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.gov 
Page 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 . 

Sincerely, 

Linda Ichiyama 

State Representative, District 32