HOUSE OF REPRESENTATIVES

STATE OF HAWAII STATE CAPITOL HONOLULU, HAWAII 96813 July 20, 2015

US EPA Region 9— Pacific Islands Contact Office 300 Ala Moana Boulevard Room 5124 Honolulu, Hawaii 96850

Solid and Hazardous Waste Branch — Attn: Red Hill Hawaii Department of Health 919 Ala Moana Boulevard #212 Honolulu, Hawaii 96814 Re: Comment on the Proposed Administrative Order on Consent Regarding the Red Hill Bulk Fuel Storage Facility

Dear US EPA Region 9 and State Department of Health: Thank you for the opportunity to submit comments on the proposed Administrative Order on Consent (the "AOC") in EPA Docket No. RCRA 7003-R9-2015-01 and DOH Docket No. 15- UST-EA-01. The Red Hill Bulk Fuel Storage Facility ("Red Hill Tanks") is an impressive monument to human determination and ingenuity. Constructed between 1940 and 1943, the Red Hill Tanks are truly a modem engineering marvel. The recent release of approximately 27,000 gallons of fuel in January 2014, however, calls into question the continued viable use of this facility. The Red Hill Tanks sit only 100 feet above one of the primary aquifers that supplies Oahu's precious drinking water to residents and visitors, including the hundreds of military servicemen and women and their families in Red Hill. In the event that this aquifer becomes contaminated to the point where it is no longer usable, the results would be devastating. Even minor contamination would require installation of costly water purification and treatment facilities, pumping water from other aquifers to compensate for loss of supply and forcing certain users to switch to stream water, adversely impacting riparian environments.

Representative Linda Ichiyama District 32— Moanalua, Salt Lake & Aliamanu State Capitol — Honolulu, Hawaii 96813 Phone: 586-6220 - Fax: 586-6221 E-Mail: repichiyama@capitol.hawaii.govPage 2

July 20, 2015 US EPA Region 9— Pacific Islands Contact Office

The AOC goes a long way in addressing tank upgrades and investigation and remediation of fuel releases and groundwater monitoring. My main concern is the significant time allowed to accomplish these goals. Under the current draft of the AOC, the Navy has two years to conduct a risk/vulnerability assessment on the Red Hill Tanks. Then the Navy has an additional twenty years to perform upgrades to the tanks. The Navy also has nearly two years to determine where to drill new groundwater monitoring wells and nearly three years to investigate and report on the extent of water contamination from Tank 5. It is not clear from the AOC when these tasks will be accomplished. I am also concerned with the lack of public comment and input throughout the AOC process. Except for the public comment period prior to approval of the AOC, neither the EPA nor the Department of Health are required to solicit public input on the decisions that will dictate the Navy's actions regarding the Red Hill Tanks. I trust that should the EPA and the Department of Health approve the AOC, that an open and transparent process for public and stakeholder involvement will be established. Thank you very much again for the opportunity to submit the above comments. Should you have any questions or need additional information, please do not hesitate to contact my office at (808) 586-6220 or via email at 

### repichiyama@capitol.hawaii.gov

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Sincerely,

Linda Ichiyama State Representative, District 32