1 

### Whalen, Marilyn

From: Michael Buck <mbuck@hawaii.rr.com>

Sent: Sunday, July 19, 2015 10:20 PM

To: RedHill

Cc: Ernest Lau; Roy.Hardy@hawaii.gov ; Ginny.Pressler@doh.hawaii.gov

Subject: Red Hill Bulk Fuel Storage Facility - Public Comments - Michael G. Buck

My name is Michael G. Buck and I current ly serve as a Commissioner on Hawaii's

Commission of Water Resources Management. I am writing to urge the United States

Environmental Protection Agency (EPA) and the Hawaii State Department of Health

(HDOH) to require the immediate implementation of corrective actions as part of the

Administrative Order on Consent (AOC) in the matter of the Red Hill bulk fuel storage

facility.

Oahu's groundwater and environment are held in trust for all of Oahu's people, and timely

corrective actions are needed now to the storage facility to av oid what could irreparable

impacts to the residents of O ahu and its environmental quality.

The lack of immediate implem entation actions is of grav e concern to residents of

communities immediately adjacent to the Red H ill Bulk Fuel Storage Facility, as well as for

state and county agencies responsible for sa feguarding Honolulu's water quality and keeping

the City's drinking water free of contaminants.

I urge the EPA and the HDOH to require the U.S. Navy and the Defense Logistics

Agency to implement upgrades and improvements already identified in past studies of

the Red Hill Bulk Fuel Storage Facility.

I also recommend that the parties involved in developing the A O C and St atement of Work (SOW)

to make the processes transparent to involve a ll stakeholders and the community. A critical first

step in this process would be for the EPA and the DOH to immediately make all studies and

reports identified in the Red Hill AOC Administra tive Record available to the Honolulu Board

of Water Supply (BWS) and the public and to c onsent to the BWS' request to make the

documents available for review on-line.

In addition, I urge the EPA and DOH to revise the AOC and SOW to require the U.S. Navy

and Defense Logistics Agency to comply with all existing and new federal underground

storage tank regulations and, in t he event there arises a conflict between the AOC and

SOW requirements and those spec ified in federal regulations, the federal regulations

and compliance with such regulations shall take precedence.

The processes outlined in the SOW are extremely protracted and lack specific due dates for completing each

process. The SOW also requires evaluating the feasibility of improvements that have already been identified. For

example, the 2008 Red Hill Repair Tank Options Study identified two alternatives for upgrading the tanks. The

study consultant recommended to the Navy to authorize a single tank repair project to start the program as a

means of proving up the concepts and confirming overall cost validity. According to the study report, the same

consultant also performed a similar study in 1998 to develop possible repair options for Tank 19. According to

the report, the 1998 study was performed due to tank integrity issues, environmental concerns, lack of leak

detection capability, and lack of secondary containment at Red Hill. There should be no need to do a two

‐ year

study to examine tank improvements when the assessment has already been done.2 As written, the processes in the SOW appear to enable the Navy to continue the operations of Red Hill as done

in the past. While there are time frames for executing the work elements, the language lacks compliance with

specific due dates to ensure steady progress. More studies will not protect Oahu's groundwater and

environment. Action is needed now, before irreparable damage occurs.

Thank you for the opportunity to provide comments.



### Michael G. Buck

-- Michael G. Buck

41-665 Kumuhau Street

Waimanalo, HI 96795

(808) 259-8946

mbuck@hawaii.rr.com