January20, 2015

The Honorable Donna Mercado Kim,

President

and Members of the Senate

Twenty-Eighth State Legislature

State Capitol, Room 409Honolulu, Hawaii 96813

The Honorable Joseph M. Souki, Speaker

and Members of the House of

Representatives

Twenty-Eighth State Legislature

State Capitol, Room 431Honolulu, Hawaii 96813

Dear President Kim, Speaker Souki, and Members of the Legislature:For your information and consideration, I am transmitting a copy of the Task Force to Study

the Effects of the January 2014 Tank Leak at The Red Hill Fuel Storage Facility, pursuant to

Senate Concurrent Resolution 73, Session Laws of Hawaii (SLH) 2014. In accordance withsection 93-16, Hawaii Revised Statutes, I am also informing you that the report may be

viewed electronically at http://co.doh.hawaii.cjov/sites/LecjRpt/201 6/default.aspx.

Sincerely, AA~47y4

DAVID .IGE

Governor, State of Hawaii

Enclosure
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REPORT TO THE TWENTY-EIGHTH LEGISLATURE 

STATE OF HAWAII 

2015 

 

PURSUANT TO SENATE CONCURRENT RESOLUTION 73 

REQUESTING THE DEPARTMENT OF HEALTH 

TO CONVENE A TASK FORCE 

TO STUDY THE EFFECTS OF THE JANUARY 2014 FUEL TANK LEAK AT 

THE RED HILL FUEL STORAGE FACILITY 

PREPARED BY: 

STATE OF HAWAII 

RED HILL FUEL STORAGE FACILITY TASK FORCE 

DECEMBER 2014 

Introduction 

On April 24, 2014, the Hawaii State Legislature adopted Senate Concurrent Resolution (SCR) 73 

which requested the Director of Health to convene a Task Force to study the effects of the January 

2014 fuel tank leak at the Red Hill Fuel Storage Facility and submit a report of the Task Force’s 

findings and recommendations, including any proposed legislation, to the Legislature no later than 20 

days prior to the convening of the Regular Session of 2015. 

Under SCR 73, the Task Force is requested to examine: 

1. Short-term and long-term effects of the leak at the Red Hill Fuel Storage Facility, including 

effects relating to the health of residents, safe drinking water, and the environment, 

2. Response strategies to mitigate the effects of future leaks at the Red Hill Fuel Storage Facility, 

3. Ways to improve communication between the United States Navy, the State, and the public in 

the event of future leaks at the Red Hill Fuel Storage Facility; and 

4. Implications of closing the Red Hill Fuel Storage Facility. 

Task Force members include the State of Hawaii Department of Health (DOH), the United States 

Environmental Protection Agency (EPA), the United States Navy (Navy), one member from the State 

House of Representatives, one member from the State Senate, the Department of Land and Natural 

Resources (DLNR), the Honolulu Board of Water Supply (BWS), and two members from the 

community. Appendix A contains a list of all the Task Force participants and alternates. 

The Red Hill Fuel Storage Facility (Facility) is the state’s largest field constructed underground storage 

tank (UST) complex, located in the south-central portion of the Island of Oahu, Hawaii. It is owned 

and operated by the United States Navy. 
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Background Provided By the Navy 

From 1940 to 1943, twenty (20) cylindrical tanks, 250 feet tall and 100 feet in diameter, were built in 

place along the Red Hill ridgeline. The tanks were constructed using 475,000 cubic yards of concrete 

around 45,000,000 pounds of l/4-inch steel plates forming 2.5 to 4-foot concrete encased steel tanks. 

Each tank was originally built with a leak detection system that consisted of a series of pipes that could 

potentially collect any released fuel at a central location. The Navy later determined that this initial 

leak detection system had design flaws which resulted in numerous false reports. This system was 

subsequently removed. Eighteen (18) tanks are active, and two (2) are presently not in use. Each tank 

is able to store up to 12.5 million gallons of fuel. The Facility is located 100 feet above a major 

groundwater aquifer, which is also used as a source of drinking water. Of the 18 in use tanks, three (3) 

are empty awaiting various stages of a service life extension program. The remaining fifteen (15) tanks 

are in use, storing over 180 million gallons of fuel at any given time. 

The Navy continues to operate and maintain the fuel tanks to support military operations in the Pacific. 

Modifications were accomplished to extend the service life of the tanks, add protective coatings, install 

new leak detection systems, and upgrade the facility’s fire protection system. 

The first major modification to the tanks came in 1960 when four of the tanks were modified to 

accommodate volatile fuels and to install inventory monitoring equipment. In 1970, a contract was 

awarded to clean and inspect tanks 5, 6 and 12. In 1978, the Navy made the determination to extend 

the service life and modernize all 16 non-volatile fuel storage tanks. During this project, the original 

leak detection system for each tank was removed as described above. In 1994, the Navy cleaned and 

inspected tanks 6-10, 12-14 and 16. Additional modifications were performed in 1997 for those same 

tanks to extend their service life. 

The inspections and modifications conducted between 1994 and 1997 greatly resembled the same 

practices used in today’s procedures. Since then the Navy has implemented the most stringent tank 

inspection and repair practices consistent with the American Petroleum Institute’s (API) 653 standards 

that would apply to the Red Hill tanks. After each tank has been thoroughly inspected, improvements 

are completed to ensure the operability of the tank for an additional twenty years. The Navy has 

adopted this program as a modified API 653 certification process which was applied to tanks 1, 6, 15 

and 16 between 2004 and 2007. Three tanks have been temporarily removed from service to 

continuously conduct the API 653 certification process on a rotational basis. Since 2008, the Navy has 

completed service life extension improvements for tanks 2 and 20 and is currently conducting 

inspections and improvements on tanks 5, 14, and 17. 

Since initial construction, the Navy has commissioned a number of projects and studies to modernize 

the facility and stay abreast of industry standards. Most notably, the Navy has installed and continues 

to use a highly sophisticated inventory system that provides real time height measurements of the fuel 

in each tank and flow rates through pipelines. In 1960, the Navy installed an initial automated tank 

gauging (ATG) system in tanks 17 – 20. Between 1972 and 1973, an identical ATG system was 

installed on the remaining 16 tanks to provide full visibility of the inventory levels within all 20 tanks. 

With the emergence of new technology, the Navy installed a Multi-function Tank Gauge (MTG) 

system in all 20 tanks by the end of 2002. This system has the capability of detecting a variance in fuel 

levels of l/16 of an inch and is based on mass and temperature measurements. 
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Over $156,000,000 was spent between 2006 and 2014 to inspect and improve the pipelines, install 

ground water and soil vapor monitoring, structurally reinforce the tunnels and passageways, improve 

the ventilation, upgrade the fire suppression system, and make other improvements. In addition, the 

Navy is constantly studying the industry’s best technologies and practices to incorporate them into the 

management of this facility. In 2008, over $120,000 was spent researching secondary containment and 

leak detection technology options to improve the infrastructure. A redacted version of this study is 

available to the Legislature upon request. A similar study is currently being conducted that will be 

finalized in March 2015. 

Environmental sampling over the years has shown a number of fuel releases dating back to 1947, 

including an oily waste disposal site. Exact qualities cannot be confirmed. 

Installation of Monitoring Wells 

After 2005, seven (7) groundwater monitoring wells (RHMW01-RHMW05, RH2254-01 and 

OWDFMW1) were installed to detect contamination into the groundwater. Upon determination that 

RH2254-01 (Red Hill Shaft) was also the Navy’s Drinking Water Well, drinking water parameters 

were added to the groundwater list of constituents to be sampled. Refer to Diagram 1 for the locations 

of all wells. Additionally, Diagram 1 shows the Commission on Water Resources Management’s 

(CWRM’s) Halawa Deep Monitoring Well which is also being monitored by the Navy. The wells are 

located on the mauka side of the Department of Public Safety’s Halawa Correctional Facility. Outside 

the confines of the Facility are five (5) drinking water wells, (Halawa Shaft, Halawa Wells, Aiea 

Wells, Aiea Gulch Wells and Moanalua Wells), that are owned and maintained by the Honolulu Board 

of Water Supply. Only Halawa Shaft is shown in Diagram 1. In this report, there is a distinction made 

between drinking water samples from the Navy’s drinking water well, RH2254-01 and the BWS wells, 

which are separate from groundwater samples taken at RHMW01-RHMW05 and OWDFMW1. 

January 13, 2014 release from Tank No. 5

In the course of refilling Tank 5 following its service life extension work, a suspected fuel release was 

discovered and verbally reported to DOH on January 13, 2014. A release of Jet Propellant 8, also 

known as Jet Propulsion fuel, type 8 (JP-8) from Tank 5 was confirmed and reported to the DOH on 

January 23, 2014. The estimated fuel loss was up to 27,000 gallons. Immediately after the release was 

detected, the Navy began draining the contents of Tank 5 and collected soil vapor samples from 

existing vapor monitoring points and groundwater samples from the existing monitoring wells. Results 

taken in and around Tank 5, indicated a spike in levels of hydrocarbons in soil vapor and groundwater. 

The elevated groundwater samples came from groundwater monitor well 2 (RHMW02) which is the 

closest monitor well to Tank 5. However, no free product was detected in the groundwater samples. 

In consultation with the EPA and DOH, the Navy is investigating the cause of the reported release 

from Tank 5 and whether any free product is present outside the tank liner, the concrete surrounding 

the tank, or in the adjacent basalt rock. In the event that free product is detected, the Navy will remove 

it to the maximum extent practicable. 

 

Following the reported release, drinking water samples were collected at an increased frequency from 

the Navy’s Drinking Water Well Shaft (2254-01/Red Hill Shaft) and the Honolulu Board of Water 

Supply (BWS) Halawa Shaft, Halawa Wells, Aiea Wells, Aiea Gulch Wells and Moanalua Wells. Test 
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results for of the BWS wells and the Navy’s Drinking Water Well, were non-detect for petroleum 

constituents in the months following the release. Laboratory analytical results showed that the water 

was within applicable safe drinking water standards. Note, there is no drinking water standard for Total 

Petroleum Hydrocarbons as diesel (TPH(d)) and naphthalene. 

In 2008, the Navy developed and implemented a Groundwater Protection Plan (GWPP), which the 

DOH approved. The plan was updated in 2009 and 2010. A 2014 interim update is under review by 

DOH. The Navy in consultation with the DOH, and EPA has initiated planning efforts to update the 

existing Groundwater Flow Model and Contaminant Transport Analysis which will also be 

incorporated into the GWPP. This Plan and the 2009 and 2010 updates are available online at: 

http://health.hawaii.gov/shwb/underground-storage-tanks/.

Negotiated Agreement Between EPA, DOH and the Navy 

Separate from the Task Force activities, DOH, EPA, and the Navy continue to work together on a 

negotiated agreement to assess the reported release of petroleum and minimize the threat of future 

releases. 

Senate Concurrent Resolution 73 & Red Hill Task Force 

Meetings were held on September 3, October 7, November 6 and December 11, 2014 to discuss the 

effects of the January 2014 release, results of on-going Navy investigations on the tank leak, Navy 

response actions since the leak was discovered and recommendations for improving operations to 

ensure protection of Hawaii’s drinking water. These included regulatory requirements, facility 

improvements and improved communication to the public. Three additional subgroup meetings were 

held on November 17, November 26, and December 3, 2014 to compile this report. Materials from the 

four Task Force meetings, and the three subgroup meetings, including attendance lists, minutes and 

other supportive materials are posted online at: http://health.hawaii.gov/shwb/underground-storagetanks/. 

This report contains the Task Force’s findings and recommendations for each of the review topics in 

accord with SCR 73.

Findings and Recommendations 

1. Short-Term and Long-Term Effects of the leak at the Red Hill Fuel Storage Facility 

including effects relating to the health of residents, safe drinking water, and the 

environment 

Finding of Facts 

Short-term effects 

In the 2008 Groundwater Protection Plan, Site-Specific Risk-Based Levels (SSRBLs) were established 

for this facility and these levels were approved by DOH. These SSRBLs raised the Environmental 

Action Levels (EALs) from 100 ppb to 4500 ppb for TPH (d), for instance. Justification was made 
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because of the low solubility of jet fuel in water. Any exceedances of this level would evoke increased 

monitoring, notification and other actions. Refer to Appendix F for more information about SSRBLs 

for the Facility compared to EALs provided by the DOH. 

After the January release, increased groundwater and soil vapor monitoring indicated contamination in 

the environment outside of Tank 5. Groundwater monitoring in RHMW02, located near tank 5, 

showed an increase in total petroleum hydrocarbons diesel (TPH(d)) of up to 5000 ppb, 500 ppb higher 

than the SSRBL approved by DOH. The Navy increased their sampling frequency to every two weeks. 

During the same period, soil vapor results increased from 794 ppbv to 204,000 ppbv (parts per billion 

by volume) under Tank 5. There were also increases in soil vapor beneath the tanks closest to Tank 5. 

Refer to Appendix B for a summary of the maximum groundwater results at the Facility and soil vapor 

monitoring analysis from Tank 5 in the past and following the release. Refer to Appendix C for the 

Navy’s current monitoring plan and an explanation of EALs and Site Specific Risk Based Levels 

(SSRBLs) from the Navy. 

The Navy’s sampling and analysis indicated that the increases of soil vapor volatile organic compound 

(VOC) concentrations beneath Tank 5 and nearby tanks may be attributed to the release of JP-8 from 

Tank 5 in January 2014. According to the Navy, results of groundwater sampling and analysis indicate 

the release of JP-8 from Tank 5 has had limited impact on the underlying groundwater and has not 

impacted any drinking water source. While, there has been detection of low levels of various 

petroleum chemicals in the RH2254-01 (Red Hill Shaft), there have been no detections from the 

accelerated and long-term monitoring since the reported January 2014 release. 

Drinking water samples were collected from the 5 BWS drinking water sources and the regulatory 

drinking water distribution point for Navy Drinking Water Well RH2254-01, all samples have been 

non-detect for petroleum contamination since the January release. Analytical results from the drinking 

water samples data were within applicable safe drinking water standards or below any Federal 

maximum contaminant levels (MCLs). Refer to Table 1 of Appendix B for a comparison table. 

The Task Force finds that the BWS and the Navy have undertaken significant efforts to assess the 

effects of the reported fuel leak on the environment and to protect drinking water resources. The Task 

Force acknowledges that the BWS has accelerated sampling at nearby drinking water sources. In 

addition, the Navy has performed extensive sampling and analysis of the groundwater, drinking water, 

and soil vapor at or near the Red Hill Fuel Storage Facility. The Navy has reported that their drinking 

water source remains safe based on analytical monitoring from certified laboratories that have been 

reviewed by DOH. The BWS has reported that 5 BWS drinking water wells in close proximity to Red 

Hill to date show no detections of petroleum chemical contaminants. 

 Long-term effects 

According to the most recent groundwater monitoring results dated, July, 21, 2014, levels of TPH(d) 

still persist in the groundwater beneath Tank 5, above DOH Environmental Action Levels (EALs), but 

are below the SSRBLs approved by DOH for this facility. The monthly soil vapor results also remain 

elevated, in the range of 100,000 – 200,000 ppbv, according to the latest report dated September 25, 

2014. However, soil vapor results remain below the SSRBL of 280,000 ppbv approved by DOH. 
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Refer to Appendix B for a more details on the soil vapor and groundwater monitoring results and

Appendix C for the Navy’s current monitoring plan and Appendix F is an explanation of EALs and 

SSRBLs provided by the DOH. Additional cumulative groundwater sampling results are posted online 

at: http://health.hawaii.gov/shwb/underground-storage-tanks/. 

BWS will continue periodic monitoring of its drinking water sources for petroleum contamination. The 

Navy will also continue periodic monitoring of the groundwater, drinking water, and soil vapor at the 

Red Hill Fuel Storage Facility, in accordance with the Groundwater Protection Plan. The Task Force 

expects the BWS and the Navy to continue providing reports on those efforts to the DOH and the EPA. 

The reports are available to the public from the DOH. 

DOH and BWS Comments & Recommendations 

• Navy must comply with state requirements for investigation of release points within Tank 5 

and characterization and delineation of contamination released, including the active 

remediation of free product to “the maximum extent practicable” to prevent any 

contamination from extending beyond the current location. The Navy has taken steps to 

determine where free product, if any, may be located. To date no free product has been 

found. The Navy is continuing efforts to investigate and recover retrievable free product. 

• Request Navy to continue to provide to DOH all water quality data collected at the Facility 

by monitoring well location and contaminant. 

• Continue groundwater modeling studies by the Navy and the BWS. The studies are critical 

to understanding the rate and direction of groundwater movement in the area to assess 

potential impacts to neighboring potable water wells. The studies will also complement 

groundwater monitoring well contaminant data collection to assess the overall condition of 

the aquifer and validate earlier studies that evaluate the direction of groundwater flow in the 

area including a northwesterly component towards the BWS Halawa Shaft drinking water 

source cited in an April 15, 2010 TEC Inc. Tier 3 letter report. The full report is available 

online: http://health.hawaii.gov/shwb/underground-storage-tanks/. According to the TEC 

report: 

“In the vicinity of the USTs, as before, the gradient indicates a regional component of 

groundwater flow to the west northwest and a local component to the southwest.” 

“The northwest regional flow places the HBWS Halawa Shaft, a major drinking water 

source for south Oahu, down gradient from the USTs.” 

“The northwest regional component of the groundwater flow may be transporting a 

petroleum plume or dissolved hydrocarbons in a direction that is not currently being 

monitored. Currently there are no compliance wells between the Halawa Shaft and the 

Facility to evaluate this possibility. For the HBWS Halawa Shaft to be threatened by 

contamination from the Facility a free product plume would have to be present within 

approximately 1200 ft. of this drinking water source.” 
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• Navy to drill and install additional groundwater monitoring wells north and south of the 

facility to enable the collection of groundwater data and provide information for the 

updated area-wide groundwater modeling. This will increase and improve the scientific 

understanding of the present and long-term quality and condition of the aquifer beneath the 

Red Hill tanks and beyond its boundaries. Select sites for additional monitoring wells after 

sampling results are obtained from the two monitoring wells installed in September and 

October 2014. Obtain relative groundwater elevation data in the Halawa/Red Hill/Moanalua 

area for proper characterization. 

• Devise a financial mechanism in which the Department of Health, the Honolulu Board of 

Water Supply, and the U.S. EPA may be reimbursed for site investigation activities needed 

to initiate (e.g. installation of additional monitoring wells, any increased groundwater and 

drinking water sampling, and any water treatment to remove contamination) within the 

area, to ensure that contamination is not migrating from the Red Hill facility into 

neighboring drinking water pump stations. 

• Strengthen Hawaii’s groundwater protection program by increasing surveillance and 

identification of potentially contaminating activities from other field constructed tanks to 

protect and mitigate impacts to groundwater aquifers. At this time there are 46 such 

facilities statewide with Red Hill being the largest in the State and the United States. See 

Appendix E for a full listing of these tanks, their location and current status and whether 

the tanks are located over a drinking water source. 

• Navy and Department of Health, Safe Drinking Water Branch should monitor the drinking 

water by collecting and testing duplicate samples for the parameters identified in the 

existing groundwater and drinking water sampling schedules and others identified by the 

Honolulu Board of Water Supply. The Groundwater Protection Plan should be updated to 

include a Quality Assurance Project Plan that specifically identifies sampling methodology, 

data acceptance criteria and laboratory selection criteria to ensure that all sampling is 

consistent and replicable. The results should be shared with all interested parties to assure 

that all Quality Assurance/Quality Control procedures were followed. 

• Request Navy to develop a system to continuously monitor the soil vapor probes as a form 

of leak detection, with alarm set points to alert operator(s) of organic vapors rising above 

pre-determined concentrations. 

BWS Comments

• Mitigate existing contamination beneath the tanks starting with the area adjacent to Red 

Hill groundwater monitoring well #2, to contain and prevent contamination from extending 

beyond the current location. The Task Force deems prevention is less expensive than clean 

up and water treatment of all releases – large and small. 

• Graph the Navy monitor well data and analyze for water quality data trends, correlation 

with past fuel release, interrelationships between wells and groundwater flow. Graphing 

data provides a pictorial view of trends over time. Comparing the data with other 

information is standard scientific practice in conducting a thorough analysis of the 

information collected. The comparisons can show any correlations between data points 

when compared with past fuel releases and contaminant presence or other monitoring wells. 
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All of this data analysis enables a better understanding of the “short and long term effects of 

the leak.” in accordance with SCR 73. 

• Fund and conduct a health effects study to assess the health significance of low level 

concentrations of petroleum chemicals in ground water and sources of drinking water in 

accordance with SCR 73 which requested the Task Force to “consider the short- and longterm effects of the leak at the Red Hill Fuel Storage Facility, including effects relating to 

the health of residents, safe drinking water, and the environment.” Presently there are no 

drinking water standards that define whether the amounts of petroleum contaminants and 

frequency being detected are safe to be in groundwater that is used as a source of drinking 

water. This study will scientifically assess and determine the maximum amount of 

petroleum contaminants that is safe to be in drinking water and provide the documentation 

to respond to any questions and concerns about the petroleum contaminants detected to 

date. 

According to the DOH document, Screening for Environmental Concerns at Sites with 

Contaminated Soil and Groundwater (Interim Final, May 2005 and updates), EALs 

were developed to help assess the risks of environmental contamination and make decisions 

regarding the need for additional site investigation, remedial action or a more detailed risk 

assessment. The EALs were developed, among others, to help protect drinking water 

resources and aquatic habitats (discharges to surface water). The DOH document indicates 

that “while the presence of chemicals at concentrations above the EALs does not 

necessarily indicate that a significant risk exists at the site. It does, however, generally 

indicate that additional investigation and evaluation of potential environmental concerns is 

warranted.” According to DOH, EALs for Total Petroleum Hydrocarbon (TPH) and many 

non-carcinogenic, petroleum related compounds (e.g., xylenes) are driven by the protection 

of groundwater quality. EALs therefore appear to be protective of the environment but is 

not a limit that when exceeded requires remedial action and clean up. This appears to infer 

an allowance of contamination to exist in the environment possibly for long periods as 

monitoring and testing continues without any mitigation. The BWS favors mitigating 

contamination before it travels and affects parts of the aquifer that are not 

contaminated. Maintaining drinking water quality criteria to the whole aquifer is favored 

over establishing a “risk based” level that appears to allow contamination at points in the 

aquifer in contact with a contaminating activity. 

• Conduct a scientific peer review and evaluation of the sampling and test methods and 

detection limits used by the Navy to develop a uniform monitoring protocol. Understanding 

the short and long term effects of Red Hill leaks needs reliable peer-reviewed and vetted 

scientific data in order to accurately understand the issues and make sound decisions on 

those issues. Professional scientific peer-review and auditing is standard practice in all 

good testing and research studies undertaken to insure data validity, quality and 

transparency. 

• A Red Hill Task Force Technical Subcommittee should be created to evaluate, comprehend 

and explain all of the complex and voluminous scientific information in support of the Task 

Force’s discussion of issues and decision-making and to provide the Task Force and public 

with easily understandable technical information on Red Hill. 
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Navy Comments: 

• The Navy will continue to ensure the safety of drinking water resources through 

implementation of the Groundwater Protection Plan. The Plan was published and approved 

by DOH in 2008 and has been updated in 2009 and 2010. A 2014 interim update was 

recently reviewed by DOH. The Plan will continue to be updated as additional information 

becomes available. The Groundwater Protection Plan and its 2009 and 2010 updates are 

available online at: http://health.hawaii.gov/shwb/underground-storage-tanks/.

• The Navy is actively investigating for the presence of free product and will remove free 

product to the maximum extent practicable. The Navy will continue soil vapor and ground 

water monitoring in accordance with the approved Groundwater Protection Plan. 

Recommendations Agreed Upon By Task Force: 

• Additional groundwater monitoring wells are warranted to adequately assess groundwater 

hydrology and to support fate and transport models for a facility of this size and unique 

geology. The number of additional wells will be based upon a technical discussion using 

available data, as well as any current and future studies. 

• BWS will continue periodic monitoring of its drinking water sources for petroleum 

contamination. The Navy will also continue periodic monitoring of the groundwater, 

drinking water, and soil vapor at the Red Hill Fuel Storage Facility, in accordance with the 

Groundwater Protection Plan. The Task Force expects the BWS and the Navy to continue 

providing reports on those efforts to the DOH and the EPA. The reports are available to the 

public from the DOH. 

2. Response strategies to mitigate the effects of future leaks at the Red Hill Underground 

Fuel Storage Facility 

Finding of Facts 

REGULAR MAINTENANCE 

The Red Hill facility consists of field constructed USTs that are currently deferred from Federal 

and State UST regulations that require other regulated non-field constructed USTs to have 

secondary containment for all new tanks and piping. It also requires corrosion protection and 

leak detection for all existing tanks and piping. Appendix D shows a summary of regulatory 

requirements for all other underground storage systems and those provisions for which field 

constructed tanks (FCTs) are exempt from. 

The Navy performs periodic inspection of all petroleum, oil, and lubricant tanks and pipelines 

to ensure that the Red Hill Bulk Fuel Storage Tank system is properly maintained. Other 

protective measures include a Mass Technology Measurement System used by the Navy to 

assess tank tightness for all active Red Hill tanks. The tank tightness testing is performed every 

two years. In addition, the Navy employs an Automated Fuel Handling System to detect 
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unscheduled fuel movements which alerts the operators of any potential fuel loss. Inventory 

levels are also assessed on a regular basis for trends that might reveal any potential fuel losses. 

Soil vapor monitoring equipment is also installed at the Facility to monitor hydrocarbon levels 

in the subsurface. 

Recent maintenance cycles performed on tanks within Red Hill utilize a modified American 

Petroleum Institute (API) 653 procedure developed by the Navy, for determining integrity of 

steel plates and welds. According to the Navy, a general corrosion rate is used to estimate how 

much of the original steel will be thinned out from corrosion at the end of a 20 year operational 

cycle. The goal of tank maintenance is to have at least 0.1 inches of steel plate remaining from 

the original 0.25 inch steel. Regarding Tank 5, the Navy reported over 600 areas where tank 

thickness did not meet the appropriate standards. The required thickness was restored through 

additional weld patch plating within Tank 5 during its maintenance cycle that ended December 

2013. 

SECONDARY CONTAINMENT EVALUATION 

In addition to the procedures mentioned above which monitor inventory levels to reveal 

potential fuel losses, the Navy uses soil vapor monitoring equipment to monitor hydrocarbon 

levels in the subsurface. However, these systems do not prevent leaks and fuel loss into the 

environment. A previous study conducted by the Navy in 2008 evaluated secondary 

containment options for the fuel tanks at Red Hill. The study included two options – a “tank 

within a tank” and a composite tank system. A redacted version of this report is available to the 

Legislature upon request. The Navy plans to continue studying secondary containment options 

as well as advanced leak detection technologies in collaboration with DOH and EPA. 

At the October 7, 2014 Task Force meeting, the Navy stated the importance of the Facility and 

its need to continually maintain the capacity at Red Hill to support its fuel needs. The Task 

Force finds that the Navy plans to study secondary containment options and advanced leak 

detection technologies in collaboration with the DOH and EPA. 

SITE ASSESSMENT & CONTINGENCY PLANS 

In continuing efforts to monitor the groundwater for contamination and to better assess the fatetransport model, the seven (7) groundwater monitoring wells that were previously installed in 

and around the Facility will continued to be monitored on a regular basis, including the Navy’s 

one drinking water well and the multiple drinking water wells maintained by the BWS. 

Monitoring of the CWRM Halawa Deep Monitoring Well and the Tripler Army Medical 

Center Monitoring Well could serve as sentinel well monitoring for any contaminant movement 

to the south towards BWS’ Moanalua Wells. 

Subsequent to the January 2014 release, the Navy, in coordination with the DOH and EPA, 

installed two additional groundwater monitoring wells in October 2014 (RHMW06 and 

RHMW07). Preliminary results from these two new wells have shown low levels of petroleum 

contamination 300 feet north of the facility. Refer to Diagram 1 for locations of all wells. 
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When available, samplings results will be submitted to the DOH and EPA. DOH will make the 

data available to the public. 

Additional wells may be necessary to adequately determine groundwater hydrology and 

support contaminant fate and transport models that are underway. Diagram 1 maps the location 

of existing wells and the two new wells installed since the reported release from Tank 5. 

The Navy has developed contingency plans with other federal agencies to address potential 

consequences from releases. These plans are periodically reviewed, updated and appropriate 

actions are taken by the Navy in response to these reviews and updates. 

DOH Comments 

• All current methods of release detection that the Navy implements at the Facility are 

reactionary. There is no ‘alarm’ until contamination has left the steel containment and then 

enters the environment. Secondary containment would capture fuel released from the inner 

wall into an interstitial space and alert Navy operators of releases. It could also be designed 

to allow for product recovery. 

• As of December 24, 2014, DOH has not been able to verify the accuracy and precision of 

any Automatic Tank Gauging (ATG) system, any Automated Fuel Handling System or the 

“highly sophisticated inventory system” that the Navy is using. 

• The Legislature should issue a resolution to encourage Navy to consider enhanced 

containment and improved leak detection at Red Hill. 

• DOH should amend the State’s UST regulations to require secondary containment and leak 

detection for all of Hawaii’s field constructed USTs. Refer to Appendix E for a listing and 

maps of these FCTs. 

DOH and EPA Comments 

• The Navy should evaluate current release detection methods, tank tightness testing 

protocol, tank inspection and repair procedures, and corrosion and metal fatigue control 

practices at Red Hill and institute best available technology where feasible and appropriate. 

BWS Comments 

• Support proposed EPA regulatory changes to cancel the deferral of field constructed USTs 

from 40 CFR Parts 280 and 281. The changes will regulate field constructed tanks (FCTs) 

and require compliance with existing release detection, spill and overfill control protection, 

and cathodic corrosion protection requirements. 

• The Legislature is urged to issue a resolution encouraging the President of the United States 

to pass the proposed changes out of the Office of Management and Budget as originally 

published. 

• Revise the DOH UST leak response requirements to specify the Resource Conservation and 

Recovery Act (RCRA) methodology for characterizing the nature and extent of 
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contamination. The RCRA site characterization approach is a comprehensive data 

collection method for producing a clear understanding of the current contamination 

problem and its extent in the environment. From there, targeted measures can be developed 

to mitigate the situation that can lead to developing strategies to mitigate the effects of 

future leaks at Red Hill. 

The major elements of the RCRA methodology are: 

3⁄4 Identify and determine the velocity of contaminant movement in the groundwater 

(saturated zone), amounts present, factors influencing plume movement and 

extrapolation of future movement (modeling). 

3⁄4 Examine the contamination in vadose zone (unsaturated zone), amounts present, factors 

influencing plume movement and extrapolation of future movement (modeling). 

3⁄4 Employ contaminant characterization presentation tools to create three-dimensional data 

plots to show lateral and vertical extent of contaminant plumes. 

3⁄4 Examine impacts to potential receptors such as potentially affected human populations, 

environmental systems, ecology, biota and endangered/threatened species. 

• Release and use EPA Drinking Water State Revolving Fund (DWSRF) set-aside grants to 

fund the drilling and installation of additional monitor wells in the Red Hill area. The use of 

DWSRF set asides describes a specific funding source and strategy to mitigate the effects of 

future leaks at Red Hill. The installation of additional sentinel wells provides long range 

surveillance and advance planning information to mitigate the effects of past and future 

leaks. The number of additional monitor wells to drill should be based on sound science 

data generated through the RCRA site characterization process. 

The Board of Water Supply believes the Hawaii State Legislature will expect the Task Force’s 

report to contain specific targeted action steps, strategies and recommendations that are based 

on sound science and the most state-of-the-art technical approaches for characterizing and 

mitigating the short and long term effects of leaking Red Hill underground fuel tanks. 

Department of Land and Natural Resources Comments & Recommendations 

• Provide an update on the wells which have been surveyed by US Geological Survey. 

• Provide the date of distribution of the final USGS survey data. 

• To effectively monitor the groundwater beneath a facility as large as Red Hill, with the 

complexities inherent in the fractured and porous basalts that underlie the facility, 

monitoring wells must be placed based upon a careful and thorough evaluation of the 

groundwater flow regime under and around the facility. Groundwater modeling will 

provide some insight and flow direction predictions, however, modeling and any other 

groundwater flow evaluation is dependent upon accurate water level data collected from 

monitoring wells with screened casings across the water table, and in locations that allow 

flow directions to be calculated. The linear locations of wells RH MW01, 02, 03, and 05, 

along the ridge, are too linear and too closely spaced to evaluate groundwater gradients. 

• At this time, the CWRM recommends that two additional monitoring wells be installed and 

sampled: one monitoring well on the south side of the Facility (e.g. near the west end of Ala 
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Iolani Street), and one monitoring well on Icarus Way, west/northwest of RHMW01, near 

the entrance of the upper tunnel. These new wells, and all others associated with the 

Facility, should be surveyed to a common benchmark. A water level survey of all wells 

should then be conducted. Based on upon water levels, and sampling results, groundwater 

gradient/flow direction can be evaluated, and then if needed, additional monitoring well(s) 

can be installed and sampled.

Navy Comments

• The Navy will continue a service life extension program for the 12 remaining tanks. 

• The Navy will explore additional containment protection solutions and seek funds to 

implement those that are likely to be effective in providing additional protection to the 

drinking water resources. 

DOH, BWS and DLNR Comment 

• Although the Navy has done, and continues to do, extensive repair work and improvements 

to this Facility, the best solution is some type of secondary containment. More research 

needs to be completed in regards to what technologies are available and if and how it can be 

successfully integrated. 

3. Improve communications between the United States Navy, the State, and the public in the 

event of future leaks at the Red Hill Underground Fuel Storage Facility 

Finding of Facts 

The technical information on Red Hill is primarily communicated between the Navy and the 

DOH and EPA as required by state and federal regulations. Regulatory monitoring data is 

available to the public and other agencies through DOH. 

DOH and BWS Comments 

• DOH continue to maintain a public website containing all information from the Task Force, 

Navy, DOH, BWS, and other agencies (e.g., meeting notices, notes of meetings, reports, 

data, trend graphs, laboratory analysis, etc.) to provide easy access to information and 

improve transparency. 

• Continue the work of the Red Hill Task Force to ensure the long-term management, 

information access and decision making on issues related to leaks at Red Hill and the 

protection of Oahu’s ground water aquifer, environment and public health. 

• Continue to utilize notification systems to communicate future leaks and incidences at Red 

Hill or other underground storage tanks located above or in the vicinity of drinking water 

aquifers. The alert system should be targeted to specific persons for first response action. 

Department of Land and Natural Resources Comments 

• To share a timeline for the distribution of any sampling results to the Task Force and/or 

involved parties (e.g. distribute results within 2 weeks of receipts of results). 
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Comments Agreed Upon by the Task Force 

• The Task Force also finds that all parties have demonstrated and continue to be fully 

committed to communicating with the public for any matters of public interest regarding 

the Red Hill Fuel Storage Facility. The Task Force acknowledges that the DOH, EPA, 

BWS and the Navy have made significant efforts to keep the public informed on the 

reported fuel leak. This began with a joint press conference by the DOH, BWS and Navy 

immediately following the January 2014 release, and continued with participation in 

community outreach events, publication of numerous media releases, and active 

coordination between and among appropriate State and Federal agencies to remediate any 

potential contamination and prevent future leaks at the Facility. The Task Force expects that 

all parties will continue to keep the public informed of any events at the Red Hill Storage 

Facility that would impact the public or the environment. 

4. Implications of Closing the Red Hill Underground Fuel Storage Facility 

Finding of Facts 

The Task Force finds that the Navy operates and maintains the Red Hill Fuel Storage Facility 

as a strategic petroleum facility that provides critical fuel to operating forces in the Pacific 

region. The Task Force acknowledges that the Navy has no plans to close the Facility. The 

Task Force expects that the Navy will inform the public should those plans change. 

The Navy indicated at the October 7, 2014 meeting that assessments are underway to explore 

alternative fuel storage solutions in lieu of either continued full or partial use of the Red Hill 

Facility. 

DOH & BWS Comments 

• The Department of Health does not have information regarding implications of shutting 

down this facility. DOH’s priority is the protection of the environment and it views the 

storage of up to 187 million gallons of fuel, 100 feet above a drinking water resource, is 

inherently dangerous. Therefore, the operation of this facility should only exist on the 

condition that the facility be upgraded with secondary containment and state-of-the-art leak 

detection to ensure safe operations and prevent adverse impact to the environment. 

• Any secondary containment feasibility study should include a comparison with the creation 

of a new fuel farm consisting of above ground tanks (ASTs) or the use of other available 

fuel storage options (i.e. closed refineries, fuel tankers, etc...) that already have secondary 

containment. 

• The Navy should have facility-wide implementation of secondary containment by 

December 31, 2024. DOH recommendations on this point may be altered through the 

negotiation of an enforceable agreement with the Navy. 

• In the interim, while the Navy studies available technologies increased protection and 

monitoring must be applied until secondary containment can be implemented. 
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BWS Comments 

• Given the age and condition of the Red Hill Fuel Storage Facility, and with its history of 

leaks dating back to 1947 to the present, the Navy should disclose all studies or reports 

conducted including possible catastrophic release scenarios (e.g. seismic related, accidents, 

etc.). 

Navy Recommendations and Opinions 

• The Navy has above described the actions taken to continually upgrade and modernize the 

Red Hill Bulk Fuel Storage Facility and intends to continue to implement a sound 

systematic phased approach using continual improvement processes to continue those 

upgrades. The initial phase consists of ongoing evaluation of additional containment 

protection solutions. The second phase would involve planning, programming and 

implementing those solutions that are likely to be effective in providing additional 

protection to drinking water resources. 

• The Navy will continue a service life extension program for the 12 remaining tanks. 

Legislative Recommendations from the DOH 

• Passage of a resolution that would request owners and operators of the 46 field 

constructed tanks (FCTs) in Hawaii to update the Legislature and the Department of 

Health on the status and condition of each of their 70+ year old tanks (e.g. construction 

and operational history, past leaks, monitoring and water quality test data, leak 

detection and liner upgrades, visual inspections, maintenance procedures, etc...). This is 

currently not required of FCTs in the current UST rules. Refer to Appendix E for a 

listing and maps of the field constructed tanks in Hawaii. 

• To increase DOH’s portion of the current allocation of the Environmental Response, 

Energy, and Food Security Tax (“Barrel Tax”). The Barrel Tax places $1.05 levy on 

every barrel of oil imported into the State. Five cents of that tax goes to DOH’s 

Environmental Response Revolving Fund (ERRF), which has not increased since the 

tax was created in 1993. As Hawaii undergoes its forward-looking transition to 

renewable energy and imports fewer barrels of oil, this also means that there is reduced 

funding available for the ERRF. An increase from 5 cents to 15 cents out of the $1.05 is 

needed to support current personnel and increase resources to the Solid & Hazardous 

Waste Branch, the Safe Drinking Water Branch, among other branches, to regulate Red 

Hill and manage other complex environmental issues. DOH recommends that an 

additional 10 cent contribution into the ERRF come from the 60 cents that currently 

goes into the general fund. 

 

• Support adoption of revisions to existing DOH UST rules requiring increased protection 

from Hawaii’s 46 field constructed tanks (FCTs), of which Red Hill tanks make up 24 

(4 of Red Hill’s surge tanks are also FCTs). All of these tanks are 70 years or older. 
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Legislative Recommendations from the BWS 

• Provide additional resources to DOH to adequately monitor, study and regulate this 

Facility. 

• Legislature issue resolution continuing the work of the Task Force until DOH is 

satisfied with progress and outcome on issues related to this Facility and will 

recommend suspension of the Task Force. 

Task Force Recommendations to the Legislature 

• Encourage the DOH, EPA, BWS, and the Navy to continue efforts to protect Hawaii’s 

groundwater and drinking water sources. 

• Encourage the DOH, EPA, BWS, and the Navy to keep the public informed on matters 

of public interest regarding the Red Hill Fuel Storage Facility. 

• The Task Force further recommends that the Legislature encourage the DOH, EPA, and 

Navy to finalize a negotiated agreement for the Red Hill Fuel Storage Facility that 

protects drinking water resources, appropriately responds to the reported release of 

petroleum, and minimizes the threat of potential future releases. 

 
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Appendices, Tables and Diagram 

Glossary 

Appendix A: List of Red Hill Task Force Members and Alternates 

Appendix B: DOH and BWS Summary of Releases at Red Hill Facility 

Table 1: Petroleum Contaminants Detected in Navy Red Hill Groundwater Monitoring 

Wells 2005-2014 

Table 2: Soil Vapor Results from SV05 

Figure 1: Soil Vapor Measurements SV05 

Appendix C: Navy Data, including Monitoring Plan, Laboratory Numerical Levels, Groundwater 

Data Beyond Tank 5, Soil Vapor Results, Free Product Floating on the Surface of the Groundwater 

Table 1: Data on Other Wells For Petroleum Contaminants of Concern 

Appendix D: Hawaii UST Regulations and Exemptions for Field Constructed Tanks 

Appendix E: List of Field Constructed Tanks in Hawaii and Maps 

Appendix F: How Red Hill Facility Site-Specific Risk-Based Levels Were Established 

Diagram 1: Location of the seven monitoring wells routinely tested by the Navy in green, and 

the two new sentinel wells north installed in Sept/Oct 2014 
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API – American Petroleum Institute

API 653- American Petroleum Institute 653 repair standard for above ground tanks that was modified to be 

applied to the Red Hill underground storage tanks.

AST- above ground tanks

ATG- Automatic Tank Gauging system

BWS – Honolulu Board of Water Supply

CWRM- Commission for Water Resource Management, a division of the Department of Land and Natural 

Resources

DLNR- Department of Land and Natural Resources

DOH – State of Hawaii Department of Health

DWSRF- EPA Drinking Water State Revolving Fund

EALs – Tier 1 Environmental Action Levels

EPA – United States Environmental Protection Agency

ERRF- Environmental Response Revolving Fund

FCT – field constructed tank 

GWPP- Groundwater Protection Plan 2008, updates in 2009 and 2010. An interim 2014 update is being 

reviewed by DOH at this time. This plan is available online at: http://health.hawaii.gov/shwb/undergroundstorage-tanks/,

HEER- DOH’s Hazard Evaluation & Emergency Response Office

JP-8- Jet Propulsion fuel, type 8

MCL – maximum contaminant levels, federal drinking water standards

MTG – Multi-function Tank Gauge

PID- photo ionization detector

POU- permanently out of use

ppb- parts per billion

ppbv- parts per billion by volume (as a measure of soil vapor)

ppm- parts per million 

RH2254-01 – The Navy’s drinking water well, also known as the Red Hill Shaft

RHMW02 – Groundwater monitoring well No.2, which is located closest to Tank 5 and has the highest 

groundwater contamination concentrations

RHMW06 and RHMW07- two additional monitoring wells installed north of the Facility after the January 

release

RCRA- Resource Conservation and Recovery Act

SCR – Senate Concurrent Resolution

SSRBLs- Site-Specific Risk-Based Levels

TOU- temporarily out of use

TPH(d) – Total Petroleum Hydrocarbons, diesel range

ug/L – micrograms per Liter (also parts per billion)

USGS – United States Geological Survey

UST – underground storage tanks

VOC- volatile organic compound
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APPENDIX A 

Red Hill Task Force Members 

1. Gary Gill, Deputy Director, Department of Health 

2. Aaron Poentis, NAVFAC Hawaii 

a. Capt. Mike Williamson 

3. Senator Mike Gabbard, Chair, Energy/Environment Committee 

4. Representative Chris Lee, Energy/Environmental Committee 

5. Steven Linder, EPA Region IX 

a. Dean Higuchi, Hawaii EPA representative 

6. Ernest Y.W. Lau, P.E., Honolulu Board of Water Supply (HBWS) 

a. Erwin Kawata, - HBWS 

7. Patrick N. Casey, P.G., CHG, Geologist, Commission on Water Resource Management 

a. Robert Chenet, alternate 

8. Steven Y. Onoue, President, Moanalua Valley Community Association 

9. David Yomes, Chair Aliamanu/Salt Lake Neighborhood Board 
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APPENDIX B 

DOH and BWS Summary of Releases at Red Hill Facility 

Navy studies and test reports show the Red Hill tanks have a history of fuel releases dating 

back to 1947 and the presence of fuel contaminants in groundwater and fractured rock beneath 

the tanks. Soil vapor and groundwater monitoring well data consistently show petroleum 

detections from 2005 to the present. 

Samples from Red Hill groundwater monitoring well 2 (RHMW02), located in the tunnel near 

Tank 5 and Tank 6, contain the highest levels of total petroleum hydrocarbons as diesel (TPHd) at 12 to 50 times above the DOH environmental action levels (EALs) of 100 μg/L (parts per 

billion) from 2005 to the present. The latest groundwater sampling event occurred on July 21, 

2014 with 1,300 ppb of TPH-d (1.3 ppm). Based on Navy monitoring well test results 

submitted to DOH, the range of petroleum chemical contaminants detected and EPA health 

advisories, DOH Hazard Evaluation & Emergency Response Office Environmental Action 

Levels (DOH HEER EALs) and EPA safe drinking water Maximum Contaminant Levels 

(MCLs) are summarized in Table 1. 

Soil Vapor sampling points were installed by the Navy beneath each of the 18 operational tanks 

at Red Hill. Tank 1 & Tank 19 were removed from service in the 1980s and lack soil vapor 

sampling points. The Navy has collected and reported monthly soil vapor for volatile organic 

compounds (VOCs) by photo ionization detector (PID) beneath each tank from 2008 to present. 

Soil vapor VOCs spiked to 225,000 ppbv (parts per billion by volume) beneath Tank 5 in the 

sampling event of January 15, 2014. The prior event on December 23, 2013 showed 794 ppbv. 

The Navy increased SV monitoring to a weekly basis from Feb 2014 to July 2014. Maximum 

SV VOCs beneath Tank 5 increased to 450,000 ppbv on May 1, 2014 and have since declined 

to 208,000 ppbv on September 25, 2014. 

Soil vapor sampling beneath the adjacent Tank 6 showed maximum VOCs of 43,600 ppbv on 

May 21, 2014 and 18,700 ppbv on September 25, 2014. Similar results were seen in the 

direction of Tanks 6-10 and sporadic high readings beneath Tanks 2, 3, 4 indicating air 

pathways thru the fractured basalt surrounding the tanks within the complex. 

Monthly data from the Navy’s soil vapor sampling report for Tank 5 is shown in Table 2. 

Figure 1 illustrates this information in graphical form (Navy report, Oct 2014). 
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Table 1 of Appendix B Petroleum Contaminants Detected in 

Navy Red Hill Groundwater Monitoring Wells 2005 to 2014 

(values that exceed DOH/EPA levels in Bold) 

# Contaminant DOH 

EAL 

drinking 

water 

threatened > 

150 m to 

surface water

(ppb) 

EPA 

drinking 

water 

MCL** 

(ppb) 

EPA 

health 

advisory 

(ppb) 

Minimum 

value 

reported 

(ppb) 

Maximum 

value 

reported 

(ppb) 

1 TPH-d (diesel) 100 None None <20 6,300 

2 TPH-g (gasoline) 100 None None 13.2 660 

3 Xylene 20 10,000 None 0.37 1.1 

4 Benzene 5 5 None 0.14 0.92 

5 Toluene 40 1,000 None 0.5 2.5 

6 Acenaphthene 20 None None 0.02 0.86 

7 Fluorene 240 None None 0.03 16 

8 1-methylnaphthalene 4.7 None None 0.02 109 

9 2-methylnaphthalene 10 None None 0.007 88.5 

10 Naphthalene 17 None 100 0.03 180 

11 Ethyl benzene 300 700 None 0.15 1.3 

12 Lead (dissolved) 15 15 None 0.14 11.9 

13 Pyrene 68 None None 0.03 0.11 

14 Chrysene 1 None None 0.0159 0.062 

15 Phenanthrene 240 None None 0.02 0.14 

16 Fluoranthene 130 None None 0.026 0.24 

17 Benzo[k]fluoranthene 0.4 None None 0.0068 0.051 

18 Benzo[a]anthracene 0.092 None None 0.077 0.071 

19 Indeno[1,2,3-

c,d]pyrene 

0.092 None None 0.0075 0.037 

20 Benzo[a]pyrene 0.2 0.2 None 0.0086 0.045 

21 Benzo[g,h,i]perylene 0.13 None None 0.0057 0.034 

22 1,2-dibromoethane 

(EDB) 

0.04 None 0.05 ND* ND* 

23 1,2-dichloroethane 

(1,2 DCA) 

0.15 None 5 ND* ND* 

ppb = parts per billion or micrograms per liter 

MCL = maximum contaminant level (EPA safe drinking water standard) 

*Non-Detectable however, minimum detection limits were higher than DOH HEER EALs 

NOTE: Additional constituents have been analyzed but have not shown significant detections 
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Table 2 of Appendix B 

Soil Vapor Results from SV05 

Soil Vapor Monitoring Letter Report 

Red Hill Bulk Fuel Storage Facility 
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APPENDIX C 

Navy Data 

Current Red Hill Monitoring Plan 

This data is provided in addition to the information provided by DOH and BWS in Appendix B. The Navy 

monitors at many wells and tanks. The current regulatory approved monitoring plan includes: 

• 50 soil vapor monitoring points (2 to 3 monitors beneath the 18 tanks) –measures volatile 

organic compounds (VOC) vapors in the soil/rock beneath the tanks. The data is collected 

monthly. 

• 7 groundwater monitoring wells and 2 new wells – groundwater samples are analyzed for 

chemical contaminants at least quarterly and the groundwater is also monitored for free product 

monthly. 

• Drinking water monitoring at Red Hill Water Shaft – samples are routinely analyzed according 

to Safe Drinking Water standards. Additional analyses are performed to check for petroleum 

products. 

All monitoring plans and sampling results are provided to the Department of Health. 

Laboratory Numerical Levels 

The results from the drinking water wells are compared against Maximum Contaminant Levels 

(MCLs) under the Safe Drinking Water Act. These MCLs were established considering human health 

risk, technology for testing and treatment and several other factors. The MCLs are the specified 

standard appropriate for source wells used for drinking water distribution. 

The results from the ground water monitoring wells are compared against the Environmental Action 

Levels (EALs) and Site Specific Risk Based Levels (SSRBLs). The EALs were established by the 

DOH based on the most conservative risk-based exposure assumptions to the environment (including 

humans and aquatic life) as well as other factors such as taste, color, etc (that may not necessarily be 

harmful to humans). EALs can be used as screening levels and evaluation starting points to be put into 

context of the specific site and other contamination found. 

The Department of Health’s guidance, “Evaluation of Environmental Hazards at Sites with 

Contaminated Soil and Groundwater” describes how to use and interpret EALs: 

• “Exceeding the Tier 1 EAL for a specific chemical does not necessarily indicate that the 

contamination poses significant environmental concerns, only that additional evaluation is 

warranted.” 

• “The Tier 1 EALs presented in the lookup tables are NOT regulatory “cleanup standards”.” 

When additional evaluation is warranted as specified above, the risks at the specific site are studied 

and Site Specific Risk Based Levels (SSRBLs) developed and submitted to the regulators. Data from a 
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particular site should also be compared against the SSRBLs approved for the site. For Red Hill, the 

following SSRBLs were approved: 

• SSRBL for TPH-d = 4,500 ug/l in groundwater 

• SSRBL for benzene = 750 ug/l in groundwater 

• SSRBL for JP8/5 = 280,000 ppb per volume in soil vapors 

• SSRBL for diesel = 14,000 ppb per volume in soil vapors 

As the derivation of EALs did not incorporate technology and are the most conservative levels based 

on numerical assessments, a consistent detection level can be a challenge for laboratories. When 

testing for drinking water consumption, there is normally an expectation of the range of results (usually 

near the MCL.) However when testing for groundwater for possible contamination, the range of 

concentration is less defined and, due to the exploratory nature of the investigation, could be very 

wide. 

Groundwater Data Beyond Tank 5 

Contaminant concentrations detected in wells RHMW01 and RHMW05, which are down-gradient of 

Tank 5 and up-gradient of the Red Hill Shaft, are below the SSRBLs for TPH-d and below the DOH 

EALs for other chemicals. Similarly, the data from the well between Tank 5 and the Halawa Shaft are 

below the DOH EALs. The data for the contaminants marked as a concern in the BWS table in 

Appendix B are summarized for the other relevant wells below. (60+ other low level chemical results 

are not listed in table.) Values are displayed in in parts per billion (ppb). 

Table 1 of Appendix C – Data on Other Wells 

For Petroleum Contaminants of Concern in Listed Appendix B 

Navy Red Hill Groundwater Monitoring Wells 2005 to 2014 

(values that exceed SSRBLs or DOH EALs in Bold) 

# Contaminant DOH 

EAL 

(ppb) 

EPA 

drinking 

water 

MCL 

(ppb) 

EPA 

health 

advisor

y (ppb) 

Min. value 

reported 

(ppb) 

Max 

value 

reported 

(ppb) 

SSRB

L 

(ppb) 

RHMW02 (nearest to Tank 5)

1 TPH-d (diesel) 100 None None <20 6,300 4,500 

2 TPH-g (gasoline) 100 None None 13.2 660 

8 1-methylnaphthalene 4.7 None None 0.02 109 

9 2-methylnaphthalene 10 None None 0.007 88.5 

10 Naphthalene 17 None 100 0.03 180 

RHMW01 (down-gradient of Tank 5)

1 TPH-d (diesel) 100 None None <80.8 1500 4500 

2 TPH-g (gasoline) 100 None None <13 16.6 

8 1-methylnaphthalene 4.7 None None <.05 0.101a 

9 2-methylnaphthalene 10 None None <0.015 3.07 

10 Naphthalene 17 None 100 <.050 5.61 
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RHMW05 (down-gradient of Tank 5, up-gradient of Red Hill Shaft) 

1 TPH-d (diesel) 100 None None <10 673b 4500 

2 TPH-g (gasoline) 100 None None <30 13.2 

8 1-methylnaphthalene 4.7 None None <0.0158* 0.0335* 

9 2-methylnaphthalene 10 None None <0.0158* 0.0246* 

10 Naphthalene 17 None 100 <0.0326* 0.17* 

**RHMW04 (between Tank 5 and Halawa Shaft)

1 TPH-d (diesel) 100 None None new 17 

2 TPH-g (gasoline) 100 None None new <60 

8 1-methylnaphthalene 4.7 None None <0.0162 * <0.052* 

9 2-methylnaphthalene 10 None None <0.0162 * <0.052* 

10 Naphthalene 17 None 100 <0.0335 * <0.073* 

* Concentration is below the DOH EAL 

** Data for RHMW04 represents the re-start of testing in July 2014. HDMW2253-03 tested and levels 

also below DOH EALs and SSRBLs, but well suitability for groundwater testing is questionable. 

Data from new monitoring wells are not yet available. 

a – The max value reported was 9.44 ppb; however, previous and subsequent analytical results were 

non-detect and the consultant indicated that the outlier is likely not representative of the true 

groundwater condition at the site. The next highest value reported was 0.101 ppb. 

b – The max value reported was 2060 ppb; however, the laboratory indicated that this value may have 

included compounds unrelated to Facility stored fuels (specifically, caprolactam and DEET). The 

analytical method quantifies the total concentration of all compounds within the diesel fuel range. 

The next highest value reported was 673 ppb. 

Soil Vapor Results 

Soil vapor results at Tank 5 are represented in the graph in Appendix B. The comparison to the 

SSRBL of 280,000 ppbv prompted more frequent monitoring. Increases at neighboring tanks were 

also detected. 

Free Product Floating on the Surface of the Groundwater 

Monthly monitoring using an oil/water interface probe has not detected any measurable product at the 

well nearest to Tank 5 or any of the other groundwater monitoring wells. 
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APPENDIX D 

Hawaii UST Regulations and Exemptions for Field Constructed Tanks 

1. Design, construction, and installation 

2. Notification, permits, and variances 

3. General operating requirements (i.e. spill & overfill protection, repairs, recordkeeping) 

4. Release detection 

5. Release reporting, investigation & confirmation* 

6. Release response action* 

7. Closure* 

8. Financial Responsibility 

9. Enforcement* 

*Hawaii UST regulations require Field Constructed USTs to comply with only 5, 6, 7 and 9. 
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APPENDIX E 

List of Field Constructed Tanks in Hawaii 

Location Status Qty Capacity of 

each tank 

(gallons) 

Composition Installation 

Date 

Over 

Drinking 

Water 

Resource 

NOTES 

Kipapa 

Gulch 

Fuel 

Storage 

Annex 

POU* 

In 2002

4 2,650,000 Bare Steel May 1941 Yes DOH Office 

of Hazard 

Evaluation 

& 

Emergency 

Response is 

overseeing 

remediation 

(bioventing) 

for a release 

Red Hill 

Facility 

TOU* 

Tank 19 in 1986 

Tank 1 in 1997 

2 12,700,000 Bare Steel, 

encased in 

concrete 

May 1941 Yes 

Red Hill 

Facility 

In use 18 12,700,000 Bare Steel, 

encased in 

concrete 

May 1941-

1943 

Yes DOH Office 

of Solid & 

Hazardous 

Waste 

Branch is 

responding 

to a release 

from Tank 5 

Kuahua 

Pennisula 

– Submarine 

Base 

Pearl Harbor

TOU* 

In 1990 

3 20,000 Concrete May 1943 No 

Kuahua 

Pennisula 

– Submarine 

Base 

Pearl Harbor

TOU* 

In 1990

5 94,000 Concrete May 1943 No 

Kuahua 

Pennisula 

– Submarine 

Base 

Pearl Harbor

In use 4 425,000 Bare Steel May 1941 No Surge tanks 

used at Red 

Hill Facility 

Pacific 

Missile 

Range 

In use 9 50,000 Cathodically 

Protected 

Steel 

April 1942 No 

Schofield 

Barracks 

POU* 

In 1996 

1 550 Concrete Unk Yes 

TOTAL In use 31 

TOU/POU* 15 

46 

*TOU – temporarily out of use, subject to additional information from the tank owners 

*POU – permanently out of use/closed 
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NOTE: Safe Drinking Water Branch has mapped out these tanks on the following pages. 

There are 5 fuel storage facilities that utilize field constructed tanks. Four of these facilities are located 

on Oahu and shown in the map above. Labels for the each facility list the name, number of tanks, fuel 

capacity, fuel type, and describe the aquifer below the tanks. The map also shows those aquifers that 

are sources of fresh drinking water. In most areas of Oahu, freshwater resides in single aquifer. 

However, in areas with extensive caprock such as the Kuahua Peninsula (Submarine Base, Pearl 

Harbor), groundwater in the sedimentary formations overlies groundwater in the lava formations 
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below. The sediments confine the groundwater in the lava formations providing it with protection 

from contamination. Where the layered aquifers do not exist there is no natural hydraulic protection 

from fuel leaks. 

The Pacific Missile Range Facility is the only Hawaii location outside of Oahu where field constructed 

tanks are in service. The 9 tanks for this facility are located over a sedimentary aquifer that is not used 

for drinking water due to excessive salinity and low productivity. Below this sedimentary aquifer is 

confined groundwater that could potentially be used for drinking water. The potential drinking water 

aquifer is protected from contamination by the overlying sedimentary aquifer. 
WĂŐĞͮϯϮ

APPENDIX F 

,ŽǁZĞĚ,ŝůů&ĂĐŝůŝƚLJ^ŝƚĞͲ^ƉĞĐŝĨŝĐZŝƐŬͲĂƐĞĚ>ĞǀĞůƐtĞƌĞƐƚĂďůŝƐŚĞĚ

/Ŷ ƐĞƚƚŝŶŐ dŝĞƌ ϭ ŶǀŝƌŽŶŵĞŶƚĂů ĐƚŝŽŶ >ĞǀĞůƐ ;>ƐͿ͕ K, ĂƐƐƵŵĞƐ ƚŚĂƚ ĐŽŵƉŽŶĞŶƚƐ ŽĨ ĞĂĐŚ dW, ŵŝdžƚƵƌĞ

ĐŽŶƐŝƐƚŽĨƚŚĞŵŽƐƚƚŽdžŝĐĨƌĂĐƚŝŽŶ͘dŚĞƐĞůĞǀĞůƐƚŚĞŶƐĞƌǀĞĂƐĂƐĐƌĞĞŶŝŶŐŵĞƚŚŽĚŽƌĂŶŝŶĚŝĐĂƚŽƌƚŚĂƚĂŚĞĂůƚŚ

ŽƌĞŶǀŝƌŽŶŵĞŶƚĂůƚŚƌĞĂƚŵĂLJĞdžŝƐƚĂŶĚƐŚŽƵůĚďĞĂĚĚƌĞƐƐĞĚŽƌĞǀĂůƵĂƚĞĚĨƵƌƚŚĞƌ͘

/ŶƚŚĞĐĂƐĞŽĨZĞĚ,ŝůů͕ĂĨƚĞƌdŝĞƌϭůĞǀĞůƐǁĞƌĞĞdžĐĞĞĚĞĚ͕ŝŶĚŝĐĂƚŝŶŐƚŚĂƚŐƌŽƵŶĚǁĂƚĞƌƵŶĚĞƌƚŚĞĨĂĐŝůŝƚLJĚŝĚŶŽƚ

ŵĞĞƚ ĐƌŝƚĞƌŝĂ ĨŽƌ ƉŽƚĂďůĞ ǁĂƚĞƌ ŶĞĞĚ͕ Ă dŝĞƌ Ϯ ĂƐƐĞƐƐŵĞŶƚ ǁĂƐ ĐŽŵƉůĞƚĞĚ͘ dŚĞ dŝĞƌ Ϯ ĞǀĂůƵĂƚŝŽŶ ůŽŽŬƐ Ăƚ

ŵŝŐƌĂƚŝŽŶƉĂƚŚǁĂLJƐ ĨŽƌĐŽŶƚĂŵŝŶĂŶƚƐ͘/ƚĚĞƚĞƌŵŝŶĞĚƚŚĂƚŶŽƐĞĞƉĂŐĞŽĨůĞĂĐŚĂƚĞǁĂƐŽĐĐƵƌƌŝŶŐƚŽƚŚĞǁĂƚĞƌ

ƚĂďůĞĂŶĚƚŚĂƚƐŽŝůǀĂƉŽƌƉĂƚŚǁĂLJƐǁĞƌĞŶŽƚĂƐŝŐŶŝĨŝĐĂŶƚĐŽŶĐĞƌŶ͘dŝĞƌϯĂƐƐĞƐƐŵĞŶƚǁĂƐƚŚĞŶĐŽŶĚƵĐƚĞĚƚŽ

ĞǀĂůƵĂƚĞƚŚĞĨƵƚƵƌĞƌŝƐŬƚŽƚŚĞƉŽƚĂďůĞǁĂƚĞƌƉƌŽĚƵĐƚŝŽŶǁĞůů͕ƚŚĞEĂǀLJ͛ƐĚƌŝŶŬŝŶŐǁĂƚĞƌƉƵŵƉƐƚĂƚŝŽŶ;ZĞĚ,ŝůů

^ŚĂĨƚͿƚŚĂƚŝƐƚŚĞŶĞĂƌĞƐƚĂŶĚŵŽƐƚǀƵůŶĞƌĂďůĞƚŽĐŽŶƚĂŵŝŶĂƚŝŽŶĨƌŽŵZĞĚ,ŝůů͘

ƵƌŝŶŐƚŚĞdŝĞƌϯĂƐƐĞƐƐŵĞŶƚ͕^ŝƚĞͲ^ƉĞĐŝĨŝĐZŝƐŬͲĂƐĞĚ>ĞǀĞůƐ;^^Z>ƐͿǁĞƌĞĞƐƚĂďůŝƐŚĞĚĨŽƌdW,͕ďĞŶnjĞŶĞĂŶĚ

ƐŽŝů ǀĂƉŽƌ Ăƚ ƚŚĞ ZĞĚ ,ŝůů ĨĂĐŝůŝƚLJ͕ ƚŚĞ ďĂƐŝƐ ŽĨ ǁŚŝĐŚ ǁĞƌĞ ŵĂĚĞ ƚŚƌŽƵŐŚ ŵŽĚĞůŝŶŐ ĞĨĨŽƌƚƐ͕ ŐƌŽƵŶĚǁĂƚĞƌ

ĞůĞǀĂƚŝŽŶƐƚƵĚŝĞƐĂŶĚƉƵŵƉƚĞƐƚƐ͘/ŶƚŚĞƐĞŵŽĚĞůƐ͕ĐĞƌƚĂŝŶĂƐƐƵŵƉƚŝŽŶƐǁĞƌĞŵĂĚĞ͘

• ŽŶĐĞŶƚƌĂƚŝŽŶƐŽĨĚŝƐƐŽůǀĞĚŚLJĚƌŽĐĂƌďŽŶƐŵĞĂƐƵƌĞĚǁŝƚŚWDĞƚŚŽĚΘϬϭρŝƐůŝŵŝƚĞĚƚŽκρϬϬƵŐͬ>ʹ

ƚŚĞĐŽŵƉƵƚĞĚŵĂdžŝŵƵŵƐŽůƵďŝůŝƚLJŽĨ:WͲρŝŶĚŝƌĞĐƚĐŽŶƚĂĐƚǁŝƚŚƚŚĞĂƋƵŝĨĞƌ͘

• 'ƌŽƵŶĚǁĂƚĞƌ ĨůŽǁƐ ͞ŵĂƵŬĂ ƚŽ ŵĂŬĂŝ͟ ĂŶĚ ƵƉĚĂƚĞĚ ǁŝƚŚ Ă ƐůŝŐŚƚ ŶŽƌƚŚǁĞƐƚĞƌůLJ ĐŽŵƉŽŶĞŶƚ͕ ďƵƚ

ĂƐƐƵŵĞƐƚŚĂƚZĞĚ,ŝůů^ŚĂĨƚŝƐƐƚŝůůĚŽǁŶͲŐƌĂĚŝĞŶƚĂŶĚƚŚĞŵŽƐƚǀƵůŶĞƌĂďůĞƌĞĐĞƉƚŽƌ

• dŚĞĚŝƐƐŽůǀĞĚ ĨƵĞůŚLJĚƌŽĐĂƌďŽŶƐǁŝůůĚĞŐƌĂĚĞĂƚĂƵůŬĞŐƌĂĚĂƚŝŽŶZĂƚĞŽĨϬ͘ϬϬεйƉĞƌĚĂLJ͘/ŶŽƚŚĞƌ

ǁŽƌĚƐ͕ ŚĂůĨͲůŝĨĞс Ϭ͘ςεϯͬ΀ƌĂƚĞ ĐŽŶƐƚĂŶƚ΁с Ϭ͘ςεϯͬϬ͘ϬϬεс ϳϳ ĚĂLJƐ͘ dŚĞ ŝŶŝƚŝĂů ĐŽŶĐĞŶƚƌĂƚŝŽŶ ŽĨ dW, ŝŶ

ŐƌŽƵŶĚǁĂƚĞƌŝƐĂƐƐƵŵĞĚƚŽďĞƌĞĚƵĐĞĚďLJŚĂůĨĞǀĞƌLJϳϳĚĂLJƐĚƵĞƚŽďŝŽĚĞŐƌĂĚĂƚŝŽŶĂŶĚĂƚƚĞŶƵĂƚŝŽŶĂƐ

ŐƌŽƵŶĚǁĂƚĞƌŵŝŐƌĂƚĞƐĂǁĂLJĨƌŽŵƚŚĞƌĞůĞĂƐĞĂƌĞĂ͘dŚŝƐĂůůŽǁƐĚŽǁŶͲŐƌĂĚŝĞŶƚĐŽŶĐĞŶƚƌĂƚŝŽŶƐŽĨdW,ŝŶ

ŐƌŽƵŶĚǁĂƚĞƌƚŽďĞƉƌĞĚŝĐƚĞĚďĂƐĞĚŽŶƚŚĞĐŽŶĐĞŶƚƌĂƚŝŽŶŝŶŐƌŽƵŶĚǁĂƚĞƌŝŵŵĞĚŝĂƚĞůLJƵŶĚĞƌƚŚĞƚĂŶŬ

ĂŶĚƚŚĞĞƐƚŝŵĂƚĞĚŐƌŽƵŶĚǁĂƚĞƌĨůŽǁƌĂƚĞ͘

• /ƚĂůƐŽůŽŽŬĞĚĂƚƚŚĞŵĂdžŝŵƵŵƉƵŵƉŝŶŐƌĂƚĞĂƚƚŚĞZĞĚ,ŝůů^ŚĂĨƚƚŚĂƚĐŽƵůĚďĞƐƵƐƚĂŝŶĞĚĨŽƌĨŝǀĞĚĂLJƐ

;ĂƉƉƌŽdžŝŵĂƚĞůLJκ͘ςŵŝůůŝŽŶŐĂůůŽŶƐƉĞƌĚĂLJͿ͘

dŚĞdŝĞƌϯĂƐƐĞƐƐŵĞŶƚĂůƐŽƌĞĐŽŵŵĞŶĚĞĚƚŚĂƚŐƌŽƵŶĚǁĂƚĞƌƐĂŵƉůĞƐďĞƚƌĞĂƚĞĚƚŽƌĞŵŽǀĞƉĞƚƌŽůĞƵŵͲƌĞůĂƚĞĚ

ďƌĞĂŬĚŽǁŶ ƉƌŽĚƵĐƚƐ ƵƐŝŶŐ ͞ƐŝůŝĐĂ ŐĞů͟ ƉƌŝŽƌ ƚŽ ĂŶĂůLJƐŝƐ͘  dŚŝƐ ǁŽƵůĚ ƌĞĚƵĐĞ ƚŚĞ ƌĞƉŽƌƚĞĚ ĂŵŽƵŶƚ ŽĨ

ĐŽŶƚĂŵŝŶĂƚŝŽŶŝŶƚŚĞƐĂŵƉůĞƐ͘dŚĞK,ƌĞĐĞŶƚůLJĐůĂƌŝĨŝĞĚƚŚĂƚƚŚŝƐŵĞƚŚŽĚŝƐŶŽƚĂĐĐĞƉƚĂďůĞĨŽƌƐĂŵƉůĞĚĂƚĂ

ƚŚĂƚǁŝůůďĞƵƐĞĚƚŽĞǀĂůƵĂƚĞƚŚĞƚŚƌĞĂƚƚŽŚƵŵĂŶŚĞĂůƚŚŽƌƚŚĞĞŶǀŝƌŽŶŵĞŶƚ͘ĂƚĂ ĨƌŽŵƵŶƚƌĞĂƚĞĚƐĂŵƉůĞƐ

ĂƌĞƐƚŝůůƌĞƋƵŝƌĞĚƚŽŵĂŬĞƚŚŝƐĞǀĂůƵĂƚŝŽŶ͘

/ƚŝƐĞƐƚŝŵĂƚĞĚƚŚĂƚƚŚĞEĂǀLJ͛ƐĚƌŝŶŬŝŶŐǁĂƚĞƌǁĞůů͕ϮϮρκͲϬϭ͕ŝƐĂƉƉƌŽdžŝŵĂƚĞůLJϯ͕ϬϬϬ ĨĞĞƚĚŽǁŶͲŐƌĂĚŝĞŶƚ ĨƌŽŵ

ƚŚĞZĞĚ,ŝůůĨĂĐŝůŝƚLJ͘dŚĞƵƉƉĞƌĞŶƚƌĂŶĐĞŽĨƚŚĞŝŶĨŝůƚƌĂƚŝŽŶŐĂůůĞƌLJŝƐůŽĐĂƚĞĚĂƉƉƌŽdžŝŵĂƚĞůLJϭ͕ςϬϬĨĞĞƚĨƌŽŵdĂŶŬ

ϭ ĂŶĚ Ϯ͘   ĐĐŽƌĚŝŶŐ ƚŽ ƚŚĞ EĂǀLJ͛Ɛ ϮϬϬϳ ƉĞƚƌŽůĞƵŵ ĨĂƚĞ ĂŶĚ ƚƌĂŶƐƉŽƌƚ ŵŽĚĞů͕ ƌĞůĞĂƐĞƐ ĨƌŽŵ ƚŚĞ ƚĂŶŬ ĨĂƌŵ

ǁŽƵůĚďĞƵŶůŝŬĞůLJƚŽŵŝŐƌĂƚĞŵŽƌĞƚŚĂŶĂƉƉƌŽdžŝŵĂƚĞůLJϭ͕ϭϬϬĨĞĞƚĂǁĂLJĨƌŽŵƚŚĞƌĞůĞĂƐĞůŽĐĂƚŝŽŶĂďŽǀĞůĞǀĞůƐ

ŽĨƉŽƚĞŶƚŝĂůĐŽŶĐĞƌŶĨŽƌŝŵƉĂĐƚƐƚŽĚƌŝŶŬŝŶŐǁĂƚĞƌ͘
WĂŐĞͮϯϯ

hƐŝŶŐƚŚŝƐĚĂƚĂ͕^^Z>ƐǁĞƌĞĞƐƚĂďůŝƐŚĞĚďĂƐĞĚŽŶĚŝƐƚĂŶĐĞŽĨƚŚĞ&ĂĐŝůŝƚLJƚŽƚŚĞĞĂƐƚĞƌŶĞŶĚŽĨƚŚĞŝŶĨŝůƚƌĂƚŝŽŶ

ƚŽƚŚĞEĂǀLJ͛ƐĚƌŝŶŬŝŶŐǁĂƚĞƌǁĞůů͕ϮϮρκͲϬϭ͘dŚĞƐĞ^^Z>ƐǁĞƌĞďĂƐĞĚƵƉŽŶƚŚĞĂƐƐƵŵƉƚŝŽŶƚŚĂƚĨƌĞĞƉƌŽĚƵĐƚ

ǁŽƵůĚďĞƉƌĞƐĞŶƚŝŶƚŚĞŐƌŽƵŶĚǁĂƚĞƌĂƚƚŚĞ&ĂĐŝůŝƚLJŵŽŶŝƚŽƌŝŶŐǁĞůůƐĂŶĚĐŽƌƌĞƐƉŽŶĚƚŽƚŚĞƐŽůƵďŝůŝƚLJůŝŵŝƚŽĨ

dW,ĨƌŽŵ:WͲρĂŶĚďĞŶnjĞŶĞ͘^ŽŝůsĂƉŽƌ^^Z>ǁĂƐĂůƐŽƐĞƚ͘

dW,ŝƐ ƚŚĞ ƌŝƐŬĚƌŝǀĞƌďĞĐĂƵƐĞŵŽĚĞůŝŶŐŝŶĚŝĐĂƚĞƐ ƚŚĂƚŝƚǁŽƵůĚďĞ ƚŚĞ ĨŝƌƐƚĐŽŶƚĂŵŝŶĂŶƚŽĨĐŽŶĐĞƌŶ ƚŽ ƌĞĂĐŚ

ƵŶĂĐĐĞƉƚĂďůĞ ĐŽŶĐĞŶƚƌĂƚŝŽŶƐ ŝŶ ƚŚŝƐ ƐĐĞŶĂƌŝŽ͘KƚŚĞƌ͕ ŝŶĚŝǀŝĚƵĂů ĐŽŵƉŽƵŶĚƐ͕ ŝŶĐůƵĚŝŶŐ ďĞŶnjĞŶĞ͕ ŶĂƉŚƚŚĂůĞŶĞ

ĂŶĚŵĞƚŚLJůŶĂƉŚƚŚĂůĞŶĞ͕ŚĂǀĞĂůƐŽďĞĞŶƌĞƉŽƌƚĞĚŝŶŐƌŽƵŶĚǁĂƚĞƌƐĂŵƉůĞƐĐŽůůĞĐƚĞĚďĞŶĞĂƚŚƚŚĞZĞĚ,ŝůůƚĂŶŬƐ

ďƵƚĂƌĞůĞƐƐůŝŬĞůLJ ƚŽ ƌĞĂĐŚ ƚŚĞŝŶĨŝůƚƌĂƚŝŽŶŐĂůůĞƌLJĂŶĚĚƌŝŶŬŝŶŐǁĂƚĞƌǁĞůůĂďŽǀĞĚƌŝŶŬŝŶŐǁĂƚĞƌĂĐƚŝŽŶůĞǀĞůƐ

ĚƵĞƚŽƚŚĞŝƌŝŶŝƚŝĂůůLJǀĞƌLJůŽǁĐŽŶĐĞŶƚƌĂƚŝŽŶ͘

ĐƚŝŽŶ>ĞǀĞůdĂďůĞ

ƌŝŶŬŝŶŐtĂƚĞƌ> dĂŶŬ&Ăƌŵ^^Z> ^ŽŝůsĂƉŽƌ

dW,;ĚͿ ϭϬϬ;ђŐͬ>Ϳ κ͕ρϬϬ;ђŐͬ>Ϳ ϮΘϬ͕ϬϬϬђŐͬŵϯ

ĞŶnjĞŶĞ ρ;ђŐͬ>Ϳ ϳρϬ;ђŐͬ>Ϳ E

K,ŚĂƐĞdžĂŵŝŶĞĚƚŚĞƐĞƐƚƵĚŝĞƐĂŶĚĂĐĐĞƉƚƐĂƉƉƌŽƉƌŝĂƚĞŶĞƐƐĂŶĚĂƉƉůŝĐĂďŝůŝƚLJŽĨƚŚĞƐĞ^^Z>Ɛ͕ƉƌŽǀŝĚĞĚƚŚĂƚ

ƚŚĞLJďĞƌĞǀŝĞǁĞĚĂƐĂĚĚŝƚŝŽŶĂůĚĂƚĂĂƌĞĐŽůůĞĐƚĞĚĨƌŽŵƚŚĞƐŝƚĞ͘

dŚĞ ^^Z>Ɛ ǁĞƌĞ ŝŶĐŽƌƉŽƌĂƚĞĚ ŝŶƚŽ ƚŚĞ ZĞĚ ,ŝůů 'ƌŽƵŶĚǁĂƚĞƌ WƌŽƚĞĐƚŝŽŶ WůĂŶ͘ dŚŝƐ ƉůĂŶ ǁĂƐ ĚĞǀĞůŽƉĞĚ ƚŽ

ŵŝƚŝŐĂƚĞ ƚŚĞ ƌŝƐŬ ĂƐƐŽĐŝĂƚĞĚ ǁŝƚŚ ŝŶĂĚǀĞƌƚĞŶƚ ƌĞůĞĂƐĞƐ ŽĨ ĨƵĞů ĨƌŽŵ ZĞĚ ,ŝůů ĂŶĚ ƚŽ ƉƌŽǀŝĚĞ ĂŶ ŽǀĞƌǀŝĞǁ ŽĨ

ĂĐƚŝŽŶƐ;ŽƌĐŽŶƚŝŶŐĞŶĐLJƉůĂŶƐͿƚŚĂƚǁŽƵůĚďĞƌĞƋƵŝƌĞĚĨŽƌĚĞƚĞĐƚŝŽŶƐďĞůŽǁďƵƚĂƉƉƌŽĂĐŚŝŶŐƚŚĞ^^Z>ƐĂƐǁĞůů

ĂƐ ĂĐƚŝŽŶƐ ƚŽ ŵŝƚŝŐĂƚĞ ůĂƌŐĞ ƌĞůĞĂƐĞƐ ŝĨ ƚŚĞLJ ǁĞƌĞ ƚŽ ŵŝŐƌĂƚĞ ƚŽ ƚŚĞ ǁĂƚĞƌ ƚĂďůĞ͘ &Žƌ ŝŶƐƚĂŶĐĞ ŝĨ Z,DtϬϮ

ĞdžĐĞĞĚƐ ϭͬϮdž ^^Z> Žƌ Ϯ͕ϮρϬ ƉƉď ƚŚĞŶ ƌĞƉŽƌƚŝŶŐ͕ ŵŽŶŝƚŽƌŝŶŐ ĂŶĚ ŝŵŵĞĚŝĂƚĞ ĞǀĂůƵĂƚŝŽŶ ŽĨ ƚĂŶŬƐ ĨŽƌ ůĞĂŬƐ

ǁŽƵůĚďĞƌĞƋƵŝƌĞĚ͘

/ƚĂůƐŽŝŶĐůƵĚĞƐƋƵĂůŝƚLJĂƐƐƵƌĂŶĐĞƉƌŽũĞĐƚƉůĂŶƐĨŽƌƐĂŵƉůŝŶŐĂŶĚĂŶĂůLJƐŝƐ͘

dŚŝƐƉůĂŶŝƐƵƉĚĂƚĞĚƉĞƌŝŽĚŝĐĂůůLJĂŶĚƐƵďŵŝƚƚĞĚƚŽK,ĨŽƌĂƉƉƌŽǀĂů͘

dŚĞƐĞƉůĂŶƐĂƌĞĂǀĂŝůĂďůĞŽŶůŝŶĞĂƚ͗ŚƚƚƉ͗ͬͬŚĞĂůƚŚ͘ŚĂǁĂŝŝ͘ŐŽǀͬƐŚǁďͬƵŶĚĞƌŐƌŽƵŶĚͲƐƚŽƌĂŐĞͲƚĂŶŬƐͬ͘

• 2008 Red Hill Groundwater Protection Plan: 2008GWprot.pdf

• 2010 Re-evaluation of the Tier III Risk Assessment: 2010RedHillTierIII
WĂŐĞͮϯκ

Diagram 1 

 Locations of the seven monitoring wells routinely tested by the Navy in green, and the 

two new sentinel wells north installed in Sep/Oct 2014 in blue.