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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 Consent 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) attached to the AOC allows the United States Department of Navy and the 

Defense Logistics Agency up to 22 years 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 groundwater 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 essential 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 contamination problem. In the early 2000s, the Navy already found petroleum stains in 

the bedrock under 19 of the 20 tanks, which 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 migration 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 proceed. 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. Furthermore, 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 signatory 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 water and (2) to pursue alternatives to take the place of 

contaminated water that is deemed prohibitive 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 increased costs must be borne by the party responsible 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, to 
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allow the Board of Water Supply and concerned citizens who 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 our 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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