16 July 2015

Solid and Hazardous Waste Branch

– Attn: Red Hill Hawai’i Department of Health
919 Ala Moana Boulevard #212 Honolulu, HI 96814

Dear Sirs:

1. As a resident of the section of Honolulu potentially affected by the Red Hill Bulk Fuel Storage Facility, the recent letter from the Board of Water Supply (BWS) and articles in the Star Advertiser have prompted a growing concern on my part. Following a discussion with staff at Councilwo man Fukunaga’s office and review of the EPA and DOH websites, I reviewed the Administrative Order on Consent (AOC) and its associated Statement of Work (SOW) in addition to the Ground Water Protection Plan (GWPP) of 2008 and its 2009 and 2010 updates.

2. The BWS letter says that it draws water from the same aquifer that the Red Hill facility has the potential to contaminate. This is confirmed by the GWPP 2010 update which says that the Pearl Harbor Water System (PHWS) well 2254-01 and the BWS Halawa shaft are both down gradient from the Red Hill Facility. The reports also make it clear that it is the PHWS well 2254-01 supplying 24

– 33% of the Pearl Harbor water supply that is most at risk from Red Hill facility leakage. It is not clear that given the

p roduction rate of other wells on Oahu that there would be excess capacity to make up the shortage for Pearl Harbor should 2254-01 become contaminated. An even larger concern would be the contamination of the Halawa shaft production which supplies drinking water to Honolulu’s Pr imary Urban Center which covers approximately 48% of Honolulu’ s population.

3. The AOC’s SOW lays out nine separate tasks investigating multiple aspects of the problem from on-going maintenance to potential failure mechanisms, possible remediation of releases, better monitoring and modeling, and finally risk/vulnerability assessment. From a cursory review of the SOW, I have three questions or concerns.

4. First, the task for the investigation and remediation of releases seems to call for its primary report 24 months after task initiation. Yet, the task calls for a deliverable to include “an evaluation and discussion of potential remediation methods for the January 2014 Tank #5 release and any future

releases. ” Is this a separate deliverable? If so, what is its due date? Why would this report not already

available some 18 months after the January 2014 incident? If part of the primary report, why would this

need to be included as a deliverable some 24 months from now in 2017?

5. Second, the risk/ vulnerability assessment task of the SOW is problematic. Given the extensive work that has gone on for decades and certainly including the work supporting the GWPP reports, why can’t a preliminary risk assessment be made immediately, based on current knowledge and processes, and then updated as new data is produced from other SOW efforts? Crucially, if the risk to Honolulu’s water supply is evaluated to be significant and no effective and efficient remediation measures for potential spillage can be identified, then the combination would present a worst case possibility and the Navy andState of Hawaii would be negligent to ignore the possibility for an additional 18 months waiting for the

first risk/ vulnerability report called for under the SOW.

6. Third, while my understanding of risk analysis is limited, I believe it normally is broken down into probability or likelihood of an event versus the consequences of the event. In the case of a fuel spill contaminating drinking water supplies, I would think the consequences would be quantified, at the minimum, by size of spill (rate and duration), effectiveness of detection, and the effectiveness of

remediation. The sum of the se parts would ultimately describe the consequential contamination of

Honolu lu’s drinking water. Strangely, the primary report from the Remediation of Releases task discussed above is due after 24 months versus the 18 month lag for the Risk/Vulnerability report and so remediation data [due 6 months later] is clearly not expected to be part of the planned risk assessment.

7. As a hypothetical example, if granular activated carbon filtering is called for [a possibility mentioned for the Waiawa well in the GWPP] but it takes 18 - 24 months to fund, contract, procure, and

ac tually install such a system, then the response time may be totally inappropriate for the urgency and magnitude of the problem and it would be prudent to start some of the longer lead-time preparations immediately. N ew data from the other SOW tasks may su bsequently justify the downgrading of the risk or upgrading of remediation effectiveness estimates but a clear risk assessment including remediation measures, available in the near term, based on currently available data, should be the starting point for

AOC efforts.

8. In view of the three concerns and the hypothetical response scenario outlined above, I believe that the SOW should be modified to require that baseline estimates of risk and the effectiveness of remediation measures should be produced in the near term [30 to 60 days] and then modified as data from the SOW tasks is made available. By any measure, threats to the drinking water for nearly half of Honolulu’s population need to be taken seriously and addressed in a prompt, professional manner.

Sincerely,

cc: Carol Fukunaga’s office – City Council

cc: EPA at RedHill@epa.gov

file: Ltr to EPA re Red Hill Storage Facility 150715