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) attached to the AOC allows the United States Department of Navy and the 

Defense Logistics Agency up to 22 years from the effective 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 since as far back as 1947 (around 68 years ago!) and as 

recently as 2014, 

c. Have already contaminated the groundwater 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 possible from an event such as an earthquake, which 

could very well occur anytime in the next 22 years. 

The people of Oahu have waited long enough and cannot afford to wait another 22 years for action to finally be 

completed, where clean drinking water is essential to our very survival! We feel that a timeline for complete 

replacement of the tanks with better 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 the early 2000s, the Navy already found petroleum stains 

in the bedrock under 19 of the 20 tanks, which indicated leaking. In 2014, there was a 27,000 gallon leak of jet 

fuel from one of the tanks. As stated by the Board of Water Supply in their testimony dated June 18, 2015, “the 

AOC needs to require clean-up of the contamination that is presently in the groundwater and rocks 

underneath the tanks to reduce the amount available for 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 unknown duration to be conducted

before further remediation action can proceed. Historically, bureaucratic government studies and pilots 

invariably result in lengthy, years-long delays and ultimately add to overall costs for taxpayers. The Board of 

Water Supply testified that the AOC administrative 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 with upgrading tank structures in 1998 and 2008, which must have been 
2

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 signatory for the AOC, would that then bind the Board of Water 

Supply and its customers to the AOC as well, and preclude 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 prohibitive to treat? If so, then we feel that the Board of Water Supply 

needs to be a party to the AOC discussions/development to represent the Oahu community’s interests. In 

addition, federal reimbursement of expenses for clean-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 short 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 through 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 help reassure that this is a meaningful, transparent 

process. 

We respectfully ask that you consider our comments and recommendations. Thank you.