PAH Detections, Flaws in Navy Water Testing Highlight Need for More Data, Integrity From Navy
by Madison Owens, Red Hill Organizer, Rosalie Luo, Volunteer, and Wayne Tanaka, Chapter Director | Reading time: 11 minutes
On Tuesday, August 20, the Commission on Water Resource Management (CWRM) heard a presentation from the Board of Water Supply’s (BWS’) Chief Engineer Ernie Lau and Deputy Manager Erwin Kawata regarding the detection of Polycyclic Aromatic Hydrocarbons (PAH) at the BWS’ ‘Aiea wells (which have been shut down since the 2021 fuel spill). This detection - the first time PAH had ever been recorded at the ‘Aiea well location - could indicate the westward movement of contamination plume(s) from the Red Hill Facility that may force the shutdown of additional drinking water wells, as well as threaten regional springs and surface waters.
(Detailed updates and findings on the PAH detections are covered in the subsequent Board of Water Supply (BWS) section, below).
In addition to the significant concerns raised regarding potential plume movement, the CWRM meeting also highlighted a concerning trend in regulators’ response: relying on uncertainty to avoid decisive, precautionary action. Representatives from the Department of Health and others belabored the possibility that the PAH contamination might have originated from a source other than Red Hill, such as from wastewater to vehicle exhaust, rather than commit to supporting the BWS’ call for more robust groundwater testing from the Navy.
Notably, the uncertainty regarding whether and how contamination from the Red Hill facility may be migrating in our sole source aquifer is due in substantial part to the Navy’s years-long failure to complete groundwater and contaminant fate and transport models and install a sufficient network of monitoring wells. Regulatory inaction based on the lack of data the Navy should have provided is only rewarding the Navy for its foot-dragging over the past decade, and placing our community at risk of toxic exposure.
Navy Closure Task Force-Red Hill Open House
On Wednesday, August 21, the Navy held their Open House at the Moanalua Community Center, where their poster parade outlined their ongoing operations at the Red Hill Bulk Fuel Storage Facility. The Navy's poster boards included descriptions of the sludge removal process, which will be manually shoveled and shipped off-island. The Navy stated that the sludge samples will determine the appropriate disposal methods, with results to be posted on the NCTF-RH website.
Additionally, in response to community concerns, the NCTF-RH reported on the installation of nine air quality monitoring stations around the Red Hill Bulk Fuel Storage Facility (RHBFSF) perimeter, including at the Halawa Correctional Facility, to monitor air quality and volatile organic compound (VOC) levels during the “venting” of the fuel tanks prior to sludge removal.
The timeline for tank cleaning was also outlined: each pair of tanks is expected to take 6-10 months to clean, with steps including preparation, installation of cleaning infrastructure, pressure washing, and eventual decommissioning if the tanks are verified as clean.
While these poster presentations provided little additional information to the community, they also were not able to address some of the most pressing concerns that have been raised by the community, including the Red Hill Community Representation Initiative (CRI): why can’t families be provided with adequate alternative water given the admitted deficiencies in the long-term monitoring program and ongoing reports of sheens and health symptoms associated with Navy water exposure? Why is the Navy not using third-party labs to analyze their water samples? What will the Navy do if a contamination plume from Red Hill hits a municipal well, or a spring that feeds local farms? The need for answers to questions like these emphasize the importance of the CRI’s role, as the entity tasked with raising community concerns directly with Navy representatives.
Community Representation Initiative
The 11th CRI meeting took place at Windward Community College in Kāneʻohe, where CRI members were joined by representatives from the Board of Water Supply (BWS), the Environmental Protection Agency (EPA), and the Department of Health (DOH). However, for the fifth consecutive meeting, Navy officials were notably absent, after refusing earlier this year to meet unless they were given the ability to control CRI discussion items.
The meeting began with an update on the aforementioned recent detections of polycyclic aromatic hydrocarbons (PAH) in the BWS’s inactive ‘Aiea wells, as also found in the Navy’s monitoring wells. This presentation reaffirmed the concerns the CRI had raised in a letter to Hawaiʻi’s congressional delegation regarding the PAH detections, urging the delegates to ensure that the US Navy and Department of Defense heeded the calls of the BWS to ensure more frequent, objective, and robust testing of their monitoring wells, among other proactive data collection and plume tracking measures.
Subject matter expert Elin Bentanzo then highlighted the alarming presence of lead in the Navy’s drinking water system, as reflected on the Joint Base Pearl Harbor Hickam’s “Safe Waters” website, and the Navy’s failure to follow proper sampling protocols as outlined in the Environmental Protection Agency’s Lead and Copper Rule. Of particular concern was the fact that many lead exceedances were being reported even when faucets were improperly “flushed” before sampling, which would have reduced lead concentrations. EPA comments that the lead and copper rule would be followed by the Navy at some point months in the future did little to reassure CRI members concerned about the long-term health effects of chronic lead exposure, especially on young children and infants.
In addition, representatives from water technology companies Waiea Water and Source described how their products could generate clean water from the atmosphere to serve affected households. Notably, the Navy had known about, but declined to take advantage of, such water-from-air technology solutions shortly after the 2021 Red Hill fuel spill, although the Department of Defense does use this water-from-air technology for demonstration projects.
Finally, the CRI meeting also addressed the ongoing issue of unexploded ordnance in Waikāne, on Oʻahu’s windward side. Residents shared their frustrations over the military's slow response and the challenges in holding the military accountable for the proper cleanup of Ko‘olaupoko - portending the struggle that present and future generations of Oʻahu residents may face in getting the Navy to remediate the ʻāina and wai contaminated by the Red Hill facility.
For those who were unable to attend, a recording of the meeting is available on the CRI youtube. Additionally, please join the CRI’s call to action by contacting your congressional representatives today. As we move forward without the cooperation and transparency of the Navy, the congressional delegation and the DOH must demand the Navy to follow the Board of Water Supply’s lead.
Board of Water Supply Monthly Meeting
The Board of Water Supply hosted their monthly public board meeting on August 26, where two important agenda items relevant to Red Hill were covered – first, a review of the Navy’s intra-agency (SWARM Team) report on the TPH detections found during the 2022-2024 “Long Term Monitoring” of its water system, and second, updates regarding the recent detections of polycyclic aromatic hydrocarbons (PAHs) in BWS’ ʻAiea wells.
As first suggested by SWARM Team member Chris Waldron during the Fuel Tank Advisory Committee (FTAC) meeting in March, the SWARM Team’s report (which is now removed from their website, but can still be found on the Internet Archives) concluded that the voluminous low-level TPH detections found during the Long-Term Monitoring program were a result of the laboratory method used.
To fact-check the SWARM Team’s conclusion,, the BWS had contracted analytical chemistry experts including Paul C. Winkler, Ph.D., and representatives from Analytical Quality Associates, to assess the SWARM Team report. These experts all reached a similar conclusion: the Navy SWARM Team’s claims that there was no actual TPH in these samples, and that the detections were the result of lab artifacts, were based on false assertions and improper lab techniques, and simply not defensible.
For example, the SWARM Team’s claims were based first on their assertion that all areas of the system had the “same” TPH detection pattern, suggesting a lab issue. However, the data in their own report showed that the TPH detections were not in fact uniform across all zones.
Meanwhile, the SWARM Team’s assertion that laboratory “blanks” were contaminated, contributing to the positive TPH results, was also not true – out of 66 samples, only one blank – affecting 6 samples – indicated any contamination error. In other words, the majority of “blanks” were acceptable, according to the data.
The SWARM Team had also asserted that the lab method’s “surrogate” compound was likely interacting with chlorine, created disinfection byproducts that appeared as TPH. If this had been the case, however, the reported TPH detections should have increased when the levels of residual chlorine in the samples increased. Here, the opposite was the case – TPH detections actually increased for samples with less chlorine.
Moreover, the amount of surrogate used was so high as to dwarf and obscure potential JP-5 “peaks” in the chromatograms that supposedly lacked a JP-5 signature.
Finally, the testing process used during the Long Term Monitoring program did not in fact appropriately apply EPA Method 8015. The “generalized” EPA method was not appropriately adjusted for the fact that it was being applied to low concentrations of TPH, in a drinking water assessment (rather than a wastewater or surface water situation); samples were not dechlorinated with sodium thiosulfate (which could have had unknown impacts on test results given the lack of information on the interaction between chlorine and jet fuel); and separate bottles were used for the two different testing methods for each “sample.”
Accordingly, Analytical Quality Associates “found the existing data to be very suspect, and thus, would qualify it as unusable for the purpose of proving the absence of jet fuel in the drinking water system.” Dr. Winkler even went further to say that “if I was in a court of law, I would have a difficult time defending that data.” As Ernie Lau, Manager and Chief Engineer of BWS summarized, “[the SWARM Team’s] conclusions don’t hold water.”
Multiple BWS board members highlighted the need for the Navy to use independent, third-party testing given that they had not properly tested over 8,000 samples over two years of testing. They also noted that the SWARM Team included representatives from DOH, EPA, and the Defense Health Agency, bringing into question the experience and expertise of the individuals advising the Team. BWS board members also discussed potential solutions through method development practices, and were hopeful based on the consultants’ conclusions that it is indeed possible to test for TPH as long as the correct methods are used and carefully followed.
On the second agenda item, Kawata updated the board and public on the PAH detections in their inactive ʻAiea wells, which are the first time BWS has observed PAH. These class of chemicals occur naturally in petroleum products like crude oil and gasoline, and are persistent in groundwater. The ‘Aiea wells are 2 miles west of the Red Hill facility, and Navy groundwater models in fact predicted the possibility of a contamination plume heading from Kapūkakī to ʻAiea. Over the course of several weeks after PAH were first detected, levels increased, and then decreased, suggesting continued western movement that could threaten the Kaʻamilo drinking water well, as well as local farms reliant on springs in the region.
Kawata emphasized that in this case, “exercising the precautionary principle is important” given the concerns of past fuel releases from Red Hill. However, he noted that more data is needed to accurately assess what the source of the PAH is, whether it stems from the Red Hill facility or otherwise.
As noted above, you can join the CRI’s call to ensure the Navy does its part to gather much-needed data and finalize its groundwater and contaminant fate and transport models, to mitigate the potentially devastating impacts of the contamination plume in our aquifer.
Future Events
As we continue to address the pressing issues surrounding water contamination and the Navy’s operations, we want to highlight an important upcoming event that aligns with the concerns discussed in this newsletter. On September 10, from 6-7:30pm, a panel discussion will be held on the Water Alliance Initiative, a government-led initiative to pursue the full remediation of our ʻāina and wai from the Red Hill Facility. This event will feature Ernie Lau and Ashley Nishihara, and will be moderated by Wayne Tanaka.
Ernie Lau will provide an in-depth explanation of the WAI in the context of the Red Hill crisis and recent findings of contaminants in the Aiea Wells. He will also draw parallels with the 1999 jet fuel spill at Kirtland Air Force Base in Albuquerque, New Mexico, shedding light on the long-term impacts and lessons that can guide our approach to the Red Hill situation. Ashley Nishihara will share insights gained from her experience on the Fuel Tank Advisory Committee (FTAC) and discuss ways to ensure that Hawaiʻi implements a remediation program that avoids the Navy foot-dragging enabled by the agency-driven FTAC. Wayne Tanaka will moderate the panel, leading a discussion on the ways we can all support much needed and critical actions to ensure that the Navy fully cleans up its mess..
Given the recent contamination detections and ongoing concerns about our water resources, this panel discussion is a crucial opportunity for community education and engagement. Please click the link here to register in advance for the event and please help spread the word!