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 Councilwoman 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 

production 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 Primary 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 and 
State 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 these parts would ultimately describe the consequential contamination of 

Honolulu’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 

actually 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. New data from the other SOW tasks may subsequently 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