The Summary of Uncertainties
The Army’s use of PFAS in Hawaii is a mystery
By Pat Elder
February 21, 2023
Upcoming Lower Waiawa Gulch & Waiawa Village PFAS Testing
The Hawaii Army National Guard will hold a rare open house and public meeting on Friday, February 24, 2023 to reveal PFAS sampling results and to discuss their plans to test nearby drinking water wells.
Is the Hawaii Army National Guard trying to keep this meeting a secret? It’s not on their website.
The red X is the location of the Army’s “Area of Interest” where PFAS foams were likely sprayed over many years and allowed to drain into the soil and water.
The Army National Guard (ARNG) says it will investigate drinking water wells that may have been contaminated with PFAS from usage at the Hawaii Army National Guard Waiawa Gulch Training Site and Unit Training and Equipment Site. The 20-acre facility is less than a mile north of the H1-H2 merge.
The public is invited to a meeting to discuss sampling results from the site, as well as the planned sampling of nearby drinking water wells. Speakers include representatives from the Army National Guard, Hawaii Army National Guard, and the Hawaii State Department of Health.
The notice to nearby residents says the firefighting foam was released during training exercises until the early 2000s, however, all four military branches continued using the carcinogenic foams in training, testing and maintenance until a departmentwide policy issued in January 2016 banned the practice.
The Army reports in its Preliminary Assessment of PFOS and PHOA at Waiawa Gulch published in 2020, that groundwater and surface water flow to the south toward Middle Loch. Storm water runoff from the “Area of Interest” is captured by storm drains that ultimately discharge into Waiawa Stream. The stream flows south to Middle Loch, within Pearl Harbor, and subsequently to the Pacific Ocean.
The ARNG is testing drinking water wells south of the facility. The Army says residents will receive a Right-of-Entry request from the U.S. Army Corps of Engineers. For those residents, once signed and returned, this signed document gives the Army temporary access to the property so they can collect drinking water samples from an outside spigot associated with the well.
Residents should sign the document and demand a copy of test results, which should take no longer than two weeks. Residents should also test their water for PFAS immediately. It’s a brave new world and we must advocate for ourselves. Homeowners and businesses can test their own water for just $79 with a kit from Cyclopure, a firm the DOD uses. If the results show high results, or results that dwarf the Army’s, it may be very worthwhile to order the more expensive tests in this litigious environment.
The Area of Interest comprises a grassy area in the north portion of the facility that is used for vehicle storage and for pump testing firetrucks. The testing activities may have released AFFF into the grass and potentially had surface run-off to the adjacent Waiawa Stream.
PFAS migrate from soil to groundwater via leaching. Drinking water at Waiawa Gulch Training Site and UTES is resourced from public drinking water wells that are approximately 0.75 miles west of the red X.
The ARNG says several domestic wells exist within 1 mile downgradient of the AOI to the south and southwest of the facility, although PFAS may travel much further. Because the facility is relatively small and is not known to house aircraft in hangers, the releases of AFFF are likely to be relatively small compared to facilities like Joint Base Pearl Harbor Hickam. Still, residents may be seriously threatened.
That’s pretty much all we know from the Preliminary Assessment. The ARNG is very slow to communicate with the American public regarding the PFAS contamination it has caused. ARNG Preliminary Assessments typically include a section called “Uncertainties.” Here is the “uncertainties” section from the Waiawa report,
“A number of information sources were investigated during this Preliminary Assessment to determine the potential for PFAS-containing materials to have been present, used, or released at the facility. Historically, documentation of PFAS use was not required because PFAS were considered benign. Therefore, records were not typically kept by the facility or available during the Preliminary Assessment on the use of PFAS in training, firefighting, or other non-traditional activities, or on its disposition… Gathered information has a degree of uncertainty due to the absence of written documentation, the limited number of personnel with direct knowledge due to staffing changes, the time passed since PFAS was first used (1969 to present), and a reliance on personal recollection. Inaccuracies may arise in potential PFAS release locations, dates of release, volume of releases, and the concentration of AFFF used.”
Will this work well in a court of law, even though the Army has known these chemicals were harmful to human health since the 1970’s? What they’re saying here is that they never took it seriously, and so, somehow, they escape liability today.
I’m grateful to those in the chain of command or recently retired, and contractors who trust me. I’m not going to divulge sources, especially when they provide rich insight into the thought processes of the command. And that’s important. The Army is waging psychological warfare against us so it’s good to gain insight into their mindset.
We are living in Post-Kunia Village Hawaii.
People in Kunia Village are drinking water containing 264.8 ppt of total PFAS, including PFOS-50 ppt, PFOA-27 ppt, and PFHxS-73. There aren’t many communities across the country with water this poisoned.
Diana Felton, State Toxicologist, Hawaii Department of Health, ought to be forced to resign. Her office suggested Kunia Village residents could purchase water filters if they were concerned about the PFAS.
We can’t forget this historic moment when Hawaii announced to the nation it wasn’t interested in protecting human health from the living hell of these chemicals. We must not forget about the children and all their anomalies caused by PFAS. California calls PFOA and PFOS deadly carcinogens and is seriously clamping down. Hawaii prefers not to deal. Hawaii is behind in every measure regarding PFAS testing and enforcement, although they talk a good game. Human life is paramount.
The Army is bull-headed and we’re not going to change them, but we can pressure the state to wake up to this scourge.
The National Guard follows the CERCLA process to investigate PFAS releases resulting from Army activities and to assess the appropriate cleanup actions based on risk to human health and the environment. CERCLA is the Comprehensive Environmental Response, Compensation, and Liability Act, or Superfund. There are many steps in the CERCLA process. The first is the Preliminary Assessment which we explored earlier. The second is the Site Inspection.
Preliminary Assessments for PFAS decide whether Site Inspections are needed. Only Site Inspections collect data. The Army hasn’t published a single Site Inspection for PFOS/PFOA in Hawaii. We don’t know anything.. There are 16 Army installations in Hawaii that showed up in a DOD report on the progress of bases in the CERCLA process. See Preliminary Assessments and Site Inspections. Four are National Guard and twelve are Active.
Of the 16 installations they identified, The Preliminary Assessment determined that No Further Action was required for 8 of them. The books are closed on half of the contamination. That was easy.
Just four installations have published Preliminary Assessment Reports:
Fort Ruger Preliminary Assessment - September, 2020
Hilo Preliminary Assessment – September, 2020
Kalaeloa Preliminary Assessment – September, 2020
Waiawa Gulch Preliminary Assessment - September, 2020
Unlike the Air Force and the Navy, the Army does not have a central place on the web for it’s environmental files pertaining to PFAS. The Army is a mess. The Navy did a good job until Red Hill when things started disappearing. The Air Force, to its very limited credit, is most transparent.
A simple google search returned the preliminary assessments on the four bases above. The other twelve bases still have not published the first step of the CERCLA process. We have no analytical results from the Army. It’s amusing to hear them say that they’ll be sharing data with residents. They’re manipulating the data and the residents.
The Kipapa Ammunition Storage facility never published its Preliminary Assessment but declared “No Further Action” was needed to safeguard public health from the PFAS used on base. It’s criminal because the DOH reported that 3.4 ppt of PFOS was found in the Kipapa Acres Water System. That’s 170 times over the health advisory set by the EPA for PFOS.
An associate who knows about these things, explained that the Army has a conscience about all of this, although its tough to distinguish it from the newly perceived notion in the minds of the command that there’s tremendous liability regarding the PFAS. How else can you explain the “Summary of Uncertainties,” he asked. The Army includes this in its figures and tables in preliminary assessments.
The “Summary of Findings” in preliminary assessments don’t include analytical results.
From the Summary of Uncertainties: “Historically, documentation of PFAS use was not required because PFAS were considered benign.”
They’re making monkeys of us all. That’s the Army. They’re in charge and they’re going to do whatever they want to do.
Wayne Tanaka, Director, Sierra Club Hawaii says he’s afraid that this is just the tip of the iceberg of what we are dealing with.
“While I appreciate the Army National Guardʻs proactive admission about the use of PFAS-based AFFF near drinking water sources in Waiawa, it only raises the question about what the rest of the Department of Defense is doing about AFFF used in other places. How much longer are they going to let people unknowingly expose themselves and their children to cancer-causing forever chemicals in their drinking water, in their streams, soil, and fish, before they come clean and tell us what we need to know about what theyʻve done to our ʻāina, our home?”
He continued, “If they are really serious about national security they need immediately halt any activities that may further contaminate the very lands and resources communities need to sustain ourselves through the climate crisis, prioritize environmental remediation as an immediate and absolute national defense priority, and ensure screening and treatment for all those whose lives may have been harmed by the mess they’ve created. Unfortunately, "common" sense is far from common, and even moreso in the bureaucratic behemoth that is the U.S. military.”
Hawaii is lucky to have this guy around.
The financial support we receive from the Downs Law Group makes this work possible.
The firm is working to provide legal representation to individuals with a high likelihood of exposure to PFAS and other contaminants.
Interested in joining a multi-base class action law suit pertaining to illnesses stemming from various kinds of environmental contamination?
Join the Veterans & Civilians Clean Water Alliance Facebook group. (2.2 K members and growing rapidly.)
Military Poisons and the Women’s International League for Peace and Freedom, US are continuing to raise funds to cover the costs of PFAS seafood testing in Maryland, Washington, DC, Virginia, and Florida. You can make a tax-deductible contribution here. What’s in your fish? What’s in your blood?