BWS AOC/SOC Comments
July 20, 2015
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
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
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
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
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
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,