1 From: Sent: Wednesday, June 24, 2015 9:35 PM To: RedHill Subject: Strongly Oppose
Follow Up Flag: Follow up Flag Status: Flagged

Dear Environmental Protection Agency,
My family and I STRONGLY OPPOSE the subject Administrative Order on Consent (AOC) for the following

reasons:
1. The Statement of Work (SOW) att ached to the AOC allows the United States Department of Navy and the Defense Logistics Agency up to 22 years from the effec tive date of the AOC to upgrade the 20 aging Red Hill fuel tank structures. This timeframe is outrageously too long and needs to be accelerated , considering that the structures:

a. Were built in the 1940s and so now are already 72 - 75 years old,
b. Are already corroding and known to have leaked sin ce as far back as 1947 (a round 68 years ago!) and as recently as 2014,
c. Have already contaminated the groundwat er and rocks underneath the tanks, and
d. Will likely cause more serious contamination of our groundwater within 22 years, when the tanks will be around 100 years old. Catastrophic contamination is even po ssible from an event such as an earthquake, which could very well occur anytim e in the next 22 years.
The people of Oahu have waited long e nough and cannot afford to wait anothe r 22 years for action to finally be completed, where clean drinking water is essent ial to our very survival! We feel that a timeline for complete replacement of the tanks with bett er double-lined ones, by no more than 5 years or less, would be more reasonable.

2. We are astounded and incensed that there is no sense of urgency reflected in the AOC and SOW to address even the existing, known contamination problem. In th e early 2000s, the Navy already found petroleum stains in the bedrock under 19 of the 20 tanks, which indicat ed leaking. In 2014, there wa s a 27,000 gallon leak of jet fuel from one of the tanks. As stated by the Board of Water Supply in their te stimony dated June 18, 2015, “ the AOC needs to require clean-up of the contamin ation that is presently in the groundwater and rocks underneath the tanks to reduce the amount available fo r migration to those parts of the aquifer that are still uncontaminated .” Immediate action must be required. Why must we wait for the contamination to worsen before taking action, when it will be too late?

3. The AOC should not provide for studies and pilot programs of un known duration to be conducted before further remediation action can proceed. Historically, bureaucra tic government studies and pilots invariably result in lengthy, years-lo ng delays and ultimately add to overall costs for taxpayers. The Board of Water Supply testified that the AOC ad ministrative record indicates that past studies were already done and identified potential improvements which have yet to be acted upon. Furthermore, it appears that the Navy already had similar experiences w ith upgrading tank structures in 1998 and 2008, which must have been2 preceded by studies (See SOW, page 1). Therefore, the AOC should first state whether or not such past studies were, in fact, previously done and why recommendations presented in those studies were not implemented.
4. While the Department of Health would be a signator y for the AOC, would that then bind the Board of Water Supply and its customers to the AOC as well, and preclud e the parties from seeking reimbursement for expenses that may be incurred: (1) to clean-up contaminated water and (2) to pursue alternatives to take the place of contaminated water that is deemed prohibiti ve to treat? If so, then we feel that the Board of Water Supply needs to be a party to the AOC discussions/develo pment to represent the Oahu community’s interests. In addition, federal reimbursement of expenses for cl ean-up and water source alternatives need to be required in the AOC . Responsibility for increased costs must be borne by the party responsible for causing the problem, and not by innocent Oahu citizens.
Finally, we object to the s hort 30-day time period for your agency to receive comments on such a critical matter. As pointed out by the Board of Water Supply in their testimony dated June 18, 2015, not all information was made available until midway th rough the comment period. Therefore, we urge that an extension be granted, until July 31, 2015 , to allow the Board of Water Supply and concerned citizens who are only now becoming aware of the issue to provide comments, and he lp reassure that this is a meaningful, transparent process.
We respectfully ask that you consider our comments and recommendations. Thank you.