EPA's Integrity Is Questioned for Withholding Red Hill Tests

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Routine inspection on a water pipe at the Red Hill well
Naval Facilities Engineering Systems Command contractors perform a routine inspection on a water pipe that connects to a granular activated carbon system at the Red Hill well, April 11, 2022. (U.S. Navy photo by Mass Communication Specialist 2nd Class Mar’Queon A. D. Tramble)

In early March the Navy notified the Environmental Protection Agency that it had detected "unvalidated test results " finding high levels of total petroleum |hydrocarbons, or TPH, in water samples taken from an on-base school and a home in the Aliamanu Military Reservation—both of which had their water systems flushed.

The National Oceanic and Atmospheric Administration also detected "abnormally high levels of TPH " in drinking water samples from two piers. EPA Region 9 Director Amy Miller sent an email on Tuesday notifying Red Hill Community Representation Initiative board Chair Marti Townsend of the tests.

In the email, Miller said that later "validated " test results had determined that the samples tested were actually below the "method detection limit " and thus deemed safe. But members of the CRI expressed frustration that EPA is sharing information about the testing after a community meeting last Thursday.

"To get this email after the CRI meeting happened, and they had had this information since the beginning of March, is a huge red flag, " said Mandy Feidnt, a member of the CRI, who said that it "calls the EPA's integrity into question."

As of press time, officials did not specify at which school the results were found.

The CRI is made up of a mixture of local residents and activists along with people directly affected by the Red Hill water crisis, which began in November 2021 when fuel from the Navy's bulk Red Hill fuel storage facility entered and contaminated the Navy's Oahu water system, which serves 93, 000 people. The CRI was created as part of a federal consent order involving the EPA, state Department of Health and military regarding the closure of Red Hill.

The CRI and community members have raised questions about the reliability of tests, particularly amid an increase in complaints of illnesses by residents on the Navy water line. After the crisis began the Navy spent months flushing the system, and in March 2022 the Navy and DOH declared water from the system was safe to drink again, but many residents remained skeptical.

Last year the EPA began testing homes of people reporting symptoms. In December, the EPA released a report after testing four homes. Three of them had traces of petroleum in the water, and in each case previous Navy testing had shown no traces. Since then there has been a surge in complaints.

"The bottom line is these families are still getting very sick, " said Feidnt. "And it's not just family that have been there the whole time, it is brand-new families that are moving in and didn't know anything about the water crisis before."

The Navy, for its part, has assembled a "swarm team " of experts to examine the water. During a March 7 meeting of the Red Hill Fuel Tank Advisory Committee, a DOH initiative, a member of the swarm team said detections of TPH, found in test samples throughout the past two years, didn't necessarily indicate the presence of petroleum. He asserted that nonpetroleum substances—like chemicals found in plastic—could trigger a positive test for TPH, saying, "In a sense you could call them false positives."

During the CRI's March 2024 meeting, Capt. James Sullivan, commander, Naval Facilities Engineering Systems Command Hawaii, said the way the lab had been testing the water was "not a drinking water method " because "as we all know, there should not be fuel in drinking water. So therefore, there was not a method developed for that specifically " and that the service made due with what it had.

Feidnt said that potentially calls all tests into question, and asked "if there can be false positives, why can't there be false negatives ?"

According to Miller's email, the two detections in March had "exceedances above the Incident Specific Parameter (ISP ) level of 266 ppb (parts per billion )." On March 8 the Navy notified the EPA of "unvalidated results " from a classroom sink at a school with TPH detected at 324 ppb. The email did not specify which school. On March 11 the Navy notified the EPA of a reading of 359 ppb from the residence in the Aliamanu Military Reservation.

"In both instances, the taps were flushed and split samples were collected and analyzed using modified lab methods (chlorine quenched micro-­extraction ), " Miller wrote. "Both the School and AMR residence returned validated results that were NON-DETECT for TPH (ie, below the method detection limit of 50 ppb)."

On March 12, the Navy was informed that NOAA industrial hygienists had collected drinking water samples from two piers in late February and sent them off-island to an independent, EPA-certified lab for analysis of TPH.

"The results entailed abnormally high levels of TPH, exceeding the established ISP, " said Miller. " NOAA's lab reported on 15 Mar, that the initial TPH detections were incorrect. The lab reanalyzed the samples which were NON-DETECT for TPH in both risers and produced a memorandum voiding the original lab results due to lab contamination (quality control ) and certifying the second, Non-Detect results. Navy's Rapid Response Test was NON-DETECT and the Navy also received VALIDATED Long Term Monitoring results of NON-­DETECT for both piers, which has addressed the matter of a false TPH."

Feidnt said "they'll take the samples and all of a sudden, they're above the 266—or they're high—and they'll come back, they'll flush the system who knows how many times, then they'll take two samples, and they'll split it to validate it. And there's no record then of there ever being an exceedance. There's only a record of it being totally fine. And it makes us wonder how often has this happened."

The CRI has been calling on the Navy, DOH and EPA to issue a water safety advisory for the Navy's water system. In November 2021 the DOH put out a water advisory when residents were reporting getting sick and the Navy continued to insist the water was safe. By December the Navy acknowledged that contaminated water had entered its water line.

In regards to why the DOH sent out an advisory in 2021 but not for the most recent reports of illness, the agency said in the statement "the situation right now in March 2024 is different in multiple ways."

The agency said that in November 2021 "there was a known fuel release at the Red Hill facility " and that "through observation of a fuel-like odor from samples taken on the Navy's water system, a preponderance of complaints from residents, and the acute nature of those hospitalized or reporting injury, DOH made the quick and precautionary decision to issue a Health Advisory for the entire Navy drinking water system on Nov. 29, 2021 because the Navy did not to do so."

By contrast the DOH said that currently "the water source for those on the Navy's water system is coming from the Waiawa Shaft (not the Red Hill shaft, which was still in use in November 2021 ). The Red Hill Shaft has been shut down since late November 2021. Joint- Task Force Red Hill has removed almost all the fuel from the underground storage tanks and there has been no known fuel release."

But the DOH said that it "takes reports of symptoms seriously and is working to identify if there is a drinking water related cause. Using the multiple lines of evidence approach to water quality testing, there is no substantial evidence to support a change in the Navy water distribution system's water quality at this time. However, we acknowledge that some are experiencing symptoms, and we continue to investigate."

"All we're saying, as a representative for the community, is the facts are people are sick, there's a visible sheen (on the water ), " said Feidnt. "While you guys figure it out what it is, while you get your story straight, what is the harm in putting out an advisory so that people are informed and they can protect their families ?"

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