing 119 ppt of total PFAS. When surface waters are this contaminated it suggests the groundwater is much worse – orders of magnitude worse. This is why the newly released groundwater results from Barbers Point (62.71 total PFAS) don’t seem right.
For its part, the State of Hawaii, Department of Health’s Hazard Evaluation & Emergency Response Office refers to a single 3-year-old graduate study of PFOS in goatfish. The study determined that it is safe for people to eat goatfish caught around Oʻahu with low to no risk of health effects from PFAS.
Multiple states have tested thousands of fish. Michigan tested 2,000 fish several years ago and found the average in the fillet was 80,000 ppt of PFOS. One fish near Wurtsmith AFB had a concentration of 10 million ppt of PFOS.
· December 7, 2019,
· September 29, 2020,
· October 26, 2021, and
· November 2022.
September 29, 2020
On September 29, 2020, the Navy released approximately 5,000 gallons of AFFF mixed foam in Adit 1. We don’t know the precise mixture of concentrate and water. An “Adit” is a nearly horizontal passage from the surface into a deep subsurface area. The floor of the pump house where the release occurred is made of porous material.
This spot is located 800 feet from the tidal waters of Pearl Harbor, while PFOS may travel through underground aquifers for miles.
To compare, 1,300 gallons of AFFF concentrate were released at Adit 6, at Red Hill on November 29, 2022.
The red X is the location of the pump house at Adit 1.
Navy officials did not provide evidence indicating that they carried out required incident response actions, including reporting, and properly cleaning up areas. Navy officials said they did not believe the incident constituted a release to the environment.
The Inspector General concluded that the AFFF incident was a release to the environment. The IG didn’t have much of a choice because the cat was already out of the bag. Too many inside and outside of the chain of command knew the truth. This is the biggest problem for the Navy. They can’t control all of their people and contractors to keep quiet. Some will speak to the media in Hawaii that is eager to broadcast their words. (Unlike here in the DC area.) Others convey the truth anonymously. Either way, the press is vibrant and willing to report the truth in the Aloha State.
The I G Report considers the September 29, 2020 incident unresolved.
The Office of Inspector General (DoD OIG) is an office within the DoD. The IG Report was addressed to the office of the Assistant Secretary of the Navy (Energy, Installations, and Environment), another office within the DoD.
One office of the DOD requested that another office provide additional comments within 30 days (December 8, 2024) describing how the Navy can incorporate the September 29, 2020 AFFF incident within the review. This is theatre.
Navy officials did not include a Commander’s Critical Information Requirements (CCIR) report or provide any evidence that they reported the AFFF incident to the required Navy chain of command, including the Commander, Navy Installations Command Regional Operations Center.
The Navy said they recovered the entire volume of the AFFF concentrate released by pumping it into a disposal tank, rinsing the floor, and pumping the residual into a second disposal tank. The Navy often addresses “disposal” as a kind of final, happy solution. They want us to believe AFFF and all PFAS waste can be safely treated for release or removed for proper disposal.
It can’t. The release of these chemicals is a great crime. The manufacture of these chemicals is also a great crime. We need to figure this out in a hurry. Maybe we can agree we need to keep 1%-2% of the stuff around while tracking and isolating its use and disposal.
We know a little bit more about the September 29, 2020 release, thanks to the reporting by Christina Jedra of Civil Beat. Military officials initially requested emergency funding to respond to the release of AFFF, but told health inspectors later that no foam had been released.
One less thing.
The Navy sampled spilled material at the site in December 2020, according to a copy of the test results obtained by Civil Beat. The lab report by the California-based company Eurofins shows one sample contained PFOS at a dangerous level of 200,000 parts per trillion. PFPeA, PFHxA, PFHpA, PFNA, PFBS, PFPeS, PFHxS, and PFHpS were also in the mix.
The EPA added a degree of levity to the situation when they said they were concerned about these detections.
The Navy said the substances in the tanks had been “tested and disposed of in accordance with regulations.” The Navy did not disclose details of the disposal method. There is no way to dispose of these materials without potentially threatening the health of the people of Hawaii or wherever they are sent.
· December 7, 2019,
· September 29, 2020,
· October 26, 2021, and
· November 2022.
October 26, 2021
On October 26, 2021, a water pipeline ruptured on base, releasing 300,000 gallons of water at the Fuel Oil Recovery Facility. The “FORFAC,” as it is known, is a facility that processes waste fuel, such as fuel that no longer meets military specifications.
The FORFAC also handles tainted water for reuse, sale, or disposal.
Navy officials say they believe that AFFF could have been absorbed in the soil from the December 7, 2019 AFFF incident described above, and mixed with the water from the 300,000-gallon release of October 26, 2021, as it flowed downhill.
Cluster -F.
The deluge of 300,000 gallons flooded the Fuel Oil Recovery Facility. Navy officials determined that the water/fuel/AFFF mixture was not fully contained within the Fuel Oil Recovery Facility, and estimated that at least 100,000 gallons of the mixture were potentially released into the environment. It flowed downhill into the Fuel Oil Recovery Facility secondary containment, and combined with approximately 2,000 to 3,000 gallons of fuel mixture already present there.
See the completely redacted Figure 2, below. The right arm of the Navy (Office of the Assistant Secretary of the Navy - Energy, Installations, and Environment), had the prerogative and chose to redact the information supplied by the left arm of the Inspector General.
Figure 2 here, shows foam flooded the secondary containment, and mixed with fuel already present.
Love that dirty water?
We must understand the ramifications involving the Navy’s policy to sell or transfer toxic water because it may threaten human health, especially when the dirty water contains high concentrations of PFAS, and likely, a host of other contaminants. It is very dangerous when these waters are used for agricultural purposes.
Two years ago, the people of Kunia Village, about 20 miles northwest of downtown Honolulu, had been drinking water supplied by the Army with 264 parts per trillion of PFAS. The Hawaii State Department of Health suggested, if people were concerned, they could purchase water filters.
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 in the area, likely causing groundwater and surface water contamination. There is no other known potential cause for this contamination of Kunia Village’s water. The Army has not fully responded to a FOIA request regarding the levels of PFAS in the tainted water.
The Navy is likely much worse than the Army. How much of the Navy’s toxic water is being spread on agricultural lands? What’s in your food, Hawaii? What’s in your fish?
One document the Inspector General reviewed stated that “A foam-like substance was observed as the water poured down the hill.” Although there was evidence of AFFF in the fuel and water mixture in the Fuel Oil Recovery Facility, Navy officials did not test for PFAS. With a straight face, the IG Report says, “See Figure 3 for a depiction of the path of the water released from the ruptured pipeline.”
Figure 3 shows the path of Water Flow from the October 2021 Water
Pipeline Rupture at the Naval Station.
The IG says it could not determine why Navy officials did not test for PFAS during the incident. The IG knows why their partners in environmental crime didn’t test for PFAS or didn’t publish results! There’s too much liability here for the Navy. They felt they could lie their way out of it, explained an engineer who is familiar with their mindset.
Navy officials could not provide the Inspector General with evidence indicating that they carried out required incident response actions, including reporting, or properly cleaning up areas affected by the and October 2021 incidents involving AFFF.
Three days later, on October 29, 2021, Navy officials began draining the fuel, AFFF, and water mixture from the Fuel Oil Recovery Facility into remediation tanks. According to documentation on this incident, Navy officials discovered that the fuel, AFFF, and water mixture was not fully contained.
Navy officials collected soil and water samples from the incident to test them for PFAS. In February 2022, Navy officials received results confirming the presence of PFAS in the soil and water samples. The specific results were not made public.
Figure 4 - Shows Fuel, AFFF, and water mixture within the Fuel Oil Recovery Facility and remediation tanks.
They are making fools of us all. We must stand up to them. It’s our world.
· December 7, 2019,
· September 29, 2020,
· October 26, 2021, and
· November 29, 2022.
November 29, 2022
On November 29, 2022, 1,300 gallons of AFFF concentrate was released inside Adit 6 at Red Hill during maintenance activities on the fire protection system. The AFFF concentrate pooled on the floor near the door, and it seeped under the door onto a paved access road and into the soil.
The Navy said they removed 3,000 cubic feet of contaminated soil, asphalt, and concrete. That’s a little more than the cubic footage of the soil in the raised beds in a suburban vegetable garden. The German government removed 17.6 million cubic feet of soil from the similarly contaminated Rhein-Main Air Base.
The IG Report says they included information on the November, 29, 2022 AFFF incident, but they did not review the Navy’s response to this incident because it occurred after their arbitrary timeframe. The IG and the Navy are on the same team.
The Navy could not provide the DOD IG with evidence that they completed the required incident response actions, including reporting, or properly cleaned up the areas affected.
1,300 gallons of concentrate can produce 43,000 gallons of foam.
A week after the release, in early December, 2022, the Hawaii Department of Health reported in its PFAS Sampling and Analysis Plan for Adit 6 that the Navy used Ansulite 3% AFFF. They wrote, however, “Due to the proprietary nature of AFFF, Draft EPA Method 1633 may not identify the other PFAS components for Ansulite AFC-3MS 3% AFFF.”
It seemed the state was giving in to “proprietary” interests, but it’s more complicated than that. A year later, in December, 2023, Hawaii’s Attorney General filed suit in the Circuit Court of the First Circuit of the State of Hawaii against the makers of AFFF, including Tyco Fire Products, LP, the manufacturer of the Ansulite AFFF.
We learned a lot from the recent spill in a hangar at the former Brunswick Naval Air Station in Maine earlier this year. Ansulite 3% AFFF and Chemguard 3% were the two types of aqueous film-forming foam (AFFF) concentrate that were released from Hangar 4 at the Brunswick Executive Airport on August 19, 2024. 1,450 gallons of the concentrate mixed with 50,000 gallons of water to create the foam mixture.
The civilians in charge today in Brunswick released this data on the concentrations of PFAS compounds in the concentrate. We had never seen this kind of data before, so it was kind of exciting. The PFOS had a concentration of 3.78 billion parts per trillion, the highest concentration of any PFAS compound ever recorded. Look at these numbers! See report by Alpha Analytical
The concentration of PFOS, PFOA, and PFHxS are particularly worrisome because they may contaminate drinking water. Even more frightening is their propensity, along with most of the others, to severely contaminate the food chain.
DOD Inspector General Report omits
volumes of information on AFFF and PFAS
The Final Preliminary Assessment, Potential Per- and Polyfluoroalkyl Substances National Priorities List Sites - Joint Base Pearl Harbor-Hickam Oahu, HI., December, 2023 tells a different story than the IG Report.
A lot of damning information regarding the use and disposal of PFAS was left off of the IG report. Although the four AFFF incidents described in the IG report emptied tremendous amounts of carcinogenic foams into the Hawaiian environment, the DOD’s internal investigation failed to highlight the everyday use and disposal of a myriad of products and applications that use PFAS.
The December, 2023 Preliminary Assessment describes four groups of PFAS releases, based on the likelihood of PFAS being present and/or entering the environment:
Group A: Known release sites like fire suppression for crashes and routine hangar tests. This group also includes repeated small quantity release sites, like fire- fighting training areas first occurring in the mid-1960s, where AFFF suppressants known to have contained PFAS were documented to have been used.
Group B: Potential release sites, including areas where AFFF suppressants known to have contained PFAS were documented to have been stored or used and/or lacked documented housekeeping practices, but have no known releases (e.g., fire stations, hangars, flight lines, runways, AFFF handling/storage areas).
Group C: Chrome-plating facilities that may have utilized vapor suppressants containing PFAS.
Group D: Areas where compounds containing PFAS “were not intentionally released,” including landfills, sludge disposal areas, and oil-water separators.
Only sites identified as Group A, B, or C were recommended for further evaluation for PFAS in the much-anticipated installation-wide Site Inspection. They left Group D out of the equation, and it may be the most important variable. Group D consists of landfills, sludge disposal areas, and oil-water separators that are used to drain fluids from hangars. The wastewater treatment plant is left out of it completely. The facilities that chronically deliver the carcinogenic materials to the environment continue to go unchecked. They are likely responsible for the majority of PFAS releases from JB Pearl Harbor Hickam.
The Navy’s Wastewater Treatment Plant is owned, operated, and maintained by Naval Facilities Engineering Command (NAVFAC) Hawaii. The facility treats approximately 6.5 million gallons of wastewater per day.
From Table ES-1 AFFF Preliminary Assessment, JBPHH
Fire Station 4 on Ford Island conducted routine truck nozzle tests, often spraying approximately 2.5 gallons of AFFF on the side of the fire station while testing pumps.
Building 67 is the Plating Facility on JBPHH. Large amounts of PFAS are used as an aerosol suppressant for chrome plating that involves Hexavalent Chromium, the toxin that drove Erin Brockovich bonkers.
Fire Station 1 routinely released AFFF behind the building.
Building 229 processed AFFF waste from ships.
Warehouse 1526 had an accidental release of AFFF in the 1990’s.
Building 1871 treated industrial waste, including PFAS.
Aboveground Fuel Storage Tank One – AFFF used during large fuel fire in the 1980’s – in Document review
Building 466 Fire Station – Routine Fire Truck testing
Building 240 – AFFF storage - Areas like this often experienced spills and accidents. The AFFF was moved to Lualualei Annex.
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The state shares the blame with the military. According to the Hawaii Attorney General’s lawsuit, the islands are tremendously contaminated. Daniel K. Inouye International Airport in Honolulu has PFOS in groundwater as high as 1,900,000 ppt, PFOA at 110,000 ppt, and PFHxS at 879,000 ppt. PFAS in groundwater were detected at levels high enough to pose an aquatic ecotoxicity hazard to flora and fauna in the adjacent surface waters of Keʻehi Lagoon and the Pacific Ocean.
On the island of Maui, Kahului Airport is contaminated with PFAS derived from AFFF. Samples contained PFOS at levels as high as 2,500,000 ppt, PFOA at 82,000 ppt, and PFHxS at 250,000 ppt. Flora and fauna are seriously threatened in Kahului Bay. The fire training facility sits approximately 0.16 miles south of Kahului Bay and just east of Kanahā Pond Wildlife Sanctuary.
On the island of Hawaiʻi, Ellison Onizuka Kona International Airport reported that PFOS was detected at 46,900 ppt and PFHxS at 96,700 ppt.
Wayne Tanaka, Chapter Director of the Sierra Club Hawaii, captures the sentiments of many in Hawaiʻi. "The Navy could just come clean and say they don’t know what they are going to do about the heartbreaking damage they’ve done to our lands, aquifers, and ocean. They could do the right thing and recommit their vast resources to prioritize environmental remediation and clean up their mess. Instead, they choose to deny, delay, and distract as they have for far too long and in far too many places here and across the Pacific - as if we are dumb, as if we don’t care about our home, our health, or our children and future generations."
Tanaka continued, “At this point it seems clear that the Navy and the Department of Defense just don’t care about our kids and grandkids inheriting a toxic stew where there once was abundance, where fisheries and farmlands once sustained generations. Whether from Kaho'olawe or Mākua or Red Hill, we need to remember what their actions and inaction have shown us - or we will end up selling out our kids' future based on smoke and mirrors, and empty promises."
Melodie Aduja is a member of the Community Representation Initiative (CRI), an elected community body established by the Environmental Protection Agency (EPA) as a result the 2023 Administrative Consent Order, (ACO) after community uproar over the EPA's first draft of the order that left out community participation.
The order required the Navy and Defense Logistics Agency (DLA), which technically owns the fuel in the Red Hill tanks, to cooperate with the CRI and provide members like Aduja with information regarding environmental and health concerns relating to Red Hill.
Melodie Aduja explained, “Regrettably, from the very beginning, the Navy failed to participate meaningfully in CRI meetings, always sending representatives who had no answers to our questions. It started with the Navy's failure to allow for a site inspection of Red Hill as contemplated during our first CRI meeting in October 2023. This was a blatant disregard for the community's right to know regarding the safety and well-being of human lives and the environment.”
The record shows Navy representatives often promised to get back to the CRI, but failed to do so. Aduja said, “We now have a backlog of over 300 legitimate, pressing questions relating to health and the environment that the Navy has not answered.”
The Joint Task Force - Red Hill (JTF-RH) was responsible for the expeditious defueling of the Red Hill Bulk Fuel Storage Facility. The JTF-RH disbanded before answering any of the CRI’s 300 questions. When these questions were posed to the Navy Closure Task Force - Red Hill (NCTF-RH), they indicated that their responsibility was limited to the closure and long-term environmental remediation efforts at Red Hill. As a result, any questions applicable to the JTF-RH were never answered.
“The EPA has not been our ally,” Aduja explained. “The EPA has sided with the Navy at every turn in our disagreements, even going so far as to claim that the Congressional Delegation favored our dissolution (which was not substantiated), resulting in a new, purported unilateral amendment to the ACO that requires our CRI meetings to be controlled by an EPA "facilitator," for no legitimate reason,” Aduja said.
Aduja says she believes the new ACO violates the federal Administrative Procedures Act, which has been settled law for 80 years. She explained, “Now, we have new and very serious and frightening substantive reports about environmental toxins in the Red Hill area. Among other things, this amended ACO purports to exclude from our oversight any issues relating to the PFAS class of chemicals, which are known to be environmental toxins.”
Aduja says it is “unconscionable” that the EPA, Navy, and DLA are prohibiting the CRI from asking questions regarding PFAS at Red Hill, considering the documented releases of massive amounts of AFFF. The CRI member also points to the state for withholding important documentation on PFAS. Aduja explained, “The Hawaii State Department of Health reviewed the Final Preliminary Assessment of Potential Per- and Polyfluoroalkyl Substances (PFAS) National Priorities List Sites - Joint Base Pearl Harbor-Hickam Oahu, HI., back in November 2021 but failed to inform the public until mid-March 2024 of Red Hill findings.”
CRI member Melodie Aduja calls for “more stringent oversight and independent testing to ensure the safety and well-being of the community.”
What’s next?
It wouldn’t be so bad if PFAS dissipated over time, but that’s not the case. They don’t go away, and they’re still being recklessly discarded by the Navy. Federal agencies can’t be trusted to precisely document or remediate these toxins throughout the Hawaiian environment. The community’s best hope is to apply pressure on the state government to come clean and confront federal agencies for their complicity in these environmental crimes. The state legislature has taken baby steps to protect public health, but so much more needs to be done, starting with a robust testing regime Aduja calls for to document PFAS concentrations in a host of environmental media.
Safer States is a good place to see what needs to be done.