BWS AOC/SOC Comments ... BWS AOC/SOC Comments July 20, 2015 Page 4 major stakeholders, will present

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  • BWS AOC/SOC Comments July 20, 2015 Page 2 how the implementations are to be evaluated, and how the Parties are to communicate and resolve disputes. The SOW describes tasks and requirements that the Navy and DLA must complete to comply with the AOC, specifically, to deploy the best available practicable technology (BAPT) to prevent fuel releases, to develop a better understanding of the hydrogeology of the area surrounding the Facility, and to conduct an assessment of the risk to the groundwater resources that is posed by the Facility (US EPA and Hawaii DOH, 2015b). The BWS cannot support the AOC or SOW as currently written. Our evaluation has identified critical issues in the proposed documents that render the AOC and SOW “inappropriate, improper, or inadequate,” per AOC Section 23 (a). We strongly recommend that the documents be revised to:

    1. Ensure appropriate characterization and remediation of past sub-surface contaminants in the vadose zone and saturated zone in concert with installation of a well-designed monitoring well network.

    2. Rehabilitate the Facility tanks to arrest the decades of corrosion to the tanks’ thin steel plates and so eliminate the threat to our drinking water from new fuel releases.

    3. Shorten the time frames to complete tank and pipeline rehabilitation, remediate past fuel releases, and comply with regulations.

    4. Include proper consultation and participation by the major stakeholders and the public.

    5. The AOC and SOW need to require full (without censoring) disclosure and access to all records, data, and studies about fuel leaks at the Facility over its history.

    6. Appropriately follow the most stringent applicable regulatory standards and guidelines.

    7. Commit the necessary funding to carry out this work and quickly put in place the necessary protections for our drinking water supply.

    The proposed AOC and SOW do not recognize that the Waimalu and Moanalua aquifers are part of the US EPA-designated Sole Source Aquifer called the Southern Oahu Basal Aquifer. This Sole Source Aquifer, which was designated in 1987, is the primary groundwater resource for the majority of the nearly one million residents and visitors on the island of Oahu. It is vital that the Parties base all of their decisions and actions for the Facility on the fact that the Southern Oahu Basal Aquifer is the only one of its kind on the island and there are no cost-effective water supply alternatives. Currently, the BWS wells nearest to the Facility appear to show no contamination from the Facility. The BWS strongly recommends that the proposed AOC and SOW be revised as described in our comments below to properly safeguard our drinking water supply from past and future releases from the Facility’s aging and corroding fuel tanks. BWS is ready to work with the Parties to expedite resolution of the important problems described below and thereby expedite mitigation of the risk posed by the Facility to our groundwater supply.

  • BWS AOC/SOC Comments July 20, 2015 Page 3 Our comments on the AOC are presented in Section 2, and our comments on the SOW are given in Section 3. Each of these sections begins with a summary of the most important comments, followed by individual detailed comments. Section 4 lists the references cited. 2.0 AOC COMMENTS 2.1 AOC Comment Summary

    1. The AOC should be revised to emphasize the fact that the Facility in its current state poses a serious risk to the Waimalu and Moanalua aquifers that underlie the Facility and to the Halawa Shaft and Moanalua Wells, which are the public water supply wells nearest to the Facility. The Halawa Shaft and Moanalua Wells provide 25% of the drinking water to our metropolitan Honolulu water system, which serves approximately 400,000 residents from Moanalua to Hawaii Kai. The AOC should be revised to state that the Facility poses a serious risk to the aquifers and metropolitan Honolulu water system and state the population size that is dependent on the Halawa Shaft and Moanalua Wells. It should also be revised to emphasize the risk the Facility poses to the Navy’s Red Hill Shaft which provides 20% of the drinking water for Joint Base Pearl Harbor-Hickam.

    2. The AOC ignores the fact that the Facility is located within the boundaries of the Southern Oahu Basal Aquifer, which was designated by US EPA Region 9 in 1987 as a Sole Source Aquifer under the authority of Section 1424(e) of the Safe Drinking Water Act (Federal Register Citation 52 FR 45496 11/30/1987). The Southern Oahu Basal Aquifer encompasses the Waimalu and Moanalua aquifers as well as the Facility. The Sole Source Aquifer designation requires appropriate assessment of potential impacts from all federally funded projects on the Southern Oahu Basal Aquifer, thus the AOC should be revised to incorporate the Sole Source Aquifer regulatory and procedural requirements.

    3. The AOC and its SOW should be revised to clearly state that the Parties will determine the current location and appropriately characterize the fate of the approximately 27,000 gallons of fuel released in January 2014 in a timely manner, and that the Parties will then proceed with remediation of the light non-aqueous phase liquid (LNAPL), sorbed, and dissolved-phase contamination caused by that fuel release as quickly as possible.

    4. The AOC unacceptably limits participation by major stakeholders, most notably the BWS, in scoping, review, and decision-making activities, as well as in the development of the initial and revised AOC and SOW documents. This should be resolved by including representatives from the major stakeholders in all scoping, review, and decision-making activities. Major stakeholders include, but are not limited to, the BWS, the City and County of Honolulu, and the Commission on Water Resource Management (Hawaii Department of Land and Natural Resources).

    5. The AOC lacks public transparency by limiting communication with and participation by the public at regular intervals, which are routinely included as part of remediation planning at other major contaminated Department of Defense (DOD) sites. The AOC should be revised to require regular public meetings in which the Parties, together with

  • BWS AOC/SOC Comments July 20, 2015 Page 4

    major stakeholders, will present recent findings, discuss next steps, and hold open question-and-answer periods for public participation.

    6. The AOC should be revised to require that all work performed by the Navy and DLA under the AOC meets the most stringent and protective regulations, including the newly updated UST regulations from US EPA (US EPA, 2015). The AOC should be revised to require that the work performed by the Navy and DLA under the AOC always achieves the highest degree of protection of the vadose zone underlying the Facility tanks, the underlying Waimalu and Moanalua aquifers (part of the greater Southern Oahu Basal Sole Source Aquifer), all water supplies, and the surrounding environment. Under no circumstances should future agreements negotiated by the Parties reduce these protections under the AOC. We strongly recommend that the Hawaii DOH adopt the newly updated US EPA UST regulations as part of the Hawaii UST program without delay

    7. According to the AOC Administrative Record, the Navy and DLA have not implemented technologies that have been available since the 1980s to slow the rate of tank corrosion and reduce leakage at the Facility. Damage to the field-constructed USTs at Red Hill from corrosion and fatigue is progressive and accumulates over time. The Red Hill tanks have been in service for more than 70 years and have experienced both internal and external corrosion (Anonymous, Undated; Weston, 2007a; Weston, 2007b). These tanks have never been cathodically protected; consequently, the corrosion continues unabated, which means that the frequency and magnitude of fuel releases from the tanks will continue to increase. Given that the Navy and DLA must soon act to bring the Facility tanks and associated piping in compliance with the newly updated EPA UST regulations (US EPA, 2015), the AOC should be revised to clearly state the steps and timeline for achieving compliance.

    The AOC revisions should clearly state that the Facility tanks and pipelines will receive leak detection and secondary containment (with cathodic protection) upgrades required under the newly updated US EPA UST regulations within the next several years or shortest time possible and state the process and timeline for achieving these upgrades. Installing a tank-within-a-tank or composite tank lining will greatly reduce the frequency and magnitude of fuel releases from the Facility tanks. Prior comprehensive, government- funded engineering evaluations commissioned by the Navy or DLA have already yielded various options for repairing the Red Hill tanks, e.g., Enterprise Engineering Inc. (2008a), including options that may provide long-term, i.e., 40-year, life extension. This report estimated that the recommended repair options would require less than 3.5 years to implement for all tanks (Enterprise Engineering Inc., 2008a).

    8. The Navy and DLA unacceptably restrict access to information about fuel releases and other environmental impacts from the Facility. Out of eight Freedom of Information Act (FOIA) requests filed with the Navy by BWS between 10 June 2014 and 19 May 2015, only two have been fulfilled (see comment # 26 in Section 2.2 below). The AOC should be revised to require full disclosure of all Facility records, studies, reports, fuel inventory records (and tank gauger log books), and documents and data about the nature,