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how the implementations are to be evaluated, and how the Parties are to communicate and 

resolve disputes. The SOW describes tasks and requirements that the Navy and DLA must 

complete to comply with the AOC, specifically, to deploy the best available practicable 

technology (BAPT) to prevent fuel releases, to develop a better understanding of the 

hydrogeology of the area surrounding the Facility, and to conduct an assessment of the risk to 

the groundwater resources that is posed by the Facility (US EPA and Hawaii DOH, 2015b). 

The BWS cannot support the AOC or SOW as currently written. Our evaluation has identified 

critical issues in the proposed documents that render the AOC and SOW “inappropriate, 

improper, or inadequate,” per AOC Section 23 (a). We strongly recommend that the documents 

be revised to: 

1. Ensure appropriate characterization and remediation of past sub-surface contaminants in 

the vadose zone and saturated zone in concert with installation of a well-designed 

monitoring well network. 

2. Rehabilitate the Facility tanks to arrest the decades of corrosion to the tanks’ thin steel 

plates and so eliminate the threat to our drinking water from new fuel releases. 

3. Shorten the time frames to complete tank and pipeline rehabilitation, remediate past fuel 

releases, and comply with regulations. 

4. Include proper consultation and participation by the major stakeholders and the public. 

5. The AOC and SOW need to require full (without censoring) disclosure and access to all 

records, data, and studies about fuel leaks at the Facility over its history. 

6. Appropriately follow the most stringent applicable regulatory standards and guidelines. 

7. Commit the necessary funding to carry out this work and quickly put in place the 

necessary protections for our drinking water supply. 

The proposed AOC and SOW do not recognize that the Waimalu and Moanalua aquifers are part 

of the US EPA-designated Sole Source Aquifer called the Southern Oahu Basal Aquifer. This 

Sole Source Aquifer, which was designated in 1987, is the primary groundwater resource for the 

majority of the nearly one million residents and visitors on the island of Oahu. It is vital that the 

Parties base all of their decisions and actions for the Facility on the fact that the Southern Oahu 

Basal Aquifer is the only one of its kind on the island and there are no cost-effective water supply 

alternatives. Currently, the BWS wells nearest to the Facility appear to show no contamination 

from the Facility. 

The BWS strongly recommends that the proposed AOC and SOW be revised as described in our 

comments below to properly safeguard our drinking water supply from past and future releases 

from the Facility’s aging and corroding fuel tanks. BWS is ready to work with the Parties to 

expedite resolution of the important problems described below and thereby expedite mitigation of 

the risk posed by the Facility to our groundwater supply. 
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Page 3 

Our comments on the AOC are presented in Section 2, and our comments on the SOW are 

given in Section 3. Each of these sections begins with a summary of the most important 

comments, followed by individual detailed comments. Section 4 lists the references cited. 

2.0 AOC COMMENTS 

2.1 AOC Comment Summary 

1. The AOC should be revised to emphasize the fact that the Facility in its current state 

poses a serious risk to the Waimalu and Moanalua aquifers that underlie the Facility and 

to the Halawa Shaft and Moanalua Wells, which are the public water supply wells nearest 

to the Facility. The Halawa Shaft and Moanalua Wells provide 25% of the drinking water 

to our metropolitan Honolulu water system, which serves approximately 400,000 

residents from Moanalua to Hawaii Kai. The AOC should be revised to state that the 

Facility poses a serious risk to the aquifers and metropolitan Honolulu water system and 

state the population size that is dependent on the Halawa Shaft and Moanalua Wells. It 

should also be revised to emphasize the risk the Facility poses to the Navy’s Red Hill 

Shaft which provides 20% of the drinking water for Joint Base Pearl Harbor-Hickam. 

2. The AOC ignores the fact that the Facility is located within the boundaries of the 

Southern Oahu Basal Aquifer, which was designated by US EPA Region 9 in 1987 as a 

Sole Source Aquifer under the authority of Section 1424(e) of the Safe Drinking Water 

Act (Federal Register Citation 52 FR 45496 11/30/1987). The Southern Oahu Basal 

Aquifer encompasses the Waimalu and Moanalua aquifers as well as the Facility. The 

Sole Source Aquifer designation requires appropriate assessment of potential impacts 

from all federally funded projects on the Southern Oahu Basal Aquifer, thus the AOC 

should be revised to incorporate the Sole Source Aquifer regulatory and procedural 

requirements. 

3. The AOC and its SOW should be revised to clearly state that the Parties will determine 

the current location and appropriately characterize the fate of the approximately 27,000 

gallons of fuel released in January 2014 in a timely manner, and that the Parties will then 

proceed with remediation of the light non-aqueous phase liquid (LNAPL), sorbed, and 

dissolved-phase contamination caused by that fuel release as quickly as possible. 

4. The AOC unacceptably limits participation by major stakeholders, most notably the BWS, 

in scoping, review, and decision-making activities, as well as in the development of the 

initial and revised AOC and SOW documents. This should be resolved by including 

representatives from the major stakeholders in all scoping, review, and decision-making 

activities. Major stakeholders include, but are not limited to, the BWS, the City and 

County of Honolulu, and the Commission on Water Resource Management (Hawaii 

Department of Land and Natural Resources). 

5. The AOC lacks public transparency by limiting communication with and participation by 

the public at regular intervals, which are routinely included as part of remediation 

planning at other major contaminated Department of Defense (DOD) sites. The AOC 

should be revised to require regular public meetings in which the Parties, together with 
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July 20, 2015 

Page 4 

major stakeholders, will present recent findings, discuss next steps, and hold open 

question-and-answer periods for public participation. 

6. The AOC should be revised to require that all work performed by the Navy and DLA 

under the AOC meets the most stringent and protective regulations, including the newly 

updated UST regulations from US EPA (US EPA, 2015). The AOC should be revised to 

require that the work performed by the Navy and DLA under the AOC always achieves 

the highest degree of protection of the vadose zone underlying the Facility tanks, the 

underlying Waimalu and Moanalua aquifers (part of the greater Southern Oahu Basal 

Sole Source Aquifer), all water supplies, and the surrounding environment. Under no 

circumstances should future agreements negotiated by the Parties reduce these 

protections under the AOC. We strongly recommend that the Hawaii DOH adopt the 

newly updated US EPA UST regulations as part of the Hawaii UST program without 

delay 

7. According to the AOC Administrative Record, the Navy and DLA have not implemented 

technologies that have been available since the 1980s to slow the rate of tank corrosion 

and reduce leakage at the Facility. Damage to the field-constructed USTs at Red Hill 

from corrosion and fatigue is progressive and accumulates over time. The Red Hill tanks 

have been in service for more than 70 years and have experienced both internal and 

external corrosion (Anonymous, Undated; Weston, 2007a; Weston, 2007b). These tanks 

have never been cathodically protected; consequently, the corrosion continues unabated, 

which means that the frequency and magnitude of fuel releases from the tanks will 

continue to increase. Given that the Navy and DLA must soon act to bring the Facility 

tanks and associated piping in compliance with the newly updated EPA UST regulations 

(US EPA, 2015), the AOC should be revised to clearly state the steps and timeline for 

achieving compliance. 

The AOC revisions should clearly state that the Facility tanks and pipelines will receive 

leak detection and secondary containment (with cathodic protection) upgrades required 

under the newly updated US EPA UST regulations within the next several years or 

shortest time possible and state the process and timeline for achieving these upgrades. 

Installing a tank-within-a-tank or composite tank lining will greatly reduce the frequency 

and magnitude of fuel releases from the Facility tanks. Prior comprehensive, governmentfunded engineering evaluations commissioned by the Navy or DLA have already yielded 

various options for repairing the Red Hill tanks, e.g., Enterprise Engineering Inc. (2008a), 

including options that may provide long-term, i.e., 40-year, life extension. This report 

estimated that the recommended repair options would require less than 3.5 years to 

implement for all tanks (Enterprise Engineering Inc., 2008a). 

8. The Navy and DLA unacceptably restrict access to information about fuel releases and 

other environmental impacts from the Facility. Out of eight Freedom of Information Act 

(FOIA) requests filed with the Navy by BWS between 10 June 2014 and 19 May 2015, 

only two have been fulfilled (see comment # 26 in Section 2.2 below). The AOC should 

be revised to require full disclosure of all Facility records, studies, reports, fuel inventory 

records (and tank gauger log books), and documents and data about the nature, 

characterization, and remediation of all fuel releases since the Facility tanks and 

pipelines went into service, and to provide all studies and data on alternative tank 
BWS AOC/SOC Comments 

July 20, 2015 

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options, current corrosion and corrosion rates, pipeline leaks, leak detection, and 

corrosion protection. The AOC should be revised to state that major stakeholders will 

also be given immediate access to data from work activities, especially with regard to 

groundwater and other sub-surface environmental characterization and monitoring. 

9. The timelines for SOW task planning and completion, approval of deliverables, funding of 

work, and dispute resolution are too long and are poorly constrained. The dispute 

resolution process has no apparent limit on duration, potentially continuing for many 

months or more, thereby delaying implementation of the needed protections for our 

drinking water supply (see comment #30 in Section 2.2 and Figure 1A and 1B). The 

dispute resolution section (AOC Section 14) should be removed from the AOC and 

replaced with dispute resolution processes found in the applicable regulations. The 

maximum amount of time for approval of deliverables and funding of work should be 

specified explicitly. The Navy and DLA should promptly comply with all appropriate 

regulations, as would be required of any other regulated person or party. 

10. The current AOC does not fully protect Honolulu’s water supply or the environment 

because its work activities and schedule are limited by poorly defined funding constraints. 

The AOC activities should be given highest priority by immediately dedicating the 

necessary funding to address this issue. Section 12 (Funding of Work) of the AOC should 

be revised to state that the US EPA and Hawaii DOH require the Navy and DLA to 

arrange necessary funding within no more than six months from the signing of the AOC 

for five important sets of activities: (1) upgrading the Facility tanks to meet US EPA 

updated UST regulations, (2) tank testing and rehabilitation/closure, (3) characterization 

of the full nature and extent of the 2014 fuel release within the sub-surface, 

(4) participation by major stakeholders in planning and decision making, and (5) regular 

public meetings to educate residents by sharing findings and decisions. 

If the funding required to carry out the necessary repair and upgrade activities is not 

available now, we respectfully request that the Navy and DLA actively start the budget 

process to procure such funding. Funding specifics for the various options to extend the 

operational life of the Facility tanks have generally been redacted from the documents 

that were made available. The AOC should be revised to state how much funding is 

currently available for the AOC and SOW tasks and how much more is estimated to be 

required. The funding commitment should be sufficient to complete the activities within 

five years (or a similarly short time period) after signing of the AOC and to enable 

preservation and continuity of institutional knowledge, responsibility, and accountability to 

all successors of the Navy and DLA in perpetuity or until all fuel releases are remediated. 

Section 12.c (Funding of Work) of the AOC should also be revised to restrict re-scoping 

or schedule delays of work activities due to lack of sufficient funding to no more than 

three months, and if unmet, the Hawaii DOH and US EPA will take appropriate actions 

against the Navy and DLA. 

11. The potential for catastrophic environmental and economic damages caused by fuel 

releases from one or more of the 20 field-constructed tanks at Red Hill is quite high, 

given a) the large (fuel) volume and age of the tanks, b) acknowledged instances of 

through-wall, corrosion-induced holes (Enterprise Engineering Inc., 2008a; Whitacre, 

2005; Weston, 2007a; Whitacre, 2005; WillBros, 2012), and c) general uncertainty about 
BWS AOC/SOC Comments 

July 20, 2015 

Page 6 

the structural integrity of the tanks and piping. The cost of immediate action to rehabilitate 

the Facility tanks and characterize and remediate the subsurface contamination will be 

far less than the cost required to remediate another large fuel release as well as 

rehabilitate the tanks. US EPA argued that upgrading large field-constructed tanks 

(including those at Red Hill) can lead to “substantial reductions in remediation costs and 

public exposure” caused by large-scale fuel releases from these previously deferred large 

field-constructed tanks (Industrial Economics, 2015). 

2.2 AOC Detailed Comments 

1. Page 2, Introduction Paragraph 1(b): The words “to take steps” should be removed from 

the sentence “The primary objectives of this AOC are to take steps to ensure that the 

groundwater resource in the vicinity of the Facility is protected and to ensure that the 

Facility is operated and maintained in an environmentally protective manner.” The original 

sentence improperly allows the actions to fall short of ensuring the aquifer is protected, 

because “steps” could be construed as taking actions that could only begin to prevent 

contamination rather than fully prevent contamination. 

2. Page 2, Introduction Paragraph 1(c): “Navy and DLA’s participation in this AOC shall not 

constitute or be construed as an admission of liability.” Please remove. Under US EPA 

and Hawaii regulations, the Navy and DLA are “operators” of the Facility and therefore 

liable for responding to reported releases of regulated substances from USTs or UST 

systems (Hawaii Revised Statutes [HRS] §342L-1; Hawaii Administrative Rules [HAR] 

Subchapter 7 §11-281-71; Code of Federal Regulations (CFR) Title 40, Chapter I, 

Subchapter I, Part 280.12). 

3. Page 2, Introduction Paragraph 1(d): The statement that the AOC is “fair, reasonable, 

protective of human health and the environment, and is in the public interest” should be 

deleted. This statement cannot be justified because it only reflects the opinions of the 

Parties and not the opinions of the major stakeholders, including the BWS. All major 

stakeholders should be the primary arbiters of whether the AOC is fair, reasonable, and 

in the public interest because the major stakeholders will have to deal with the 

consequences of the AOC and SOW. 

4. Page 2, Jurisdiction Paragraph 2(a) and 2(b): Revise to acknowledge that the AOC 

should conform to the requirements set forth under the Hawaii DOH UST program, the 

US EPA Resource Conservation and Recovery Act (RCRA), and the authority of Section 

1424(e) of the Safe Drinking Water Act (Federal Register Citation 52 FR 45496 

11/30/1987). The Southern Oahu Basal Aquifer, which includes the Waimalu and 

Moanalua aquifers as well as the area surrounding the Facility, was designated as a Sole 

Source Aquifer by US EPA in 1987. Federally funded activities within a sole source 

aquifer can be brought under review by US EPA if those activities could contaminate the 

groundwater (Public Law 93-523, 42 U.S.C. 300 et seq Section 1424e). 

5. Page 2, AOC Section 2(c): According to the AOC, the Navy and DLA agree to undertake 

and complete all actions required by the terms and conditions of the AOC, and the AOC 

is binding upon the parties and their successors. The Navy and DLA are also jointly and 
BWS AOC/SOC Comments 

July 20, 2015 

Page 7 

severally liable under this AOC. However, the AOC also states that the participation of 

the Navy and DLA in this AOC shall not constitute or be construed as an admission of 

liability. The AOC further states that the Navy and DLA neither admit nor deny the factual 

allegations and legal conclusions set forth in the AOC under the AOC’s Findings of Fact 

and Conclusions of Law. This section appears to suggest that the Navy and DLA are not 

responsible or accountable for the past fuel releases from Red Hill as described in Navy 

reports and measurements that show the presence of fuel contaminants in the rocks and 

groundwater underneath the Facility or for future fuel releases. 

This section of the AOC should be revised to clearly state that the Navy and DLA are 

responsible for past fuel releases, will be responsible for future fuel releases, and are 

obligated to clean up this contamination and to improve the tanks now to protect the 

subsurface, including the vadose zone and the Southern Oahu Basal Aquifer, and the 

environment. 

The Navy and DLA, as the owner and/or operator of the Facility, are subject to 

requirements regarding response and remediation in HRS Chapter 342L and HAR 

Chapter 11-281 (40 CFR § 280 Subpart E) and are subject to orders which may be 

necessary to protect the health of persons who are or may be users of a public water 

system as provided in HRS Chapter 340E and the rules promulgated pursuant thereto 

including, but not limited to, HAR §11-19 and 11-20, and are subject to administrative 

orders and civil actions which are necessary to address discharges to state waters as 

provided for in HRS Chapter 342D. 

Additionally the ownership and operation of the Facility, which is federally owned and 

operated, is subject to “all administrative orders and all civil and administrative penalties 

or fines, regardless of whether such penalties or fines are punitive or coercive in nature 

or are imposed for isolated, intermittent, or continuing violations in the same manner and 

to the same extent as any person is subject to such requirements,” as codified in 

42 United States Code (U.S.C.) § 6991f. 

6. Page 4, Paragraph 4(h): Findings of Fact: The underground storage tanks at Red Hill are 

field-constructed USTs and were formerly exempt from many Hawaii DOH and US EPA 

requirements (HAR Subchapter 1 §11-281-01(b)(2) and CFR Title 40, Chapter I, 

Subchapter I, Part 280.10(c)(5)). The AOC and SOW should be revised to state that the 

US EPA 1988 UST regulations have been updated (US EPA, 2015) and the exemptions 

for field-constructed USTs have been removed. 

a. The AOC and SOW should be revised to implement the newly updated US EPA 

regulations for field-constructed USTs, and to provide the timeline for completing 

these and any additional modifications to field-constructed USTs added by the 

Hawaii DOH. 

b. In addition, the AOC should dictate that the Parties agree that the Navy and DLA 

will be required to adhere to the most stringent and current US EPA regulations in 

anticipation of the Hawaii DOH incorporating these same new requirements into 

the Hawaii DOH UST program. 
BWS AOC/SOC Comments 

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Page 8 

7. Recommend adding the US EPA Sole Source Aquifer provisions (Public Law 93-523, 42 

U.S.C. 300 et seq Section 1424e) that govern activities at the federally funded Red Hill 

Facility to Page 2, Jurisdiction Paragraph 2(b), and to Page 5, Findings of Fact 

Paragraph 4(k). The AOC and SOW should be further amended to apply and enforce the 

regulations and processes stipulated under the Sole Source Aquifer provisions and 

Federal Register Citation 52 FR 45496 11/30/1987. 

8. Page 5, Paragraphs 4(k)-4(n): Findings of Fact: This item should be revised to include 

important information about the Southern Oahu Basal Aquifer groundwater resources. 

The information shall include, but not be limited to, the following: 

a. A statement explaining that the Waimalu and Moanalua Aquifers are part of the 

US EPA-designated Sole Source Aquifer called the Southern Oahu Basal Aquifer. 

b. The location of the Waimalu and Moanalua Aquifers relative to Red Hill. 

c. The distance from the Facility to Halawa Shaft and to the BWS Moanalua Wells 

(note that there are three wells, not one well). 

d. The population served by the Halawa Shaft and Moanalua Wells. 

e. The distance from the Facility to other water supply wells and shafts. 

f. The population served by the Navy’s Red Hill Well and Water Plant. 

9. Page 5, Paragraph 4(r): Findings of Fact: The AOC states that approximately 

27,000 gallons of fuel were released from Tank #5. Please revise to state the type of fuel 

released and the investigative analyses and studies done by the Navy and DLA to 

determine the basis and uncertainty for the estimated amount of leaked fuel. Additionally, 

this section states that the immediate action taken once the release was discovered was 

to empty the fuel from Tank #5. Per Hawaii DOH and US EPA regulations, were any 

additional steps taken over the five-day period to empty Tank #5 of its contents to prevent 

the further release of regulated substance to the environment at Red Hill? When a 

release is discovered, immediate action must be taken to prevent any further release of 

regulated substance into the environment (HAR Subchapter 7 §11-281-72(3); HRS 

§342L-35; and CFR Title 40, Chapter I, Subchapter I, Subpart F Part 280.61(b)). Please 

document any additional actions taken to prevent any further release in this paragraph of 

the AOC. Please revise the AOC to state whether Tank #5 has been repaired and is 

currently in use. 

10. Page 5, Paragraph 4(t): Findings of Fact: The AOC states that following the January 

2014 release from Tank #5, the Navy increased the frequency of monitoring and 

performed additional monitoring of Navy Well 2254-01. Per Hawaii DOH and US EPA 

requirements, it is imperative to carry out appropriate investigations to determine the 

presence of free product and begin free product removal (HAR Subchapter 7 §11-281-

74(5) and CFR Title 40, Chapter I, Subchapter I, Subpart F Part 280.62(a)(5)). Please 

describe the steps that will be taken to find and recover the free product remaining from 

the fuel release documented by the Navy and DLA in 2014. 

11. Page 5, Paragraph 4(s): Findings of Fact: The fate of the fuels that have been previously 

released into the environment on numerous occasions (Table 1 below; see also section 
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3.1.1 on pages 3-2 to 3-5 in TEC, 2008) should be required to be determined as part of 

the AOC. There is no specific mention within the AOC of any plan to conduct a “forensic” 

historical assessment of total potential fuel releases, which correspond to potential future 

contamination sources to the Waimalu and Moanalua Aquifers from this Facility. 

12. Pages 5-6, Paragraph 4(t): Findings of Fact: The AOC states that no impact from 

release(s) has been measured in Navy Well 2254-01 and that groundwater results are in 

compliance with state and federal Maximum Contaminant Levels (MCLs). 

a. Please clarify which regulatory standards are used when evaluating groundwater 

results. The groundwater monitoring reports for the Facility compare groundwater 

results against Hawaii DOH Environmental Action Levels (EAL) for Drinking Water 

Toxicity standards (ESI, 2015a; ESI, 2015b). 

b. Clarification is needed regarding the definition of “impact.” Does this mean 

petroleum hydrocarbons were not detected above laboratory reporting limits or 

limits of detection, above MCLs, above Hawaii DOH EALs, or another definition? 

The groundwater sample collected at Navy Well 2254-01 in November 2014 had 

a concentration of total petroleum hydrocarbon, diesel (TPH-d), detected above 

the laboratory reporting limit but below the Hawaii DOH EAL (ESI, 2015b); 

therefore, impacts have been observed after the January 2014 release. 

c. The AOC document should state that even though minimal impact has been 

measured in this well, there is inadequate characterization of the nature (LNAPL, 

sorbed, dissolved phases) and extent of the released fuel; therefore, additional 

wells are required to determine the impact to the underlying aquifer. 

13. Page 5, Paragraph (k): Findings of Fact: The text should read “The Waimalu and 

Moanalua Aquifers...are located beneath the Facility....” 

14. Page 5, Paragraph (n): Findings of Fact: The text should read “The BWS’s Moanalua 

Wells, which are part of a public water system....” 

15. Page 5, Paragraph (t): Findings of Fact: When will the Navy’s Groundwater Protection 

Plan be “updated in accordance with the SOW”? 

16. Page 7, Paragraph 5(b): EPA Conclusions of Law and Determinations: Add the 

requirements for characterization, remediation, and prevention of future fuel releases 

from this contamination site under the US EPA Sole Source Aquifer provisions. 

17. Page 7, Paragraph 5(b)(ii): EPA Conclusions of Law and Determinations: The AOC 

states that US EPA has determined that any fuel released from the Facility would be a 

“solid waste” within the meaning of Section 1004(27) of RCRA, 42 U.S.C. § 6903(27). 

Revise the text to state that the released fuel is also defined as a “release” (CFR Title 40, 

Chapter I, Subchapter I, Part 280.12 and HRS §342L-1). 

18. Page 9, Paragraph 7: Regulatory Agencies Approval of Deliverables: The AOC does not 

allow appropriate participation and review of AOC actions by non-”Party” stakeholders, 

i.e., BWS and others, in our view. The AOC should be revised to allow all major 

stakeholders to participate in developing work plans, evaluating data and other 

deliverables, and decision making. The Parties should seek and consider input from the 
BWS AOC/SOC Comments 

July 20, 2015 

Page 10 

major stakeholders and resolve differences through discussion and negotiation prior to 

document approval or final decision-making. Given that the BWS is acknowledged as a 

subject matter expert in the SOW and a major stakeholder, this constitutes a gross 

oversight in the review process. Active stakeholder participation in review and decisionmaking processes is a key factor at other DOD contamination sites affecting the water 

supply for a major metropolitan area, such as the Kirtland Air Force Base Bulk Fuels 

Facility (KAFB BFF) fuel spill project. This lack of public transparency and openness in 

the proposed AOC and SOW processes should be corrected before the AOC can be 

approved. 

19. Page 11, Paragraph 8(a)(i): The AOC should not permit modifications of the compliance 

date stipulated in the SOW that delay the implementation of BAPT. 

20. Page 9, Paragraph 7(a): Regulatory Agencies Approval of Deliverables: Page 9, 

Paragraph (a): This paragraph discusses the submittal of deliverables to the regulatory 

agencies and discusses due dates to be specified by the AOC. It is appropriate to state in 

this paragraph that the deliverable due dates will adhere to the schedule set forth for 

corrective action plans as provided in HAR Title 11, Subchapter 7 §11-281-79(b). 

Because of the threat to groundwater, a corrective action plan was required to be 

submitted within 30 days of the January 2014 release. If a corrective action plan has 

been submitted, please provide an unredacted copy to BWS and the public. Additionally, 

the existence of the corrective action plan and the corrective action plan objectives 

should be discussed in AOC Section 4.0 FINDINGS OF FACT.

21. Page 12, Paragraph (ii): Does discovery of additional fuel leaks constitute “immediate 

threat to human health or the environment”? If so, what immediate actions would the 

Navy and/or DLA take? If not, why not? Is there a minimum amount of fuel leak that 

would constitute an immediate threat? 

22. Page 12, Paragraph 8(b)(iii): Modification of the SOW and this AOC and Additional Work: 

The AOC should be revised so that it conforms to the most stringent and current state 

and federal standards when changes have been made to applicable regulations, such as 

US EPA’s newly updated UST regulations. 

23. Page 14, Paragraph 10(a)(i): Sampling, Access, and Document Availability: No provision 

is made to allow BWS (or other stakeholders) access to raw data and information 

generated by this process. Given the very lengthy period (potentially years) between data 

collection, analysis, and public release of report documents as outlined in the SOW, 

major stakeholders should have immediate access to this data and information. Such 

data sharing is very common in the USA; examples include California’s statewide 

GeoTracker system and the Kirtland Air Force Base (KAFB) Bulk Fuels Facility (BFF) fuel 

spill project. 

24. Page 14, Paragraph 10(a)(i): What documentation, if any, will be available to timestamp 

the Navy and DLA’s initial receipt of analytical data? Who at the Navy and DLA are the 

contacts for initial receipt of these data? 

25. Page 17, Paragraph (d): Define the “burden of proof” that the Navy or DLA must meet to 

withhold records from disclosure via the AOC. Revise the AOC to begin immediate public 
BWS AOC/SOC Comments 

July 20, 2015 

Page 11 

disclosure of all documents relating to tank inspection and maintenance, as well as 

historical fuel leak records. 

26. Page 17, Paragraph 10(d): Sampling, Access, and Document Availability: BWS and other 

major stakeholders should have immediate access to documents, data, and records 

without having to wait (potentially years) for them to be released to the public. 

It is the BWS’s experience that the Navy and DLA have improperly restricted access to 

information about fuel releases and other environmental impacts from the Facility. For 

example, out of eight FOIA requests filed with the Navy by BWS between 10 June 2014 

and 19 May 2015, only two have been fulfilled (see Table 2 below). The AOC and SOW 

should be revised to explicitly state that these restrictions will be removed and that there 

will be full disclosure of all Facility records, studies, reports, documents about the nature, 

characterization, and remediation of all fuel releases since the Facility tanks and 

pipelines went into service, and provision of all studies and data on alternative tank 

options, corrosion and corrosion rates, pipeline leaks, leak detection, and corrosion 

protection. 

27. Page 18, Paragraph 12(c): Funding of the Work: The lack of a funding commitment is a 

serious concern in the current AOC. The Navy and DLA should commit all necessary 

funding to support the protection of the vadose zone and Sole Source Aquifer 

surrounding the Facility from past and future fuel releases, just as the Air Force did last 

year for the KAFB BFF fuel spill. The AOC should state to what extent cost-saving 

measures or reworking the scope will affect the acquisition of sound scientific data and 

timely rehabilitation of the Facility. The BWS and other stakeholders should be included 

in any meeting involving potential changes/modifications to work plans. 

28. Page 18, Paragraph (c): Do “rescoping measures” include reducing the total amount of 

work, or staggering the work schedule to fit annual budgets? If rescoping includes 

reducing the number of work activities or the amount of work, this implies that AOC tasks 

can be eliminated solely due to budgetary constraints. Such rescoping is not acceptable, 

and the AOC should be revised to ensure that all work activities are completely carried 

out in a timely manner. 

29. Page 18, Paragraphs (b) and (c): Do these Paragraphs imply that the funding discussions 

are outside the Dispute Resolution Process outlined in Part 14 of the AOC? Can Hawaii 

DOH or US EPA take action against the Navy or DLA outside of the Dispute Resolution 

Process if it has to do with available funding? Under what circumstances does the AOC 

become null and void? 

30. Page 19, Paragraphs (a) through (g): Dispute Resolution: The dispute resolution process 

has no apparent limit on duration, potentially continuing for many months or more, 

thereby delaying implementation of the needed protections for our drinking water supply 

Figure 1A and 1B below is a flow chart that illustrates the length and complexity of the 

combination of work planning and approval and dispute resolution processes, which, 

when taken together, can lead to many months or years of delays in completing the SOW 

tasks. We recommend that the dispute resolution section (AOC Section 14) be removed 

from the AOC and replaced with dispute resolution processes found in the applicable 

regulations. The AOC and SOW should be revised to explicitly specify the maximum 
BWS AOC/SOC Comments 

July 20, 2015 

Page 12 

amount of time for planning and implementation of tasks, approval of deliverables, and 

funding of work. The AOC should state that the Navy and DLA should promptly comply 

with all appropriate regulations, as would be required of any other regulated person or 

party. 

31. Page 23, Paragraph 16(b): The first sentence reads “Subject to the Dispute Resolution 

Provisions...nothing in this AOC shall preclude the State of Hawaii from seeking to 

enforce...” What if Hawaii DOH does not agree with a Dispute Resolution decision, 

which, if significant enough, may be elevated to the US EPA Assistant Administrator for a 

final decision? What recourse does Hawaii DOH have, if any? 

32. Page 26, Paragraphs 19(a) and 19(b): Define “satisfactory performance by Navy and 

DLA of their obligations under this AOC” and the role of timeframes, quality of work, and 

other metrics. 

33. Page 27, Paragraph 21(a): The period of all AOC-related records retention should be 

longer than 10 years after the AOC is terminated. Legal counsel should verify recordretention requirements, but we believe US EPA Superfund records have different 

retention schedules depending on the type of record. For example, we believe lab data 

are kept at least 30 years after cost recovery actions are completed or site closure is 

achieved. 

34. Page 27, Paragraph 23(a): Does the term “settlement” carry any legal ramifications? 

Does this imply no other liability can be applied to the Navy or DLA during the term of the 

AOC? 

35. Page 26, Paragraph 18(d): Reservation of Rights: This section states “EPA or DOH’s

review.” The “or” needs to be replaced with “and”; per Paragraph 7(b), Page 9, it is 

required that both regulatory agencies approve of any deliverable required pursuant to 

the AOC. 

3.0 SOW COMMENTS 

3.1 Comment Summary for SOW 

1. The SOW should be revised to clearly state that the Parties will determine the current 

location and appropriately characterize the fate of the approximately 27,000 gallons of 

fuel released in January 2014, and that the Parties will proceed with remediation of the 

LNAPL, sorbed, and dissolved-phase contamination caused by that fuel in the vadose 

zone and the Waimalu and Moanalua aquifers. 

2. The SOW should be revised to account for the Sole Source Aquifer regulations. The 

Southern Oahu Basal Aquifer is designated by the US EPA as a Sole Source Aquifer and 

encompasses the Waimalu and Moanalua aquifers and the Facility. This designation 

requires appropriate assessment from all federally funded projects on the Southern Oahu 

Basal Aquifer; thus the SOW should be revised to incorporate work activities needed to 

meet the Sole Source Aquifer regulatory requirements. 
BWS AOC/SOC Comments 

July 20, 2015 

Page 13 

3. The SOW’s groundwater and fate and transport work elements do not contain sufficient 

detail to evaluate how the Parties will accomplish these important work tasks and so are 

inappropriately generic. The subsequent “scoping meetings” will apparently lead to 

specific work plans, but the SOW lacks appropriate and proper review of such key plans 

by the BWS and other major stakeholders. 

4. The SOW will generate an extensive list of reports and work plans, but improperly limits 

stakeholder participation in their development, as well as public release of these reports 

and work plans. Deliverables include reports about Tank Inspection, Repair, and 

Maintenance; Tank Upgrade Alternatives, Piloting, and Re-evaluation; Release 

Detection/Tank Tightness Testing; Corrosion and Metal Fatigue Practices; Investigation 

and Remediation of Releases; Groundwater Protection and Evaluation; and 

Risk/Vulnerability Assessment. However, for each deliverable, the scoping and decision 

meetings will be attended only by the Parties, which improperly precludes participation by 

the major stakeholders, including the BWS. The SOW unacceptably limits public release 

of the reports to only synopses that “may” be made available to the public by the Parties. 

The SOW should be revised to include participation by major stakeholders during the 

design and pre-decisional meetings prior to finalization of the deliverables and to include 

public involvement throughout the entire process. The current SOW is seriously flawed by 

its lack of transparency and exclusion of major stakeholders from work activities. 

5. Page 2, Paragraph 1.1 acknowledges BWS as a subject matter expert, but states that 

they will be consulted “as needed” as determined by the “Parties” to the AOC. The BWS 

and other major stakeholders have important contributions to make to protect the 

Southern Oahu Basal Aquifer and our drinking water supply. Ultimately, the outcomes of 

the work, successful or not, will be directly felt by the community in cost and quality of the 

environment. We believe the entire process should be transparent and embrace the 

collective effort and involvement by the entire community as the groundwater and 

environment is held in trust for all people on the island of Oahu, as is stated in the Hawaii 

State Constitution Article XI Section 1 (Conservation and Development of Resources) 

and Section 7 (Water Resources). 

6. The SOW’s subsurface characterization work activities lack a standalone Quality 

Assurance Project Plan (QAPP) and Sampling and Analysis Plan (SAP). The SAP and 

QAPP must be developed according to the appropriate state and federal regulations, 

approved, and strictly followed during all data acquisition activities at Red Hill. The SOW 

should be revised to include a SAP and a QAPP that are appropriately rigorous because 

the quality assurance and quality control (QA/QC) procedures outlined in those plans will 

improve the reliability and validity of field and laboratory measurements used for decision 

making purposes. 

7. Please provide the scientific and engineering data and analyses for the choice of the 

apparently arbitrary 22-year period (with an allowable extension of up to 5 additional 

years) over which to deploy BAPT or cease tank use. The Red Hill fuel tanks have been 

in service for over 70 years, which is more than three times the average time-to-leak of 

about 20 years or less (Stephenson, 1998; Rogers, 1989; Rogers, 1981; Jacobs, 1987; 
BWS AOC/SOC Comments 

July 20, 2015 

Page 14 

Flora, 1999).1

 No data or technical analyses have been presented to convincingly 

demonstrate that continued operation of the tanks will not lead to future fuel releases. 

The 22-year period appears arbitrary because there is no factual basis provided in the 

SOW that the tanks will not release fuel to the sub-surface during that period. More 

importantly, the SOW implies that the future release rate from the tanks will be 

acceptable, even though the risk of future releases will increase as the tanks continue to 

deteriorate. 

8. The 22-year tank rehabilitation period is overly optimistic given the extent of corrosion 

damage observed in several of the tanks at the Facility over the years. For instance, 

following the January 2014 Tank #5 fuel release (Navy, 2014; US EPA and Hawaii DOH 

2015a), a Navy investigation found that “poor workmanship and oversight resulted in a 

tank that could no longer hold fuel” (Navy Region Hawaii, 2015). The inspection and 

integrity report prepared in 2010 indicated the presence of corrosion areas and pits of 

varying depths and sizes on Tank #5 (WillBros, 2010). It also stated that if all defects of a 

critical size were repaired, the tank could safely be re-inspected after another 10 or 20 

years of service (WillBros, 2010). Yet Tank #5 leaked in 2014. Given that the 10 or 20 

year “safe re-inspection interval” was not achieved at Tank #5 because of “poor 

workmanship and oversight”, and given that it is not currently known how many of the 

other tanks may suffer from similar defects in workmanship and oversight, the deadline 

for implementing tank rehabilitation should be reduced to five years or a similarly short 

period. 

9. Many leaks have been reported in the telltale system2

 of the subject tanks (Whitacre, 

2014b). If these leaks have arisen due to internal or external corrosion, they may provide 

valuable information that has not been taken into account when estimating remaining 

tank life. In addition: 

 It is not clear if all the tanks that remain in service has been subjected to 100-

percent non-destructive examination (NDE) and/or that all proposed repair 

recommendations have been implemented. 

 There is no indication that a detailed statistical analysis of the tank wall defects 

has been performed and factored into tank reliability and safe re-inspection 

intervals. 

 The corrosion rates used to establish remaining tank life do not appear to 

consider internal corrosion processes, statistical analysis, or appropriate safety 

factors. 

 

1

 We are aware that the data provided in the above references refer to steel USTs and not speciallyengineered tanks like those at Red Hill. In particular, the database referred to in these documents is based 

on steel tanks exposed to soil, not concrete. However, it must be realized that many locations on the Red 

Hills tanks are no longer in intimate contact with the surrounding concrete and that extensive corrosion has 

been noted on the outside of the tanks. 

2

 The “telltale system” is the leak release system incorporated into the Red Hill tank during construction; it 

consists of a series of pipes, and is intended to monitor leaks on the outside of the steel tanks. We have 

not been able to find detailed drawings showing how the telltale system was designed and constructed or 

records detailing the nature of the corrosion failures. 
BWS AOC/SOC Comments 

July 20, 2015 

Page 15 

 There is insufficient information to independently verify the reported tank leak 

detection limit of 0.7 gallons/hour. 

10. As described above, the SOW outlines tasks and requirements that the Navy and DLA 

must complete to comply with the AOC, including deploying the BAPT to prevent fuel 

releases (US EPA and Hawaii DOH, 2015b). As defined in the SOW, BAPT includes 

prevention methods and procedures that offer the best available protection to the 

environment, including protection against external and internal corrosion of tank metal 

components. As such, it is imperative that the SOW acknowledge previous studies. For 

instance, see Enterprise Engineering Inc. (2008a), in which BAPT alternatives for tank 

repair and rehabilitation could be engineered and implemented quickly, i.e., within 

3.5 years. These schemes could be engineered and implemented quickly while additional 

BAPTs are being studied and deployed. 

11. According to US EPA UST regulations, all metal UST system components that are in 

contact with the ground and routinely contain product must be protected from corrosion. 

The regulations stipulate that UST systems installed before December 22, 1988, must 

meet the current corrosion protection standards or implement one of the upgrade options 

listed below (or be properly closed): 

 Interior lining 

 Cathodic protection 

 Internal lining combined with cathodic protection 

However, newly revised US EPA UST regulations do not permit internal linings as an 

acceptable method of meeting the corrosion protection upgrade requirement as internal 

linings do not protect the steel in contact with the ground from corroding and causing 

environmental releases (US EPA, 2015). In fact, today’s final UST regulation modifies the 

1988 UST regulation by requiring owners and operators to permanently close a UST that 

uses internal lining as the sole method of corrosion protection for the tank when the lining 

inspection determines the internal lining is no longer performing according to original 

design specifications, and the internal lining cannot be repaired according to a code of 

practice developed by a nationally recognized association or independent testing 

laboratory. Furthermore, under these circumstances, US EPA regulations exclude 

options to add cathodic protection and/or to recoat the tank as alternatives to permanent 

closure, as internally lined tanks that fail the lining inspection and cannot be repaired are 

generally older and/or nearing/past the end of their useful lives. 

Given the extent of internal and external corrosion damage observed for the subject 

tanks, the Navy and DLA should give serious consideration to the immediate use of 

BAPTs to mitigate further internal and external corrosion of the fuel tanks and minimize 

the probability of future fuel releases (Enterprise Engineering Inc., 2008b). However, if 

the Navy or DLA now believes the remediation options listed in previous studies, e.g., the 

report by Enterprise Engineering Inc. (2008b) are not viable, or that funding for such 

repairs is not readily available, consideration should be given to the permanent closure of 

the corroded tanks or the temporary relocation of currently stored fuel until funding and 

rehabilitation actions are taken to upgrade the tanks to eliminate the risk to the water 

resources and environment . In addition, Navy and DLA should perform a comparative 
BWS AOC/SOC Comments 

July 20, 2015 

Page 16 

analysis of the cost and benefits of relocating the fuel to other facilities in lieu of 

renovating the Red Hill fuel facility. 

12. The SOW lacks sufficient information to conduct a structural risk assessment based on 

the extent of external and internal corrosion damage observed on the subject tanks. In 

order to obtain accurate data regarding the condition of the subject tanks, it is 

recommended that additional NDE be performed, followed by destructive testing (to verify 

NDE results) on coupons removed from tanks. This could be implemented immediately 

on tanks that are now permanently out of service (i.e., Tank #1 and Tank #19). 

Appropriately sized coupons should be removed from these tanks to encompass areas 

where, NDE indicates significant corrosion, where damage is expected to be most severe 

based on previous inspection reports or where structural damage has been observed in 

other tanks. The data collected through these efforts would provide the necessary 

information required to effectively conduct a structural risk assessment of the subject 

tanks. 

13. The SOW fails to address the critical need for non-destructive evaluation of tank-related 

piping, which includes lines up to 32-inches in diameter. There is no indication that the 

tank-related piping has been systematically inspected, despite indications of hydrostatic 

failures, weld cracks, and metal loss locations as recent as 2008. For example, when 2.1 

miles of 32-inch pipeline (F-76 line) running from the Red Hill Complex to the Pearl 

Harbor pump house were examined in 2005, 27 external metal loss locations were 

discovered (Regin, et al., 2008). Multiple loss locations exceeded 50% wall loss, 

indicated as the wall loss that DOD generally repairs. When the study was performed, the 

DOD explicitly indicated that “internal integrity inspections” had never been performed on 

the subject line. Furthermore, when the piping associated with Tank #2 was 

hydrostatically tested in 2008, a 6” slop line failed the hydrotest (Enterprise Engineering 

Inc., 2008b). In addition, “slight cracks” were detected in the welds of the sampling line 

penetrations in the welded plate on the blind flange at the end of the casing in the lower 

tunnel. The details of repairs reportedly performed in response to these inspection 

initiatives are not available. In the approximately ten years since the initial inspections 

and repairs were reportedly performed, there is also no evidence that additional 

inspections and/or repairs have been carried out to address wall loss locations that have 

continued to thin (corrode) and/or locations where the coating has subsequently been 

compromised. 

14. The SOW should be revised to specifically describe and require development of a 

hydrogeological conceptual site model (CSM). If a previously existing hydrogeological 

CSM is to be used, it should be described with references listed for all supporting 

documents and reports. All data and information used to develop the existing 

hydrogeological CSM will need to be vetted and requalified under the QA/QC 

requirements established for the SOW work. 

15. The SOW should be revised to include evaluation of contaminant distribution and 

migration through the vadose zone beneath Red Hill and the vadose zone’s impact on 

movement of contaminants. All data and information used to develop the existing 

groundwater flow model will need to be vetted and requalified under the QA/QC 

requirements established for AOC/SOW work. 
BWS AOC/SOC Comments 

July 20, 2015 

Page 17 

16. The SOW schedule for refining the existing groundwater flow model and contaminant fate 

and transport model and associated reporting is overly long and spans nearly three 

years. More importantly, the schedule for the monitoring well network component 

appears to occur in parallel with the refining of the groundwater flow model. It is unclear if 

and when additional monitoring wells will be installed. Given that the location and fate of 

the 27,000-gallon release still remain unknown, the Facility cannot be considered to be 

adequately characterized. Inadequate site characterization will lead to inadequate 

models, which will lead to inadequate and improper remediation decisions. The SOW 

must be revised to complete the appropriate site characterization before moving to fate 

and transport modeling that is to be used for remediation and other mitigation decisions. 

3.2 Detailed Comments for SOW 

1. Page 1, Introduction: The list of major components of work should be revised to include 

characterization of the nature and extent of contamination from past fuel releases in both 

the vadose zone and the underlying Sole Source Aquifer, as well as remediation of that 

NAPL, sorbed, and dissolved-phase contamination. 

2. Page 2, Paragraph (4): According to the SOW, “Implementation will occur in phases so 

that all Tanks in operation will deploy BAPT, as approved by the Regulatory Agencies, 

within twenty-two (22) years of the effective date of the AOC or as otherwise provided for 

in the AOC or this SOW.” 

The rehabilitation schedule does not reflect variations in tank integrity from tank-to-tank, 

or address the need to prioritize the application of BAPT to high-risk tanks. Furthermore, 

the implication that these tanks can be operated safely for the next 22 years is untenable 

for the following reasons. Firstly, there is a lack of detailed information and analysis on 

the severity and extent of corrosion and other damage that has occurred over the last 70 

years to the tanks and associated piping and equipment. Secondly, there is evidence that 

the tanks have suffered significant corrosion that resulted in through-wall holes and prior 

fuel releases (Enterprise Engineering Inc., 2008b; Whitacre, 2005; Whitacre, 2014b; 

Weston, 2007a; Whitacre, 2005; WillBros, 2012). Thirdly, there is the certainty that the 

tanks will continue to corrode and deteriorate unless immediate action is taken to prevent 

further corrosion damage. If action is not taken quickly, it is likely that the frequency and 

severity of fuel releases will increase. For these reasons, the SOW should be revised to 

replace the 22-year BAPT implementation period with a much shorter time period, such 

as five years. 

It is not clear if all the tanks that remaining in service has been subjected to 100-percent 

non-destructive examination and/or that all proposed repair recommendations have been 

implemented. For instance, more than 800 indications and flaws were found during the 

2010 Tank #5 API 653 Inspection (WillBros, 2010). The depths found ranged from 0.015 

to 0.195 inch. Two through-wall holes were found in the shell extension and upper dome, 

and 80% of the internal coating had disbonded, flaked, or deteriorated. The detailed 

information regarding “mandatory repairs” is contained in Section 7 of the document (and 

Tables 6-1 thru 6-4 and Tables 7-1). We have been unable to find these documents in 

the files provided for review; therefore, we do not have information on the depths or 
BWS AOC/SOC Comments 

July 20, 2015 

Page 18 

locations (inner or outer surface, top or bottom dome, barrel, etc.) to clearly understand 

the nature and extent of the damage or methodology used for defect repair. We also 

have limited information about the location and nature of the “poor workmanship” 

referenced in the context of the 2014 Tank #5 release (Navy Region Hawaii, 2015). 

Without this information, it is difficult to evaluate if other repairs on the remaining inservice tanks may also suffer from future leaks as a result of “workmanship and/or 

oversight” issues. The aforementioned information should be provided in order to allow 

an independent review of the nature and extent of the identified defects, determine which 

defects were repaired, and better understand why the 2014 release occurred. 

As another example of the extent of corrosion, Tank #6 was subjected to NDE in 2007 

(Weston, 2007b). Their report indicates that 80% of the entire tank area underwent NDE, 

including 100% of the barrel and extension, but only 31% of lower dome area. A total of 

684 defects/flaws were located during this inspection; 476 were determined to require 

repair. The steel is 0.25-inch thick for the upper dome, extension, and barrel. The 

nominal plate thickness of the bottom is 0.5-inch thick. The tank was coated in the early 

1980s with a thin film of polyurethane. The pitting corrosion found on the lower dome 

inner surface was found to be as deep as 0.300 inch in the 0.50-inch thick plate. 

Additionally, pitting as deep as 0.100 inch was found on the inner surface of the 0.25-inch 

thick plate. To date, we have not been able to find any documents regarding the 

incorporation of internal corrosion information or corrosion rates into API inspection and 

repair methodologies. Depth of corrosion of Tank #6 steel plate from the outside was as 

high as 0.136 inch out of 0.25-inch thickness. No corrosion was reported on the outside 

of the lower dome, but only 31% was inspected. The API inspection and repair report 

indicates that a 0.0045 inch per year corrosion rate based on Tank #15 and Tank #16 

data was used to determine which of the 476 flaws needed to be repaired to set a safe 20 

year re-inspection interval. The report stated that 0.090 inch of further corrosion (0.0045 

inch per year x 20 years) can occur, meaning all defects greater than 0.06 inch must be 

repaired. However, the re-inspection and repair methodology does not appear to account 

for corrosion from both the inside as well as from the outside. In addition, no supporting 

analysis has been provided to support why an average corrosion rate is safe to use when 

determining which defects to repair and how frequently to inspect the tank. 

A similar report prepared by WillBros for Tank #17 indicated similar corrosion damage 

with pit depths ranging from 0.015 to 0.210 inch (WillBros, 2012). Furthermore, 42 holes 

and leaks were found in the shell extension and upper dome. In another instance, as-built 

repair records for Tank #15 from 2005 show the presence of numerous through-wall 

holes on the upper dome and upper barrel (between the dome and stiffening ring) 

(Whitacre, 2005). Given that significant corrosion damage has been observed in a 

number of tanks (a chronology of leaks is provided in Table 1 below), it is likely that 

corrosion will continue to occur and result in future releases, likely at an accelerating 

frequency and with increasing severity. It is likely that all the tanks have areas where their 

wall thickness has been substantially reduced to the point of imminent fuel release. In 

fact, unless there is evidence, or persuasive arguments founded on sound scientific and 

engineering principles, to the contrary, it is expected that all tanks are in imminent danger 

of leaking. 
BWS AOC/SOC Comments 

July 20, 2015 

Page 19 

The predicted corrosion rates used to establish remaining tank life do not appear to 

consistently consider internal corrosion processes or appropriate safety factors. 

Estimated corrosion rates of 0.0017 inch per year (Enterprise Engineering Inc., 2008a; 

Enterprise Engineering Inc., 2008b) appear to significantly underestimate actual 

corrosion rates; a rate as high as 0.0045 inch per year was reported for a through-wall 

hole in Tank #15 (Weston, 2007a). If we were to assume that such corrosion rates are 

likely to exist, at least in certain areas on the other tanks (not an unreasonable 

assumption), it becomes clear why there have been so many leaks in the past. That is, 

0.0045 inch per year times 72 years is 0.328 inch, which is greater than the 0.25-inch 

wall thickness of the tanks. Likewise, pit depths of 0.300 inch found on tank bottoms 

(Weston, 2007b) do not appear to have been taken into account in the setting of repair 

and re-inspection intervals. 

3. Page 2, Paragraph 1.1: Subject Matter Experts Involvement: BWS is a key stakeholder 

and acknowledged subject-matter expert by the Parties and should provide technical 

review and comments on all work plans and deliverables prior to their approval by the 

Regulatory Agencies. 

4. Page 2, Paragraph 1.2: Community Involvement: the Parties should arrange and hold 

public meetings at certain intervals (i.e., quarterly, semi-annually, etc.). 

5. Page 2, Paragraph 1.2: Community Involvement: According to the SOW, the Navy and 

DLA “shall submit a synopsis of each final report developed under the AOC, and this 

SOW, to the Regulatory Agencies who may make that synopsis available to the public.” 

The final reports developed for the Facility under the AOC and SOW should be made 

available to the public in their entirety. Additionally, public access should not only be 

limited to final reports but should include other documents including, but not limited, to 

scopes of work, regulatory agency written responses (page 2, paragraph 1.4), and 

technical memoranda. Public access to these reports should be provided in accordance 

with FOIA for federal agencies and the Hawaii Uniform Information Practices Act for 

Hawaii government offices and agencies. We strenuously object to any withholding of 

data and findings from the SOW work activities. 

6. Page 2, Paragraph (5): The SOW describes a risk/vulnerability assessment. Please 

clarify provide more information about this assessment, especially how it will interrelate to 

the other SOW tasks and how it will affect the Navy’s Contingency Plan. 

7. Page 3, Paragraph 1.6: Quality Assurance: This section states that “The Navy and DLA 

shall include a discussion of quality assurance and quality control (“QA/QC”) procedures 

in each Scope of Work submitted to the Regulatory Agencies for approval. The QA/QC 

procedures shall be used to ensure that environmental or other data generated meets 

standards established by the Parties.” 

a. A stand-alone QAPP should be developed, approved, and strictly followed during 

all data acquisition activities at the Red Hill site. The QA/QC procedures outlined 

in the QAPP will improve the reliability and validity of field and laboratory 

measurements used for decision making purposes. 
BWS AOC/SOC Comments 

July 20, 2015 

Page 20 

b. If this work is performed under US EPA RCRA and/or Sole Source Aquifer 

regulatory rules, then US EPA QA/QC requirements for these programs should be 

followed. 

c. The term “standards” needs to be further defined. How and why will the Parties, 

defined in the SOW as including the Navy, DLA, Hawaii DOH, and US EPA (Page 

1, Introduction), establish environmental or other data standards? 

d. Furthermore, this section states that the Navy and DLA use laboratories that have 

a documented quality system that complies with federal regulations. The QAPP 

discussed in (a) above should also comply with these federal regulations. 

8. Page 4, Section 3: Tank Upgrade Alternatives: Since the term Best Available Practicable 

Technology (BAPT) is not a state, federal, or industry term, additional clarification is 

required. The factors considered should include evaluating and quantifying the level of 

environmental protection (not limited to groundwater) that each BAPT alternative 

provides. 

9. Page 4, Section 3: Tank Upgrade Alternatives: Please clarify the justification by which the 

Parties determined the need for additional studies of tank rehabilitation methods when 

the Navy has already conducted several similar studies since the late 1990s. For 

example, the 2008 Red Hill Repair Tank Options Study (Enterprise Engineering, 2008a) 

identified the following two alternatives for upgrading the tanks: 

a. Alternative 1 – Composite Tank: The Composite Tank consists of inspecting and 

repairing the existing steel liner in each tank, which would become the secondary 

containment system, and then constructing a new liner with a 3-inch-wide 

interstitial space between the new liner and the existing liner. The interstitial 

space would be filled with grout and have a leak detection system. 

b. Alternative 2 – Tank Within A Tank: The Tank Within A Tank concept consists of 

inspecting and repairing the existing steel liner in each tank, which would become 

the secondary containment system, and constructing a new tank inside the 

existing tanks with a 5-foot-wide annular space between the new tank and 

existing tank shell that is accessible for inspection and visual leak detection. 

Enterprise Engineering (2008a) recommended that the Navy authorize a single tank 

repair project as a means of proving up the concepts and confirming overall cost validity. 

According to this same report, Enterprise Engineering also performed a similar study in 

1998 to develop possible repair options for Tank #19, which was driven by tank integrity 

issues, environmental concerns, lack of leak detection capability, and lack of secondary 

containment. These studies concluded that a composite tank option is a viable option for 

a long-term life extension renewal of the Red Hill tanks. The tank within a tank alternative 

also has merit in that it provides a long-term life extension, secondary containment, and 

the capability to detect and locate leaks as required by federal regulations (40 CFR 

Subpart D – Release Detection). Furthermore, the study by Enterprise Engineering Inc. 

(2008a) also concluded that the repair and recoating approach does not improve the 

service interval of the tanks beyond 20 years, at which point another cycle of repair and 

mitigation is required. 
BWS AOC/SOC Comments 

July 20, 2015 

Page 21 

The SOW should address these conclusions and explain why the Parties ignored the 

previous work and now seek 22 years or more to carry out additional studies and 

implement their findings. 

10. Page 6, last paragraph of section 3.5: Page 6 of the SOW states “Tanks to which BAPT 

has not been successfully applied in accordance with a TUA Decision Document shall be 

taken out of use, temporarily closed, and emptied of all regulated substances no later 

than twenty-two (22) years from the effective date of this AOC unless an extension of 

time to implement BAPT has been granted pursuant to this Section...The Regulatory 

Agencies may grant an extension, or a series of extensions, of the twenty-two (22) year 

deadline, totaling no more than five (5) years, to allow additional time to apply BAPT....” 

a. The stipulation that tanks be “temporarily” closed leaves open the possibility that 

tanks be reopened at a later point in time. The SOW does not articulate conditions 

under which the temporary closure may be reversed, or scenarios under which 

the closure must remain permanent. 

b. The SOW gives no sound engineering or scientific basis for the selection of a 22-

year remediation period with an allowable extension of up to 5 years. Tank leaks 

were noted as early as 1948 (Whitacre, 2014h), and there is an extensive history 

of general and localized corrosion, weld discontinuities and defects, and 

hydrotesting failures for the tanks and associated piping. A number of tanks have 

patch plates, some with unknown provenance, installed to mitigate wall corrosion 

that resulted in through-wall holes (Dunkin & Bush, 2007a; Dunkin & Bush, 2007b; 

Enterprise Engineering Inc., 2008b). There is evidence of improper coating 

application, coating holidays, and premature coating degradation, calling into 

question the effectiveness of polyurethane coatings introduced in the late 1970s 

and early 1980s (Whitacre, 2014c; Whitacre, 2014d; Whitacre, 2014e; Whitacre, 

2014i; WillBros, 2010). An engineering analysis performed in 2008 stipulated that 

Tank #2 should undergo an API 653 out-of-service internal inspection no later 

than 2028. However, there is no indication that the 22-year deadline takes into 

account the current assumed corrosion rate of 0.0045 inch/year with the factor of 

two on this estimated rate, i.e., it does not use a corrosion rate of 0.009 inch/year 

to estimate the safe re-inspection interval. 

Given these considerations, please clarify whether the Parties believe that the tanks will 

not release fuel over the 22-year time period, or whether the parties assume that the risk 

of release is acceptable to the Parties. If so, please provide the scientific and engineering 

justification for this belief or assumption. Please clarify what probability of release (as a 

function of quantities and frequency of release) the Parties have assumed are 

acceptable, and on what engineering and scientific basis, given that the tanks will 

continue to corrode and deteriorate if not upgraded. 

11. Page 6, Paragraph 3.6: Pilot Programs: This section states that “Any proposed pilot 

program shall at least be designed to provide environmental protection substantially 

equivalent to that of the currently approved BAPT at the time of the pilot program 

approval”. The timeline of events is unclear. Can a pilot program be initiated on tanks that 

have not had a BAPT implemented in accordance with Paragraph 3.5, Page 5? 
BWS AOC/SOC Comments 

July 20, 2015 

Page 22 

12. Page 7, second and third paragraphs: The SOW mentions that “at least once every 5 

years...Navy and DLA shall (re-evaluate) new (tank upgrade) technologies to determine if 

either Best Available Practicable Technologies, Tank Inspection/Repair/Maintenance 

procedures, or both, should be modified....” The SOW should not be allowed to propose 

less stringent BAPT or tank inspection, repair, and maintenance (TIRM). 

13. Page 8, Section 4: Release Detection/Tank Tightness Testing: Please clarify the 

justification by which the Parties determined the need for additional studies to evaluate 

new release detection alternatives when the Navy has implemented and performed thirdparty evaluations on mass-based leak detection systems installed on Tank #16 and 

Tank #9 in the later 1990s and early 2000s (Karr, 2002). The Navy, under the 

Environment Security Technology Certification Program (ESTCP), developed and 

validated a low-range differential pressure (LRDP) system for bulk USTs that reportedly 

exceed regulatory requirements for leak detection. According to the Navy’s final report, a 

LRDP system was installed in Red Hill Tanks #16 and #9 in 1996 and 2001, respectively. 

According to this same report, a third-party evaluation was completed for Tank #9 (Karr, 

2002). 

The SOW should (1) address the conclusions stemming from the aforementioned 

studies, (2) identify which previously studied/recommended leak detection methods have 

been rejected and on what basis, and (3) clarify on what basis the Parties now seek 

additional time and money to carry out similar studies to determine optimal methods for 

leak detection. 

14. Page 11, Paragraph 6: Investigation and Remediation of Releases: The report, Tank 5 

Initial Release Response Report Red Hill Bulk Fuel Storage Facility, was submitted in 

April 2014. How will the Investigation and Remediation of Releases deliverable discussed 

in this section differ from this 2014 report (Navy, 2014)? Several fundamental elements 

were missing from this 2014 report including, but not limited to the following: 

a. Initial responses to the release include the increased frequency of groundwater 

sampling and fluid level measurements at select wells. This increased frequency 

was only continued for a brief period immediately after the release was 

discovered. These results are discussed at length, but there is no reference to the 

anticipated travel time for LNAPL or dissolved-phase contamination to reach 

these wells (Navy, 2014). The brief increased monitoring frequency may not be 

the appropriate initial release response depending on travel times for 

contaminants to reach these wells. 

b. A detailed discussion of how LNAPL will move within the approximate 80-footthick vadose zone (distance between the bottoms of the tank and groundwater) is 

omitted. Additionally, a detailed discussion on the movement of contamination in 

the saturated zone is omitted (Navy, 2014). The movement of contaminants 

through the vadose zone to groundwater as a migration pathway is 

acknowledged, but the report does not discuss the importance of understanding 

the geologic and hydrogeologic framework at a site-specific scale to accurately 

assess the movement of contaminants (fuel and vapor) in the vadose zone (and 

the potential for retardation of movement/retention), contaminants (fuel and 
BWS AOC/SOC Comments 

July 20, 2015 

Page 23 

dissolved-phase) in the saturated zone, and contaminants (fuel and dissolvedphase) in potential perched groundwater zones (Navy, 2014). The reports 

reference migration pathways that are discussed in the 2007 Final Technical 

Report (TEC, 2007) and the 2008 Groundwater Protection Plan (TEC, 2008). 

15. Page 11, Paragraph 6: Investigation and Remediation of Releases: The section also 

states that the deliverable shall include “an evaluation and discussion of potential 

remediation methods for the January 2014 Tank #5 release and any future release.” The 

mass of fuel lost during the January 2014 release has not been accounted for in the 

subsurface (Navy, 2014); additionally, the dissolved-phase contaminant plume has not 

been adequately defined (ESI, 2015a; ESI, 2015b). A comprehensive understanding of 

the nature and extent and fate and transport of contamination in the subsurface (vadose 

zone and saturated zone) is imperative to conducting a dependable evaluation of 

remedial technologies. 

16. Page 11, Paragraph 6: Investigation and Remediation of Releases: This section of the 

SOW discusses the deliverables associated with “determining the feasibility of 

alternatives for investigating and remediating releases from the facility.” This section of 

the SOW would be written more appropriately if it followed the Hawaii DOH Office of 

Hazard Evaluation and Emergency Response (HEER) technical guidance manual (TGM) 

(Hawaii DOH, 2008). The Hawaii DOH HEER TGM describes a three-stage site 

assessment process (Site Investigation, Environmental Hazard Evaluation, and 

Response Action) to determine whether further action is necessary for a site. It is 

important that Section 6.0 of the SOW be revised to reflect this three-stage regulatory 

process. Additional actions associated with these stages that must be addressed within 

the SOW should include, but are not limited, to the following: 

a. Stage 1: Site investigation to determine the extent and magnitude of 

contamination. Per section 3.1.2 of the Hawaii DOH HEED TGM, “Consult with 

Stakeholders. Stakeholders are individuals or organizations who are affected by, 

who can affect, or who otherwise have interest, in the site (e.g., owners, 

operators, employees, government officials, past owners or occupants, nearby 

residents, developers, or lenders). It is critical to consult with stakeholders early in 

the investigation scoping process to aid in an understanding of site issues. Early

consultation with stakeholders, especially with the HEER Office, will help minimize 

the risk of wasting time and effort on insufficient investigation designs. 

Stakeholders may also be a source of valuable site information (e.g., site 

employees may be aware of hazardous substance release areas, and locations of 

important site features).” Please provide a detailed plan (including schedule) of 

stakeholder involvement relative to the site investigation process. Per Section 3.3 

of the Hawaii DOH HEER TGM, “the Conceptual Site Model (CSM) prepared 

during the first step of the systematic planning is a comprehensive representation 

of site environmental conditions with respect to recognized or potential 

environmental hazards. CSMs are also a necessary starting point for preparation 

of an Environmental Hazard Evaluation. The CSM is presented in a series of 

figures that depict current and future site conditions in three dimensions, with 
BWS AOC/SOC Comments 

July 20, 2015 

Page 24 

textual explanations of the figures, as needed. There are many ways to present a 

CSM.” 

The SOW should be revised to include development/update of a site-specific 

CSM. A CSM is an important document that assists in identifying data needs 

(data gaps), guiding data collection, and evaluating risk to human health and the 

environment (ASTM, 2014). A CSM serves as the backbone for planning 

additional work and guiding the decision making process. A new CSM needs to 

be developed or the CSM described in the 2007 Final Technical Report needs to 

be updated. It is strongly recommended that a CSM deliverable be included as its 

own component within the SOW. Once an updated CSM has been developed, the 

CSM should be updated in an iterative process as additional data are collected. 

Please include a plan and schedule for how the CSM will be updated as new site 

data are generated. 

b. Stage 2: Environmental Hazard Evaluation (EHE) to determine the presence or 

absence of potential environmental hazards. Per Section 13.3 of the Hawaii DOH 

HEER TGM, “the Tier 1 Environmental Action Levels (Tier 1 EALs) are 

concentrations of contaminants in soil, soil gas and groundwater below which the 

contaminants are assumed to not pose a significant threat to human health or the 

environment. Exceeding the Tier 1 EAL does not necessarily indicate that 

contamination at the site poses environmental hazards. It does, however, indicate 

that additional evaluation is warranted. This can include additional site 

investigation and a more detailed evaluation of the tentatively identified 

environmental hazards. For example, the Tier 1 EALs incorporate conservative, 

risk-based exposure assumptions that may not be applicable under current site 

conditions and warrant a more site-specific risk assessment (see also Hawaii 

DOH HEER TGM Section 13.5.3 ). The action levels, or approved alternatives, 

can be used to delineate specific areas of the site that require response actions. 

These actions can vary, depending on the hazard present and site conditions.” 

Due to the groundwater resource being threatened, the Navy and DLA must 

appropriately use both Tier 1 EALs for Drinking Water Toxicity, unless more 

stringent US EPA MCLs exist, and a site-specific action risk assessment with 

BWS inputs for exposure scenarios as part of determining any action levels. 

Additionally, an evaluation of unregulated substances should be considered. 

c. Stage 3: Response Action to determine appropriate actions to address the 

identified hazards include two response action processes: the removal action 

process (typical for emergency responses) and the remedial action process. 

Because of the sensitivity of the underlying aquifer and potential groundwater 

receptors in the immediate area of the release, it is appropriate that the work at 

Red Hill should be conducted under Section 2.3 of the Hawaii DOH HEER TGM, 

Emergency Response. 

17. Page 12, Paragraph 6.3: Investigation and Remediation of Release Report: We strongly 

advise including interim progress reports and meetings for the deliverable outlined in 

SOW Section 6 to guarantee the regulatory agency’s approval of the deliverable. 

Characterization work on complex sites such as Red Hill requires an iterative approach 
BWS AOC/SOC Comments 

July 20, 2015 

Page 25 

that involves the participation of all vested parties and stakeholders in the decision 

making process. 

18. Page 12, Paragraph 6.4: Investigation and Remediation of Release Report: Investigation 

and Remediation of Releases Decision Meeting: This section of the SOW describes a 

decision meeting to be held once the Investigation and Remediation of Releases Report 

has been issued to “evaluate the feasibility to investigate and remediate potential 

releases from the facility to the maximum extent possible.” This meeting would be more 

appropriately held in a public forum. Per Section 16.3.2 of the Hawaii DOH HEER TGM: 

“For remedial response actions, public notice and a minimum 30-day public comment 

period to review the Draft Remedial Action Memorandum (RAM) and associated 

documents and provide comments are required under the Hawaii State Contingency Plan 

(SCP). This public notice and comment period must be completed prior to adopting the 

Final RAM and implementing the selected remedial alternative. A public meeting may 

also be held to review and discuss the Draft RAM, at the discretion of the HEER 

Office...In some cases, public participation and community involvement activities should 

be started long before the Draft RAM is prepared. Site assessment and remedial 

investigation activities can identify the presence of off-site contamination, and potentially 

affected human and ecological receptors. Early contact with adjacent property owners as 

well as affected and interested groups, such as neighborhood boards, community groups, 

and environmental or public interest organizations, may be valuable in helping to identify 

site-specific issues relevant to the remedial action that otherwise might be overlooked. At 

a minimum, it is recommended that a public participation plan be developed concurrent 

with, or as soon as the Draft RAM is completed.” It is appropriate to develop a public 

participation plan immediately for the additional work to be conducted at the Red Hill 

facility. A meeting should be held with all stakeholders and other interested parties within 

30 days of the signing of the AOC to discuss the scope of a public participation plan. A 

public participation plan should be developed for review and comment within 14 days 

following that meeting. All comments should be addressed within 30 days. Once all 

comments are addressed, the public participation plan should be adopted and followed. 

The public participation plan should include language that prior to the approval of any 

corrective action plan(s), public notice must be given and a minimum 30-day comment 

period to review the draft corrective action plan(s) must be allowed. The public 

participation plan should further allow for a review period following the addressing of 

comments to determine if all issues have been addressed to the satisfaction of the public. 

19. Page 12, Paragraph 7: Groundwater Protection and Evaluation: This section states 

“characterize the flow of groundwater around the Facility.” The word “around” needs to be 

replaced with “around and beneath.” 

20. Page 12, Paragraph 7: Groundwater Protection and Evaluation: This section states “this 

Section may include the installation of additional monitoring wells as needed.” The word 

“may” needs to be replaced with “will.” The current dissolved-phase plume is undefined; 

dissolved-phase contamination has been detected in groundwater samples from crossgradient (HDMW2253-03) and up-gradient wells (RHMW04) (ESI, 2015a; ESI, 2015b). 

Note: HDMW2253-03 is a deep monitoring well. 
BWS AOC/SOC Comments 

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Page 26 

21. Page 12, Paragraph 7: Groundwater Protection and Evaluation: None of the work 

descriptions in the subsequent sections specifically describe how site project 

data/information (both past and future) will be maintained and made available to the 

Parties, stakeholders, and the public. Will summary electronic databases be available for 

monitoring well water level data and water quality data? Again, there is no specific 

description of how past data/information will be “qualified for use” under the QA/QC 

procedures developed under this SOW. 

22. Page 12, Paragraph 7: Groundwater Protection and Evaluation: This section describes 

the steps to be taken to “update” the existing Groundwater Protection Plan. It also states 

that work performed under this section “may” include the installation of additional 

monitoring wells. It is appropriate to include in this section a discussion that the Hawaii 

DOH agrees that the necessary information about the characteristics of the site and the 

nature of the release to adequately assess the impact or potential impact of the release 

on human health and the environment has been acquired, and that this information 

includes, at a minimum, data on the nature and estimated quantity of release, and data 

from available sources and any and all previous site investigations concerning 

surrounding populations, water quality, use and approximate locations of wells potentially 

affected by the release, subsurface soil conditions, locations of subsurface sewers, 

climate data, and land use (HAR Subchapter 7 §11-281-74(a)(b)). If this information is 

not available and/or inconclusive, then additional monitoring wells are needed and should 

be made part of the corrective action plan. 

23. Page 12, Paragraph 7.1: Groundwater Flow Model Report: Part of the deliverable in this 

section includes refining the current groundwater flow model to “improve the 

understanding of the direction and rate of groundwater flow within the aquifers around the 

Facility.” The word “around” needs to be replaced with “around and beneath.” 

24. Page 13, Paragraph 7.1.2: Groundwater Flow Model Report Scope of Work: 

a. The model has been developed on a much larger scale and may not accurately 

assess the contaminant fate and transport on a site-specific scale. Due to the 

complex hydrogeologic framework, it is imperative to understand the direction and 

rate of groundwater flow on a site-specific scale. 

b. The extraction rate for the regional aquifer test varied between 10 and 18 million 

gallons per day during the pumping period (TEC, 2007). The validity of this test 

and resulting data needs to be evaluated further as these data were used to 

calibrate the existing groundwater model which will be updated per the SOW 

(TEC, 2007). Additionally, the groundwater flow model needs to be created using 

site-specific hydraulic parameters, not parameters obtained from the literature. 

25. Page 13, Paragraph 7.2: Contaminant Fate and Transport Model Report: The scale of the 

model is not appropriate for modeling contaminant transport beneath the Red Hill facility. 

The 2007 Final Technical Report explores fate and transport scenarios using the 

generalized groundwater flow model; this may not be appropriate and likely will result in 

inaccurate assessment of contaminant movement (TEC, 2007). 
BWS AOC/SOC Comments 

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Page 27 

26. Page 14, Paragraph 7.3: Groundwater Monitoring Network: State that the purpose of this 

deliverable is to “evaluate the number and placement of groundwater monitoring wells 

required to adequately identify possible contaminate migration...to obtain additional data 

for the Groundwater Flow Model and Contaminant Fate and Transport Model Report.” 

a. What is the decision making process with regard to the placement of new 

monitoring wells? The detections of TPH-d in the “up-gradient” monitoring well 

RHMW04 and “cross-gradient” deep monitoring well HDMW2553-03 suggest that 

the contaminant migration path does not only follow the anticipated groundwater 

flow direction, and that the vertical extent has not been defined (ESI, 2015a). 

b. The proposed schedule suggests that the groundwater flow model and fate and 

transport model will be updated in parallel with the groundwater monitoring well 

network. The SOW should be revised to first site and install additional monitoring 

wells before the flow and transport models are completed. Inadequate site 

characterization will lead to inadequate models which will lead to inadequate 

protections of our drinking water. 

27. Page 14, Paragraph 7.3.3: Groundwater Monitoring Well Network Report: The statement 

“including those already installed” needs additional clarification. Does “those” mean 

existing monitoring wells, newly installed monitoring wells as part of the Groundwater 

Protection and Evaluation SOW Component (Paragraph 7, Page 12), or a combination of 

both? 

28. Page 15, Paragraph 8: Risk/Vulnerability Assessment: 

a. This section states “The Risk/Vulnerability Assessment Report may include.” The 

word “may” needs to be replaced with “shall.” 

b. The purpose of this portion of the work scope is to evaluate hazards to the 

drinking water aquifers posed by failure of the field-constructed USTs at Red Hill. 

We presume that this is anticipated to be a formal, probabilistic risk assessment in 

which the likelihood of various failure modes and effects are quantified and 

compared. Typically this type of multi-hazard risk assessment has three 

fundamental aspects: (1) quantification of the hazards (e.g., return periods for 

earthquake ground shaking or rates of ground/slope movements), (2) given the 

hazards, calculation of the probability of triggering one or more failure modes, and 

(3) predicting the possible consequences of each failure mode. 

The probability of failure is calculated based on the ability of the structures to 

withstand anticipated loads, and will necessarily be a function of the expected 

structural condition of the tanks over the remainder of their design life. This 

calculation will likely need to be informed by the results of other aspects of the 

SOW, in particular, Section 2 – Tank Inspection, Repair and Maintenance, and 

Section 5 – Corrosion and Metal Fatigue Practices. The future structural condition 

of the Facility will change with time as a function of the ongoing corrosion and 

potential physical improvements. The Navy needs to provide additional detail 

regarding how (or if) the condition assessment results will be used in their 

risk/vulnerability assessment, and whether the timing of those results will affect 
BWS AOC/SOC Comments 

July 20, 2015 

Page 28 

the expected completion of the risk/vulnerability study. In addition, the Navy 

needs to specify which standard(s) will be used to design the risk study and by 

which standard(s) the results will be assessed. 

29. Page 15, Paragraph 8: Risk/Vulnerability Assessment: This section describes the 

deliverables to be developed and work to be performed to assess the level of risk the 

facility may pose to the groundwater and drinking water aquifers. The Risk/Vulnerability 

Assessment should also include the factors defined as part of an “exposure assessment” 

described in HRS §342L-50. 

30. General Comments regarding groundwater sampling and the approved Work 

Plan/Sampling Analysis Plan (WP/SAP) (TEC, 2014). 

a. The approved WP/SAP document appears to be omitted from the Administrative 

Record Index. Please provide this document for review immediately. 

b. Is future groundwater sampling to be completed under the already approved 

SAP? Several issues with the approved SAP are evident in the most recent 2015 

1st Quarter Groundwater Report. The SOW should include a SAP deliverable that 

complies with state and federal regulations. 

c. Stabilization criteria for sampling at outside monitoring well RHMW04 and inside 

monitoring well RHMW01 do not follow the US EPA low-flow groundwater 

sampling guidance (Puls and Barcelona, 1996; ESI, 2015a; ESI, 2015b). 

d. Monitoring well OWDFMW01 (5L were purged, water column height is 24.2 feet) 

and Halawa deep monitoring well HDMW2253-03 (5 L were purged, water column 

height is 1,368 feet) had less than one well casing volume removed via bailing 

prior to sampling (ESI, 2015a). Confirm that sampling procedures comply with 

state and federal regulations. 

e. Contamination has been detected at HDMW2253-03, the deep monitoring well, 

indicating that the vertical extent is unknown. 

f. Several laboratory reporting limits exceed Hawaii DOH EAL for Drinking Water 

Toxicity; the presence of these contaminants with laboratory reporting limits 

greater than standards cannot be accurately assessed. The reports conclude that 

the elevated reporting limits do not affect the assessment of groundwater 

contamination with the exception of 1,2-dichloroethane. Groundwater samples are 

not analyzed for nitrate, iron, manganese, and sulfate, which are important 

petroleum hydrocarbon degradation indicators (ESI, 2015a; ESI, 2015b). 

g. The discussion on naphthalenes being biased low via US EPA Method 8270 

should be a driver to include analysis of naphthalene by both US EPA Method 

8260 and US EPA Method 8270. It is stated that the bias low should not bias 

project decisions (for outside wells), yet naphthalenes exceedances have been 

documented (for inside wells) and therefore should be considered a contaminant 

of concern (ESI, 2015a; ESI, 2015b). All efforts should be made to obtain the 

most reliable and representative data. 
BWS AOC/SOC Comments 

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Page 29 

4.0 REFERENCES 

Anonymous. Historical Data of Tank Releases (in file titled: Historical Data of Tank 

Releases.pdf), Undated. 

ASTM International. 2014. Standard Guide for Developing Conceptual Site Models for 

Contaminated Sites, ASTM E1689 - 95(2014). West Conshohocken, PA. 

Commander Navy Region Hawaii (Navy). 2014. Tank 5 Initial Release Response Report, Red 

Hill Bulk Fuel Storage Facility, JBPHH, Oahu, Hawaii, Letter 5090 Ser N45/044, Jan 23, 

2014. 

Dunkin & Bush, Inc. (Dunkin & Bush). 2007a. Report on Tank 6 As Built Repairs, CONTRACT 

NUMBER N62742-03-C-1402, Jun 2007. 

––––––. 2007b. Report on Tank 16 As Built Repairs, CONTRACT NUMBER N62742-03-C-1402, 

Dec 2006. 

Enterprise Engineering Inc. 2008a. Red Hill Repair Tanks Options Study, FISC Pearl Harbor, 

Hawaii (Final Report), Enterprise Engineering, Inc., NFESC Contract N62473-07-D-4006, 

Delivery Order 0007, Doc. No. EEI Project 08-4942, Sep 2008. 

––––––. 2008b. Tank 2, Engineering Review and Suitability for Service Evaluation, API 653 Outof-Service Tank Inspection by Others, FISC Pearl Harbor Red Hill Complex, Hawaii, 

NFESC Contract N47408-04-D-8503, Delivery Order 0031, EEl Project 08-4895, Oct 

2008. 

Environmental Science International, Inc. (ESI). 2015a. Final First Quarter 2015 – Quarterly 

Groundwater Monitoring Report Outside Tunnel Wells. Red Hill Bulk Fuel Storage 

Facility. Joint Base Pearl Harbor – Hickman, Oahu, Hawaii. March. 

––––––. 2015b. Final First Quarter 2015 – Quarterly Groundwater Monitoring Report Inside 

Tunnel Wells. Red Hill Bulk Fuel Storage Facility. Joint Base Pearl Harbor – Hickman, 

Oahu, Hawaii. March. 

Flora, J.D. 1999. Demonstration and evaluation of technologies for determining the suitability of 

USTs for upgrading with cathodic protection, Midwest Research Institute, Kansas City, 

MO, Report, EPA/600/R-99/037, Apr, 1999. 

Industrial Economics, Incorporated. 2015. Assessment of the Potential Costs, Benefits, and 

Other Impacts of the Final Revisions to EPA’s Underground Storage Tank Regulations. 

April. 

Jacobs Engineering (Jacobs), 1987. EPA-68-01-7053, "Causes of Release from UST Systems, 

Report to US EPA/OUST, EPA Contract 68-01-7053," 1987. 
BWS AOC/SOC Comments 

July 20, 2015 

Page 30 

Karr, L. A. 2002. Validation of the Low-Range Differential Pressure (LRDP) Leak Detection 

System for Small Leaks in Bulk Fuel Tanks, Environmental Security Technology 

Certification Program (ESTCP) Final Report, May 2002. 

Navy Region Hawaii, 2015, Red Hill Bulk Fuel Storage Facility, Oahu, Hawaii, Fact Sheet, Mar 4, 

2015. 

Puls, R. W. and Barcelona, M. J. 1996. Ground-Water Issue Paper: Low-Flow (Minimal 

Drawdown) Ground-Water Sampling Procedures, U.S. Environmental Protection Agency, 

EPA/540/S-95-504. 

Regin, T. M., et al. 2008. “Internal Inspection of 813 Mm (32-Inch) Red Hill Diesel Pipeline, Fisc 

Pearl Harbor, Hawaii,” in CORROSION 2008. 

Rogers, W. 1981. "Report on the statistical analysis of corrosion failures unprotected 

underground steel tanks," Washington, DC: American Petroleum Institute, 1981. 

––––––. 1989. "Statistical Predictions of Corrosion Failures - Paper 596," in Corrosion, New 

Orleans, LA, 1989. 

Sommer, J. T. 2002. Confirmed Release Notification for Release at Tank 6 Red Hill Tank 

Complex, Fleet and Industrial Supply Center (FISC) Pearl Harbor, 5090 Ser N465/0013, 

Apr 17, 2002. 

State of Hawaii Department of Health (Hawaii DOH). 2008. Hazard Evaluation and Emergency 

Response Office Technical Guidance Manual (TGM) (Interim Final), Nov 12, 2008. 

Stephenson, L. 1998. Leak Potential Index Model for Use in Priority Ranking of Underground 

Storage Tanks at Formerly Used Defense Sites, US Army Corps of Engineers, 

Construction Engineering Research Laboratories, Technical Report 98/50, Mar, 1998. 

TEC Inc. (TEC). 2006. Red Hill Bulk Fuel Storage Facility, Final – Addendum Planning 

Documents, Pearl Harbor, Hawaii, Contract Number N62742-02-D-1802, CTO 007, May 

2006. 

––––––. 2007. Final Technical Report, Red Hill Bulk Fuel Storage Facility, Pearl Harbor, Hawaii, 

Contract Number N62742-02-D-1802, CTO 007, Aug 2007. 

––––––. 2008. Red Hill Bulk Fuel Storage Facility Final Groundwater Protection Plan. January 

2008, revised December 2009. 

––––––. 2014. Interim Update Red Hill Bulk Fuel Storage Facility Final Groundwater Protection 

Plan. January 2008, revised August 2014. 

United States Environmental Protection Agency and Hawaii Department of Health (US EPA and 

Hawaii DOH). 2015a. Administrative Order on Consent (AOC) in the Matter of the United 

States Department of the Navy and Defense Logistics Agency Respondents Red Hill Bulk 

Fuel Storage Facility, Oahu, Hawaii, May 27, 2015. 
BWS AOC/SOC Comments 

July 20, 2015 

Page 31 

––––––. 2015b. Attachment A Statement of Work (SOW) to Administrative Order on Consent 

(AOC) in the Matter of Red Hill Bulk Fuel Storage Facility. May 27, 2015. 

––––––. 2015c. AOC -Red Hill Bulk Fuel Storage Facility - Administrative Record Index, May 29, 

2015. 

United States Environmental Protection Agency (US EPA). 2015. Federal Register. Vol. 80 No. 

135, 40 CFR Parts 280 and 281. Revising Underground Storage Tank RegulationsRevisions to Existing Requirements and New Requirements for Secondary Containment 

and Operator Training; Final Rule. July 15 2015. 

Weston Solutions Inc. (Weston). 2007a. Final API-653 Inspection Report, PRL 99-21: Clean, 

Inspect, and Repair Tank 15, Red Hill, FISC Pearl Harbor, Hawaii, Contract No. FA8903-

04-D-8681, Task Order: 0176, Jan 30, 2007. 

––––––. 2007b, Final API-653 Inspection Report, PRL 03-12: Tank 6, Red Hill, FISC Pearl 

Harbor, Hawaii, Contract No. FA8903-04-D-8681, Task Order: 0176, Jan 29, 2007. 

Whitacre, J. M. 2005. (Feb 18) Red Hill Document Production - EPA/DOH Requests 2.a.i-ii/Navy 

Questions #13-17 (Pre-APR 653 Repairs) Tank #15 Part 1 of 2 citing Weld Repair As 

Built Record for Tank 15 [E-mail]. Available e-mail: Jan.M.Whitacre@navy.mil. 

––––––. 2014a. (Oct 14; 2:59 PM) Red Hill Document Production - EPA/DOH Request 1.b. / 

Navy Questions # 6 and 7 - Dates and Estimates of Historical Releases - Tank #16 [Email]. Available e-mail: Jan.M.Whitacre@navy.mil. 

––––––. 2014b. (Oct 14; 2:33 PM) Red Hill Document Production - EPA/DOH Request 1.b. / 

Navy Questions # 6 & 7 - Dates and Estimated Volumes of Historical Releases, Tank #1 

[E-mail]. Available e-mail: Jan.M.Whitacre@navy.mil. 

––––––. 2014c. (Oct 14; 2:41 PM) Red Hill Document Production - EPA/DOH Request 1.b. / 

Navy Questions # 6 and 7 - Dates and Estimates of Historical Releases - Tanks 6 and 7 

[E-mail]. Available e-mail: Jan.M.Whitacre@navy.mil. 

––––––. 2014d. (Oct 14; 2:46 PM) Red Hill Document Production - EPA/DOH Request 1.b. / 

Navy Questions # 6 and 7 - Dates and Estimates of Historical Releases - Tanks 8 and 10 

[E-mail]. Available e-mail: Jan.M.Whitacre@navy.mil. 

––––––. 2014e. (Oct 14; 2:49 PM) Red Hill Document Production - EPA/DOH Request 1.b. / 

Navy Questions # 6 and 7 - Dates and Estimates of Historical Releases - Tanks 11-13 [Email]. Available e-mail: Jan.M.Whitacre@navy.mil. 

––––––. 2014f. (Oct 14; 2:57 PM) Red Hill Document Production - EPA/DOH Request 1.b. / 

Navy Questions # 6 and 7 - Dates and Estimates of Historical Releases - Tanks 14 and 

15 [E-mail]. Available e-mail: Jan.M.Whitacre@navy.mil. 
BWS AOC/SOC Comments 

July 20, 2015 

Page 32 

––––––. 2014g. (Oct 14; 3:02 PM) Red Hill Document Production - EPA/DOH Request 1.b. / 

Navy Questions # 6 and 7 - Dates and Estimates of Historical Releases - Tanks 17 and 

18 [E-mail]. Available e-mail: Jan.M.Whitacre@navy.mil. 

––––––. 2014h. (Oct 14; 2:37 PM) Red Hill Document Production - EPA/DOH Request 1.b. / 

Navy Questions# 6 and 7 - Dates and Estimated Volumes of Historical Releases, Tanks 

#2-5 [E-mail]. Available e-mail: Jan.M.Whitacre@navy.mil. 

––––––. 2014i. (Oct 14; 3:13 PM) Red Hill Document Production - EPA/DOH Requests 1.b. and 

2.b. / Navy Questions # 6, 7 and 18 - Dates and Estimates of Historical Releases / Fuel 

Observations - Tanks 19 and 20 [E-mail]. Available e-mail: Jan.M.Whitacre@navy.mil. 

WillBros Government Services, LLC (WillBros). 2010. Tank 5 & 17 Cleaning, Inspection, and 

Repairs Project; Tank 5 Inspection Report, Task Order No.: N62583-09-D-0002/0003, 

WGS Project No. 54118, Nov 22, 2010. 

––––––. 2012. Tank 5 & 17 Cleaning, Inspection, and Repairs Project; Tank 17 Inspection 

Report, Draft, Task Order No.: N62583-09-D-0002/0003, WGS Project No. 54118, Nov 2, 

2012. 
BWS AOC/SOC Comments 

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Page 33 

Table 1: Site Chronology 

1940 The existing Red Hill tanks were constructed between late 1940 and 

September 1943 (Enterprise Engineering Inc., 2008a). 

1940 Dec. 15 Tank #1 construction started (Whitacre, 2014b). 

1941 Jul. Tank #16 excavation started (Whitacre, 2014a). 

1942 Feb. Finished gunniting side walls of Tank #1 (Whitacre, 2014b). 

1942 Oct. Tank #1 finished; turned over to Navy to fill with diesel oil (Whitacre, 2014b). 

1943 May Tank #16 turned over to Navy for operation (Whitacre, 2014a). 

1947 Tanks #1 and #2 leaks reported (Whitacre, 2014b). Diesel oil draining from 

Tank #1 telltale at a rate of 0.625 gallons per minute (Whitacre, 2014b). 

1947 Oct. Tank #2 telltale leak of unknown severity noted; tank emptied (TEC, 2008; 

Whitacre, 2014h). 

1948 Jul. Tank #16 telltale leak noted; tank emptied (TEC, 2008). 

1949 Jul. Tank #16 telltale leak. Level down 2.25-inches in 11 days (approximately 

11,000 gallons lost) (TEC, 2008). 

1949 Mar. No leaks reported for Tank #14 from Mar. 1949 to Feb. 1982 (TEC, 2008; 

Whitacre, 2014f). 

1949 Dec. Tank #16 was refilled and the level decreased 3.63-inches in about four 

days, indicating a loss of about 18,000 gallons. No information was given as 

to when the leakage was stopped (TEC, 2008). 

1950 Dec. No leaks were reported for Tank #18 from Dec. 1950 to Sep. 1975 (TEC, 

2008; Whitacre, 2014g). 

1952 Mar. No leaks were reported for Tank #8 from Mar. 1952 to Apr. 1983 (TEC, 

2008). 

1953 Jan. No leaks were reported for Tank #4 from Jan. 1953 to Apr. 1983 (TEC, 

2008). 

1953 Mar. No leaks were reported for Tank #3 from Mar. 1953 to Dec. 1981 (TEC, 

2008). 

1953 Aug. Tank #1 leak found on telltale number 7; crack found in tank (TEC, 2008; 

Whitacre, 2014b). 

1954 May Tank #2 second leak found. Reported leak rates of 3 pints in 2 hours and 

10 gallons in 7 hours; no reported estimate of volume loss (Whitacre, 

2014h). 

1958 Apr. Tank #9 leaked approximately 1,500 gallons from telltale in the Apr. to May 

timeframe (TEC, 2008). 

1960 Aug. No leaks were reported for Tank #20 from Aug. 1960 to Mar. 1979 (TEC, 

2008; Whitacre, 2014i). 
BWS AOC/SOC Comments 

July 20, 2015 

Page 34 

1963 Jun. Tank #6 telltale system problems reported; no clear indication of external 

leaks (TEC, 2008). 

1964 Jan. Tank #12 dome section leak identified; no evidence of corrosion on bottom 

plates or piping (TEC, 2008; Whitacre, 2014e). Tank #11 found to be in 

good condition, with no evidence of liner plate corrosion in bottom section 

(Whitacre, 2014e). 

1964 Apr. Tank #7 cleaning completed. Stated to be in good shape; no corrosion 

found (Whitacre, 2014c). 

1964 Jun. Tank #19 weld leak discovered (Whitacre, 2014i). The telltale leak was 

estimated to be about 5 mL/hr. Other small holes discovered during 

inspection were repaired (TEC, 2008; Whitacre, 2014i). 

1964 Aug. Tank #1 leak discovered (1 quart per 2.5 minutes) (Whitacre, 2014b). 

1965 Mar. Tank #5 exhibits suspected leak in telltale system (1 gallon per 1.25 hours); 

tank was worked on intermittently for six months, but no leak found. It was 

suspected that the leak “partially rusted over” (Whitacre, 2014h). 

1969 Jun. Tank #17 reported as leaking about 1 gallon per 1.5 minutes based on 

telltale. Fuel was transferred (TEC, 2008; Whitacre, 2014g). 

Late 1960s/Early 

1970s 

Full tank coating implemented (including aluminum metalizing of the floors) 

using the earliest versions of the NRL polyurethane coating system 

(Enterprise Engineering Inc., 2008a). 

1970 Aug. Tank #1 exhibited unexplained fuel drops amounting to 31,294 gallons 

between Aug. 1970 and Apr. 1972 (TEC, 2008; Whitacre, 2014b). 

1972 Feb. Tank #5 telltale leak at 2 quarts per day; response uncertain (TEC, 2008; 

Whitacre, 2014h). 

1973 Jan. Tank #10 leak suspected; tank emptied (TEC, 2008; Whitacre, 2014d). 

1973 May Tank #16 telltale leak of 1 drop per 20 seconds (TEC, 2008). 

1973 Mar. Tank #12 emptied due to suspected leak (TEC, 2008). 

1973 Nov. Tank #7 telltale leak (possibly only internal); tank emptied (TEC, 2008). 

1975 Jan. Tank #16 was emptied (TEC, 2008). Tank #17 started leaking based on 

telltale (Whitacre, 2014g). 

1975 May Tank #1 exhibited unexplained fuel drops amounting to 32,765 gallons 

between May 1975 and Aug. 1978 (TEC, 2008; Whitacre, 2014b). 

1976 RCRA (Resource Conservation and Recovery Act of 1976) enacted (US 

EPA and Hawaii DOH, 2015a). 

1976 Jan. Tank #16 had tank bottom “magnafluxed” in between Jan. and May; large 

pits (approximately 0.5 inch) found (Whitacre, 2014a). 

1976 Apr. Tank #10 was emptied and removed from service as a result of a leak 

detected from telltale (TEC, 2008; Whitacre, 2014d). 

1976 May Tank #13 reported as leaking (TEC, 2008; Whitacre, 2014e). 
BWS AOC/SOC Comments 

July 20, 2015 

Page 35 

1978 May Tank #1 history refers to Contract N62471-77-C-1316 for MILCON Project 

P-060, Modernization of Red Hill POL Facility awarded to Dillingham Corp. 

(Hawaiian Dredging and Construction of Honolulu, HI);$19,912,000 with 

project administered by ROICC Pearl Harbor (Whitacre, 2014b). 

1978 May Tank #7 exhibits significant telltale leak; tank emptied (TEC, 2008; Whitacre, 

2014c). 

1978 Jul. Tank #9 repair performed from Jul. 1978 to Feb. 1981; telemetering system 

installed. Leak test rates after the repair project were reported to range from 

4.5 to 17.9 gallons/day; no documentation of any actions taken to mitigate 

Tank #9 leak(s) (TEC, 2008). 

1978 Oct. Tank #10 repair performed from Oct. 1978 to Apr. 1980; telemetering 

system installed (TEC, 2008). 

1980s Federal and State programs for the management of USTs first published 

(US EPA and Hawaii DOH, 2015a). 

1980 Feb. Tank #7 leak rate after filling measured, and approximately “6,505 gallons 

leakage measured until rate dropped to< 13 gallons per day below 207 foot 

fill level” (TEC, 2008; Whitacre, 2014c). 

1980 Aug. Tank #11 reported to be leaking 1,000 to 1,500 gallons per day according to 

Whitacre (2014e) and 165 to 2,412 gallons per day (Anonymous, Undated). 

Leak location determined to be at 51 feet from bottom of tank . Repairs 

made. Based on these volumetric flow rates, fuel loss was estimated to be 

between 10,000 to 20,000 gallons (TEC, 2008). 

1980 Sep. Tank #11 emptied and repaired (TEC, 2008). 

1981 Tank #16 was found to be leaking badly after repairs when filled to 242-foot 

level (Anonymous, Undated). 

1981 Jan. Tank #10 found to have a severe leak near the top of the tank (between the 

235- and 242-foot level) during refill (TEC, 2008). Fuel ran out on the 

concrete near the first platform on the stairway to top of dome; tank emptied 

(TEC, 2008; Whitacre, 2014d). 

1981 Feb. Tank #12 was found to be leaking at a rate of 1,440 gallons per day after 

repairs at the 100-foot level (TEC, 2008; Whitacre, 2014e). Tank #12 

returned to service after leak testing (Whitacre, 2014e). 

1981 Mar. Tank #6 removed from service for repairs and lining (Whitacre, 2014c). 

1981 Apr. Tank #7 removed from service for repairs; put back in service in May 1981 

(TEC, 2008). 

1981 May Tank #5 removed from service for repairs and lining (Whitacre, 2014h). 

Tank #12 removed from service for a second time for leak repairs (Whitacre, 

2014e). 

1981 Jul. Tank #15 found to be leaking badly upon refilling after tank repair and lining 

(TEC, 2008; Whitacre, 2014f). 
BWS AOC/SOC Comments 

July 20, 2015 

Page 36 

1981 Aug. Tank #15 removed from service from Aug. to Oct. 1981. Following repair, 

leak testing showed continued leaking; tank repaired again (TEC, 2008). 

1981 Sep. Tank #4 removed from service for repairs and lining (Whitacre, 2014h). 

Tank #13 returned to service after lining and repairs; leaks found above the 

188-foot level and repaired (TEC, 2008; Whitacre, 2014e). 

1981 Oct. Tank #1 modernization repair project started (TEC, 2008). Original telltale 

pipes removed and replaced; holes in tank shell patched (Whitacre, 2014b). 

Tank #10 refilled after repairs had been made as a result of leak in Jan. 

1981 (TEC, 2008). Tank #16 refilled after repairs and lining and was found 

to be “leaking badly” (TEC, 2008; Whitacre, 2014a). 

1981 Nov. Tank #16 was removed from service; reworked and returned to service in 

Dec. (TEC, 2008; Whitacre, 2014a). 

1981 Dec. Tank #2 removed from service for repairs and lining (TEC, 2008; Whitacre, 

2014h). 

1982 Feb. Tank #14 removed from service for leak repairs (Whitacre, 2014f). 

1982 Mar. Tank #3 removed from service for repairs and lining (Whitacre, 2014h). 

1982 July Tank #1 estimated as having leaked 5,517 gallons from Jul. 1982 to Jan. 

1983 based on drops in fuel level (TEC, 2008; Whitacre, 2014b). 

1985 Jan Tank #19 cleaned and taken out of service for Automated Fuel Handling 

System Project by Asteroid Corp (Whitacre, 2014i). Tank not placed back in 

service, as “weeping” was observed from some of the channel doublers in 

the upper dome (Enterprise Engineering Inc., 2008a). 

1988 Federal UST regulations issued (US EPA and Hawaii DOH, 2015a). 

1992 – 1999 Ogden completed several investigations at the Red Hill oily waste disposal 

facility (OWDF) located approximately 3,200 feet west of the facility tanks. 

Remedial Investigation/Feasibility Study (RI/FS) initiated (TEC, 2006). 

1995 Facility records declassified (TEC, 2007). 

1995 Jun. Tank #12 found to have a deep pit in upper section of “A” course bottom 

plate (Whitacre, 2014e). 

1995 Sep. Tank #8 side walls (0.25-inch thick) inspected between Sep. and Oct. and 

found to contain deep pits (Whitacre, 2014d). Pits were found as unbroken 

blisters in the coating surrounded by wet spots of fuel; when the blisters 

were opened, corrosion and pitting were found (Whitacre, 2014d). UT 

thickness measurements around 24-inch diameter patch indicated several 

areas where the shell thickness was only 0.05 to 0.07 inch thick (Whitacre, 

2014d). 
BWS AOC/SOC Comments 

July 20, 2015 

Page 37 

1996 Jan. Tank #10 inspected for suspect areas of the shell plate in the upper dome 

and near the expansion joint. Several small through-wall holes in the shell 

plate found due to backside corrosion (Whitacre, 2014d). Several porous 

welds found that had fuel seeping through (Whitacre, 2014d). Several small 

areas of damaged polyurethane coating found that exposed the shell plate 

(Whitacre, 2014d). 

1996 Apr. Tank #9 middle 18-inch pipe support hole identified (TEC, 2008). 

1998 Tank #19 repair option study performed by Enterprise Engineering Inc. 

(Repair Tank 19 Red Hill FISC Pearl Harbor, HI DESC Project PRL 98-9) 

(Enterprise Engineering Inc., 2008a). 

1998 Tank #19 “back seepage” observed during tank maintenance project (TEC, 

2008). 

1998 Jul. Tank #7 notes state that from Jul. to Sep., ultrasonic thickness testing and 

vacuum testing were done along with checks for pitting and chloride levels; 

flame-sprayed aluminum was applied; holidays found in coating (Whitacre, 

2014c). Same notes are reported for Tank #8 (Whitacre, 2014d). 

1998 Aug. Tank #8’s bottom plate found to be heavily pitted. (Whitacre, 2014d). 

1998 Sep. Tank #6 note indicates that NRL polyurethane coating system applied to 

inside of slop line under MILCON Project P-060 in the early 1980s had 

failed. Red rust found attached to bottom of coating samples, indicating 

improper surface preparation. Extreme thickness (0.375-inch) of coating 

sample indicated improper coating application (Whitacre, 2014c). 

1998 Oct. Tank #16 experienced a loss of 1,469 gallons (71 gal/day) over 30.7 days 

(Whitacre, 2014a). Cores removed from under the center of Tank #16 found 

to smell of fuel and contain oily sludge-like material (Whitacre, 2014a). 

Tank #16 emptied from Oct. to Nov. due to concerns over tank level drop; 

petroleum found under base of tank (Whitacre, 2014a). 

1998 Nov. 10 First report by Navy to Hawaii DOH of a release from the Facility following 

the discovery of petroleum-stained basalt cores beneath the tanks (US EPA 

and Hawaii DOH, 2015a). 

1999 Mar. J. Gammon (FISC FUEL SUPT) compiled tank histories from all available 

sources between Mar. and Apr. 1999 (Whitacre, 2014b). 

1999 Sep. Tank #1 telltale pipe number 11 found to be leaking a steady stream into the 

Lower Access Tunnel. The pipe was capped to stop the leak (Whitacre, 

2014b). 

2000 Jan. State of Hawaii promulgated rules requiring owners and operators to report 

suspected or confirmed releases from USTs (US EPA and Hawaii DOH, 

2015a). 

Early 2000s Navy performed transverse cores beneath each tank and discovered 

evidence of staining beneath 19 of the 20 tanks (US EPA and Hawaii DOH, 

2015a). 
BWS AOC/SOC Comments 

July 20, 2015 

Page 38 

2002 Sep. 30 According to the AOC, Hawaii obtained US EPA state program approval for 

Hawaii’s UST program to operate in lieu of US EPA’s UST program under 

Subtitle I RCRA (US EPA and Hawaii DOH, 2015a). 

2002 Apr. Tank #6 taken out of service after a confirmed release (Sommer, 2002). 

2004 Tank #1 was taken out of service (Anonymous, Undated). 

2004 Sep.7 Contract No. N62742-02-D-1802 signed for the environmental investigation 

and risk assessment investigation of the Bulk Fuel Storage Facility at Red 

Hill by TEC Inc. and the Fleet and Industrial Supply Center (FISC) (TEC, 

2007). 

2007 Aug. Report submitted for the environmental investigation and risk assessment 

investigation of the Bulk Fuel Storage Facility at Red Hill by TEC Inc. and 

the FISC (TEC, 2007). 

2007 Aug. TEC indicates that it is not currently known if the tanks are leaking (TEC, 

2007); investigation results clearly confirm that petroleum was released from 

the Facility in the past (TEC, 2007). Soil vapor measurements from Soil 

vapor monitoring points (SVMPs) beneath seven of the USTs showed 

petroleum vapor throughout the subsurface and at greater concentrations at 

Tanks #6, #11, #12, #14 and #16 (TEC, 2007). TEC report notes that the 

age of the Facility and its storage capacity combine to present a future risk 

to the underlying groundwater. 

2008 Sep. Enterprise Engineering, Inc. completes a comprehensive engineering 

evaluation resulting in the programming of a MILCON project to repair the 

FISC Pearl Harbor Red Hill tanks (Enterprise Engineering Inc., 2008a). 

Project was to provide a long-term life extension renewal of the tanks 

(40 years additional expected tank life), secondary containment, and the 

capability to detect and locate leaks (Enterprise Engineering Inc., 2008a). 

The report evaluated and discussed various repair alternatives, and also 

identified new tank repair technologies and evaluated their applicability to 

the Red Hill tanks (Enterprise Engineering Inc., 2008a). It also stated that 

the existing steel liner (necessary for containment) needed to be 100% 

scanned for thinning due to corrosion and weld defects and repaired unless 

it was inspected within the past 5 years (Enterprise Engineering Inc., 

2008a). Additionally, 100% scanning of the steel liner and welds of the 

barrel and lower dome of the existing tanks were to be performed if the steel 

liners had never been scanned (Enterprise Engineering Inc., 2008a). 

Inspections circa 2008 were the first inspections wherein Tanks #2, #6, #15, 

#16, and #20 received 100% scanning of the steel liner plates and welds 

(Enterprise Engineering Inc., 2008a). 

2011 Nov. 18 US EPA proposed revisions to strengthen the 1988 federal UST regulations, 

including requirements for field-constructed USTs and new requirements for 

secondary containment and operator training (US EPA and Hawaii DOH, 

2015a). 
BWS AOC/SOC Comments 

July 20, 2015 

Page 39 

2012 Apr. 16 Public comment period closed for the US EPA proposed revisions to 

strengthen the 1988 UST regulations (US EPA and Hawaii DOH, 2015a). 

2013 Dec. 9 Tank #5 back in service after routine scheduled maintenance, including 

cleaning, inspecting, and repairing multiple sites within the tank (US EPA 

and Hawaii DOH, 2015a). 

2014 Jan. 13 Tank #5 fuel loss identified. Hawaii DOH and US EPA immediately notified. 

Fuel transferred from Tank #5 to other tanks at the Facility between Jan. 13 

and 18 (US EPA and Hawaii DOH, 2015a). 

2014 Jan. 16 Tank #5 release verbally confirmed to Hawaii DOH and US EPA (US EPA 

and Hawaii DOH, 2015a). 

2014 Jan. 23 Tank #5 fuel loss estimated as approximately 27,000 gallons in written 

notification to Hawaii DOH (US EPA and Hawaii DOH, 2015a). Navy 

increases tank monitoring frequency (US EPA and Hawaii DOH, 2015a). 

2015 May Navy reports storing only three types of fuels (JP-5, JP-8, and diesel marine 

fuel) at the facility (US EPA and Hawaii DOH, 2015a). 

2015 US EPA proposed revisions to the 1988 UST regulations should come into 

effect (US EPA and Hawaii DOH, 2015a). 

 
BWS AOC/SOC Comments 

July 20, 2015 

Page 40 

Table 2: FOIA Request and Completion Chronology 

FOIA Tracking Number Date 

Submitted 

Estimated 

Completion Date 

Status Records 

DON-NAVY-2014-006708 6/10/2014 7/23/2014 Assignment One of three requested 

reports released. 

DON-NAVY-2014-006761 

6/12/2014 7/25/2014 Closed 

No records released; 

Final Disposition: No 

Records 

DON-NAVY-2014-007031 

6/24/2014 TBD Closed 

Letter referring BWS to 

contact the proper 

official. 

DON-NAVY-2014-009060 

8/25/2014 10/10/2014 Assignment 

No records released; 

Final Disposition: 

Undetermined 

DON-NAVY-2014-009167 

8/28/2014 10/14/2014 Evaluation 

No records released; 

Final Disposition: 

Undetermined 

DON-NAVY-2015-000842 

11/3/2014 12/18/2014 Assignment 

No records released; 

Final Disposition: 

Undetermined 

DON-NAVY-2015-001401 

11/28/2014 1/13/2015 Evaluation 

No records released; 

Final Disposition: 

Undetermined 

DON-NAVY-2015-006109 

5/19/2015 7/1/2015 Assignment 

No records released; 

Final Disposition: 

Undetermined 

TBD: to be determined 
Figure 1A

Task 2: Tank Inspection, Repair, Maintenance (TIRM) – Scoping to Report Approval: No Cure or Dispute Resolution NAVY/DLA EPA/DOH/NAVY/DLA EPA/DOH

Set and Hold Initial 

TIRM Scoping 

Meeting

(SOW Page 3)

Set Final Scope 

Meeting

Additional 

Scoping 

Meetings 

Needed?

(SOW Page 3)

Set and Hold 

Additional Scoping 

Meetings

(SOW Page 3)

2

FINAL SCOPE: No deadline to 

complete preliminary scope 

discussions (ASSUME 60 

days)

1

INITIAL SCOPE: 30 

days of AOC 

Effective Date

Develop and 

Submit TIRM 

Procedures Report

(SOW Page 3)

Approve TIRM 

Procedures 

Decision Document

3

REPORT 

SUBMITTAL:

120 days to 

submit

Review Report

(SOW Page 3)

4

REPORT REVIEW: 

60 days

Schedule TIRM 

Procedures 

Decision 

Meeting

(SOW Page 4)

YES

NO

Submit TIRM 

Procedures 

Decision Document

(SOW Page 4)

Review Decision 

Document

Modify TIRM 

Procedures 

Decision 

Document?

(AOC Page 9)

7

DECISION DOCUMENT 

REVIEW AND 

APPROVAL: No 

deadline to review 

report (ASSUME 60 

days)

NO

YES Exhibit B

Implement TIRM 

Procedures 

Decision Document

5

TIRM 

DECISION 

MEETING: 

60DAYS 

6

TIRM 

DECISION 

DOCUMENT: 

60DAYS 
Figure 1B

Task 2: Tank Inspection, Repair, Maintenance (TIRM) – Scoping to Report Approval: With Cure or Dispute Resolution DRC SEC Assistant Secretary of the Navy EPA Assistant Administrator DOH/EPA NAVY/DLA

Modify TIRM 

Procedures 

Decision 

Document?

(AOC Page 9)

YES

Accept 

Modifications?

Send Navy/DLA 

Notice of Deficiency 

and Opportunity to 

Cure

(AOC Page 9)

Invoke Dispute 

Resolution 

Procedures?

(AOC Page 11)

NO

Review 

Modifications

Revise TIRM 

Procedures Report NO

Approve 

Modifications?

Submit written 

statement of 

dispute to DRC

(AOC Page 20)

8

CURE PERIOD: 30 Days to Cure

(AOC Page 9)

9

FORMAL 

DISPUTE:

Within 30 

days of 

dispute

Review Decision 

Document

NO

NO YES

Written statement 

of dispute received

(AOC Page 20)

Unanimous 

agreement to 

resolve dispute?

10

Senior Level Manager from All Parties with an 

Alternate

20 days – Other parties submit statements

45 days – Unanimous resolution with Parties 

(includes 20 days)

11

EPA – Regional Administrator of EPA Region 9

DOH – Director of Health

Navy – Commander Navy Installations Command

DLA – Chief of Staff of DLA

10 days written statement of dispute forwarded to SEC

30 days – Unanimous resolution with Parties

40 days – EPA Region 9 issues written position

Written statement 

of dispute 

forwarded to SEC

(AOC Page 20)

Written statement of 

position submitted by 

Regional Administrator 

EPA Region 9

(AOC Page 20)

NO

12

Assistant to the Nav for Energy Installations & 

Environment

30 days – written notice to elevate to EPA Assistant 

Administrator

Elevate to EPA 

Assistant 

Administrator

(AOC Page 21)

Issue written final 

decision to all 

Parties

(AOC Page 21)

YES

Other parties 

statements received 

regarding dispute

13

30 days – meet with Assistant Secretary the Nanvy, 

DLA and Governor

30 days – Issue final written decision

NO

YES

From Exhibit A

YES

Implement TIRM 

Procedures Decision 

Document

(AOC Page 21)

Approve Decision 

Document

14

IMPLEMENTATION:

Within 30 days of 

final decision

YES

Meet with Navy, 

DLA, and 

Governor

(AOC Page 21)

NO

Meet and Discuss

YES