Navy report on PFAS at Pearl Harbor, Hawaii comes up short
Preliminary Assessment closes the door on future scrutiny at many sites.
By Pat Elder
March 31, 2024
Contamination at Joint Base Pearl Harbor-Hickham threatens human health.
The Navy is creating a narrative about PFAS in Hawaii by waging a sophisticated psychological campaign orchestrated to confuse the public while closing the books on huge swaths of perpetually contaminated land and water. We’ll look at the Navy’s Preliminary Assessment of Potential Per- and Polyfluoroalkyl Substances National Priorities List Sites - December, 2023, Pearl Harbor-Hickham, Oahu.
The highly significant, yet relatively brief 238-page preliminary assessment was released to the public in mid-March, 2024 even though the State of Hawaii Department of Health reviewed the document in 2021.
The Navy began releasing PFAS preliminary assessments all over the country seven years ago. What took so long in Hawaii?
The Navy’s superficial study coincides with the Army’s report on PFAS in December, 2023, in which the Army glossed over contamination on eight bases while dismissing an additional eight bases from further PFAS-related scrutiny. Compelling evidence suggests the Army is prematurely shutting down PFAS investigations throughout Hawaii. Now we see the Navy doing the same thing.
We still don’t have any data from these Navy facilities.
Congress requires the DOD to follow the Superfund, or CERCLA process in its investigation and “remediation” of PFAS contamination. CERCLA is the Comprehensive Environmental Response, Compensation and Liability Act. Hawaii is just now beginning to enter into the CERCLA process for PFAS.
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The Navy in Hawaii is dreadfully behind the rest of the country in the CERCLA “clean up” process.
The Naval command continues to adhere to the EPA’s outdated Health Advisory of 70 parts per trillion for a combination of PFOS and PFOA even though the EPA has instituted an interim health advisory of .02 ppt for PFOS and .004 ppt for PFOA in drinking water. The Hawaii Department of Health has set Environmental Action Levels of 7.7 ppt for PFOS and 12 ppt for PFOA.
There are many more PFAS compounds in drinking water and the environment the Navy steadfastly refuses to address.
Preliminary assessments include a historical record search and interviews with DoD employees (in the chain of command) who have historical knowledge of the operations that may have contributed to a potential release. It’s like kicking the tires. Theoretically, the information collected helps the Navy determine whether there is a “potential” historical release and if further investigation is warranted. If the Navy doesn’t thoroughly examine sites, it can rule them out in this crucially important first round of the CERCLA process – and that is exactly what we see with the Navy’s Preliminary Assessment. They’re not kicking many tires and it will save them a lot of money on “cleanup.”
The Navy will allow a small handful of sites to proceed to the site inspection phase of the CERCLA process so we must keep an eye on future reports. The site inspections are accompanied by data describing PFAS in multiple environmental media. There is a noticeable trend that shows all three branches are releasing less and less data in the site inspections. While the Navy has shared volumes of data with much of the country, that information has been largely withheld in Hawaii.
The skimpy 238-page report covers ten facilities in Honolulu. By comparison, Naval Air Station Point Mugu’s Preliminary Assessment (PA) contains 3,159 pages. Naval Air facility El Centro’s PA has 744 pages, while Hunter’s Point has 447 pages and Port Hueneme has 462 pages. These bases are in California.
The Patuxent River Naval Air Station in Maryland, a much smaller facility than Joint Base Pearl Harbor Hickam, released its Preliminary Assessment back in 2018. They examined 48 sites and 16 of them moved on to the site inspection. Critics say most of these sites should have moved on to the site inspection phase.
At JBPHH, the Navy examined 18 locations on 10 facilities and identified 13 locations to be further scrutinized in the site inspection.
The Navy’s Preliminary Assessment includes the following facilities:
· Joint Base Pearl Harbor Hickam
· Naval Computer and Telecommunications Area Master Station (NCTAMS)
· Pearl Harbor Solid Waste Management Unit 13 (SWMU 13)
· Pearl Harbor Solid Waste Management Unit 6 (SWMU 6)
· Navy Munitions Command, East Asia Division Unit Pearl Harbor
· Fleet and Industrial Supply Center Pearl Harbor.
· Pearl Harbor Naval Submarine Base
· Pearl Harbor Naval Shipyard
· Naval Computer and Telecommunications Area Master Station - Naval Facilities Engineering Command Pacific National Priorities List site
· Pearl Harbor Naval Complex (PHNC) National Priorities List Site
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A prevalent theme runs through the Navy’s rationale when describing potential pathways to the human ingestion of these carcinogens. They want the public to forget that these toxins may migrate off their installations!
We can gain an understanding of the psychology inherent in the Navy’s report by analyzing the following section pertaining to three areas that used aqueous film-forming foam, or AFFF.
Human Health Exposure Pathway Evaluation
Figure 3-10, shown and analyzed in 5 brief sections below, appears in the Navy’s preliminary assessment. It analyzes three sources of PFAS contamination:
· Ford Island - Building 467 Fire Station #4.
· Richardson – Fleet Training Group Firefighting (FLETRAGRU) Training Area.
· Pearl Harbor Main Base - Building 206 Fire Station #1.
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Exposure pathways identified by the Navy include:
· Dermal contact from surface soil
· Inhalation of particulates
· Ingestion of plant/animals
· Dermal contact from surface water
· Ingestion of fish/shellfish
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Figure 3-10 Preliminary Assessment Potential Per- and Polyfluoroalkyl Substances National Priorities List Sites - December, 2023
The Navy: “Incidental ingestion and dermal contact with surface soil in areas with exposed dirt at all sites are potentially complete exposure pathways for all listed current and future receptors, although PFAS are not known to be absorbed dermally and information pertaining to health effects from dermal exposure is limited.”
Military Poisons: The scientific consensus is that dermal exposure to PFAS is of relatively low concern for most people - compared to ingesting contaminated food or drinking tainted water. Still, dermal exposure may be an important pathway for some. Firefighters across the U.S. are filing lawsuits against turnout gear manufacturers, claiming that the PFAS in their protective turnout gear caused cancer through dermal contact. Also, several states have moved to post signs warning recreational swimmers to avoid the PFAS foam.
The Navy: “Onsite occupational workers could potentially be exposed during the workday, with duties that might include landscaping/grounds maintenance.
If the property ownership changes, future residents could potentially be exposed to contaminants of potential concern in soil during outside activities (e.g., gardening) or to contaminants of potential concern in house dust originating from site soil at the Marina Park sites.”
“Because the fire stations are on a secured military base, it is unlikely that trespassers or recreational users would have on-site access (this rationale applies for all on-site pathways for these receptors). However, the Marina Park Former FLETRAGRU fire-fighting training area is an unrestricted area used for recreation, thus current and future dermal contact may occur.”
Military Poisons: The Navy makes the dust sound relatively insignificant. Carcinogenic dust is a major route of exposure, and it endures forever. PFAS coats the banks of Pearl Harbor’s streams and shoreline. When the streams ebb and the tide falls, the toxic sediment dries and is lifted into the wind. It settles as dust in our lungs and in our homes. Hawaii’s Department of Health ought to be testing people’s homes. It’s up to the activists to make it happen.
The graphic here shows the concentrations of PFAS in the dust of homes in a neighborhood outside of the Shepherd Field Air National Guard Base in Martinsburg, West Virginia.
Sources - Final Expanded Site Inspection Report for Per- and poly fluoroalkyl substances Shepherd Field Air National Guard Base – November 2020. - and PFAS Exposure Assessment - National Center for Environmental Health Agency for Toxic Substances and Disease Registry, Martinsburg, West Virginia – January, 2022.
Dust containing 16.4 million ppt of PFHxS and 13.9 million ppt of PFOS were found in a home in a neighborhood outside of the base. In Martinsburg, the Air Force reported that groundwater on the Shepherd Field Air National Guard Base contained 80,000 ppt of PFHxS, while they reported 8,100 ppt of the toxin in surface water on base. Consequently, residents showed elevated levels of PFAS in their blood, another “environmental media” that ought to be tested, like they’re doing throughout Japan.
The red dot is the location of the pump house at Adit 1. The location is 1,000 feet from Pearl Harbor. It leaked 5,000 gallons of PFOS containing 200,000 parts per trillion of PFOS. The floor of the pump house is made of porous material. This area is contaminated forever, and the dust is likely to be highly poisonous. The Navy kept this a secret as long as it could.
Figure 3-10, continued -
The Navy: “VOC’s are not COPC’s for any of these PFAS, so this pathway is incomplete.”
Military Poisons: C’mon, Navy! Write it so people can understand it. VOC’s are volatile organic contaminants like benzene, ethylene glycol, formaldehyde, methylene chloride, tetrachloroethylene, toluene, xylene, and 1,3-butadiene. Enough exposure to these will kill you as well. COPC’s are contaminants of potential concern. PFAS are the COPC’s du jour et pour toujours! (of the day and forever.)
The Navy: “Inhalation of particulates from surface soil is considered potentially complete for all current and future on-site receptors. Winds can cause the formation of fugitive dusts by suspending surface soil particulate matter in air. Shallow excavations and earthwork would also enhance the generation of soil dusts.”
Military Poisons: “Potentially complete”? Still, it’s rare to read such candor from the Navy. The continued agitation by activists in Hawaii pays dividends, although this Goliath is not easily moved.
Figure 3-10, continued -
The Navy: “Bio-uptake is considered an incomplete pathway for most current and future on-site receptors because no agricultural or hunting activities occur at the sites and occupational workers and construction workers are not expected to eat produce or animals obtained from these sites. If the property ownership changes, future residents could potentially be exposed during gardening activities. However, such exposure would likely be insignificant compared to other pathways.”
Military Poisons: How about a thousand years from now and what about off-site receptors? We can expect profound contamination of the entire food web, starting with the soil, sediment, surface waters, and invertebrates.
Figure 3-10, continued -
The Navy: “Because of the close proximity of waterways to the Bldg. 467 Fire Station Number 4 and Marina Park former fire-fighting training area, contaminants of potential concern in site surface soil could migrate to the off-site water body of Pearl Harbor. Exposure pathways in these waterways are considered insignificant for recreational users/trespassers, however, because of expected low exposure time, frequency (based in part on Pearl Harbor access restrictions) and concentrations. Exposure of current and future onsite workers and future residents is considered incomplete. If exposure to these receptors were to occur, it would occur off site, and they would have the same exposure as a recreational user/trespasser.”
Military Poisons: The Navy has created a parallel universe and prefers to live in it.
Figure 3-10, continued -
The Navy: “The same rationale for incidental ingestion and dermal contact in waterways apply to bio-uptake pathways.”
Military Poisons:
Most of the PFAS in our bodies is from the “Ingestion of fish/shellfish,” an inconvenient truth for Hawaii.
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Preliminary assessments are all about the environmental sites that proceed to the site inspection phase of the CERCLA process.
With this preliminary assessment in Hawaii, only sites identified as Group A, B, or C are recommended for further evaluation for PFAS in the Site Inspection. Therefore, only 13 sites from the 10 facilities will be further scrutinized. The descriptions of two of the Group D sites which were eliminated from further inspection were redacted. The Navy is only admitting they used the carcinogenic foams at seven “Group A” locations on these facilities. We’ll examine this below.
Like the Army - the Navy is focusing on the firefighting foams while they use PFAS in hundreds of products and applications every day. Congress directed the DOD to prepare a report outlining the uses of PFAS that are critical to the national security of the United States. Lots of things fit that bill! In response, the DOD published a report on Critical Per-and Polyfluoroalkyl substance uses in August, 2023.
Today, the contamination in Hawaii has more to do with the everyday, routine use of PFAS in products and applications, like tape made with Teflon, adhesive sprays made by 3M, or Viton, made by the Chemours Company, that is added to synthetic rubber. 3M’s Novec Cleaner is loaded with PFAS. It is all irreplaceable, according to the U.S. military. Almost all of it winds up in the sewer effluent, the sewer sludge, or the landfill - three locations not covered by the preliminary assessment.
Groups A,B,C,D in the Preliminary Assessment of Potential Per- and Polyfluoroalkyl Substances National Priorities List Sites - December, 2023
Group A: Known release sites (fire suppression for crashes, hangar tests); or repeated small quantity release sites (fire fighting training area [FFTA]), first occurring in the mid-1960s, where AFFF suppressants known to have contained PFAS were documented to have been used. Group A sites are considered the most likely to have impacted the subsurface soil and/or groundwater.
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: Electro-plating facilities that may have utilized vapor suppressants containing PFAS.
Group D: Potential other secondary sources of PFAS releases (areas with documented housekeeping practices or where compounds containing PFAS were not intentionally released, including landfills, sludge disposal areas, and oil-water separators). These areas do not have documentation of past use of AFFF or PFAS.
Eliminating landfills from the Site Inspection is unwise. The Navy admits that firefighting foams “may have been released” to the landfills. We know many industrial items containing PFAS are disposed of in landfills. Sludge disposal areas, both on base and off base are typically heavily impacted by the carcinogens. Where does the sludge go? We can’t burn it, we can’t bury it, and we can’t spread it on agricultural fields.
Here’s a task for researchers to learn about the role played by the Hawaii Department of Health during their review of this preliminary assessment back in 2021. Go all the way to the last two pages of the document to see the comments by the Hawaii Department of Health and the Response to DOH comments by the Navy.
Environmentalists ought to keep an eye on Table ES-1 below.
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