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 currently 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 avoid what could irreparable 

impacts to the residents of Oahu and its environmental quality. 

The lack of immediate implementation actions is of grave concern to residents of 

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

state and county agencies responsible for safeguarding 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 Statement of Work (SOW) 

to make the processes transparent to involve all 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 Administrative Record available to the Honolulu Board 

of Water Supply (BWS) and the public and to consent 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 the event there arises a conflict between the AOC and 

SOW requirements and those specified 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