An examination of PFAS contamination at Wheeler Army Airfield
The Army routinely violates federal law.
Part 4 of a 6-part series
Part 1 – The Army is leaving contaminated O’ahu sites to focus on Pohakuloa
Part 2 – PFAS contamination at Pohakuloa
Part 3 – PFAS contamination at three leased bases on O’ahu
By Pat Elder
February 1, 2026
A 3D modeling of a planned southern flightline expansion project at Wheeler Army Airfield in Hawaii.
The U.S. Army is flouting the intent and enforcement mechanisms of federal law designed to regulate and remediate PFAS contamination at Wheeler Army Airbase and throughout Hawaiʻi. It systematically narrows the scope of investigations, minimizes documented contamination, and delays meaningful cleanup. As it has for decades, the Army prioritizes weapons systems and operational budgets over environmental responsibility, public health, and the communities left to live with the consequences of its pollution.
In doing so, the Army has made a mockery of the CERCLA investigatory and remedial process—a failure that remains largely invisible to the public. The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted by Congress in 1980 to compel polluters to identify, contain, and clean up hazardous contamination. From the outset, the Department of Defense aggressively opposed the law, fully aware that enforceable liability for chronic contamination would expose the military to enormous cleanup obligations. That resistance never disappeared; it simply evolved.
The Army pretends not to see the contamination; it doesn’t want to hear criticism; and it refuses to address its critics.
Today, the Army effectively dominates the very regulatory framework meant to hold it accountable. Through constrained Preliminary Assessments, truncated Site Inspections, selective sampling, and institutional deference by regulators, the Army controls how PFAS contamination is defined, how risks are characterized, and whether remediation ever occurs. This pattern is plainly visible across 20 Army installations throughout Hawaiʻi.
The urgency of this analysis was underscored in 2025, when the Hawaiʻi Board of Land and Natural Resources voted 5–2 to reject the Army’s Final Environmental Impact Statement, concluding that it failed to adequately disclose environmental impacts and did not satisfy the requirements of Hawaiʻi law. That decision represents a rare and consequential rebuke of the Army’s environmental practices and places heightened scrutiny on every unresolved contamination issue statewide.
This analysis is especially critical now as the federal government pressures state officials to extend its lease of public lands at the Pōhakuloa Training Area on the Big Island and the remaining land at Kahuku Training Area on O’ahu—despite unresolved contamination, incomplete investigations, and a long record of environmental noncompliance at every one of its major installations in Hawaiʻi.
PFAS contamination on military installations is designed to be addressed under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
Under CERCLA, the first step in the “cleanup process” is the Preliminary Assessment (PA)—a largely paper-based screening that relies on existing records, interviews, and sometimes, site reconnaissance. The PA can either terminate further action or identify Areas of Potential Interest,- (AOPIs) to be carried forward.
A Site Inspection (SI) is intended to follow the Preliminary Assessment and involves targeted field work and environmental sampling at identified Areas of Potential Interest (AOPIs) to confirm contamination, evaluate exposure pathways, and determine whether a site must advance to a full Remedial Investigation (RI).
In practice, however, there is a fundamental disconnect. Under CERCLA, a Remedial Investigation is a detailed, phased field study designed to characterize the nature and extent of contamination so that a Feasibility Study (FS) can evaluate potential cleanup alternatives. That framework presumes that a remedy exists! With PFAS, it does not. There is currently no scientifically viable method to remediate these chemicals once they are released into soil, groundwater, air, or surface water at scale. Like the evils released from Pandora’s box, PFAS cannot be meaningfully recovered, destroyed, buried, or burned without creating additional risks.
As a result, the CERCLA process—designed for contaminants that can be excavated, treated, or contained—fails when applied to PFAS. Investigations proceed as if cleanup were possible, while in reality the process produces studies, delays, and paper remedies rather than meaningful environmental restoration. For PFAS, CERCLA has become a mechanism for managing liability and deferring action, not for achieving cleanup.
To understand how the Army is living in a kind of parallel universe, examine the first page of the Environmental Working Group (EWG) chart below identifying the seven most heavily PFAS - contaminated Air Force bases in the country. At many installations on the mainland, it is routine to test dozens of groundwater locations for PFAS. By contrast, in Hawaiʻi, the Army collected a single groundwater sample at Wheeler Army Airfield. That lone sample—drawn from 557.97 feet below ground surface—contained 174.7 parts per trillion of total PFAS.
The implications are obvious. Sampling one deep location tells us nothing about contamination at various depths, closer to source areas, or migrating laterally through the aquifer. Had the Army conducted meaningful sampling at different depths and locations; it could have discovered PFAS concentrations orders of magnitude higher, as has occurred repeatedly at comparable military airfields nationwide.
This is a despicable shell game. EWG’s nationwide analysis of PFAS contamination at military installations—particularly airfields—shows that all 100 bases examined had PFAS in groundwater exceeding 33,000 ppt. Sixty-four bases exceeded 100,000 ppt, and 13 bases exceeded 1 million ppt. These are not outliers; they are the norm when comprehensive sampling is conducted.
Highest Levels of PFAS Contamination in Groundwater at U.S. Military Installations
— Environmental Working Group
Since the publication of the EWG study, the Navy has reported 2,882,554 ppt of PFAS in groundwater at Joint Base Pearl Harbor-Hickam. Meanwhile, the Army, citing its commitment to environmental stewardship, has reported 174.7 ppt of PFAS in groundwater at Wheeler Army Airbase.
The EPA under the Biden Administration, sought to limit drinking water to 4 parts per trillion for PFOS and PFOA, and 10 parts per trillion for four other PFAS compounds, reflecting the growing scientific consensus that these chemicals are extraordinarily dangerous. EPA drinking water standards apply to any groundwater that is used, or may reasonably be used, as a public drinking water source, not just water currently drawn from active municipal wells.
That standard has now been deferred under the Trump Administration. PFAS also poisons the food chain on O’ahu.
The Navy has reported PFAS concentrations as high as 2.88 million parts per trillion in groundwater, levels that pose a grave threat to ecosystems and raise profound concerns about contamination of Hawaiʻi’s interconnected food web. To its credit, the Honolulu Board of Water Supply has remained vigilant, aggressively monitoring drinking water sources and maintaining tap water that meets public health standards.
That success, however, masks a deeper failure in how the military evaluates PFAS contamination. Across its PFAS investigations, for instance, the U.S. Army focuses almost exclusively on drinking-water exposure pathways, while systematically refusing to assess PFAS concentrations in other critical environmental media. Soil, sediment, surface water, invertebrates, fish, wildlife, human biomonitoring, and air pathways are ignored. By narrowing its analysis to treated drinking water—rather than the broader environment through which PFAS migrate, persist, and bioaccumulate—the Army obscures the true scale of contamination and avoids confronting the long-term ecological and human health consequences of its pollution.
Wheeler Army Airfield - Preliminary Assessment / Site Inspection, June, 2023
Wheeler Army Airfield occupies about 1,500 acres on the island of O’ahu and is primarily dedicated to aviation operations. Schofield Barracks, next door, by contrast, spans roughly 17,000 acres, making it one of the largest Army installations in the Pacific, with extensive training areas, housing, industrial facilities, wastewater infrastructure, landfills, and multiple historical fire-training and maintenance zones.
Despite its much smaller footprint, Wheeler has likely used substantially more aqueous film-forming foam (AFFF) than its neighbor. Carcinogenic firefighting foams are routinely associated with aircraft hangars, crash-rescue training areas, and flight-line operations—core functions at Wheeler. Schofield Barracks, meanwhile, provides a broader case study, revealing how PFAS contamination arises not only from firefighting foams but from nearly every imaginable Army operation. We’ll examine Schofield Barracks in part 6 of this series.
A glance at the summary of “areas of potential interest” at Wheeler shows seven sites will be further evaluated. All of them are associated with the use of aqueous film-forming foam, (AFFF).
Table ES-1. Summary of AOPIs Identified during the PA/SI at WAAF
PFOS, PFOA, PFBS, PFNA, and PFHxS Sampling and Recommendations
Notes: 1. Soil analytical data indicate PFOS, PFOA, PFBS, PFNA, and/or PFHxS presence below Office of the Secretary of Defense (OSD) risk screening levels, but because there is a potential for migration to groundwater, further evaluation is recommended.
2. The existing monitoring well sampled during the PA/SI was in close proximity to both Building 200: Fire Station #14 AOPI and Building 251: Civil Air Patrol Hangar AOPI. Therefore, the groundwater results were used to evaluate and recommend both AOPIs for further study in a remedial investigation.
Gray shading – detection greater than the OSD risk screening level.
GW – groundwater
SO – soil
NS – not sampled
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Table 6-2 Office of the Secretary of Defense (OSD) Risk Screening Levels Calculated for PFOS, PFOA, PFBS, PFNA, PFHxS, and HFPO-DA in Tap Water and Soil Using USEPA's Regional Screening Level Calculator
Notes: 1. Risk screening levels for tap water and soil provided by the Office of the Secretary of Defense, 2022. Memorandum: Investigating Per- and Polyfluoroalkyl Substances within the Department of Defense Cleanup Program. July 06 (Appendix A).
2. All soil data will be screened against both the Residential Scenario and Industrial/Commercial risk screening levels (if collected from less than 2 feet bgs), regardless of the current and projected land use of the AOPI.
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The U.S. Army’s soil screening level for PFOS is set at .16 ppm. This is the same as160,000 ppt. A screening level is a non-binding risk-assessment benchmark used to decide whether further investigation is warranted, whereas an enforceable limit is a legally binding standard that triggers mandatory compliance, corrective action, or penalties when exceeded.
To put this non-binding standard into perspective, soil levels at the Pōhakuloa Training Area were found to have 1,700,000 ppt of PFOS in soil at the former fire station, Building 39. (See Table 7-1). This is 10.6 times higher than the soft screening advisory. These levels were not made clear to the public when the Army submitted its sadly lacking Final Environmental Impact Statement for Pōhakuloa in April, 2025. The former fire station site advanced to the “remedial investigation” phase of the CERCLA process where it is expected to languish for years until most everyone forgets about it.
Germany and the Netherlands have set enforceable limits of PFOS in soil that apply across these counties, except at U.S. military installations like Volkel Air Base (Vliegbasis Volkel) and Germany’s Büchel Air Base (Fliegerhorst Büchel) that host U.S. B61 nuclear gravity bombs under NATO’s nuclear-sharing arrangement. These bases and other US/NATO facilities are subjected to the Status of Forces Agreements (SOFAs) that manage to circumvent pesky national environmental standards. Groundwater, surface water and fish are highly contaminated at U.S. / NATO bases across the continent.
Women who are pregnant or who may become pregnant must not eat the contaminated fish or food from these regions. No one else should either.
Germany has binding PFAS assessment guidelines that regulate both groundwater and the soil–to–groundwater pathways. This is something the EPA and its “partner” the Army, do not seriously pursue. Under German guidelines, PFOS in groundwater has a “trigger value” of 100 ppt. the level at which remediation or further investigation becomes mandatory.
The Netherlands enforces a standard of 2,300 ppt of PFOS in soil – compared to the 160,000 screening levels that really don’t mean much in the U.S. Source: RIM, Germany PFAS Guidelines
So sorry about the diversion from the Wheeler Army Airfield discussion. We are back on.
Figure 5-2 Areas of Potential Interest (AOPI) Locations, Wheeler Ary Airfield. The Former Fire-Fighter Training Area is shown here, but not included in the listing of areas of potential interest. We’ll look at it later.
Below we will examine the narratives associated with each AOPI at Wheeler Ary Airfield.
AOPI - Building 200 – Fire Station 14 – During site visit interviews, Federal Fire Department personnel noted that fire truck water tank reservoirs were emptied onto a grassy field located near the northern installation boundary, just north of Building 200: Fire Station #14, when the water reservoirs became contaminated with AFFF. It was standard procedure to flush out the system and refill the foam and water reservoirs following any AFFF use. AFFF has been stored at Building 200: Fire Station #14.
AOPI - Fire Truck Water Tank Drainage Area is a grassy field located approximately 700 feet northwest of AOPI Building 200: Fire Station #14. Federal Fire Department personnel noted that on multiple occasions (likely from the late 1960s through approximately 2004), the fire truck water tank reservoirs were emptied onto the grassy field when the reservoirs became impacted with AFFF. Neither groundwater nor soil were sampled here.
AOPI - Building 100 Car Fire - In about 2005, a car fire occurred in the asphalt parking lot adjacent to Building 100. AFFF was used for approximately 20 seconds during emergency response efforts. Neither groundwater nor soil were sampled here.
AOPI - Runway AFFF Training Area - Nozzle testing at this site involved spraying AFFF through fire equipment. Fire equipment training also included arc training to maximize the arc, reach, and distance covered by AFFF in an emergency response. A review of readily available documents and interviews confirmed the Runway AFFF Training Area and Wheeler Gulch are the only known locations of AFFF training at WAAF. Neither groundwater nor soil were sampled here.
AOPI – Helicopter Crash - In May 2009, a helicopter crashed on the east side of the WAAF runway. Two Federal Fire Department fire trucks discharged a full tank of water mixed with AFFF concentrate (1,500 gallons each). At the time of the crash, the asphalt runway was cracked; however, it has since been repaved. No groundwater was collected but soil samples were.
AOPI - Wheeler Gulch - Nozzle testing at this site involved spraying AFFF through fire equipment. The PA/SI describes the area as one of repeated AFFF disposal, yet soil samples were limited to the upper 0–2 inches, and no groundwater samples were collected. Under these conditions, it is not only reasonable but expected that rainfall would drive PFAS downward through the soil profile. This same expectation applies to all of the soil samples collected at Wheeler.
PFAS compounds such as PFOS and PFOA are highly persistent, mobile, and resistant to degradation. Wheeler Gulch is characterized by tropical rainfall, episodic high-intensity storm events, and disturbed soils associated with dumping and grading. Percolating rainwater tends to flush PFAS out of surface soils and transport them to deeper vadose-zone soils and groundwater. As a result, low concentrations in surface soils do not indicate an absence of contamination at depth; in fact, they can be a signature of downward migration, not clean conditions. Still, the reported soil concentrations of PFOS are extremely high.
AOPI - Building 251 – Civil Air Patrol Hangar - The hangar had a foam fire-suppression system. “The foam onsite was likely Aer-O-Foam XL-3% and was stored in a 400-gallon tank. The Army says there is no indication the foam system has ever been deployed and there have been no known leaks. Groundwater was sampled here in one location. Soil was not sampled.” The hangar was not advanced for further investigation.
Section 5-1 in the PA/SI, however, says there were “no fire-suppression systems utilizing AFFF in any of the Army or Army National Guard hangars.”
This is an internal inconsistency regarding the treatment of hangar fire-suppression systems at Wheeler. In its discussion of Building 251 the Army states that the suppression system was loaded with Aer-O-Foam XL-3%. This is a fluoroprotein foam that contains high concentrations of PFAS.
The inconsistency is resolved only by a narrow definition of “AFFF” that excludes PFAS-containing fluoroprotein foams. From a chemical and environmental perspective, this distinction is not meaningful. Aer-O-Foam XL-3% contains dangerously high concentrations of PFAS and is capable of producing the same environmental contamination pathways as AFFF when released through leakage, maintenance activities, system flushing, or future activation.
The PA/SI excludes from further evaluation a hangar that stored a substantial mass of PFAS-containing material. This definitional narrowing directly influenced the decision not to conduct soil sampling beneath or adjacent to the foam system, despite nearby groundwater contamination. It seems the Army got off track by concentrating solely on a strictly defined AFFF substance, rather than investigating PFAS.
The relevant question under CERCLA is not whether a particular foam met a strict AFFF specification, but whether PFAS were present, stored, or capable of being released. Here, the record establishes that a hangar housed a fixed fire-suppression system containing a substantial mass of PFAS-bearing foam, yet soil beneath and adjacent to that system was not sampled, even though nearby groundwater showed PFAS contamination.
This definitional narrowing materially distorted the site-screening process. By treating “non-AFFF” PFAS foam as functionally irrelevant, the PA/SI prematurely foreclosed investigation of a plausible source area and disregarded well-established release pathways, including leakage, maintenance losses, system flushing, and future activation.
The Fort Drum Comparison
On August 5, 2015 an aqueous film-forming foam overhead suppression system accidentally discharged at Wheeler-Sack Army Airfield, located at Fort Drum in New York.
8 feet of foam covered a half-dozen UH-60 Black Hawk helicopters, according to Army Times. A similar event also occurred there in 2021.
Fort Drum and Wheeler Army Airfield support roughly comparable numbers of Army helicopters, a level of aviation activity the Army itself considers sufficient to necessitate AFFF use in an emergency. Wheeler Army Aifield also houses the UH-60 Black Hawk Helicopters, but claims it has never used AFFF in these suppression systems.
Fort Drum identified 36 AOPIs, including eight separate fixed fire-suppression systems, and carried 18 sites forward into remedial investigation—all but two related to AFFF use at fire stations and hangars—while Wheeler identified only seven AOPIs, all of which were advanced under CERCLA and all related to AFFF use, with none involving fixed fire-suppression systems.
Believe it or Not
The mission of the Holston Army Ammunition Plant in Tennessee is to produce explosives for the DoD. The Army says no firefighter training or fire response activities involving AFFF have been conducted at Holston, according to historical documents, personnel interviews, and a survey conducted at Army Materiel Command installations that included Holston.
The Holston Army Ammunition Plant in Tennessee manufactures some of the Army’s most dangerous energetic materials, including RDX and HMX. If there were ever a facility where the Army might be justified by some to maintain, train with, and deploy AFFF, it would be an active ammunition plant.
The PFAS PA/SI report states that a one-time fire equipment training exercise used only water and Dawn® dishwashing liquid.
Fire trucks, foam proportioners, hoses, and nozzles used at Army installations are designed and operated under MIL-SPEC and UFC standards, including MIL-PRF-24385. Dishwashing soap doesn’t make the grade.
The dish soap claim raises a more serious question than the Army acknowledges. As seen throughout the PFAS PA/Sis nationwide, interview-based assurances are used to narrow investigative scope while avoiding system-level verification, procurement records, or maintenance documentation.
The Army says Dawn has also been used for training exercises at Letterkenny Army Depot, Tobyhanna Army Depot, Fort McClellan, and Army Aviation Support Facility – Helena.
Despite what the Army says, Wheeler Army Airfield’s long history of housing and servicing fueled aircraft likely involved the use of the deadly carcinogenic foam in overhead suppression systems.
For decades, AFFF-based foam-water systems were the standard fire-suppression method for aircraft hangars throughout the Department of Defense because of their effectiveness against jet-fuel fires. DoD standard operating procedures explicitly included AFFF for hangar protection.
It should be noted too, that a University of Maryland study found that nearly all hangar foam discharges occurred without a fire present, highlighting the propensity of these systems to activate accidentally.
The Former Fire-Fighter Training Area (FTA)
The former FTA at Wheeler Army Airbase is not addressed in the present Site Inspection, aside from its location shown in Figure 5-2 above. This FTA is described in the Wheeler Installation Restoration Program, July, 1983 report. Fire training activities used flammable wastes exclusively. The Fire Department trained roughly three times a month. Fire Department personnel indicated that the average fire started with 500-1,000 gallons of flammable material, with 50 to 70 percent being consumed in the burn. Site 4 is underlain with 5-10 feet of topsoil, under which is a decomposed rock layer approximately 130 feet thick. Under the rocky layer is unaltered basalt having the 3 characteristics of freshly solidified lava.
From the 1983 report, “Movement of contaminants from Site 4 would be to the perched aquifer. From the perched aquifer contaminants would migrate downward into both the Wahiawa High Level Aquifer and the Pearl Harbor Basal Aquifer. The Army Environmental Services Officer informed the investigative team that the fire training area was excavated in 1980 and the dirt taken to the Schofield Barracks landfill. Waste crankcase oils were generally spread on dirt roads for dust controls and/or taken off base under private contract. Flammable liquids, including oils, solvents, contaminated fuels and paints, were burned by the Fire Department during training exercises.”
Common sense dictates two obvious and prudent courses of action. First, test for soil and groundwater at this location and second, do the same at the Schofield Barracks landfill. It’s not happening.
The Army removed the 35-acre Schofield Barracks landfill from further PFAS evaluation after reporting no detections in shallow soils. Following closure of the landfill in 1981, a 2- to 2.5-foot-thick compacted soil cover was installed over the waste. The Army nonetheless relied on two soil samples collected from 0–2 feet below ground surface—within the cover material itself—and reported no detections of PFOS, PFOA, PFBS, PFNA, or PFHxS. On that basis alone, the landfill was screened out, and no further investigation was proposed.
Landfills are a major source of PFAS contamination. Landfills produce liquid leachate, one of the deadliest substances known to humanity. These liquids are laced with chemicals that are associated with deadly diseases and cancers.
The Army is cheating and lying about PFAS contamination, so it’s not tough making monkeys of them.
Cesspools
EPA records show that Wheeler Army Airfield continued to use large-capacity cesspools well after such systems were banned under the Safe Drinking Water Act’s Underground Injection Control (UIC) program. It is the cheapest and most environmentally destructive method of disposing toxic waste.
The Army’s continued reliance on these systems at Wheeler meant that any PFAS-containing liquids entering sanitary drains—whether from firefighting operations, equipment wash-down, or maintenance activities—would likely have been routed into cesspools.
Numerous studies have demonstrated that PFAS are present in septic and cesspool waste streams and that these systems can serve as direct sources of PFAS to soil and groundwater, particularly because PFAS are highly persistent and mobile in water. Given Wheeler’s documented use of cesspools and its aviation and firefighting mission, it is reasonable to conclude that PFAS-containing liquids likely entered the cesspool system, creating a plausible pathway for subsurface contamination even in the absence of direct disposal records. There are no publicly released DoD or EPA reports that specifically present PFAS analytical results from cesspool samples.
Groundwater Sampling at Wheeler
Just one groundwater sample was collected across the entire 1,389-acre Wheeler Army Airfield. We only know what they tell us because they won’t let us un base to do the testing ourselves.
Table 7-1 Groundwater PA/SI Wheeler Army Airfield
Groundwater results from near Building 200 (Fire Station 14) are reported in nanograms per liter ng/L, or ppt. Let’s examine the groundwater sample taken at 557.97 feet below the surface.
PFAS ppt.
PFOS 48
PFOA 44
PFBS 7.9
PFNA 1.8
PFHxS 73
Total 174.7 ppt
This is all they’re willing to tell us.
Kunia Village, about 2.2 miles southwest of Wheeler, had 264.8 ppt of total PFAS taken from a drinking well at 452 feet. 11 compounds were reported at Kunia Village. People drank this water for many years. When the dangerous levels were publicized, the Hawai’i Department of Health advised residents to install water filters, rather than call out the Army. Just 5 compounds were reported at Wheeler. Neither site reported results for PFAS precursors. Approximately 16,000 PFAS compounds are known to exist.
Can we take a quick break from this Army foolishness? We must step back to appreciate the disservice they are doing to the Hawaiian nation. Compare the results the Army is reporting (174.7 ppt total PFAS) in groundwater, to the 2,882,554 ppt of PFAS the Navy has reported in groundwater at Joint Base Pearl Harbor-Hickam. See the results below from Joint Base Pearl Harbor-Hickam PFAS Groundwater Sampling Results – NAVFAC – June 30, 2023. Both the Army and the Navy are poisoning Hawai’i.
Make it stand out
The Army is lying about PFAS concentrations, while many in state and federal regulatory roles understand what is going on and are powerless to change it. Their frustration is palpable. Everything is going to hell. (well, not everything..)
No comprehensive PFAS cleanup has been completed at Joint Base Pearl Harbor–Hickam; instead, the Navy and other agencies have conducted initial studies, assessments, meetings, monitoring programs, conducted further studies, field activities, and developed plans for possible future work.
That’s what they’re doing.
There is no record that PFAS contamination has been remediated or removed from soil, groundwater, or other environmental media at the installations.
AI and DOD Data
Let’s examine how a popular artificial intelligence bot electronically generated a response to my query. Military Poisons reported on the 2.8 million ppt of total PFAS at Joint Base Pearly Harbor-Hickam last year. I simply wanted to grab the URL for this report.
Military Poisons: Please give me the highest levels of PFAS reported at JBPHH. Wasn’t it 2.8 million ppt?
AI Bot: “I could not find credible, publicly reported data showing PFAS levels reaching ~2.8 million ppt at Joint Base Pearl Harbor-Hickam (JBPHH) in EPA, GAO, state health, or news reporting during standard web searches. In fact:
Government oversight reporting (e.g., GAO) says that, as of early 2024, PFAS have not been detected in the active drinking water shaft at JBPHH above regulatory thresholds, though PFAS below 70 ppt were found in two inactive shafts not currently used for drinking water.
News reports about Navy or EPA sampling near the Red Hill facility have noted PFAS detections in groundwater monitoring wells, but they have not publicly disclosed specific high-end concentrations in the millions of ppt for JBPHH in those reports.
Other local reporting (e.g., EPA/DOH letters) described groundwater PFAS detections above health advisory levels but below Hawaii’s state action levels — again without detailing multi-million-ppt concentrations at JBPHH.
It’s possible that detailed raw analytical data from specific monitoring wells (e.g., PFOS or other PFAS in soil or groundwater) exists on the JBPHH SafeWaters database or in environmental restoration data reports, but I did not find verified published values at ~2.8 million ppt in the web sources available.”
I found it in my story -
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The Navy (and the Army and the Air Force) do not make PFAS data easy to find or interpret. Environmental results are fragmented across multiple platforms:
· NAVFAC Environmental Restoration Data tables,
· Installation-specific portals
· Appendices to Site Inspections
· Appendices to Environmental Impact Statements
A typical page may look like this, while the Army prefers to measure PFAS in soils in mg/kg - miligrams per kilogram, or parts per million. We must multiply these numbers by 1,000,000 to arrive at the publicly recognizable parts per trillion.
If data are scanned in, or appear in certain PDF formats, they can’t be searched. Font size and the clarity of text also present challenges. Meanwhile, the length of DOD documents often exceeds a thousand pages.
Extraordinarily dangerous PFAS concentrations are typically buried deep in laboratory data tables or scanned appendices rather than summarized in executive summaries, press releases, or compliance-focused fact sheets created for public consumption. The modern American military/industrial data retrieval system tends to obscure contamination in surface soil, subsurface soil, sediment, surface water, and indoor air.
In practice, the Navy’s disclosure framework prioritizes barebone regulatory sufficiency over transparency. Data portals can be poorly indexed, intermittently accessible, or designed for internal communication rather than public accountability, and they present results in ways that mask extreme outliers.
Sometimes data exists on private servers only accessible through paywalls. This is particularly bothersome when a google search returns results stating a particular military base has severely contaminated local water or fish, but access to the article is precluded unless the user pays $29.99 for access.
Robust PFAS data was once available through targeted FOIA requests, but those days are over. Christina Jedra with Civil Beat in Honolulu describes the latter day FOIA process. Jedra has filed numerous FOIA requests with the military only to have them ”fizzle into nothingness.” She writes, “The Freedom of Information Act, which is supposed to provide the transparency needed for a healthy democracy, is too often a pathway to a dead end that leaves us in the dark on critical issues.”
Back to the Army’s PFAS record in Hawai’i. Sorry again for the diversion.
Wheeler Army Airbase – Soil
Five surface soil samples were collected via hand auger near Building 200 - Fire Station #14 on 18 October 2022. No other soil samples were collected at Wheeler Army Airfield.
PFOS had a concentration of .28 mg/kg at 0 to 2 inches of soil at the fire station. It doesn’t sound like much.
0.28 mg/kg = 280 parts per billion = 280,000 parts per trillion.
We don’t know any of the PFAS concentrations deeper into the ground. It could be a lot worse at different locations, and at different depths. We only know what they are willing to tell us.
Think of the PFAS as a kind of giant coffee percolator. It’s all heading toward the aquifers.
It is a ticking time bomb—persistent, highly mobile, and capable of spreading rapidly through water. It doesn’t go away.
PFOS at 280,000 ppt in surface soil (0–2 inches) poses a human-health threat because this is the zone where people, dust, and rainwater interact. Residents, workers, and especially children can be exposed through direct contact and incidental ingestion when soil attaches to hands, shoes, or toys.
Dust is the primary pathway of PFAS ingestion for infants.
PFAS pose their greatest danger to young children, whose bodies and immune systems are still developing. Early-life exposure has been strongly linked to suppressed immune response, including reduced effectiveness of childhood vaccines, as well as developmental harm such as low birth weight and impaired growth. PFAS also interfere with thyroid hormones, which are critical for brain development, and can alter liver function and cholesterol levels even at very low concentrations. Because these chemicals persist in the body for years and children consume more food and water per pound of body weight, early exposure can lock in a lifetime burden of disease, increasing long-term risks that include cancer and chronic metabolic disorders.
The scariest part of it has to do with the propensity of PFAS to impact childhood brain development.
Exposure to PFAS during pregnancy and early childhood has been associated with behavioral and neurodevelopmental problems. Multiple studies link higher PFAS exposure to ADD, hyperactivity, impulsivity, and increased risk of ADHD-like behaviors in children.
Associations are correlated with emotional regulation problems, including anxiety, aggression, and difficulties with social interaction. These effects are biologically plausible because PFAS can disrupt thyroid hormones and neurodevelopmental signaling, both of which are critical during fetal brain development and early childhood. Ask elementary education school teachers if things have changed much in the classroom in the last 20 years.
As the soil with dangerous PFAS concentrations on Wheeler Army Airfield dries, everyday activities—wind, traffic, mowing, or construction— resuspends contaminated dust, which is inhaled and then swallowed or absorbed, adding to cumulative PFOS exposure. Because many PFAS compounds are extremely persistent and bioaccumulative, even low-level, repeated contact increases long-term health risks, including immune suppression, developmental effects, and elevated cancer risk. These are harmful chemicals in a class of their own and people should be aware of them.
Coarse dust, PM10 and larger, typically settles within a few hundred yards of the source, contaminating nearby yards, sidewalks, vehicles, and building interiors. Fine particles, PM 2.5 and smaller, which PFOS can adhere to—can remain airborne for hours to days and be transported several miles, especially during dry, windy conditions or construction and soil disturbance.
More on the dust
PFAS concentrations in dust in homes adjacent to Shepherd Air National Guard Base in Martinsburg, West Virginia
We have learned from the CDC’s robust sampling of dust near military installations across the country that dust levels in homes adjacent to military bases contain high levels of the carcinogens.
The Army has failed to address the propensity of PFAS to be suspended in air to threaten human health.
Rain drives the toxins downward into the subsurface, where it can leach into groundwater and contaminate drinking-water wells, or move laterally with stormwater into streams and drainage systems. From there, PFAS can enter the food chain, accumulating in garden produce, fish, and wildlife consumed by people. These combined pathways—soil, air, water, and food—mean a shallow PFAS hotspot is not isolated; it can become a chronic, community-wide exposure source if left unaddressed as the Army prefers to do.
Next, we will examine “Section 5.1 Areas Not Retained for Further Investigation” at Wheeler Army Airfield. Each eliminated site raises serious questions.
From the Wheeler Army Airfield Preliminary Assessment / Site Inspection:
“Fuselage Fire-Fighting Training Prop -Approximately 2009 to present.
A propane-fueled fuselage prop is used for fire-fighter training. According to an interview with the Federal Fire Department Captain, they have had the prop for approximately 10 years, and only water has been used in training with the prop, never AFFF. No evidence of PFOS, PFOA, or PFBS containing materials used, stored, and/or disposed.”
The claim rests entirely on a single interview with a Fire Department captain, and we don’t have his name or bio. It was conducted years after the fact. This is the weakest possible form of evidence in a PA/SI. The CERCLA process was meant to be taken more seriously! We ought to be relying on publicly available training records, procurement logs, AFFF inventories, spill reports, fire-response SOPs, disposal records and soil and groundwater testing!
Firefighter training programs across DoD installations routinely used AFFF until just a few years ago and it is likely still occurring at Wheeler with its valuable Army assets, considering that the FY 2026 National Defense Authorization Act extends the deadline for the Department of Defense to end its use of PFAS-containing firefighting foams, moving the statutory cutoff to October 1, 2026. The Trump Administration continues to kick the AFFF can down the road.
The categorical statement “No evidence of PFOS, PFOA, or PFBS containing materials used, stored, and/or disposed” reflects a fundamental misunderstanding of what “evidence” means in a PA/SI. The absence of records is not evidence of absence, especially when they didn’t perform any testing!
Wheeler’s toxic sewage
Wheeler Army Airfield sends its wastewater to the Schofield Barracks Wastewater Treatment Plant. The facility has been owned and operated by Aqua Engineers, Inc. since 2004.
The liquid effluent from the Schofield Barracks wastewater treatment plant is primarily reused as R-1 recycled water for irrigation on the base and nearby areas. The dirty water is not treated for PFAS. When reuse is not possible, permitted overflow is discharged via Outfall 001 into Kaukonahua Stream, which flows north toward Kaiaka Bay on Oʻahu’s North Shore. We don’t know the exact parameters of the arrangement described above.
The documented presence of high levels of PFAS in soil underscore the importance of testing sewer outflows from Wheeler Army Airbase. There is a lot the Army could do to stem the flow of these toxins, and it starts with an honest testing regime, although it is costly, as we will see in part 6.
The Army says the sludge is incinerated.
From the Wheeler Army Airfield Preliminary Assessment / Site Inspection: “According to USAG-HI personnel, wastewater treatment plant sludge and biosolids are hauled offsite for incineration at the Honolulu Program of Waste Energy Recovery (H-Power) facility in Kapolei; additionally, when H-Power is intermittently unable to accept waste, it is either hauled offsite to Waimanalo Gulch Sanitary Landfill in Kapolei, or temporarily stored in roll-off containers at the WWTP for later disposal at H-Power.
This is reprehensible public policy if it is true. PFAS compounds often survive incineration and re-enter the environment as soot or ash. These are forever chemicals and they can’t be incinerated at normal operating temperatures. We don’t know what to do with them.
The Navy says the sludge is landfilled.
According to the Naval Facilities Engineering Command, (NAVFAC), Hawaii, The sludge generated from Wheeler’s sewer water (via Schofield WWTP) is disposed at the Navy’s Biosolids Treatment Facility in Kalaeloa. The Navy and Army provide approximately 48 wet tons per week. All loads are trucked to the Navy’s Biosolids Treatment Facility in covered, leak-proof containers.
It makes sense. Kalaeloa is where PFOS was reported to contain a staggering 1,500 ug/kg in soil. (Table 6)
The Navy’s Biosolids Treatment Facility in Kalaeloa
The Navy’s Sludge Treatment Process
The treatment of human fecal matter is as critical today as it has been since the dawn of civilization. Wastewater today is not merely organic waste; it contains a Pandora’s box of pathogens, pharmaceuticals, industrial chemicals, and persistent toxic compounds that—if inadequately treated—pose serious risks to public health and the environment. The waste flowing into sewage treatment plants does not originate solely from toilets, washing machines, and household drains. It also comes from industrial facilities and military installations, including vast workshops and aircraft hangars that use and dispose of a wide range of toxic chemicals, including PFAS. While treatment processes may remove or reduce a limited number of contaminants, PFAS are not removed. As a result, these “forever chemicals” persist in both treated liquid effluent and solid sewage sludge, allowing contamination to spread downstream and into the environment.
Modern sewage treatment is one of society’s primary defenses against disease, chemical exposure, and ecological degradation.
Yet the United States is falling dangerously behind its European counterparts in regulating and upgrading wastewater treatment to ensure that sewage effluent does not poison people or ecosystems. While Europe has moved toward precautionary standards, advanced treatment technologies, and tighter controls on toxic discharges, the U.S. regulatory framework is bending under political and economic pressure.
The mantra from the Sen. Edwin Muskie environmental regulatory era is that the polluter pays, but that has shifted today. Oversight is being diluted, enforcement weakened, and responsibility increasingly shifted away from polluters to consumers. Meanwhile, the corporate–government cabal treats public exposure as an expected outcome of the “regulatory process.”
Back to the sludge
The Sludge at the Navy’s Biosolids Treatment Facility is mixed together with green waste, watered and piled on top of an air line in the “extended aeration” area. The mixture is oxygenated via the air line and left in a static pile for a minimum of 21 days. Then, the static pile is sifted, removing the large pieces of greenwaste that remain so they can be recycled back into the process. The static pile is then transferred to a “curing window,” or holding area, where it is piled into rows. The piles are watered, as needed, and turned over to oxygenate at regular intervals for approx. 3-4 months. When the material no longer generates a significant amount of heat, the windrow pile is sifted, and it is moved to a “cured pile” area. The composting process is now completed, and the resulting product is a rich compost soil. Prior to use, accroding to the Navy, the compost must pass numerous analytical tests to ensure that it can be used safely.
There is no federal requirement that biosolid compost products be tested for PFAS before they are sold or land applied. The EPA is on the sidelines. The DOD calls the shots.
The Army says the toxic sludge is incinerated. The Navy says it is landfilled. This is about as clear as the sludge itself. The public must understand that we are discussing highly carcinogenic materials that impact their health and the health of their progeny.
As of February, 2026, Hawaii does not have an established, mandatory program under state law or Department of Health administrative rules that requires all wastewater treatment plants to test sewage sludge for PFAS before disposal or reuse.
Hawaii Senate Bill 2096 is currently working its way through the Hawi’i State Legislature. It an important first step that acknowledges PFAS contamination in sewage sludge. SB 2096 establishes mandatory testing of sewage sludge intended for land application and applies to all wastewater treatment plants authorized for such use. It ties PFAS detections to permit-based restrictions and triggers action at any detectable level of PFAS.
The bill ought to specify EPA Method 1633 and it should mandate the testing of the 40 PFAS compounds this method detects and commercial labs report.
The bill must mandate public disclosure of PFAS results. Otherwise, most of us will still be in the dark.
Other states have numeric limits and published testing intervals, often tied to dry tons of sludge produced. SB 2096 prohibits land application of “any amount” of PFAS is detected. This becomes a de facto ban on sludge application. Lawmakers must prepare companion legislation to address what to do with the sludge once it can no longer be land applied. There are no good alternatives.
The legislation must be amended to close non-agricultural reuse loopholes like golf courses commercial landscaping, and the sale of soil conditioners made with sludge. Federal facilities are left out of the legislation.
======================
Toxic DoD compost has been issued to: Marine-Corps Klipper Golf Course, Kaneohe; Navy’s Barbers Point Golf Course, Kalaeloa; Navy Marine Golf Course; Navy demolition projects; and Navy housing grounds maintenance. These places are potentially dangerous.
Devil’s Been Busy - Song by the Traveling Wilburys
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.
=================
Kunia Gate Dump
From the Preliminary Assessment / Site Inspection: “From the 1950s to 1974 Kunia Gate Dump was the primary base landfill operating from the 1950s until its closure in 1974. Stage 1 and 2 investigations resulted in a site cleanup and removal action performed in 1995. As of 1998, the only activity at the Kunia Gate Dump was military vehicle fueling in a fenced fueling station located centrally within the Kunia Gate Dump site. No evidence of PFOS, PFOA, or PFBS containing materials used, stored, and/or disposed of at this location.”
The Army claims it orchestrated a “site cleanup and removal action performed in 1995.” A 20-year base landfill may take up millions of cubic feet of buried material; even if only 1-5% of that stream was industrial/shop waste with hazardous constituents, the resulting potentially toxic fraction could still be tens of thousands to a few hundred thousand cubic feet.
Did they really clean it up or are they just saying they did? And, when it comes to PFAS, how, exactly did they “clean it up”? Science hasn’t figured it out yet. We are in trouble.
According to the Wheeler Installation Restoration Program, July, 1983, the Kunia Gate Dump is suspected of containing large amounts of hazardous materials. Toxic sewer sludge was deposited at this location. The Army prefers to ignore it.
Conclusion
What emerges at Wheeler Army Airfield is a deliberate institutional strategy: test narrowly, define terms opportunistically, fragment data, and declare uncertainty where thorough investigation would almost certainly reveal catastrophe. The Army’s handling of PFAS at Wheeler reflects a systemic abuse of the CERCLA process—one designed to create the appearance of compliance while evading its substance. By limiting groundwater sampling to a single deep well, ignoring soil at various depths, excluding known disposal areas, redefining PFAS-containing foams out of relevance, and relying on unverifiable interviews in place of records and testing, the Army ensures that the full scope of contamination remains officially unknowable. This is not stewardship; it is regulatory theater, performed at the expense of public health and Hawaiʻi’s fragile aquifers.
PFAS contamination at Wheeler is not hypothetical, localized, or contained—it is persistent, mobile, and already moving through soil, air, water, wastewater, and the food chain. The Army’s refusal to confront this reality condemns surrounding communities to lifelong exposure risks while shifting the true costs of pollution onto civilians and future generations. CERCLA was meant to force polluters to reckon with the damage they cause. At Wheeler, it has been hollowed out into a bureaucratic shield. And this is precisely why renewing military land leases in Hawaiʻi is reckless. Extending leases without independent testing, full disclosure of contamination, and binding cleanup obligations is not a neutral administrative act—it is a decision to tolerate ongoing pollution on public lands and to lock in decades more of evasions, delays, and denials.
If the state renews these leases before the Army proves—through transparent data and enforceable action—that it will stop contaminating the land and begin meaningful cleanup, Hawaiʻi will surrender its leverage and its sovereignty. It will inherit a toxic legacy that cannot be undone. This exposes a fundamental paradox: the very purpose of the Pōhakuloa Training Area—routine explosives detonations and other inherently toxic military activities—is, by definition, environmentally destructive. No amount of mitigation language can reconcile that reality. The Army must be restrained, its leases terminated, and it must be compelled to fund tens of billions of dollars in cleanup and long-term remediation for the damage already inflicted, as required under federal law.
This is the 4th part of a 6 part series. Next, we will examine PFAS contamination at other Army facilites.
Part 1 – The Army is leaving contaminated O’ahu sites to focus on Pohakuloa
Part 2 – PFAS contamination at Pohakuloa
Part 3 – PFAS contamination at three leased bases on O’ahu
This project is supported by financial assistance from the Sierra Club of Hawaii.
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