Hawaii relaxes PFAS standards in drinking water
Measure moves the regulatory goal posts.
Red Hill shows no exceedances now.
By Pat Elder
October 19, 2023
The U.S. Environmental Protection Agency has announced that groundwater monitoring sample results at the Red Hill Bulk Storage Facility show no exceedances of PFAS based on the Hawai‘i Department of Health Environmental Action Levels, (EALs). See the report here.
The Hawaii Department of Health has made compliance a lot easier by relaxing regulatory standards for PFAS concentrations in drinking water. They have said all along they are addressing the PFAS crisis and this is how they’re doing it.
Compare Hawaii’s PFAS Environmental Action Levels (EAL’s) from TABLE A, December 2022 to the new EAL’s from TABLE A, April, 2023. The tables appear in scientific notation. Although most states report regulatory limits and results for PFAS in parts per trillion, Hawaii prefers to lay it out in a way that few can understand.
The chart immediately below shows the change in regulatory limits for PFAS compounds in the state’s drinking water, leading up to the publication of the EPA’s recent investigation report. On average, 19 PFAS compounds had regulatory limits increased by nearly 100%.
Hawaii’s already weak Environmental Action Levels in December, 2022 are compared to the levels in April, 2023. See the corresponding percentage of increase. - Military Poisons
Hawaii’s Environmental Action Levels for 20 PFAS compounds are non-mandatory, advisory measures. Exceeding the levels calls for additional evaluation. Many states have enforceable limits, but not Hawaii.
According to the Hawaii Department of Health, “If potential concerns are confirmed, (by exceeding the EAL’s) then the specific hazards posed by the contamination are identified, the need for additional data to complete the site investigation is determined and the preparation of appropriate remedial actions is recommended.”
It sounds like the Navy wrote it.
While states have been tightening regulations regarding the presence of PFAS in groundwater and drinking water, Hawaii has been relaxing standards.
States have been responding to last year’s frightening publication of the EPA’s Interim Lifetime Health Advisories for PFOS and PFOA in drinking water. The EPA has set a threshold of .004 ppt for PFOA and .02 ppt for PFOS in the water!
The EPA is strong on the science but weak on the enforcement. The EPA still does not regulate PFAS. It leaves it up to the states and this is a shame in Hawaii, the only state that is aggressively relaxing regulations in this regard.
When it was disclosed earlier this year that the people in Kunia Village were drinking water with hundreds of parts per trillion of PFAS, the Hawaii Department of Health told them to install water filters if they were concerned. That’s what we’re dealing with in Hawaii. Thousands have been sickened by the military’s carelessness. It’s enough to keep tourists away. Hawaii is contaminated.
The Navy released this statement: “The Navy is consolidating Notice of Interest (NOi), Groundwater Long-Term Monitoring (GW LTM), delineation, and sentinel wells, and per- and polyfluoroalkyl substances (PFAS) groundwater sampling programs into one comprehensive, optimized groundwater sampling program.”
It sounds like they’ve got this under control. Do you think they’ll allow independent, 3rd-party scientists on base to conduct environmental testing?
Comparing Hawaii to Massachusetts
In 2020 Massachusetts set the standard across the country when it established a maximum contaminant level, (MCL) of 20 parts per trillion for the total of 6 toxic PFAS compounds (MA 6) in drinking water. (PFOS, PFOA, PFDA, PFHpA, PFHxS, & PFNA.) Still, scientists say we shouldn’t be drinking any of these chemicals and that Massachusetts ought to be regulating other PFAS toxins. There are 15,000 varieties to keep track of now and they are all believed to be harmful.
MCL’s are enforceable standards. If a combination of the MA 6 exceeds this level, municipal water providers must treat the water or shut down the contaminated well.
Massachusetts will shut wells down
if the combination of these 6 toxins
exceeds 20 ppt. Hawaii has
non-enforceable action levels.
PFAS HI - EAL
PFOS 7.7 ppt
PFOA 12 ppt
PFDA 7.7 ppt
PFHpA 77 ppt
PFHxS 77 ppt
PFNA 12 ppt
Total 193.4 ppt
Hawaii says it will launch investigations to see if action is warranted if EALs are exceeded. This didn’t happen in Kunia Village, however.
PFOA and PFOS
Hawaii’s Environmental Action Level (EAL) is 12 ppt for PFOA. The EAL is 3,000 times higher than the EPA’s interim lifetime health advisory of .004 ppt (12 / .004 = 3,000) Twice as much PFOA is allowed in the water since regulations were relaxed earlier this year. California considers PFOA and PFOS to be human carcinogens.
Just .1 part per trillion of PFOA in drinking water is thought to be enough to elevate the chances for developing pancreatic cancer.
Hawaii’s EAL is 7.7 ppt for PFOS. The EAL is 385 times higher than the EPA’s interim lifetime health advisory of .02 ppt (7.7 / .02 = 385).
Fish in Hawaii may contain hundreds of thousands of parts per trillion of PFOS because of the military’s activities. The contamination has been widely documented at military bases in South Korea, Japan, and Germany, but not in Hawaii. The state is determined to continue looking the other way, despite mounting frustrations among state health personnel. Meanwhile, Michigan has tested more than 2,000 fish and found the average to contain 80,000 ppt of PFOS. Some fish near Wurtsmith AFB had 10 million parts per trillion of PFOS in them.
Hawaii prefers to live in the PFAS dark ages.
Lots of carcinogens allowed in Hawaii’s water
15,000 parts per trillion of PFBA are now tolerated in Hawaii’s drinking water, up from 7,600 ppt earlier this year. The chemical is used in firefighting foams. It is found in Chesapeake Bay Blue Crabs near Navy bases in Maryland. The National Institute of Health says PFBA is associated with Hyperplasia, (dangerous enlargement of organs), kidney disease, necrosis, skin disease, liver disease, fibrosis, and hepatomegaly.
92% more PFDA is allowed in Hawaii’s water now. The toxin is associated with liver tumors, breast cancer, liver cancer, and brain cancer.
The concentration of PFHxS was increased from 40 ppt to 77 ppt. The compound is prevalent because it was used as a substitute for the PFOS and PFOA in firefighting foams. The compound is heavily regulated by multiple states and that’s largely because it plays havoc on the developing fetus. PFHxS is associated with:
· Deficit Disorder with Hyperactivity
· Autism Spectrum Disorder
· Low Birth Weight
· Breast Neoplasms
· Cognition Disorders
· Diabetes Mellitus, Type 2
· Dyslipidemia
· Fatty Liver
· Hypertension
· Embryonal tumors
· Liver Disease
What’s in your water, Hawaii? The military won’t tell you. Numerous unanswered Freedom of Information Act requests are proof of that. The Environmental Protection Agency is a criminal entity. They stopped protecting us. Now, they’re protecting their corporate and military clients. Advocates for public health are enemies of the state.
Financial support from the Downs Law Group makes it possible for us to challenge state enforcement of environmental laws like we are doing here in Hawaii.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to trichloroethylene, PFAS, and other contaminants.
The Downs Law Group employs attorneys accredited by the Department of Veterans Affairs to assist those who have served in obtaining VA Compensation and Pension Benefits they are rightly owed.
If you spent time in the military and you think you may be sick as a result of your service, think about joining this group to learn from others with similar issues. Are you interested in joining a multi-base class action lawsuit pertaining to illnesses stemming from various kinds of environmental contamination?
Join the Veterans & Civilians Clean Water Alliance Facebook group. (2.5 K members and growing rapidly.)