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### Whalen, Marilyn

From: Conroyrealtyllc@aol.com
Sent: Tuesday, June 30, 2015 5:06 PM
To: RedHill Subject: Water Contamination Problem Re Red Hill Underground Fuel Tanks

Follow Up Flag: Follow up Flag Status: Flagged

TO: Environmental Protection Agency ( RedHill@epa.gov ) FROM: LINDA CONROY (Concerned Citizen) SUBJECT: Comments Regarding Administrative Order on Consen t In the Matter of Red Hill Bulk Fuel Storage Facility
DATE: June, 30, 2015
We STRONGLY OPPOSE the subject Administrative Order on Consent (AOC) for the following reasons: 1. The Statement of Work (SOW) a ttached to the AOC allows the United States Department of Navy and the Defense Logistics Agency up to 22 year s from the effective date of the AOC to upgrade the 20 aging Red Hill fuel
tank structures. This timeframe is outrageously too long and needs to be accelerated , considering that the

structures: a. Were built in the 1940s and so now are already 72 - 75 years old, b. Are already corroding and known to have leaked since as far back as 1947 (around 68 years ago!) and as recently as 2014, c. Have already contaminated the ground water and rocks underneath the tanks, and d. Will likely cause more serious contamination of our groundwater within 22 years, when the tanks will be around 100 years old. Catastrophic contamination is even possible from an event such as an earthquake, which could very well occur anytime in the next 22 years. The people of Oahu have waited long enough and cannot afford to wait another 22 years for action to finally be completed, where clean drinking water is ess ential to our very survival! We feel that a timeline for complete replacement of the tanks with better double-lined ones, by no more than 5 years or less, would be more
reasonable.
2. We are astounded and incensed that there is no sense of urgency reflected in the AOC and SOW to address even the existing, known contaminatio n problem. In the early 2000s, the Navy already found petroleum stains in the bedrock under 19 of the 20 tanks, wh ich indicated leaking. In 2014, there was a 27,000 gallon leak of jet fuel from one of the tanks. As stated by the Board of Water Supply in their testimony dated June 18, 2015, " the AOC
needs to require clean-up of the contamination that is presently in the groundwater and rocks underneath the tanks to reduce the amount available for migrat ion to those parts of the aquifer that are still
uncontaminated ." Immediate action must be required. Why must we wait for the contamination to worsen before taking action, when it will be too late?
3. The AOC should not provide for studies and pilot programs of unknown duration to be conducted before further remediation action can pr oceed. Historically, bureaucratic government studies and pilots invariably result in lengthy, years-long delays and ultimately add to overall costs for taxpayers. The Board of Water Supply
testified that the AOC administrative record indicates that past studies were already done and identified potential improvements which have yet to be acted upon. Furthe rmore, it appears that the Navy already had similar experiences with upgrading tank structures in 1998 and 2008, which must have been preceded by studies (See SOW, page 1). Therefore, the AOC should first state whether or not such past studies were, in fact, previously done and why recommendations presented in those studies were not implemented. 4. While the Department of Health would be a signator y for the AOC, would that then bind the Board of Water Supply and its customers to the AOC as well, and preclude the parties from seeking reimbursement for expenses that may be incurred: (1) to clean-up contaminated wate r and (2) to pursue alternatives to take the place of contaminated water that is deemed prohibi tive to treat? If so, then we feel that the Board of Water Supply needs to be a party to the AOC discussions/development to represent the Oahu community's interests. In addition, federal reimbursement of expenses for clean-up and water source alternatives need to be required in the AOC . Responsibility for incr eased costs must be borne by the party res ponsible for causing the problem, and not by innocent Oahu citizens. Finally, we object to the short 30-day time period for your agency to receive comments on such a critical matter. As pointed out by the Board of Water Supply in their testimony dated June 18, 2015, not all information was made available until midway through the comment period. Therefore, we urge that an extension be granted, until July 31, 2015, to2 allow the Board of Water Supply and concerned citizens w ho are only now becoming aware of the issue to provide comments, and help reassure that this is a meaningful, transparent process. We respectfully ask that you consider ou r comments and recommendations. Thank you.

Linda M. Conroy, (B), REALTOR ®, GRI, SRES 

# Conroy Realty, LLC

Office Address: 1806 S. King St. Suite 31 Honolulu, Hawaii 96826 Mailing Address: PO Box 22567 Honolulu, Hawaii 96823-2567 Telephone: Office: (808) 955-5282 Fax: (808) 525-6413 Cell: (808) 371-1204
E-Mail: Conroyrealtyllc@aol.com

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