Page 1 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

Per- and polyfluoroalkyl substances (PFAS) are a large group of heat and stain 

resistant chemicals that can persist in the environment—including in water, soil, 

and air—for decades or longer. According to the Environmental Protection 

Agency (EPA), exposure to certain PFAS may have adverse effects on human 

health, including effects on fetal development, the immune system, and the 

thyroid, and may cause liver damage and cancer. 

During November 2022 maintenance activities at Joint Base Pearl HarborHickam in Hawaii, 1,300 gallons of aqueous film-forming foam (AFFF) 

concentrate was released from a pipe in a tunnel at the installation’s Red Hill 

Bulk Fuel Storage Facility. Some of the concentrate migrated out of the tunnel 

and into the environment. Because AFFF—a product used to fight flammable 

liquid fires—contains PFAS, this incident raised concerns about how the Navy 

would remediate PFAS contamination at the installation. 

We were asked to examine the Department of Defense’s (DOD) efforts to 

address PFAS at Joint Base Pearl Harbor-Hickam. This report describes DOD

processes for the ongoing monitoring and long-term cleanup of PFAS at Joint 

Base Pearl Harbor-Hickam; DOD’s response to the November 2022 AFFF 

release at the installation; and DOD and EPA policies addressing PFAS in the 

environment. 

• As of February 2024, DOD testing has not detected PFAS in the active 

drinking water shaft at Joint Base Pearl Harbor-Hickam. According to 

installation officials, they monitor drinking water for PFAS at frequencies 

required by DOD policy and requests by EPA and the state of Hawaii. 

• DOD has policies and guidance related to monitoring PFAS levels in drinking 

water at its installations, conducting long-term cleanup and remediation of 

PFAS in the environment, and using and disposing of products containing 

PFAS—including AFFF. 

• On April 10, 2024, EPA issued a National Primary Drinking Water Regulation

that established allowable levels for six PFAS in drinking water. Prior to this, 

PFAS in drinking water were not regulated at the federal level. In addition, 

EPA has proposed a rule that designates certain PFAS as hazardous 

substances, which is expected to facilitate nationwide cleanup of sites 

contaminated by these compounds. Once this proposed rule is finalized, 

DOD plans to update its policies to reflect the new regulation. 

• The Navy, as part of DOD’s departmentwide environmental restoration 

program, has identified 32 sites of known or potential PFAS contamination at 

Joint Base Pearl Harbor-Hickam. The Navy is taking steps to assess these 

sites and, where appropriate, develop plans for their long-term cleanup.

U.S. Government Accountability Office

Persistent Chemicals: Navy Efforts to Address

PFAS at Joint Base Pearl Harbor-Hickam 

GAO-24-106812

Q&A Report to Congressional Requesters 

April 15, 2024

Why This Matters

Key Takeaways
Page 2 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

PFAS can enter the environment through the use and disposal of PFAS and 

products containing PFAS—including AFFF. First developed in the 1940s, PFAS 

are used in a wide range of products, including carpet, nonstick cookware, 

waterproof clothing, and firefighting foam used at airports and military bases. 

Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) are two of 

the most widely used and studied chemicals in the PFAS group.1 See figure 1 

for examples of how PFAS can get into water sources. 

Figure 1: Examples of How Per- and Polyfluoroalkyl Substances (PFAS) Enter Water 

Sources

AFFF has traditionally been considered the most effective product available for 

suppressing fires caused by jet fuel. According to DOD officials, since 1970, 

AFFF has been the designated firefighting agent for fuel fires at military facilities, 

commercial airports, and other industries (e.g., oil and gas). Release of AFFF 

into the environment, either through accidental spills or releases or for fire 

training and suppression, has resulted in PFAS contamination of drinking water 

and groundwater in and around DOD installations. 

The National Defense Authorization Acts for Fiscal Years 2020, 2021, 2022, and 

2023 established several requirements aimed at reducing DOD’s use of AFFF; 

disposal of products containing PFAS, including AFFF; and increasing efforts to 

identify, remediate, and report on PFAS contamination at its installations.2 

How do PFAS get into

the environment? 

What restrictions has 

Congress placed on 

DOD’s use and 

management of AFFF? 
Page 3 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

Specifically, the National Defense Authorization Act for Fiscal Year 2020 

established several restrictions on DOD’s use of AFFF, including prohibitions on 

its:

• procurement of AFFF containing in excess of 1 part per billion of PFAS 

substances after October 1, 2023, unless for use onboard ocean-going 

vessels; 

• use at military installations after October 1, 2024—with waivers possible until 

October 1, 2026, and an exemption for shipboard use; and 

• uncontrolled release at military installations unless for emergency response 

or for the purposes of testing of equipment or training of personnel, if 

complete containment, capture, and proper disposal mechanisms are in place 

to ensure no AFFF is released into the environment. 

The National Defense Authorization Act for Fiscal Year 2022 also placed a 

temporary moratorium on the use of incineration to dispose of AFFF and other 

specified materials contaminated with PFAS until the Secretary of Defense 

issued guidance implementing EPA’s interim guidance on destruction and 

disposal of PFAS and other legal requirements or until EPA issued a final rule 

regarding the destruction and disposal of materials containing PFAS. In 

December 2020, EPA issued its initial interim guidance on the destruction and

disposal of certain PFAS and PFAS-containing materials.3 In July 2023, DOD 

issued its own interim guidance on destruction and disposal of materials 

containing PFAS in response to the requirement in the National Defense 

Authorization Act for Fiscal Year 2022. In a separate July 2023 policy memo, 

DOD decided to continue the temporary moratorium on incineration of these 

PFAS materials.4 DOD’s interim guidance also stated that DOD anticipated that 

EPA would be updating its December 2020 interim guidance and noted that DOD 

will update its guidance annually to reflect changes as technologies mature, EPA 

updates its guidance, and additional data become available. In April 2024, during

the week preceding issuance of our review, EPA updated its initial interim 

guidance.5

On April 10, 2024, EPA issued the National Primary Drinking Water Regulation.6

The regulation establishes maximum contaminant levels for PFOA and PFOS in 

drinking water of 4.0 parts per trillion for each (one part per trillion is equivalent to 

a single drop of water in 20 Olympic-sized swimming pools). This regulation 

requires that:

• Public water systems must monitor for these PFAS and have 3 years to 

complete initial monitoring (by 2027), followed by ongoing compliance 

monitoring. Water systems must also provide the public with information on 

the levels of these PFAS in their drinking water beginning in 2027.

• Public water systems have 5 years (by 2029) to implement solutions that 

reduce these PFAS if monitoring shows that drinking water levels exceed 

these maximum containment levels.

• Beginning in 5 years (2029), public water systems that have PFAS in drinking 

water which violates one or more of these maximum contaminant levels must 

take action to reduce levels of these PFAS in their drinking water and must 

provide notification to the public of the violation. 

Prior to finalization of this regulation, PFAS in drinking water were unregulated by 

EPA. However, in 2016, under the authority of the Safe Drinking Water Act, EPA 

published health advisory levels of 70 parts per trillion for PFOA and PFOS in 

drinking water.7 EPA health advisories are nonenforceable and nonregulatory but 

serve to provide information on contaminants not subject to drinking water 

How are PFAS 

regulated in drinking 

water at the federal 

level? 
Page 4 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

regulations, including those that can cause adverse human health effects and are 

known or anticipated to occur in drinking water. Since 2016, DOD has had

policies in place for monitoring PFAS levels in drinking water at its installations.8 

In 2022, EPA issued updated interim health advisory levels for PFOA and PFOS 

in drinking water at 0.004 parts per trillion and 0.02 parts per trillion, 

respectively.9 This supersedes EPA's 2016 health advisory levels. EPA also 

issued health advisories for two additional PFAS substances. However, the 

updated interim levels are lower than available testing methods can detect.10

DOD did not revise its drinking water policies to reflect the new interim levels, but 

according to officials, revised its drinking water policy in 2023 in anticipation of a 

final EPA drinking water standard. According to DOD policy and officials we met 

with, DOD will implement and comply with the April 2024 EPA regulation. 

Joint Base Pearl Harbor-Hickam is also subject to environmental regulation of the 

State of Hawaii Department of Health. As of February 2024, Hawaii has no 

regulations for PFAS in drinking water. Hawaii will also adopt federal PFAS limits 

in drinking water in compliance with the April 2024 EPA regulation. 

Table 1 provides an overview of key DOD policies related to PFAS in drinking

water that have been in place since 2016. 

Table 1: Key Department of Defense (DOD) Policies Related to Per- and Polyfluoroalkyl 

Substances (PFAS) in Drinking Water since 2016

Policy Summary of requirements

Assistant Secretary of Defense for 

Energy, Installations, and Environment 

Memorandum, Testing DOD Drinking 

Water for Perfluorooctane Sulfonate 

(PFOS) and Perfluorooctanoic Acid 

(PFOA)

(June 10, 2016)

Required military installations to test drinking water for 

PFOS and PFOA. Established actions required of 

installations if test results are greater than 70 parts per 

trillion, including providing alternative drinking water. 

(Superseded by March 2, 2020, Office of the Assistant 

Secretary of Defense memorandum.)

Assistant Secretary of Defense 

Memorandum, Per- and 

Polyfluoroalkyl Substances Sampling 

of Department of Defense Drinking 

Water Systems 

(March 2, 2020)

Established requirements for the frequency of and 

methods for testing drinking water for all DOD-owned 

drinking water systems. Required that where state, local, 

or federal regulations for PFAS were more stringent than 

the DOD guidance, the more stringent regulations would 

apply, and implemented requirements for more frequent

testing of drinking water systems with testing results that 

exceed 70 parts per trillion for PFOS and PFOA. 

(Superseded by July 11, 2023, Office of the Assistant 

Secretary of Defense memorandum.) 

Assistant Secretary of Defense 

Memorandum, Monitoring of Per- and 

Polyfluoroalkyl Substances Sampling 

for Installations with Non-Department 

of Defense Drinking Water Systems

(July 23, 2020)

Required military installations that receive drinking water 

from a non-DOD purveyor to request drinking water 

sampling data for PFAS from the purveyor or conduct 

drinking water sampling for PFAS if the purveyor will not. 

If sampling results exceed 70 parts per trillion for PFOS 

and/or PFOA, the installation would notify the public and 

request that the purveyor take immediate action to 

decrease the PFAS levels. 

Assistant Secretary of Defense 

Memorandum, Department of Defense 

Guidance on Using State Per- and 

Polyfluoroalkyl Substances (PFAS) 

Drinking Water Standards in 

Comprehensive Environmental 

Response, Compensation, and 

Liability Act Removal Actions

(December 22, 2021)

Established guidance that DOD may initiate a removal 

action under the Comprehensive Environmental 

Response, Compensation, and Liability Act of 1980, as 

amended, where DOD is responsible for a confirmed 

release of PFOA or PFOS concentrations above 70 parts 

per trillion in drinking water. The guidance also provided 

that DOD should, to the extent practicable, attain state 

PFAS drinking water standards when conducting a 

removal action.

a
Page 5 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

Assistant Secretary of Defense

Memorandum, Memorandum for 

Sampling of Per- and Polyfluoroalkyl 

Substances in DoD-Owned Drinking 

Water Systems 

(July 11, 2023)

Updated requirements for the frequency of and methods 

for testing drinking water for all DOD-owned drinking 

water systems based on EPA detection methods and in 

anticipation of a final EPA drinking water standard for 

certain PFAS. Implemented requirements for increased 

testing of drinking water systems with testing results that 

exceed EPA's minimum reporting levels. If DOD-owned 

systems detect PFOA and/or PFOS in drinking water 

exceeding 70 parts per trillion, requires DOD to provide 

alternative drinking water and take action to lower 

concentrations. Requires that where state and local 

regulations for PFAS have been fully implemented, and 

are more stringent than DOD’s guidance, the more 

stringent regulations will apply.

 Source: GAO presentation of DOD information. | GAO-24-106812

a

There are generally two types of cleanup actions under the Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980, as amended. Removal actions are usually short-term cleanups for 

sites that pose immediate threats to human health or the environment. Remedial actions are generally longterm cleanups that aim to permanently and significantly reduce contamination. As a part of a remedial action, 

the lead agency is to identify “applicable or relevant and appropriate requirements” (ARAR) for the cleanup. 

State drinking water standards may qualify as an ARAR for remedial actions. While DOD is not required to 

attain ARARs for a removal (as opposed to a remedial) action, if a state’s PFAS drinking water standard is 

properly promulgated and consistently implemented, DOD will, to the extent practicable, seek to attain those 

standards upon the completion of the removal action and may use the state standard to determine the cleanup 

level to be attained by DOD. 

According to Joint Base Pearl Harbor-Hickam officials, they responded to the 

November 2022 AFFF release as required by DOD policy and the Navy Region 

Hawaii Integrated Contingency Plan, which established response and reporting 

requirements in the event of an AFFF release.11 The incident, which occurred 

during maintenance activities, resulted in the release of 1,300 gallons of AFFF 

concentrate from a pipe in a tunnel at the installation’s Red Hill Bulk Fuel Storage 

Facility. Some of the concentrate migrated out of the tunnel and into the 

environment. Further, according to officials, in responding to the AFFF release 

the Navy followed additional procedures that were determined to be necessary 

by EPA and state regulators. 

Both DOD and EPA have since completed investigations of the November 2022

AFFF release and issued final reports.12 According to these reports, immediately 

following the AFFF release, emergency responders—including DOD, Navy, and 

civilian personnel—conducted an initial evaluation of the release and performed 

containment measures. For example, they placed absorbent padding inside and 

outside of the affected areas to remove as much AFFF as possible and sealed 

the interior tunnel walls and concrete floor where the pipe was located with epoxy 

to lock any residual contamination in place and prevent contamination from 

migrating to subsurface soils. The Navy also restricted access to the site. 

According to the EPA investigation report, because some AFFF breached the 

facility, DOD, supported by the Navy, in the days following the AFFF release 

removed approximately 3,000 cubic feet of soil from the surrounding area and 

took measures to prevent any AFFF-contaminated materials from entering a 

nearby storm drain. In addition, a temporary asphalt cap was installed to 

minimize rain infiltration. The Navy then backfilled the excavated area with clean 

soil. 

Both the Navy and EPA investigations recommended that (1) increased 

government oversight of AFFF-related activities at the Red Hill facility was 

necessary, (2) all AFFF concentrate should be removed from the facility, and (3) 

the AFFF system at Red Hill should be decommissioned. According to the Navy 

investigation, immediately following the incident, the Navy began the process to 

How did Joint Base 

Pearl Harbor-Hickam

respond to the 

November 2022 AFFF 

release?
Page 6 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

remove AFFF from the system’s pipelines and make preparations for proper

disposal.13 Officials at Joint Base Pearl Harbor-Hickam told us there are no plans 

to resume use of the system and, once the fuel is removed from the facility, an 

AFFF system will not be required.14

According to Navy officials, as a result of the 2022 AFFF concentrate release, the 

Navy also took steps to investigate PFAS in groundwater in the surrounding 

area. Specifically, according to DOD officials, at the request of EPA and state 

regulators, the Navy developed a sampling and analysis plan that included 

weekly monitoring for PFAS at 10 groundwater monitoring wells through June 

2023.15 Further monthly monitoring of the same wells was performed through 

December 2023 under a different agreement with EPA and state regulators. 

According to EPA officials, in September 2023, at EPA’s request the Navy 

performed a separate one-time PFAS sampling of 21 wells around the Red Hill 

Bulk Fuel Storage Facility. This included the 10 groundwater wells around Red 

Hill that had been previously sampled. This sampling found low-level PFAS 

detections in four wells that exceeded the state of Hawaii groundwater screening 

levels.

16 DOD officials stated they are not concerned that these PFAS detections 

will impact drinking water as the nearest drinking water well is upgradient and 

approximately six miles away. Additionally, according to Navy officials, the PFAS

that were detected were not the result of the November 2022 AFFF release.

According to EPA officials, as of December 2023, the Navy determined it had 

met the state regulator’s emergency response requirements and discontinued 

PFAS groundwater monitoring at Red Hill until implementation of long-term 

cleanup actions planned for 2025 (discussed later in this report). According to 

these officials, based on results from the September 2023 sampling, EPA and 

state regulators requested, in March 2024, that the Navy resume interim PFAS 

groundwater sampling until implementation of the planned long-term cleanup 

actions commence.

The Navy conducts PFAS sampling in the drinking water shafts at Joint Base 

Pearl Harbor-Hickam in accordance with DOD policy, according to Navy 

officials.17 According to DOD policy, active DOD-owned drinking water systems 

must be tested for PFAS at least every 2 years if the presence of PFAS is below 

minimum reporting levels. At the time we conducted our audit work, DOD policy 

used the 2016 health advisory level of 70 parts per trillion as its minimum 

reporting level. In the days preceding issuance of our report, EPA finalized 

maximum contaminant levels for PFOA and PFOS in drinking water of 4 parts 

per trillion. Information presented in this report reflects DOD policy prior to the 

establishment of the new EPA regulation. According to DOD, its monitoring 

requirements will comply with EPA’s April 2024 drinking water regulation.

For systems with results showing PFAS above 2016 minimum reporting levels, 

testing will occur semiannually until the levels are below 70 parts per trillion for 

two consecutive samples. Additionally, if combined concentrations of PFOA or 

PFOS exceeding 70 parts per trillion are detected in drinking water, DOD must 

provide alternative drinking water and take other actions to lower concentration 

levels to below 70 parts per trillion. We have previously reported that DOD has 

taken actions to address PFAS in drinking water at or near military installations 

such as shutting down drinking water wells, providing alternative drinking water, 

or installing treatment systems.18

As of February 2024, only one of the three drinking water shafts at Joint Base 

Pearl Harbor-Hickam was in use. See figure 2 for a map of the three drinking 

water shaft locations. 

How does Joint Base 

Pearl Harbor-Hickam

monitor for PFAS in 

drinking water? 
Page 7 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

Figure 2: Map of Department of Defense’s Three Drinking Water Shafts at Joint Base Pearl 

Harbor-Hickam

• Waiawa shaft (active). The Waiawa shaft is currently the only operating 

drinking water shaft at Joint Base Pearl Harbor-Hickam; it provides drinking 

water for the entire installation. PFAS have not been detected in drinking 

water samples taken from the shaft. According to Navy officials, in 

accordance with DOD monitoring policy, water in the Waiawa shaft is tested 

for PFAS at least every 2 years; however, they have been testing the Waiawa 

shaft more frequently since the November 2022 AFFF release. The most 

recent test results, taken on January 30, 2024, indicate that there were no 

PFAS in the shaft.19 Officials from both the Navy and EPA have raised 

concerns about relying on the Waiawa shaft as the sole source of drinking 

water at Joint Base Pearl Harbor-Hickam and about the need for an alternate

drinking water source in case of an emergency.

• Aiea-Hālawa shaft (inactive). PFOA and PFOS were detected in November

2021 at the Aiea-Hālawa shaft. Detected levels were below 70 parts per 

trillion, which, per DOD policy, did not require the Navy to take any action to 

close the shaft or provide alternative drinking water sources. Navy officials do 

not attribute the source of these PFAS to AFFF, and they noted that the 

detections of PFAS were below the 70 parts per trillion 2016 health advisory 

levels—less than 6 parts per trillion for each of the five PFAS detected—and 

not clearly linked to a specific source. At the time of this testing DOD policy 

not require that any action to close the shaft or provide alternative drinking 

water sources based on these levels. However, in December 2021, following 

the Red Hill fuel release the Navy made the decision to take the water shaft 

offline out of an abundance of caution for potential fuel contamination. 

According to Navy officials, sampling conducted in April, August, and October 

2023 at the shaft showed that PFAS levels declined from previous sampling. 

April sample results were less than 2 parts per trillion for five detected PFAS 

and both August and October sample results did not detect any PFAS. In light 

of concerns about the need for another water source at Joint Base Pearl 
Page 8 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

Harbor-Hickam, Navy, and EPA officials indicated they are in preliminary 

discussions with state regulators about steps that would need to be taken to 

reactivate the Aiea-Hālawa shaft as a second drinking water source. 

According to state regulators—as part of their responsibilities enforcing the 

Safe Drinking Water Act—state regulations require they certify the 

reactivation of the shaft since it has been offline for over 6 months.20 State 

regulators told us they are being more cautious and comprehensive in their 

oversight than they might otherwise be because of the 2021 Red Hill fuel 

release. As of February 2024, there was no estimated date for reactivating

the shaft. 

• Red Hill shaft (inactive). The Navy closed this shaft in November 2021 in 

response to fuel contamination in the drinking water following the Red Hill fuel 

release. According to DOD officials, PFAS were not detected at the Red Hill 

drinking water shaft. However, groundwater sampling in this area detected 

low levels of PFAS in the general area in December 2022, but as of April 

2024, they are below the state of Hawaii groundwater screening levels.

According to EPA, while PFAS have not been detected in the Red Hill 

drinking water shaft above 70 parts per trillion, Navy testing in December 

2021 found low parts-per-trillion concentrations of PFAS that fell below EPA’s 

health advisory levels current at that time. According to Navy officials, 

monitoring at the Red Hill shaft is not expected to continue for PFAS and 

there are no current plans to reactivate the shaft.

PFAS contamination at Joint Base Pearl Harbor-Hickam is being addressed 

through the Defense Environmental Restoration Program. It is a requirement of 

this program that DOD’s environmental restoration activities be conducted in 

accordance with the Comprehensive Environmental Response, Compensation, 

and Liability Act of 1980, as amended (CERCLA) and other applicable federal, 

state, and local requirements.21 CERCLA, also known as “Superfund,” provides 

the federal government with the authority to respond to releases or threatened 

releases of hazardous substances, pollutants, and contaminants that pose a 

threat to public health or the environment.22 

As of February 2024, PFAS were not designated as hazardous substances under 

CERCLA.23 However, CERCLA also authorizes federal agencies, including DOD, 

to take cleanup actions for pollutants or contaminants in accordance with 

CERCLA regulations. Under a CERCLA Federal Facility Agreement for the Pearl 

Harbor Naval Complex, for certain locations at Joint Base Pearl Harbor-Hickam, 

the Navy is required to define the nature and extent of PFAS contamination and 

clean it up where necessary to protect public health and the environment.24

According to officials, DOD is currently using the full range of CERCLA 

authorities to respond to PFAS as a pollutant or contaminant and has responded 

to PFAS under this authority for many years.

In addressing PFAS as a pollutant or contaminant under CERCLA, DOD 

identifies, evaluates, and where appropriate, responds to known or potential 

DOD releases of PFAS to the environment.25 According to DOD officials, these 

actions include both short-term interim responses and long-term cleanup phases. 

See figure 3 for an overview of the timeline of each of these phases.

How is PFAS

contamination being 

addressed at Joint 

Base Pearl HarborHickam? 
Page 9 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

Figure 3: Phases of Department of Defense’s (DOD) Environmental Restoration Process

To identify potential areas of interest for PFAS contamination, the Navy reviewed 

data and historic documents and conducted interviews with installation officials 

with historical knowledge of known or suspected PFAS releases. The Navy 

provided its site inspection reports to EPA in November 2023 for official 

comment. EPA provided comments in January 2024, to include recommending 

that the Navy investigate additional areas of interest.

The Navy reports identified 124 potential areas of interest for PFAS 

contamination. According to officials, these sites included all aircraft hangars, 

locations of known or suspected jet fuel fires, AFFF training sites, and other 

locations that may have been used in the storage or use of AFFF. The Navy 

reports determined that use or releases of PFAS-containing materials could not 

be substantiated at 92 of these areas. They organized the remaining 32 areas of 

interest—including Red Hill—into four categories; sites in Groups A, B, and C 

were recommended to advance further through the CERCLA process to the indepth remedial investigation phase; no action will be taken for Group D sites, for 

which there is no documentation of AFFF or PFAS use. See table 2 for number of 

sites in each category. 

Table 2: Categories for Areas of Interest at Joint-Base Pearl Harbor-Hickam Involving

Releases Known or Suspected Per- and Polyfluoroalkyl Substances (PFAS) 

Category Number of sites

Group A

Known AFFF releases. Sites are where AFFF suppressants known to have 

contained PFAS were documented to have been used for hangar tests, 

firefighter training, or fire suppression for crashes. 12

Group B

Potential AFFF releases. Sites are potential release sites, including areas 

where AFFF suppressants known to have contained PFAS were documented 

to have been stored or used but have no known releases (e.g., fire stations, 

hangars, flight lines, runways, AFFF handling/storage areas). 7

Group C

Electroplating facilities. Sites are electro-plating facilities that may have used

vapor suppressants containing PFAS. 1

Group D

No documentation. Sites are potential other secondary sources of PFAS 

releases but do not have documentation of past use of AFFF or PFAS. 12

Total 32

Source: GAO presentation of Department of the Navy information. | GAO-24-106812 
Page 10 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

We provided a draft of this report to DOD and EPA for review and comment.

DOD and EPA generally agreed with our findings and did not provide written 

comments. Where appropriate, we incorporated their technical comments into 

the report. 

We reviewed and summarized information from previous GAO reports on PFAS

contamination in the environment—including drinking water and groundwater.26

We identified and reviewed relevant DOD, EPA, and state of Hawaii guidance, 

policies, and other documentation on regulating release, response, use, and 

disposal of PFAS-containing substances. We interviewed officials from DOD, 

EPA, and the state of Hawaii on efforts to regulate PFAS at Joint Base Pearl 

Harbor-Hickam and nationally.

We identified and reviewed relevant DOD, EPA, and state of Hawaii documents

on the Navy’s response to the November 2022 AFFF release at Joint Base Pearl 

Harbor-Hickam. We conducted a site visit to Joint Base Pearl Harbor-Hickam, 

during which we toured the site of the November 2022 AFFF release and 

interviewed officials from DOD, EPA, and the state of Hawaii on the Navy’s 

response and cleanup of the AFFF release.

We identified and reviewed relevant DOD and EPA reports on drinking water and 

groundwater monitoring at Joint Base Pearl Harbor-Hickam. We interviewed 

officials from DOD, EPA, and the state of Hawaii on the drinking water and 

groundwater monitoring at Joint Base Pearl Harbor-Hickam. 

We identified and reviewed relevant statutes and DOD and EPA policies and

other requirements for long-term cleanup and remediation of PFAS in the 

environment. We reviewed documents and interviewed officials from DOD, EPA, 

and the state of Hawaii on these efforts at Joint Base Pearl Harbor-Hickam. 

We conducted this performance audit from March 2023 to April 2024 in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based on 

our audit objectives. 

The Honorable Mazie K. Hirono

Chair 

Subcommittee on Readiness and Management Support

Committee on Armed Services

United States Senate

The Honorable Brian Schatz

United States Senate

The Honorable Ed Case

House of Representatives

The Honorable Jill N. Tokuda

House of Representatives

We are sending copies of this report to the appropriate congressional committees and 

members, the Secretary of Defense, the Secretary of the Navy, the Administrator of the 

Environmental Protection Agency, and other interested parties. In addition, the report is 

available at no charge on the GAO website at https://www.gao.gov.

Agency Comments

How GAO Did This 

Study

List of Addressees
Page 11 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

For more information, contact: Alissa H. Czyz, Director, Defense Capabilities and 

Management, CzyzA@gao.gov, (202) 512-3058. 

Chuck Young, Managing Director, Public Affairs, YoungC1@gao.gov, (202) 512-

4800. 

A. Nicole Clowers, Managing Director, Congressional Relations, 

ClowersA@gao.gov, (202) 512-4400. 

Staff Acknowledgments: Gina Hoffman (Assistant Director), Susan Iott 

(Assistant Director), Tida Barakat Reveley (Analyst-in-Charge), Nicole Ashby, 

Taylin Bower, Claudia Hadjigeorgiou, Amie Lesser, Felicia Lopez, Michael Silver, 

and Ian Toller-Clark. 

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. Subscribe to our 

RSS Feeds or Email Updates. Listen to our Podcasts. 

Visit GAO on the web at https://www.gao.gov. 

This work of the United States may include copyrighted material, details at 

https://www.gao.gov/copyright. 

1PFAS are a group of chemicals that include PFOA, PFOS, and many other chemicals. PFOA and 

PFOS are the two types of PFAS most produced and studied. Both chemicals are persistent in the 

environment and the human body, which means that they do not break down and can accumulate 

over time.

2National Defense Authorization Act for Fiscal Year 2020, Pub. L. No. 116-92, §§ 322, 323, and 

324 (2019); William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021, 

Pub L. No 116-283, § 318 (2021); National Defense Authorization Act for Fiscal Year 2022, Pub L. 

No 117-81, §§ 341, 343, 344, 345, and 346 (2021); and James M. Inhofe National Defense 

Authorization Act for Fiscal Year 2023, Pub. L. No. 117-263, § 345 (2022).

3EPA, Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl 

Substances and Materials Containing Perfluoroalkyl and Polyfluoroalkyl Substances (Dec. 18, 

2020). Under the National Defense Authorization Act for Fiscal Year 2020, EPA was required to 

publish this interim guidance and update it at least every 3 years. Pub. L. No. 116-92, § 7361. 

4Assistant Secretary of Defense for Energy, Installations, and Environment Memorandum, 

Guidance on Incineration of Materials Containing Per- and Polyfluoroalkyl Substances (July 14, 

2023). 

5EPA, Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl 

Substances and Materials Containing Perfluoroalkyl and Polyfluoroalkyl Substances—Version 2

(April 8, 2024).

6EPA, PFAS National Primary Drinking Water Regulation Rulemaking, Docket No. EPA-HQ-OW2022-0114 (April 10, 2024).

7EPA, Lifetime Health Advisories and Health Effects Support Documents for Perfluorooctanoic Acid 

and Perfluorooctane Sulfonate, 81 Fed. Reg. 33250 (May 25, 2016).

8Assistant Secretary of Defense for Energy, Installations, and Environment Memorandum, Testing 

DOD Drinking Water for Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA)

(June 10, 2016).

9EPA, Lifetime Drinking Water Health Advisories for Four Perfluoroalkyl Substances, 87 Fed. Reg. 

36848 (June 21, 2022). In addition to updating the 2016 interim health advisory limits for PFOA and 

PFOS, EPA issued final health advisories for two additional PFAS substances—

hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (together referred to as GenX 

GAO Contact 

Information

Endnotes
Page 12 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

chemicals) and perfluorobutane sulfonic acid and its related compound potassium perfluorobutane 

sulfonate (together referred to as PFBS).

10Because currently available analytical methods cannot detect PFOA and PFOS at the levels of 

the interim health advisories, EPA recommended that if water systems detect PFOA and PFOS, 

water systems take steps such as informing residents, undertaking monitoring, and examining 

steps to limit exposure. 

11Assistant Secretary of Defense for Energy, Installations, and Environment Memorandum, 

Response and Reporting of Aqueous Film Forming Foam Usage, and Accidental Releases/Spills 

on Military Installations and National Guard Facilities (April 7, 2022); Navy, Commander Navy 

Region Hawaii, Integrated Contingency Plan (Aug. 2023) (incorporating Change 12). In accordance 

with guidance in the April 2022 memo issued in response to the National Defense Authorization Act 

for Fiscal Year 2021, DOD components are required to report any AFFF usage or spill above 10 

gallons of AFFF concentrate or 300 gallons of mixed foam. Within 24 hours, notification shall be 

forwarded to the Office of the Deputy Assistant Secretary of Defense for Environment and Energy 

Resilience.

12DOD, Joint Task Force-Red Hill Command Investigation into the Facts and Circumstances 

Surrounding the Discharge of Aqueous Film Forming Foam at Red Hill Bulk Fuel Storage Facility 

on 29 November 2022 (May 5, 2023); EPA, Aqueous Film Forming Foam Investigation Report: Red 

Hill Bulk Fuel Storage Facility (Oct 2023).

13Consistent with statute and EPA guidance, DOD has identified four commercially available 

options to destroy or dispose of PFAS-containing materials. Assistant Secretary of Defense for 

Energy, Installations and Environment Memorandum, Interim Guidance on Destruction or Disposal 

of Materials Containing Per- and Polyfluoroalkyl Substances in the United States (July 11, 2023). 

EPA released its interim destruction and disposal guidance in 2020. EPA, Interim PFAS 

Destruction and Disposal Guidance; Notice of Availability for Public Comment, 85 Fed. Reg. 83554 

(Dec. 22, 2020). Updated EPA guidance is expected to advise federal agencies and others on the 

best methods of disposal or destruction for waste containing PFAS, taking into account 

technologies developed after 2020. As of April 2024, updated guidance was in the final stages of 

the federal review process and is expected to be finalized by spring 2024.

14In November 2021 about 20,000 gallons of fuel were accidentally released from the Red Hill Bulk 

Storage Facility at Joint Base Pearl Harbor-Hickam. Subsequently, the Navy began the process of 

defueling the facility. In February 2024, we reported that the Navy was unable to recover about 

5,500 gallons, contaminating portions of the surrounding area, or site, and the Red Hill drinking 

water shaft that supplies drinking water to about 93,000 service members and civilians, many of 

whom used the contaminated water. GAO, Environmental Cleanup: DOD Should Consider 

Disclosing Total Future Costs for Cleanup Efforts at Red Hill, GAO-24-106185 (Washington, D.C.: 

Feb 14, 2024).

15Naval Facilities Engineering Systems Command, PFAS-Specific Sampling and Analysis Plan, 

Red Hill Bulk Fuel Storage Facility, Adit 6: Joint Base Pearl Harbor-Hickam, O’ahu, Hawaii (Dec. 7, 

2022).

16Hawaii Department of Health, Interim Soil and Water Environmental Action Levels (EALS) for 

Perfluoroakyl and Polyfluoroalkyl Substances (PFASs) (Jan. 2024). The state of Hawaii’s screening 

levels were most recently updated in January 2024 available at

https://health.hawaii.gov/heer/guidance/ehe-and-eals/#ehe6. 

17Assistant Secretary of Defense for Energy, Installations, and Environment Memorandum, 

Sampling of Per- and Polyfluoroalkyl Substances in DOD-Owned Drinking Water Systems (July 11, 

2023).

18GAO, Drinking Water: DOD Has Acted on Some Emerging Contaminants but Should Improve 

Internal Reporting on Regulatory Compliance, GAO-18-78 (Washington, D.C.: Oct. 18, 2017).

19Navy, Safe Waters Joint Base Pearl Harbor-Hickam, Joint Base Pearl Harbor-Hickam (JBPHH) 

Drinking Water Long Term Monitoring Dashboard available at 

https://app.powerbi.com/view?r=eyJrIjoiNTIyNDU0OTMtODgwNS00ZjQ4LTg1Y2UtODkxYTgxMjQ

5NGZhIiwidCI6ImUyYzE5MDhiLTI2NzItNGE0Ni05M2ZkLTdmMDhkYTExNjZiNSIsImMiOjJ9

(accessed on Feb. 7, 2024).
Page 13 GAO-24-106812 PFAS at Joint Base Pearl Harbor-Hickam

20Safe Drinking Water Act, Pub. L. No. 93-523 (1974), as amended; codified at 42 U.S.C. §§ 300f–

300j-26 (2010). Among other things, the Safe Drinking Water Act authorizes EPA to establish 

National Primary Drinking Water Regulations, which generally limit the levels of specific 

contaminants in public drinking water systems that can adversely affect public health. States 

generally have primary responsibility for enforcing federal drinking water regulations.

21DOD Instruction 4715.07, Defense Environmental Restoration Program (DERP) (May 21, 2013) 

(incorporating Change 2, Aug. 31, 2018). The Defense Environmental Restoration Program was 

established by the Superfund Amendments and Reauthorization Act of 1986, which amended 

CERCLA. In implementing the program, DOD is required to carry out its activities addressing 

hazardous substances, pollutants, or contaminants in a manner consistent with section 120 of 

CERCLA. 10 U.S.C. § 2701.

22Comprehensive Environmental Response, Compensation, and Liability Act of 1980, Pub. L. No. 

96-510 (1980), as amended; codified at 42 U.S.C. §§ 9601-9675. 

23EPA has proposed a rule to designate certain PFAS as hazardous substances under CERCLA, 

which EPA expects will provide additional tools that the government and others could use to 

address PFAS contamination and facilitate the cleanup of contaminated sites. EPA, Designation of 

Perflouorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous 

Substances, 87 Fed. Reg. 54415 (Sept. 6, 2022). This rule is currently under review, and according 

to EPA officials, is anticipated to be finalized in spring 2024. According to DOD officials, once 

EPA’s proposed rule is finalized, DOD will revise its policies, as necessary, to comply with EPA’s 

regulations.

24EPA Region 9, State of Hawaii and Navy, Pearl Harbor Naval Complex Federal Facilities 

Agreement (Mar. 1994). According to EPA officials, in addition to DOD requirements the Navy is 

investigating PFAS releases at Joint Base Pearl Harbor-Hickam pursuant to the 1994 Pearl Harbor 

Naval Complex Federal Facility Agreement under CERCLA. The purpose of this multiparty 

agreement is to ensure that environmental impacts associated with past and present activities at 

the Navy’s Pearl Harbor complex are investigated and remediated as necessary to protect public 

health and welfare and the environment. 

25Assistant Secretary of Defense for Energy, Installations, and Environment Memorandum, Taking 

Interim Actions to Address Per- and Polyfluoroalkyl Substances Migration from DoD Installations 

and National Guard Facilities (July 11, 2023). DOD components are further directed to prioritize 

implementation of interim actions as expeditiously as possible to address PFAS under CERCLA, 

such as removal of soil “hot spots” and installation of groundwater extraction systems, where 

supported by site-specific information. 

26For an overview of our work on government and other efforts to detect PFAS, prevent exposure, 

and treat contamination see GAO, Persistent Chemicals: Detecting, Limiting Exposure To, and 

Treating PFAS Contamination, GAO-23-106970 (Washington, D.C.: Sept. 27, 2023).
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