Hawaii, the EPA, the Navy, and 6:2 FTS
A technical report in plain language on this pervasive PFAS compound
By Pat Elder
June 26, 2024
Adit #6 (horizontal tunnel #6) at the Red Hill Underground Fuel Storage Facility at Joint Base Pearl Harbor–Hickam after the leak of firefighting foam concentrate.
Photo: Spc. Matthew Mackintosh/Joint Task Force Red Hill
See the report, “Red Hill AFFF Assessment Sampling” by APPL Labs, dated December 27, 2022. The results for Adit 6 show 4,700 parts per trillion, (ppt) of 6:2 Fluorotelomer sulfonic acid (6:2 FTS) in groundwater. This is a frightening level.
Adit 6 is the location of the PFAS spill of 1,300 gallons of PFAS concentrate released by the Navy at Red Hill on November 29, 2022.
To understand the significance of the 4,700 ppt in groundwater, see the concentrations of 11 PFAS compounds below reported by the Navy from the leak at Adit #6.
6:2 FTS
86% of the 5,480 ppt of total PFAS found in the groundwater at Adit 6 was comprised of 6:2 FTS.
Normally, the news media reports on two compounds: PFOS and PFOA. These compounds have been phased out of production and use for many years, although they’ll be with us forever. They’ve been replaced with compounds like 6:2 FTS that never make the headlines.
The groundwater at Adit 6 contains concentrations of 2.9 ppt of PFOS and 25 ppt of PFOA. The EPA has set a mandatory level of 4 parts per trillion for each of these two carcinogens found in our groundwater and drinking water.
6:2 FTS is a substitute for PFOS in firefighting foams and chrome plating. It may also cause injury to human health and the environment. Once the Navy and the state realized the high numbers associated with 6:2 FTS, they relaxed the regulations on it, while the EPA watched from the sidelines.
Apparently, the Navy and the state work in tandem on these things while many still think the state of Hawaii and the EPA act in a regulatory role. The Navy calls the shots.
Examine the March 1, 2024 letter from the Hawaii Department of Health to the Navy a little more than a year after the Red Hill leak:
"The weekly sampling conducted in response to the 2022 AFFF release consistently detected low-level PFAS compounds in multiple wells. The PFAS detected included 6:2 FTS, a primary component of newer formulations of AFFF such as the material released at Adit 6. While the monthly routine sampling results did not exceed current screening levels, detections were persistent, widespread throughout the monitoring area, and not delineated."
In Hawaii, “screening levels” are called Environmental Action Levels, (EAL’s). The 4,700 ppt detected for 6:2 FTS in December, 2022 was 6 times over the EAL of 780 ppt at the time. It didn’t matter then, and it doesn’t matter now. The Navy calls the shots.
While much of the rest of the country has been tightening regulations regarding allowable levels of PFAS in water, Hawaii has been relaxing regulations. From 12/22 to 4/23 Hawaii increased its EAL for 6:2 FTS from 780 ppt to 1500 ppt in groundwater.
Still, the 4,700 ppt for 6:2 FTS is 3 times over the new EAL of 1,500.
See Table A for the Dec., 2022 EAL’s. (HIDOH)
See Table A for the April, 2023 EAL’s. (HIDOH)
See Table A for the April, 2024 EAL’s. (HIDOH)
We can see that the Hawaii Department of Health greatly relaxed the regulatory standards for groundwater for several PFAS compounds. They moved the goal posts! They are putting the desires of the naval command ahead of the health of the people. Groundwater is used for drinking water. It empties into surface water and the sea.
Notice the sudden and drastic increases in the concentrations allowed for PFBS, PFBA, PFPeA, PFHxA, PFDoDA, PFTrDA, PFTeDA, PFOSA, HFPO-DA. All of these compounds are found in fish, generally the most prevalent pathway to human ingestion. Often, concentrations may exceed 100,000 parts per trillion in the filet of fish. 6:2 FTS has been documented in Okinawa with 190,000 parts per trillion. Hawaii does not test fish for PFAS. Michigan tested 2,600 fish and found the average to contain 80,000 parts per trillion of PFOS alone.
These compounds are all likely used in products and applications at Joint Base Pearl Harbor Hickam.
The Navy largely controls THE DOH and the EPA, the first two monkeys here. They’re having a problem with the third monkey. (please allow the editorial discretion with the monkeys.)
Hawaii’s Department of Health pretends not to see it. The EPA doesn’t want to hear about it, while the people are studying and organizing. They are resisting the suffering and disease they have endured.
Below is a list of these dangerous chemicals and their associated diseases and disorders compiled by the National Institutes for Health. Pub Chem still offers no associated diseases and disorders for 6:2 FTS, PFPeA, or PFTeDA.
PFBS
Diabetes, Gestational
Dyslipidemias
Hepatomegaly
Hypertension, Pregnancy-Induced
Pre-Eclampsia
PFBA
COVID-19
Chemical and Drug Induced Liver Injury
Fatty Liver
Fibrosis
Hepatomegaly
Hyperplasia
Hypertrophy
Kidney Diseases
Necrosis
Skin Diseases
PFHxA - 6:2 FTS may biodegrade forming PFHxA.
Gilbert Disease
Nose Diseases
Poisoning
PFDoDA – Associated Diseases
Chemical and Drug Induced Liver Injury
Conotruncal cardiac defects
Diabetes, Gestational
Eczema
Polycystic Ovary Syndrome
Prenatal Exposure Delayed Effects
PFTrDA
Birth Weight
Fetal Growth Retardation
PFOSA
Teratogenesis
HFPO-DA
Birth Weight
Chemical and Drug Induced Liver Injury
Fatty Liver
Hepatomegaly
6:2 FTS – We know a little
The EPA has not established a reference dose or a reference concentration for 6:2 FTS. This compound now dominates the PFAS landscape at locations across the country while the EPA-monkey is sitting on its hands.
Several studies indicate 6:2 FTS can cause kidney and liver damage in rodents. Scientists have found considerable concentrations of 6:2 FTS in marine invertebrates, indicative of bioaccumulation. Deer in Michigan and Maine have been found with high levels of 6:2 FTS near military bases.
The EPA finds that the manufacture, distribution in commerce, processing, use, or disposal of 6:2 FTS may present “an unreasonable risk of injury to human health or the environment.” The EPA says 6:2 FTS may present concern for inhalation exposures.
The EPA, however, finds that the inhalation toxicity information on 6:2 FTS is insufficient, so there are no restrictions on its use.
Like other PFAS compounds, 6:2 FTS may be emitted into the air as vapors or fine particles that travel by attaching to dust that settle in our lungs and homes. They may be deposited in the sediment of creeks and rivers.
Mist suppressant products used in chrome plating, such as Fumetrol 21, contain 6:2 FTS as a PFOS replacement
Fumetrol reduces the surface tension of the chromium electroplating bath. Reduced surface tension means reduced size of the bubbles produced. Reduced bubble size causes less misting, hence less hexavalent chromium emissions. The Navy uses a lot of hexavalent chromium, Erin Brockovich's favorite compound.
Many consumer products containing 6:2 FTS are eventually sent to the landfill. The rain creates liquid leachate containing disease-causing agents. From there, it’s a matter of determining the pathways to human ingestion.
In a 2021 study, the EPA estimated the average wastewater concentration of 6:2 FTS was more than 100 times greater than any other PFAS detected in chromium electroplating wastewater.
Michigan has derived health-based standards for 6:2 FTS in outdoor air. Hawaii has not.
Legislative efforts in Hawaii go nowhere.
SB 2418, an effort to enact procedural and substantive requirements for the establishment and revisions of Environmental Action Levels by the state was defeated by the legislature of the state of Hawaii earlier this year.
From the bill: “The legislature further finds that there are currently no procedural requirements or standards to establish EALs for various toxins that are monitored, or to revise, upward or downward, EALs for toxins and pollutants. Previously, EALs have been raised by state agencies without public notice and without publication of the scientific justification for the increases, resulting in a relaxation of enforcement standards and a potential increase in pollution.”
Increasingly, the eyes of the world are on Hawaii. The state has been blessed with fearless and accurate news reporting and an aroused citizenry that understands the threat to the public health and the environment while overcoming reprehensible Navy, EPA, and DOH propaganda.
Restoration Advisory Boards
The Navy uses Restoration Advisory Boards, (RAB's) to restrain community-based environmental activism. See my report, Survey Monkey and the Dog and Pony Show on the Navy's RAB's.
I will be travelling to Ireland, UK, and Germany in July and to Japan in August to meet up with environmental activists working with Veterans for Peace to test surface waters that drain from industrial and military sites for PFAS contamination. We’ve raised a lot of money, but we still need to raise $3,000. Please help. Please make a note that your contribution is for testing waters in Europe and Japan.
The Downs Law Group helps to make this work possible. Their support allows us to research and write about military contamination around the world.
The firm is working to provide legal representation to individuals in the U.S. and abroad with a high likelihood of exposure to a host of 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 or your dependents 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? Contact James Bussey at busride1969@hotmail.com
Consider joining the Veterans & Civilians Clean Water Alliance Facebook group. 2,700 members and growing.