## AOC C omments (Administrative Oder of Consent)

Signing the present AOC will not result in significant improvements in protecting drinking water.

The Hawaii State L egislature requested a Task Force to examine : 1. Short and long term effects, 2.
Strate g ies to mi tigate
, 3. Ways to improve communication and 4. Implications of c losing

.
The Task Force report to the Legislature revealed varied opinions and recommendations among the parties.

The Task Force recommends that the Legislature encourage the parties to negotiate an agreement to cover the followi ng objectives : to protect drinking water resources, appropriately respond to reported releases of petro, and minimize the threat o f potential future releases.

This proposed AOC does not address the Legislature requests or the Task Force objectives. It only agrees
to continu e tests , monitoring and additional studies which was always don e to some extent . It basically keep s the status quo.

All parties to the AOC know that past studies indicate that once the water is declared unsafe no reasonable/immediate corrective action is possible. There is no emergency plan. M itigation is difficult, costly and may not be possible.

Unsafe drinking water will affect the entire island popula ces and the economy.

Our Congressional delegation should be well aware of this potential problem

.

Recommend ation to EPA and DOH : Do not sign the proposed AOC in its present state

.



## Items of interest

It states that chronic exposure 

### can be harmful to human health. It 

### is

.......... EPA states that Red Hill 

### may present imminent and substantial endangerment to health and

environment. It 

### presents

...... At another time it was labeled “critical”

It states that actions in the AOC 

### may be necessary. It 

### is

...... this is the reason for this agreement.

It does not acknowledge the 27K spill as a threat to health.

It does not discuss/address mitigation and rem ediation.

It does not provide for any meaningful protection for health and environment.

It does not mention that past studies indicate remediation is difficult and costly

.It lacks immediate action.

It is not transparent as to funding and that any A&E stud ies , all work or fines are subject to the availability of funds.

Do es the EPA and DOH agree to this AOC version as signed off by the Navy?

Besides the public ’s comments what are EPA and DOH’s comments if any s ince th e Task Force
recommendations and concerns are not addressed ?



## Additional Items of Interest

P ast records show that 30K+ fuel was lost on two occasions

. Most tanks have experienced leaks in the past.

Red hill is deferred from some Federal and state UST regulations due to the fact that they are field
constructed tanks

.
The p olicy is to conduct routine maintenance on a tank at least within a 20 year period

. Once in 20

years ?

Other past tank routine maintenance repair s have resulted in a similar failure s were welds failed and
had to be drained and re p aired again

.
Lacking is the technology
, skill and physical ability and equipment to perform proper maint enance on the largest
, aging tanks in the Uni ted States

. This is uncharted wa ters.

Present detection system can detect a 1/16” drop in tank. How many gals does 1/16” equate to? Maybe 300 gals.

Various d etection systems in the past ha ve failed due to various reasons and have been removed

. The present system may not be sufficient.

It would be interesting to know what triggered the first al arm in the EST 27K spill and subsequent time line of events

.

In the EST 27K release i t t ook 5 days just to empty the tank.

Once a detection alarm goes off what are the procedures

.

Different product s and size of the failure may result in different volume relea sed

. Past failures were probably due to only pin holes which are difficult to detect.

After the verbal announcement of the spill was given it took many days just to confirm

.Any free product located will be removed only to the “maximum amount practical ” ?

Only a token $50K per year is allowed for reimbursement to DOH ?

Believe the only method to check the 250 ft. tall tanks are from interior with hand held instruments while standing on scaffolds.

There is no intention to consider secondary containment or any other option.



## Additional concern

The underground piping infrastructure below the tanks and transmission line is a concern

.

N ot addressed is the danger of the aging underground piping infrastructure.

T he underground transmission pipes from Red Hill travels 2.5 miles t o Hickam and Pearl Harbor are just
as old

. Are there maintenance/repair records for the underground transmission pipes?

Any past breaks noted? Is there present ly a cathodic/ m aintenance program in place ?