THE CARROLL COX SHOW

Subject: Red Hill Bulk Fuel Storage Facility
From: "Yamada, Stuart H" <stuart.yamada@doh.hawaii.gov>
Date: Wed, February 19, 2014 9:28 am
To: <carroll@carrollcox.com>
Cc: "Gill, Gary L." <Gary.Gill@doh.hawaii.gov>

Hi Carroll,

Per our discussion on Friday, Gary asked me to coordinate the responses to your questions.

Aloha Mr. Gill,

>> On February 5, 2014, HDOH issued a press release stating, "the State Department of Health (HDOH) is notifying the public that very low levels of lead and other chemicals have been detected in the Joint Base Pearl Harbor Hickam water system". Are all of the monitoring wells considered to be within or a part of the Joint Base Pearl Harbor Hickam water system?

No, the monitoring wells are part of the Red Hill Bulk Fuel Storage Facility. Only RHMW2254-01, which is not actually a monitoring well but the drinking water source before treatment and distribution, is part of the Joint Base Pearl Harbor-Hickam water system.

If no, would you please advise which monitoring wells are not included?

RHMW01, RHMW02, RHMW03, RHMW04, RHMW05 – The Navy has been reporting the test results for these monitoring wells since 2005 and on a quarterly basis from January 2008 to the DOH.

>> The press release also stated, " In addition, very low levels of toluene, napthalene, total petroleum hydrocarbons as gasoline ((TPH-g), total petroleum hydrocarbons as diesel (TPH-D), 1-methylnaphthalene, and- methylnaphthalene were discovered during subsequent search of historical records of groundwater monitoring at the Red Hill Shaft source". Is the Red Hill Shaft source a part of the Joint Base Pearl Harbor Hickam water system?

Yes. Please note that the Navy has been referring to the Red Hill Shaft drinking water source as RHMW2254-01 in its quarterly reports to the DOH, Solid and Hazardous Waste Branch, Underground Storage Tank Section. The Navy began testing this location in July 2008.

If not, would you please advise and identify the monitoring wells that are located in or associated with the Red Hill Shaft.

>> The press release stated, "The level of toluene was well below the drinking water Maximum Contaminant Level (MCL). The other chemicals were detected at levels well below DOH environmental action levels (EALs) and do not pose a health threat". Were the Site Specific Risk Base Level (SSRBL) used to conclude that the other chemicals were detected at levels well below DOH environmental action levels (EALs) and do not pose a health threat"?

The Solid and Hazardous Waste Branch, Underground Storage Tank Section uses the Hazard Evaluation Emergency Response Office’s (HEER) Environmental Action Levels (EALs) to evaluate sampling results at all underground Storage tank release sites.

Perhaps the following excerpt from the Executive Summary of the EAL guidance, Volume 1 may be helpful:

“The EALs are used to rapidly screen soil, soil gas and groundwater data collected for a site and identify potential environmental hazards. Under most circumstances, and within the limitations described, the presence of a chemical in soil, soil gas or groundwater at concentrations below the corresponding Tier 1 EAL can be assumed to not pose a significant threat to human health and the environment. This allows sites or portions of sites with minimal or no contamination to be quickly cleared for potential environmental concerns, a task which could easily take months or even years using a traditional, environmental risk assessment approach.”

The EALs incorporate an enormous amount of technical expertise across fields as diverse as toxicology, geology, chemistry, physics, ecology, engineering and even economics. Much like driving a car, however, it is not necessarily to understand the technical intricacies of the EALs in order to use them. As potential environmental hazards are identified, additional expertise can be brought in as deemed necessary and cost-beneficial for remediation of the contamination. Exceeding the Tier 1 EAL for a specific chemical does not necessarily indicate that the contamination poses significant environmental concerns, only that additional evaluation is warranted. A detailed review of specific hazards and preparation of alternative action levels can be carried out at the discretion of the responsible party if time- and cost-beneficial (or as otherwise required by the HEER office). This can include the preparation of a detailed, human health or ecological risk assessment, although this level of effort will rarely be required for typical sites. An Environmental Hazard Evaluation (EHE) serves as the link between site investigation activities and the selection of final response actions. The site investigation can be modified to ensure that adequate types and amounts of data are collected as potential environmental hazards are identified. For example, soil gas should be collected if a comparison of initial soil or groundwater data to action levels indicates a potential vapor intrusion hazard. Once the site investigation and EHE are completed, Environmental Hazard Maps can be prepared to summarize the findings of the investigations and serve as a tool to help guide and design subsequent remedial efforts. The type of remedial actions required at the site will vary, depending on the nature of the environmental hazards identified (e.g., soil removal or capping to address direct exposure or leaching hazards versus soil vapor extraction to address vapor intrusion hazards).

The Tier 1 EALs presented in the lookup tables are NOT regulatory "cleanup standards". Site-specific action levels and cleanup levels are, however, subject to the approval of the Hawai‘i Department of Health. EALs presented for chemicals that are known to be highly biodegradable in the environment may be excessively conservative for use as final cleanup levels (e.g., many petroleum-related compounds). Stand alone use of the Tier 1 EALs may be inadequate in some cases. Examples include sites with a high public profile that cannot be fully cleaned up and require a detailed discussion of potential risks to human health. Other examples include sites where physical conditions differ drastically from those assumed in development of the EALs (e.g., mine sites, landfills, etc., with excessively high or low pH) and sites where impacts pose heightened threats to sensitive ecological habitats. Use of the EALs as stand alone screening criteria or final cleanup levels should be evaluated in terms of overall site conditions and potential environmental hazards, the cost/benefit of developing site-specific cleanup levels as well as the pros and cons of full site cleanup versus long–term management.”

>> What is the name of the person that authored the press release?

Ann Zane, Safe Drinking Water Branch, coordinated the significant inputs from the Solid and Hazardous Waste Branch, along with information provided by the Navy.

>> Our review of the records from as far back as 2005 found that the >> sampling and analytical results for years showed TPH-DRO, >> 1-methylnaphthalene, and 2-methylnapthalene exceeded EALs for HDOH Drinking water standards in monitoring wells RHMW01, RHMW02, and RHMW03.

>> A July 2009 monitoring report submitted by the United States Navy states "In September 2005, with concurrence from the HDOH", the Navy decided to use the newer HDOH- Environmental Action Levels (EAL's) for the Red Hill Site investigation and Risk Assessment Project". What did the HDOH use to justify the changes to the EALs? Who decided on the higher numbers and why?

In 2005, Dr. Roger Brewer, HEER, introduced the first version of the HEER’s EAL guidance. The Solid and Hazardous Waste Branch, Underground Storage Tank Section has allowed responsible parties to investigate and seek closure for sites using the HEER EALs and guidance. This includes all responsible parties of confirmed underground storage tank release sites in Hawaii. It is our understanding that Dr. Brewer subsequently revised some of the EALs to reflect the most recent scientific research and findings.

>> We also found in the July, 2009 monitoring report, on page 3, that "Well RHMW02, concentrations of TPH-DRO have been greater than HDOH Drinking water EAL since September 2005, and greater than 50 percent of the SSRBL (estimated solubility limit of 4,500 ug/L over that same period.

>> The average TPH-DRO concentration from the February 2009, sampling event was 2,840 ug/L and the October 2008, average TPH-DRO concentration of 5,420 ug/L was above the SSRBL".

Note: RHMW02 is a deep monitoring well within the Red Hill Bulk Fuel Storage Facility complex and is located between Tanks 5 and 6. It samples the groundwater that lies 80 to 100 feet beneath the tanks. TPH-d has and continues to exceed the EAL of 100 ug/L (parts per billion) in groundwater. According to the HEER EAL guidance, the risk associated with such findings is dependent on the receptors in the environment that could encounter them such as humans, flora, and fauna, by inhalation, ingestion, or direct exposure. The downstream monitoring wells, RHMW01 and RHMW05 are showing much lower levels of TPH-d than RHMW02.

>> There are many more examples of sampling events that reflect a number of contaminants of concern exceeding the HDOH EALs are found in the drinking water under and around the Red Hill Tank Facility and we hope that you review the information submitted by the Navy to your agency.

>> While we readily admit that we are not experts in this subject we do have concerns for accuracy and transparency in information disseminated by the HDOH on matters such as the Red Hill Tank Facility and its impact on a valuable and limited source of drinking water.

>> We respectfully ask that you review the contents of your press release and the monitoring reports to give the public information consistent with what is found in the monitoring reports. Clean water determines health or wellness. Please don't hesitate to let us know if we have misinterpreted some or all of the information in the Navy's monitoring reports regarding the sampling and analytical results. I would like to ask for a response by end of the work day on 2/15/14.

>> Sincerely,

>> Carroll Cox

I hope that this information is helpful.

Stuart

QUESTIONS ABOUT DRINKING WATER FOR THE STATE DEPTARTMENT OF HEALTH