STATE OF HAWAII 

 DEPARTMENT OF HEALTH 

P. O. BOX 3378 

 HONOLULU, HI 96801-3378 

February 12, 2014 U0204RT 

Mr. Aaron Poentis 

Program Director 

Environmental Department 

Navy Region Hawaii 

850 Ticonderoga St. Suite 110 

Pearl Harbor, Hawaii 96860 

Dear Mr. Poentis: 

SUBJECT: Red Hill Tank Complex 

 Facility ID 9-102271/Release ID 140010 

The U.S. Navy notified the Department of Health’s Hazard Evaluation and Emergency 

Response (HEER) Office on Monday, January 13, 2014 to report a suspected 

underground storage tank release from Tank 5 of the Red Hill Tank Complex. The 

capacity of the tank is 12.7 million gallons. The DOH-HEER Office initiated an Incident 

Command structure and began gathering data from the Navy and coordinating the DOH 

response. Meetings were conducted by the DOH-HEER Office with participants from 

the Navy, DOH-Safe Drinking Water Branch, DOH-Solid and Hazardous Waste’s 

Underground Storage Tank (UST) Section, and the Honolulu Board of Water Supply. 

This letter will address the requirements of the DOH-UST Program and the regulations 

governing USTs under Hawaii Administrative Rules (HAR) Chapter 11-281 

Underground Storage Tanks http://gen.doh.hawaii.gov/sites/har/AdmRules1/11-281.pdf

Monitoring of oil/water interface probes, soil vapor, and groundwater monitoring wells 

have been performed at increased frequency since the release was discovered. The 

DOH-HEER Office, Safe Drinking Water Branch, and UST Section have provided 

comments and approved the proposed short-term increased monitoring schedule that 

will continue monitoring of these parameters until July 2014, with increased monitoring 

frequency specified if increasing concentrations are found. 

The Initial Release Response Report is due within 90 days of reporting a confirmed 

UST release. The DOH received the Confirmation of UST Release form on 

January 24, 2014. 

NEIL ABERCROMBIE

GOVERNOR OF HAWAII 

DIRECTOR OF HEALTH 

In reply, please refer to:

File:
Mr. Aaron Poentis 

February 12, 2014 

Page 2 

Please also include the following information in your Initial Release Response Report: 

1. Date and time release was discovered. 

2. Method of detection and measurements and calculations for determining fuel 

lost. 

3. Time interval between discovery of release and commencement of tank draining. 

4. Time interval to drain tank to bottom and remove all residual product. 

5. Modification of 2008 Groundwater Protection Plan and 2009 revisions to comply 

with the requirements of Environmental Hazard Evaluations as specified in the 

DOH-HEER Guidance. 

6. Models to estimate groundwater flow and capture zones using recent local 

groundwater elevations for the Navy’s drinking water pump station and Honolulu 

Board of Water Supply wells. 

The facility is unique in both construction and storage capacity. As responsible parties 

of this UST system, the Navy is responsible for compliance with Subchapter 7, “Release 

Response Action.” Certain requirements that are routine for a UST release at a retail 

gasoline facility may be difficult to achieve for this subterranean facility constructed 

within the basalt. 

In addition to the Initial Release Response Report, the DOH requests a preliminary 

Work Plan report to discuss methods for achieving the requirements of HAR 11-281 

Subchapter 7. Please complete the preliminary report within 30 days of your receipt of 

this letter and discuss with the DOH if you encounter any challenges or obstacles to this 

deadline. The following should be included in the preliminary Work Plan report: 

1. Models to estimate downward vertical migration of free product. 

2. Methods or options for non-invasive scanning of basalt to determine area and 

volume of contaminant mass prior to any drilling investigation. 

3. Methods and locations for borings to most efficiently characterize the extent of 

contamination. 

Following review, the DOH-UST Section would like to meet with the Navy and other 

interested parties to discuss selection of methods before the final work plan is prepared 

and work commences. 

 

The DOH-UST Section uses the DOH-HEER guidance for Environmental Action Levels 

(EALs), Environmental Hazard Evaluations (EHEs) and Environmental Hazard 

Management Plans. All sites with contamination exceeding the DOH-HEER EALs are 
Mr. Aaron Poentis 

February 12, 2014 

Page 3 

required to prepare an EHE. The data provided previously for the comprehensive risk 

assessment may be used and updated with data obtained since 2008. 

The DOH-HEER EAL guidance: http://eha-web.doh.hawaii.gov/ehacma/Leaders/HEER/environmental-hazard-evaluation-and-environmental-action-levels

The DOH-HEER Technical Guidance Manual (TGM) http://www.hawaiidoh.org/. For 

petroleum guidance and use of EALs, including for soil vapor sampling. The DOH-UST 

Section does not currently require multi-increment sampling for UST release sites but it 

is an option if responsible parties wish to perform MIS according to the DOH-HEER 

TGM. 

The DOH UST homepage: http://health.hawaii.gov/shwb/underground-storage-tanks/.

If you have any questions regarding this letter, please contact Mr. Steven Chang, 

Program Manager, Solid & Hazardous Waste Branch at (808) 586-4226. 

 

Sincerely, 

 STUART YAMADA, P.E., CHIEF 

 Environmental Management Division 

c: Gary Gill, Deputy Director for Environmental Health 

Steven Chang, Solid and Hazardous Waste Branch 

Keith Kawaoka, Hazard Evaluation and Emergency Response Office 

Joanna Seto, Safe Drinking Water Branch 

Roger Brewer, Hazard Evaluation and Emergency Response Office 

Ernest Lau, Honolulu Board of Water Supply 

Wade Hargrove III, Hawaii Department of the Attorney General 

Steven Linder, EPA Region 9 

Bob Pallarino, EPA Region 9 

Roy Hardy, Department of Land and Natural Resources 
Mr. Aaron Poentis 

February 12, 2014 

Page 4 

DOCUMENT TRACKING FORM

Action By Date

1

st draft RT 02.07.14 

Revised RT 02.10.14 

Revised RT 02.10.14 

Revised RT 02.11.14 

To md Rk 2/12/14 

Finalized for signature Md 2/12/14 

c: 

Gary Gill, Deputy Director of Health 

Keith Kawaoka, DOH HEER Office 

Joanna Seto, Safe Drinking Water Branch 

Dr. Roger Brewer, DOH-HEER Office 

Ernest Lau, Honolulu Board of Water Supply 

Wade Hargrove III, Hawaii Dept of the Attorney General 

Steven Linder, EPA Region 9 

Bob Pallarino, EPA Region 9 

Roy Hardy, DLNR