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From:

Sent: Friday, June 19, 2015 2:49 PM

To: RedHill

Subject: Public comments on Red Hill AOC and SOW 

Follow Up Flag: Follow up

Flag Status: Flagged

Remarks on the AOC and its SOW:

1. The AOC lacks a sense of urgency, especially when it's been established that there have been multiple

releases of contaminants into the groundwater. Immediate action is required.

2. The first order of business is to install more monitoring wells in appropriate locations around the facility, and to

immediately start monitoring for the type of fuel (and its byproducts) released from Tank 5, especially since not even

experts agree on which direction the groundwater is flowing.  

a. Rate of flow of groundwater does not seem to be known, but new data from monitoring wells may be able to

contribute to establishing functional time windows for action, and functional time frames for handling activities

described in the SOW deliverables.

b. Groundwater in Hawaii most often consists of a freshwater "lens" sitting atop salt water. If the level of salt water in

the aquifer changes for whatever reason, or overpumping of freshwater in neighboring locations occurs, the direction of

flow of the groundwater can theoretically change. The idea of a unidirectional flow model for the aquifer seems

oversimplified. Only data from monitoring wells can establish a data‐based rationale for addressing potential

contamination in the groundwater.

3. In the Corrosion section of the SOW, there should be immediate efforts to reduce the rate of corrosion in existing

Tanks that are not scheduled for routine maintenance within the next two years.  

4. Corrosion. Note that not all stainless steels are alike. Stainless steel alloys of differing electrochemical properties (e.g.,

stainless steel A plates welded to stainless steel B tank walls) can induce small electrical currents, resulting in corrosion.

Noninvasive approaches such as Cathodic protection with sacrificial anodes should be considered to be introduced as a

stopgap measure to reduce corrosion rates in Tanks waiting to be upgraded. Of course testing needs to be done first to

establish the types of materials in use in each Tank, especially as they may not all be of the same identical materials.  

5. There does not seem to be an Emergency Response Plan in place; one should be established. Neither the

Navy's Groundwater Protection Plan nor the AOC document itself references an Emergency Response Plan specifically

for the Facility. The AOC Section 8.a.2 says that Navy and DLA shall take "all appropriate actions to prevent or minimize

the threat", and then notify the Regulatory Agencies. An Emergency Response Plan should contain a sequence of steps

to be taken immediately upon detection of a possible release of stored materials into the environment. People in an

emergency don't always think clearly, so an Emergency Response Plan is necessary. This Emergency Response Plan

should also incorporate overlapping responsibilities and/or shared oversight among other governmental entities,

including the Board of Water Supply, State Department of Health, and other organizations. There should be a

mechanism for Annual Practice Drills and for regular updates to the Plan.

6. Develop a plan for recovery or remediation for existing contamination that may be detected in the groundwater as

monitoring continues, and for any future releases of contaminants. The Recovery and Remediation plan should be

specific to the type of fuel released, and should include short‐term (days to weeks), medium‐term (months) and long‐

term components (years). Include financial responsibility and funding guidelines.
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7. Section 6 of the AOC is ambiguous; it was only in the Public Hearing that I learned that remediation in the AOC refers

to remediation of the Tanks, not of groundwater. If Section 6 refers to remediation of Tanks, it should say so explicitly.

8. A report on the health effects of exposure to groundwater contamination by stored fuels and their byproducts should

be commissioned. Any bioactive and/or toxic constituents of these fuels and byproducts should be identified.  

9. The AOC is supposed to expand and update the Navy’s Groundwater Protection Plan, but this plan only specifies

protection of the Navy’s well. There are 5 other public drinking water wells that are in the vicinity of the Facility. The

AOC needs to specify that these particular wells (as well as specified aquifers) are to be included for protection, and to

name the governmental entities to be responsible for performing work‐to‐be‐specified (since, for example, the Navy

cannot work on public wells without proper authority, and vice versa).