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UNITED STATES ENViRONMENTAL 

PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

0. 

 1 ~.

v 

STATE OF HAWAII 

DEPARTMENT OF HEALTH 

P. 0, BOX 3378 

HONOLULU, HI 96801-3378 

September 17, 2014 

Mr. Aaron Poentis 

Program Director 

Enviroru-nental Department 

Navy Region Hawaii 

850 Ticonderoga St., Suite 110 

Pearl Harbor, I -lawaii 96860 

Re: Red Hill Bulk Fuel Storage Facility - Work Plan/Sampling and Analysis Plan: Tank 5 

Area Characterization ("Tank 5 Workplan") 

DOH Facility ID No. 9-102271 / DOH Release ID No. 140010 

Dear Mr. Poentis: 

The Hawaii Department of Healtli ("DOH") and the U.S. Environmental Protection Agency 

("EPA") have reviewed the draft Tank 5 Workplan dated July 2014. In the Tank 5 Workplan, 

the Navy proposes to install wells and vapor monitoring points undemeath and near Tank 5 for 

the purposes of testing for the presence of light non-aqueous phase liquid ("LNAPL") in the 

basalt rock below the tank, evaluating the exteilt of fuel in vapor within the unsaturated zoiie of 

the basalt below the Tank, and utilizing the data collected to model the downward migration of 

LNAPL towards the aquifer. 

The DOH and EPA are concemed that the limited scope of work proposed in the Tank 5 

Workplan may not satisfy the workplan's stated objectives or the Navy's rcgulatory requirements 

under Hawaii Administrative Rules (HAR) § 11-281-76. Nevertlieless, the Navy may perform 

the work outlined in the Tank 5 Workplan in order to gain insights to the extent of contamination 

below Tank 5 after addressing the following comments: 

The Navy shall modify their drilling procedures in a manner to eliminate the spread of 

contamination and prevent the creation of pathways that could cause accelerated 

contaminant migration. The workplan shall include a description of the drilling 

procedures and contingency plans that will be implemented during drilling activities in 

the event that LNAPL is encountered prior to boreliole completion. If LNAPL is 
Mr. Aaron Poentis 

September 17,2014 

Pagc 2 

encountered during drilling the Navy shall consult with the DOH and EPA before 

recommencing drilling. 

2) The Navy shall modify the plan to include geophysical logging of boreholes to the 

niaximum extent practicable in order to aid in the development/refinement of the 

conceptual flow and transport model of releases fi-om the facility. The Navy shall 

provide a written geophysical logging plan to the DOH and EPA for approval. 

3) The modeling approach outlined in the Tank 5 Workplan relies on the use of a soil-based 

model which is not applicable for the Red Hill hydrogeologic setting. The Navy sliall 

refine the modeling plans and provide thorough justification regarding the applicability of 

the proposed site specific modeling methods for use in a basalt geologic environment. 

4) The Navy's sainpling and analysis plan for this work shall include all historic 

components of fuel stored at the facility. This includes the lead scavengers that may have 

been present in the leaded fuel. 

5) The Navy shall propose an implementation schedule in coordination with the DOH and 

EPA in order to facilitate appropriate regulatory agency oversight, as necessary. 

Although a revised Tank 5 Workplan may provide some information on the downward migration 

of contaminants starting from the bottom of Tank 5, it addresses only part of the Navy's 

obligations. HAR § I 1-281-63(b)(2) requires owners and operators of confirmed releases to 

repair or replace the UST or tank system, begin release response actions and to conduct a site 

assessment that measures for the presence of a release where contamination is most likely to be 

present. 

In weekly reports the Navy has stated that 17 potential release points have been identified on the 

interior of Tank 5. The workplan submitted does not address the presence of contamination that 

most likely exists near the 17 potential release points identified during the re-iiispection ofI'ank 

5. 

Within 30 days from the date of this letter, the Navy shall revise the Tank 5 workplan in order 

to address the numbered points above. The Navy shall not begin implementation of this work 

until they receive written approval from the DOH. 

Within 60 days from the date of this letter, the Navy shall submit a workplan for additional 

work that describes how the Navy will investigate the nature and extent of the releases from the 

locations where release poiiits were identified in order to comply with Hawaii's regulations. 

Additionally, the workplan sliall include all data and procedures used to identify these tank 

deficiencies, including, but not limited to photographs, vacuum box tests, and non-destructive 

testing data. 
Mr. Aaron Poentis 

September 17, 2014 

Page 3 

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

Solid and Hazardous Waste Branch at (808) 586-4226 or steven.chang@doh.hawaii.gov , or 

Mr. Steven Linder, Manager of US EPA's Underground Storage Tank Program at 

(415) 972-3369 or linder.steven@epa.gov . 

Si e

S~ 4LERz=MANAGER 

Underground Storage Tank Program 

US EPA, Region 9 

~~~ 

STEVEN CHA.NG, P.E. F ....,_s 

Solid and Hazardous Waste Branch 

Department of Health 

c: Mr. Gary Gill, Deputy Director, Department of Health 

Mr. Stuart Yamada, DOH-Environmental Management Division 

Ms. Joanna Seto, DOH-Safe Drinking Water Branch 

Mr. Roger Brewer, DOH-Hazard Evaluation and Emergency Response Office 

Mr. Keith Kawaoka, DOH-Hazard Evaluation and Emergency Response Office