REVISIONS TO THE RED HILL GROUNDWATER PROTECTION PLAN 

Date: December 2009 

Document Title: Red Hill Bulk Fuel Storage Facility Final Groundwater Protection Plan, Pearl Harbor, Hawaii of January 2008 

No. Page Section Revision Comment 

1. ES-2 Executive Paragraph 4, Line 10 — Delete "These data will also be Soil vapor monitoring points were installed under each of 

Summary provided to the HDOH quarterly." the 18 active USTs. Samples have been collected monthly, 

but resuits have been inconclusive. No trends in soil vapor 

concentrations have been observed. The HDOH UST Case 

Officer, Mr. Rich Takaba, concurred with the Navy's 

recommendation to exclude soil vapor moniforing results 

from the quarterly re orts 

2. ES-3 Executive Paragraph 2, Line 2— Revise "The U.S. Navy will provide the The API inspection and maintenance reports will be 

Summary results of the API inspections and maintenance reports to the submifted to the HDOH under separate cover from the 

HDOH with the quarterly reports associated with groundwater quarteriy groundwater monitoring reports upon request 

and soil vapor monitoring." 

to "The U.S. Navy will provide the API inspection and 

maintenance re orts to the HDOH u on com letion." 

3. 1-14 Figure 1-4 Added the location of RHMW05 An additional groundwater monitoring well, RHMW05, was 

installed between RHMW01 and US Navy Well 2254-01 in 

July 2009. 

4. 3-8 3 3.1.1 Delete Bullet 2—"Resuits from any soil vapor testing that is Same as Comment 1 

conducted." 

5. 3-8 3.3.1.1 Delete Bullet 5—"Modified API 653 Inspection and Repair Same as Comment 2. In addition, the HDOH UST Case 

scheduling and reports." Officer concurred that the inclusion of the inspection and 

repair scheduie in the quarterly monitoring report is not 

necessary 

6., 3-9 Table 3-1 The table of Tank Inspections and Scheduling has been 

updated to reflect compieted inspections and revised 

schedule. 

7. 4-5 Table 4-2 - U.S Navy Pumping Well 2254-01, Results Category 1— - There is no Specific Response "P" 

Delete "P" 

- Specific Response J— Revise to "Immediately evaivate - Tank inventories will be checked for any unexpiained 

tanks for leaks" decreases in fuel volume. Manual tank gauging will be 

performed in the area of concern. Soil vapor monitoring 

data will be re-evaivated in the area of concern 

- Revise coiumn header to "RHMW02, RHMW03, or - An additional groundwater monitoring well, RHMW05, was 

RHMW05" installed between RHMW01 and US Navy Well 2254-01 in 

July 2009. 

Page 1 of 1 Enclosure (1) 
Final: Red Hill Bulk Fuel Storage Groundwater Protection Plan Executive Summary 

Date: January 2008 Page: ES-I 

EXECUTIVE SUMMARY 

This Groundwater Protection Plan was developed to mitigate the risk associated with inadvertent 

releases of fuel from the United States (U.S.) Navy Red Hill Bulk Fuel Storage Facility, Oahu, 

Hawaii (the Facility). Previous environmental Site Investigations (Sls) at the Facility showed 

that past inadvertent releases have contaminated the fractured basalt, basal groundwater, and soil 

vapor beneath the Facility with petroleum hydrocarbons. In response to these findings, the State 

of Hawaii Department of Health (HDOH) requested that the U.S. Navy: 

• Conduct a detailed environmental SI at the Facility; 

• Develop a groundwater model of the sunounding aquifers to evaluate the risk associated 

with petroleum releases to the groundwater; and 

• Prepare a contingency plan to protect the U.S. Navy well 2254-01, which lies down 

gradient from the Facility and provides drinking water to the U.S. Navy Pearl Harbor 

Water System (PHWS). 

The Facility consists of 20 underground storage tanks (USTs), each with the capacity to hold 

12.5 million gallons (Mgal) of petroleum-based fuel as a reserve for the U.S. Navy Pacific Fleet. 

It was constructed in the field, entirely underground within the Red Hill Ridge for security and 

confidentiality reasons and was activated in 1943 to maintain the war effort. At the same time, 

the U.S. Navy well 2254-01 was installed approximately 3,000 feet downgradient from the 

Facility, and included a water tunnel, known as an infiltration gallery, which extends across the 

water table to within 1,560 feet of the Facility. The U.S. Navy well 2254-01 currently provides 

approximately 24 percent of the potable water to the PHWS, which serves approximately 52,200 

military consumers. Model simulations of the measured contaminant concentrations beneath the 

Facility did not show contaminants entering the infiltration gallery at measurable concentrations. 

However, similar simulations showed hypothetical future releases of the jet propellant (JP-5 and 

JP-8) most commonly stored in the Facility USTs had the potential to contaminate the water that 

enters the infiltration gallery, if they are not identified quickly. In addition, the SI concluded that 

the aging of the Facility will increase the possibility that such a release could occur as a result of 

leaks breaching both the steel liners and concrete containment of the tanks. While the tank steel 

liners have been repaired, the concrete containment cannot be maintained. 

Both the Facility and the U.S. Navy we112254-01 are critical to the mission of the U.S. Navy in 

the Pacific and there are no alternative facilities to replace them. This Groundwater Protection 

Plan presents a strategy for ensuring that both the Facility and the U.S. Navy well 2254-01 can 

continue to operate at optimum efficiency into the future. This Groundwater Protection Plan 

focuses on long-term mitigation. It is not an emergency response plan. 

The Facility USTs are deferred from many of the Federal and State UST regulations, including 

the requirement for release detection, because they are field constructed bulk fuel tanks. 

However, following the notification of releases from the Facility, HDOH strongly recommended 
Final: Red Hill Bulk Fuel Storage Groundwater Protection Plan Executive Summary 

Date: January 2008 Page: ES-2 

the installation of a leak detection system to protect U.S. Navy. well 2254-01. Due to the 

importance of the groundwater resource, the U.S. Navy has evaluated methods to detect leaks at 

the Facility in the past and continues to do so. A final recommendation is expected in FY2008. 

In addition, the U.S. Navy has installed three groundwater monitoring wells within the lower 

access tunnel of the Facility and conducted a soil vapor monitoring pilot study under seven of the 

18 active USTs. In accordance with this Groundwater Protection Plan, the U.S. Navy has 

implemented a groundwater monitoring program in which groundwater samples are collected 

quarterly from three groundwater monitoring wells installed in the Facility lower access tunnel 

and the U.S. Navy well 2254-01. Samples are analyzed for specific petroleum compounds and 

mixtures in accordance with the HDOH EALs (HDOH, 2005). The U.S. Navy will: 

• Maintain a complete database of chemical results from the groundwater sampling events; 

• Evaluate concentration trends for chemicals of concern over time, evaluate chemical 

concentrations with respect to HDOH drinking water EALs; 

• Monitor the groundwater for concentrations that may indicate that liquid fuel may be in 

direct contact with groundwater beneath the tanks; and 

• Submit concentration trend data and comparisons of sampling results to drinking water 

EALs to HDOH quarterly. 

In groundwater model simulations, an extended light non-aqueous-phase liquid (LNAPL) fuel 

plume of jet propellant (JP-5 or JP-8) within 1,099 feet of the U.S. Navy well 2254-01 

infiltration gallery resulted in benzene concentrations greater than the Federal maximum 

contaminant level (MCL) of 5 μg/L in the infiltration gallery. It was estimated that a release as 

small as 16,000 gallons of JP-5 near Tanks 1 or 2 could result in this condition. The 

groundwater monitoring program provides Site-Specific, Risk-Based Levels (SSRBLs) for total 

petroleum hydrocarbons (4.5 mg/L) and benzene (0.75 mg/L). These are used as indicators that 

LNAPL is present. In addition, this Groundwater Protection Plan provides a table of 

recommended responses to contaminant levels and trends in each of the four wells that are 

sampled quarterly. 

In accordance with this Groundwater Protection Plan, the U.S. Navy will implement a soil vapor 

monitoring program using the existing boreholes beneath each of the active tanks in the Facility 

to support leak detection and the groundwater monitoring program. Soil vapor monitoring 

beneath each tank can provide quick confirmation of potential leaks identified by the automatic 

system. This will potentially limit the size of a hypothetical fuel release, by shortening the 

confirmation and response time. Soil vapor will be analyzed for total volatile hydrocarbons 

(TVH) with calibrated field instruments, and data will be evaluated for changes in concentration 

which would indicate a release of fuel from the associated tank. Along with confirmation 

sampling at suspected leaking tanks on an as needed basis, the U.S. Navy will collect soil vapor 

samples from slant borings beneath each tank quarterly. The U.S. Navy will maintain a complete 

database of SVMP results to evaluate trends. 
Final: Red Hill Bulk Fuel Storage Groundwater Protection Plan Executive Summary 

Date: January 2008 1 Page: ES-3 

The U.S. Navy will continue to conduct a rigorous maintenance schedule for all USTs in the 

Facility in accordance with the modified American Petroleum Institute (API) 653. The U.S. 

Navy will provide the results of the API inspections and maintenance reports to HDOH upon 

request. 

Finally, the Groundwater Protection Plan provides an overview of actions that would be required 

to remediate the basal drinking water aquifer if a large release of fuel were to migrate to the 

water table. Well head treatment facilities at the U.S. Navy well 2254-01 may be required to 

ensure that adequate water is available to meet the U.S. Navy mission at Pearl Harbor. The U.S. 

Navy estimated $28,300,000 would be required for a granular activated carbon water purification 

plant for the U.S. Navy Waiawa well shaft. This system was proposed to remove low levels of 

agri-chemicals for a system with a maximum pumping capacity of 18 million gallons per day 

(mgd), and included a testing laboratory (see Appendix E). The U.S. Army estimated costs for 

an air stripping water purification facility in Schofield Barracks to remove low levels of 

trichloroethylene for a system with a maximum capacity of 4.3 mgd including capital costs and 

operations for 30 years at $3,990,000 (see Appendix E). 

Under site conditions, remediation of a large fuel release would be extremely costly and 

technically difficult, due to the underground nature of the Facility, the steep ridgeline upon 

which the Facility in located, the distance from ground surface to the aquifer (between 400 and 

500 feet on the Red Hill ridgeline), and finally because of the complex hydrogeology associated 

with the fractured basalt aquifers. Pump and treat methods could be implemented but would be 

costly and inefficient in this environment. Multi-phased extraction may be more efficient, but 

very complex at the depths required. 

Downgradient enhanced bioremediation was considered through the addition of dissolved 

oxygen to the groundwater. An array of wells between the Facility and the potable water 

infiltration gallery would be required as oxygen distribution points to create a reactive pet7tteable 

barrier to the transmission of dissolved petroleum compounds. Air sparging, while economical, 

is inefficient in saturating the groundwater to enhance bioremediation. Oxygen release 

compounds or gas infusion technology could be considered to increase the efficiency of the 

barrier by increasing the dissolved oxygen content of the groundwater and the radius of 

influence. 
Final: Red HiII Bulk Fuel Storage Groundwater Protection Plan Executive Summary 

Date: January 2008 Page: ES4 

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Final: Red Hill Bulk Fuel Storage Facility Groundwater Protection Plan Section: 3 

Date: January 2008 Page: 3-7 

3.2.2 Groundwater Monitoring at the Facility 

Although a groundwater monitoring program is currently in place at the Facility, this program is 

not a viable leak detection method, since leaks can occur that are not observed at the monitoring 

wells. Its purpose is to evaluate groundwater quality under the Facility to determine whether 

contamination presents a risk to consumers of the water within the Red Hill sub-basin. In 

addition, the groundwater monitoring program will also provide "triggers" to the groundwater 

protection responses presented in Table 4-2. Petroleum in groundwater from each well can be 

inferred to have come from upgradient sections of the Facility; however, the objective of the leak 

detection program is to verify and correct any leakage before the drinking water resource is 

impacted in order to minimize the chance that the responses presented in Table 4-2 are required. 

In the current configuration, three groundwater monitoring wells are in place within the lower 

access tunnel of the Facility. 

• RHMWOI is at the southwest edge of the Facility, between Tank 1 and the U.S. Navy 

well 2254-01. RHMWOI is considered to be hydraulically downgradient from the USTs 

and is the last sentry well before the U.S. Navy well 2254-01 infiltration gallery. 

RHMWOI will be the first point of detection for releases from Tanks 1 through 6. 

• RHMW02 is upgradient of Tank 6, approximately 600 feet upgradient of RHMWOI. It 

will be the first point of detection for Tanks 7 through 14. 

• RHMW03 is upgradient of Tank 14, approximately 800 feet upgradient from RHMW02 

and 600 feet downgradient from Tanks 19 and 20. It is the first point of detection for 

Tanks 15 through 20. 

The current groundwater monitoring program consists of quarterly sampling events, and results 

generally take two to three weeks from the time of sample collection. While this is a very 

important part of the confinnation process, it does not provide timely information required for 

protection of the groundwater resource. A detailed groundwater monitoring program has been 

developed for the Facility. This program is described in Section 4 of this report and in Appendix 

C(Groundwater Monitoring Field Sampling and Analysis Plan). 

3.3 Ongoing Groundwater Protection Activities 

1. Continue to conduct modified API 653 tank inspections and repairs for USTs (see 

proposed schedule in Table 3-1). This process is an extension of previous tank inspection 

and repair procedures that have been conducted to date. Tanks will continue to be 

inspected periodically at time intervals based on the results of the latest inspection (no 

greater than 20 years). 

2. Expand vapor monitoring program to all active Red Hill tanks. Currently seven active 

tanks are fitted with SVMPs. Install SVMPs in existing borings in the eleven remaining 

tanks as part of the overall fuel management program. The estimated cost to equip each 

tank with SVMPs is approximately $15,000, for a total cost of $165,000. An additional 
Final: Red Hill Bulk Fuel Storage Facility Groundwater Protection Plan Section: 3 

Date: January 2008 Page: 3-8 

$10,000 is estimated for field instrumentation for real-time measurement of fuel vapors. 

Coordinate vapor monitoring of Tanks to same quarterly cycle as the well water 

monitoring cycle. An estimate of the cost to sample and assess a complete round of 

SVMPs from 18 tanks is approximately $3,000. Integrate vapor monitoring into TIMP. 

3. Continue quarterly groundwater monitoring of three wells within the Facility and the U.S. 

Navy well 2254-01 as required by the HDOH Release Response Requirements. The 

annual cost for the groundwater monitoring is approximately $40,000. 

4. Implement a market survey to evaluate best available technologies for leak detection on 

large field constructed bulk fuel storage facilities, such as the Facility. This will be a 

multi-phased project involving both identification of available technologies and pilot 

testing of potential candidate technologies. The initial step will consist of traditional 

research (internet, vendor specifications/literature, previous research studies, third party 

certification evaluations, etc.) to identify potential technologies. The study will evaluate 

systems based on applicability to the following Red Hill parameters: 

o Proposed system leak detection sensitivity; 

o Operational challenges; Relative costs; and 

o Third parry certifications. 

5. Implement pilot studies of technologies that show promise on one or more of the tanks at 

Red Hill. Pilot testing will be done to evaluate the challenges associated with testing 

these tanks as well as the results versus cost to implement. 

3.3.1.1 Reporting Tank Inspections, Leaks, and Releases to HDOH 

Quarterly reports will continue to be provided to HDOH. These reports will contain the 

following: 

l. Monitoring results from quarterly groundwater sampling. 

2. Progress in developing a leak detection system for tank fluids and results from leak 

detection testing after the method is certified and accepted by FISC. 

3. Any other information regarding leaks or groundwater contamination. 

4. Notification that tanks were taken out-of-service (HDOH Form 1). 
Final: Red Hill Bulk Fuel Storage Facility Groundwater Protection Plan Section: 3 

Date: January 2008 Page: 3-9 

Table 3-1. Tank Inspcctions and Scheduling 

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RFS — Removed from Service (HDOH Form 1 submitted) 

Schedule may be changed based on the needs of the U.S. Navy 
Final: Red Hill Bulk Fuel Storage Facility Groundwater Protection Plan Section: 3 

Date:January 2008 Page:3-t0 

This page intentionally left blank. 
Final: Red Hill Bulk Fuel Storage Faciliry Groundwater Protection Plan Section: 4 

Date: January 2008 Page: 4-5 

Table 4-2. Responses to Groundwater Monitoring Results 

Results Category RHMW02, RHMWOI U.S. Navy 

RHMW03, or Pumping Well 

RHMW05 2254-01 

Results Category 1: Result abpve A A A,D,M,E 

detection limit but below drinking 

water EAL and trend for all 

compounds stable or decreasing 

Results Category 2: Trend for any A, B A, B A,B,C,D,E,F,G,K, 

compound increasing or drinking L,O 

water EAL exceeded 

Results Category 3: Result A,B,G,H,I,J A,B,E,G,H,I,J A,B,C,D,E,F,G,I,J, 

Between 1/lOX SSRBL and K,L,O 

SSRBL for benzene, or between 

1/2X SSRBL and SSRBL for TPH 

Results Category 4: Result A,C,D,E,F,I,J, A,C,D,E,F,I, A,C,D,E,F,G,I,J,K, 

Exceeding any SSRBL or K,M,N J,K,M,N,O L,O 

petroleum product measured or 

observed 

Specific Responses: 

A. Send quarterly reports to HDOH 

B. Begin program to determine the source of leak 

C. Notify HDOH verbally within 1 day and follow with written notification in 30 days 

D.Notify FISC Chain of Command within 1 day 

E. Send Type 1 Report (see box below) to HDOH 

F. Send Type 2 Report (see box below) to HDOH 

G. Increase monitoring frequency to once per month (if concentrations increasing) 

H. Notify HDOH verbally within 7 days and follow with written notitication in 30 days 

1. Remove sampling pumps (see Appendix C), measure product in pertinent wells with interface probe, 

re-install pumps if product is not detected. 

J. Immediately evaluate tanks for leaks 

K. Collect samples from nearby Halawa Deep Monitoring Well (2253-03) and OWDF MW01 

For permission to sample 2253-03, call DLNR Commission on Water Resource Management 

(808) 587-0214,DLNR.CWRM(@,Hawaii.gov 

L. Provide altemative water source at 2254-01 

M. Prepare for alternative water source at U.S. Navy Well 2254-01 

N. Re-measure for product every month with reports to HDOH 

O. Install additional monitoring well downgradient 
Final: Red Hill Bulk Fuel Storage Facility Groundwater Protection Plan Section: 4 

Date: January 2008 Page: 4-6 

Report Types 

HDOH Type I Report 

• Re-evaluate Tier 3 Risk Assessment/groundwater model results 

• Proposal to HDOH on a course of action 

HDOH Type 2 Report 

• Proposal for groundwater treatment 

If an anomalous result is suspected, the Navy may immediately resample a well or may have 

results validated by a third party before these results are accepted. These will be completed 

within 30 days from receipt of the original result. 

4.4 Responsibilities 

Navy Region Hawaii, Regional Envirotunental Department has the ultimate responsibility for 

implementation of this plan, including reporting to HDOH. Other responsibilities are shown in 

Table 4-3.