PFAS levels at Red Hill may be highest worldwide
Hawaii Dept. of Health also identifies frightening levels of carcinogenic PFAS in landfills and wastewater.
By Pat Elder
December 19, 2024
Crews shovel contaminated soil onto a wheelbarrow at the site of the Adit 6 PFAS spill that occurred on November 29, 2022 at Red Hill. They removed 3,000 cubic feet of soil, about the same amount of soil in a backyard garden.
Data released by the Hawaii Department of Health show that 3% Ansulite aqueous film-forming foam, (AFFF) concentrate contained 191.5 billion parts per trillion of total PFAS. The previous record was held by the former Brunswick Naval Air Station in Maine with 3.78 billion ppt.
On November 29, 2022, 1,300 gallons of the Ansulite AFFF concentrate was released at the Red Hill Bulk Fuel Storage Facility in Hawaii. The AFFF was part of the facility's fire suppression system. Accidents like this have occurred on U.S. military installations worldwide.
The Hawaii Dept. of Heath Report, (HIDOH Report) says the high concentration could pose a significant threat to groundwater that is a source of drinking water. This includes the potential long-term leaching of residual PFAS from highly impacted soil. The study calls for additional investigation of potential impacts to aquatic habitats that are the basis of the island’s food chain.
Ansulite 3% concentrate is available for purchase. The Red Hill AFFF spill totaled approximately 5 of these 265 gallon containers.
It is rare for us to have a glimpse of the makeup of AFFF concentrate.
What’s in the AFFF Concentrate?
Technical note: The pre-total oxidizable precursor (Pre-TOPs) analyzes a sample as it is received, while the Post-Tops analyzes a sample after it is combined with oxygen. The initial sample may include many PFAS precursors, which may be converted into other PFAS compounds through oxidation. The “results” are the comparison between the two samples. The science is evolving.
PFPeA (Perfluoropentanoic acid)
The Red Hill concentrate contained 100 billion parts per trillion of PFPeA, which is not a regulated substance in the U.S. The National Institutes of Health does not list diseases and disorders that are associated with PFPeA, while the FDA does not regulate PFPeA in chocolate cake or any other food. The EPA does not regulate PFPeA, although the European Union does.
For what it’s worth, the state of Hawaii has established an Environmental Action Level for PFPeA in drinking water at 1,530 ppt.
Five years ago FDA scientists found PFPeA in chocolate cake at a concentration of 17,640 parts per trillion. Their lack of regulatory actions suggests they think it’s OK to eat.
PFPeA is absorbed through the skin. It is known to become part of the air, dust, and rain. Like all types of PFAS it is believed to be bio accumulative and adversely impacts bodily organs. More study is needed on PFPeA, especially on heavily impacted Oahu. Why don’t we know more about PFPeA?
PFBA
PFBA had a concentration of 50 billion parts per trillion in the concentrate at Red Hill. Unlike PFPeA, PFBA has been extensively studied. PFBA’s concentration is thought to be the highest level ever reported.
The Navy - with the EPA and the states conveniently on the sidelines - has assumed the role of a regulatory agency by publishing project screening levels, (PSL’s) for PFAS they routinely release into the nation’s rivers and fish. If a contaminant level at a site falls below the screening level, no additional action is needed - not that the Navy would do anything anyway. The Navy has set a project screening level for PFBA at 57,400 ppt in surface water, which includes rivers and the ocean. The Navy has also set a project screening level of 260,000 ppt for PFBA in fish.
Ng/L stands for nanograms per liter, or parts per trillion.
If water has 203 ppt of PFOS, the fish may be expected to have tens - or hundreds of thousands of parts per trillion of PFOS, while the EPA says we should not drink water with more than 4 ppt of PFOS.
Ug/kg stands for micrograms per kilogram, which is the same as parts per billion, so 260 ug/kg = 260,000 ppt.
PFBA has been used as a substitute for PFOS and PFOA in firefighting foams. PFBA bioaccumulates in fish and it is known to accumulate in our lungs. It is associated with poor covid outcomes, according to the world-renowned scientist and PFAS pioneer Dr. Phillippe Grandjean.
PFBA is also associated with fatty liver disease and kidney disease. It has been found to accumulate in agricultural crops and has been detected in household dust, soil, food products, and surface, ground, and drinking water. Oahu may have more of it in the environment than anywhere on the planet.
Hawaii's kidney failure rate is 30% higher than the national level. Earlier this year, a study of nonalcoholic fatty liver disease in adolescent and young adult Pacific Islanders and Asians living in Hawai'i shows a much higher rate of nonalcoholic fatty liver disease than those reported in other parts of the United States.
AFFF impacted soil
A trowel was used to collect gravelly, clayey soil from the upper two to four inches of the impacted area. Samples were tested using SGS Method MLA110 and TOPs method MLA111. The soil contained 23,839,000 parts per trillion of total PFAS at the Red Hill AFFF site.
The previous world record for PFAS in soil was held by the Naval Research Laboratory’s Chesapeake Bay Detachment in Chesapeake Beach, Maryland. That site on the banks of the Chesapeake Bay contained 7,950,000 ppt of PFAS in the subsurface soil. The fish and the oysters are contaminated there, although few seem to care.
AFFF release sites are like toxic injections into mother earth. They contain the highest concentration of PFAS compared to the chronic, every day releases contributed by wastewater treatment plants, landfills, and incinerators. It is both criminal and incomprehensible that the Army and the Navy in Hawaii have closed the books on many of these AFFF release sites.
Wastewater Treatment Plants
The HIDOH Study provides analytical results of liquid effluent and biosolids in selected wastewater treatment plants throughout Hawaii. “Biosolids” is a euphemistic name given by the industry for sludge. HIDOH claims these results “were characterized by relatively low concentrations of less toxic, short-chain PFAS compounds” and that the health risk “posed by largely hypothetical, regular exposure to PFASs in these media is estimated to likewise be relatively low.”
HIDOH may be right by referring to “relatively low concentrations” if the levels are compared to the concentrations where AFFF was routinely used or spilled, but this is a misleading characterization.
Twenty cubic yard roll-off bins like this one are used to collect and transport biosolids at wastewater treatment plants. Human feces are the primary component of biosolids, although they are mixed with heavy concentrations of PFAS from both industrial and residential sources.
The HIDOH Report explains that “biosolids” at most wastewater facilities are disposed of in municipal landfills. This is terrible public policy because the practice contaminates produce, livestock, groundwater, and surface water.
The report says the use of effluent for irrigation of agricultural fields where food crops are grown “requires additional research.” We didn’t learn anything from Kunia Village? The state should know where they allowed the sludge to be spread. We must demand that they release the inventory of the locations where these carcinogens have been applied to agricultural lands.
Effluent is shown here. It is the liquid product of the wastewater treatment process.
The liquid effluent from wastewater treatment plants in Hawaii is injected into coastal groundwater which ultimately drains to the ocean. They also use the toxic liquid for the irrigation of landscaped areas and golf courses.
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While you're strolling down the fairway
Showing no remorse
Glowing from the poisons
They've sprayed on your golf course
While you're busy sinking birdies
And keeping your scorecard
The devil's been busy in your backyard.
Devil’s Been Busy - Song by Traveling Wilburys
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The HIDOH report says uptake of PFAS and biomagnification in the food chain could be a concern in areas where effluent is discharged into bodies of water with limited circulation, particularly freshwater lakes, or streams. These ecosystems may be fantastically poisoned while the tiny fish in streams may travel to deeper waters and be consumed by larger fish.
The state has still not engaged in a large-scale fish testing regime, so it is preposterous to continue reading that HIDOH says dangerous levels of PFAS have not been reported in fish. The European Food Safety Authority says that 86% of the PFAS in human blood is from the food we consume, especially the fish and seafood. In Honolulu, the contaminated air is likely to be a greater pathway of ingestion of PFAS than the drinking water. Water officials in Honolulu. take their kuleana to provide safe drinking water.
The biosolids at the Sand Island Wastewater Treatment plant contain a total PFAS concentration of 90 ug/kg, or 90,000 ppt., while the Hono’uli’uli biosolids contain 73,000 ppt. No one has been able to come up with a better way to meet the challenge of how to “dispose” of these chemically laden materials.
The HIDOH Report says the liquid leachate periodically removed from landfills is, in some cases, disposed at wastewater treatment plants (WWTPs), which allow them to pass through to the ocean. The report says that discharges of effluent from WWTPs included in the study do not threaten a source of drinking water, however, they say “environmental and engineering controls at regulated, municipal landfills serve to minimize the risk to underlying groundwater.” Perhaps these measures minimize the threat to public health, but they don’t eliminate it.
Are these “engineering designs” expected to last a hundred years? A thousand years? It is eerily reminiscent of spent nuclear fuel, considering that the development of nuclear energy and PFAS are inter-related.
The liquid effluent of the Sand Island WWTP contains 445 parts per trillion of total PFAS while the Hono’uli’uli WWTP contains 522 ppt. Military Poisons tested the waters at Sand Island and found more than 100 ppt of total PFAS draining into the ocean. Many of the compounds emptying into the sea are known to bioaccumulate in fish.
H-Power and PFAS
The HIDOH Report says biosolids generated at three of the six WWTPs may be disposed of at municipal waste-to-energy incinerators. They didn’t mention H-Power by name. This is the Honolulu Program of Waste Energy Recovery, owned by the City and County of Honolulu. On Oahu, "H-POWER" is the only facility that incinerates trash. The plant can burn up to 3,000 tons of garbage per day. They burn the trash to produce electricity.
H-POWER contaminates the air.
When incinerators burn household trash they produce a range of harmful chemicals including dioxins, furans, lead and mercury, nitrogen oxides, sulfur dioxide, carbon monoxide, volatile organic compounds (VOCs), and polycyclic aromatic hydrocarbons (PAHs).
And lots of PFAS.
H-Power is operated by Reworld, a company formerly known as Covanta. Honolulu’s H-Power waste-to-energy facility burns trash at temperatures up to 2,000 degrees Fahrenheit. This is a big problem because incineration of PFOA and PFOS usually occurs at temperatures ranging between 1600 and 2000°C, or from 2,912°F to 3,632 °F. Honolulu’s H-Power can’t touch this. It means a silent carcinogenic dusting of PFAS is likely covering the island and the ocean.
The smoke produced when trash is burned in an incinerator can travel through the air and drift to nearby areas, carrying harmful pollutants and impacting air quality and the health of people living nearby.
H-Power’s smokestack in Kapolei rises to 303 feet and is situated at the southwest corner of the island. The graphic here depicts the time period from December 15-22, 2024.
On Monday, Tuesday, and Wednesday, the wind blows the toxins toward Waipahu. On Thursday, it will head toward downtown Honolulu. On Friday and Saturday, it will head out to sea, and on Monday it will point toward Waipahu again.
Landfills and Leachate
We’ve examined AFFF release sites, wastewater treatment plants, and incineration. Now, we’ll compare the leachate flowing from the Waimanalo Gulch Sanitary Landfill and from the PVT Landfill, a construction and demolition landfill in Nanakuli.
The leachate from the PVT Landfill has nearly 3 times the concentration of PFAS than the Waimanalo Gulch Landfill. The PVT Landfill receives debris from the demolition of residential and commercial properties. Demolished buildings contain lots of PFAS because the chemicals are in carpets, paint, wiring, and furniture.
As far as PFAS is concerned, burying demolished buildings is worse than landfilling the ash and trash, although it’s all bad.
The left-over AFFF
The Navy announced the remaining AFFF from Red Hill “will be taken off Oahu for proper disposal at an Environmental Protection Agency (EPA)-permitted facility in Arlington, Oregon.” They rarely mention the names of their private partners. Chemical Waste Management of the Northwest, Inc. is located in Arlington near the Columbia River about 2 hours east of Portland.
The Hawaii Department of Health must explain to the public exactly what is involved in “proper disposal” of PFAS. They don’t have a clue about how to dispose of these chemicals and neither do their “partners,” the Navy and the EPA.
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This summer I’d like to return to Hawaii and Japan to test tap water, surface water, and people’s blood. The water test kits are $70 each, while the Empower DX pin prick tests are $249. Testing blood is politically explosive. It has managed to move the Japanese government to begin taking the threat of PFAS more seriously and it may help to nudge Hawaii to stiffen its resolve in its interactions with the Navy.
The Downs Law Group also helps to make this work possible.
The Downs Law Group understands the contamination flowing from military bases. The firm 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.