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The Administrative Order on Consent (AOC) Statement of Work ( SOW) should include the 

### design and construction of a water treatment plant for the Pearl Harbor aquifer

. Here is reference explaining the quantity of fuel lost:

Red Hill Task Force Meeting #1 Draft Notes from September 3, 201 4

“ Based on the operator calculations, what they call plus or minuses or reconciliation, once they put the tank back into service they detected a fuel discrepancy up to 27,000 gallons. And that’s what was reported to the De partment of Health .”

According to SPAWAR: “ The tank data received from the field (product level, BS&W level, and temperature) is preprocessed to smooth and eliminate harsh spikes (positive and negative) before being passed to the rest of the AFHE system functions for processing and display.”


## This means that in order to get an accurate picture of the fuel release you need to analyze the raw data from the Automatic Fuel Handling Equipment ( AFHE ) database.

Furthermore, the SPAWAR Report identified the following: 

### “ The first occurrence of a warning Unscheduled Fuel Movement (UFM) did occur on 10 December 2013 7:52:29 PM; however, during this time the operator had placed the tank level in manual mode and manually changed
the level below the UFM threshold.”



## This means that this whole incident could have been avoided after just one day! It also demonstrates that all the technological advances suggested by the AOC are ineffective if management lacks the skills
and technical expertise to implement the new technology!

Additional info: 

### “ During the timeframe between 9 December 2013 and 12 December 2013, multiple daily transfer evolutions were started and stopped.

Start Level – 0’ 3” 14 on 9 December 2013

Stop Level – 105’ 2” 11 on 12 December 2013”

“ On 13 December 2013, Tank 105 transfer evolution setup.

Start Level – 105’ 2” 10 on 13 December 2013 08:03:29 AM

Stop Level – 106’ 3” 7 on 13 December 2013 09:36:29 AM

Upon completion of the evolution a warning UFM occurred while the tank was in settling mode
on 13 December 2013 10:55:44 AM. An evolution was created and named ‘Clear Evolutions’.Upon conclusion of the evolution the tank level had returned to the level preceding the UFM, i.e.
106’ 3” 7. ”



## The above excerpts from the SPAWAR Report demonstrates Managements lack of understanding of their monitoring system, yet they want the SOH to believe there is only a loss of 27,000 gallons !

The State of Hawaii ( S OH ) needs to perform and independent analysis using the raw data from the Automatic Fuel Handling Equipment System (AFHE) to determine the actual quantity lost. The Space and Naval Warfare Systems Command ( SPAWAR ) used this data and determined that the lost was actually 40,000 gallons

. SPAWAR is the agency who developed and maintains the MTG (Mass Tank Gauging) system used to monitor the tanks and the AFHE (Automatic Fuel Handling System) used for remote operation of fuel infrastructure. This analysis was based on quantities lost while the tank was in a static condition. There is additional analysis dur ing the filling/empting process that indicates the spill may be as high as 47,000 gallons.

UFM Alarms:Based on the Fate and Transport Modeling software provided to the Navy from Ogden a spill of that magnitude will hit the Pearl Harbor aquifer in 4 to 5 years unless there is some undiscovered barrier that did not show up when they conducted boring surveys under the tanks in order to build the modeling software perimeters. Based on quantity of fuel and distance to aquifer the software shows a 3D model of the possible migration of plume and time it will take to reach aquifer. A leak of 16,000 gal leaking from Tank 1 is predicted to reach aquifer in 5 to 6

years – anything less would probably be mitigated by the natural environment. Tank 5 is 400 feet further from the aquifer at approx. 2000 feet. According to the modeling software a leak of 40,000 gallons will not be naturally mitigated by the existing soil conditions!

Here is a simulation view:This is a view of existing plumes. Using 3D modeling software one can insert distance from aquifer and quantity of fuel lost to see an animated movement of the plume over time. It predicts time for plume to reach aquifer.