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From: "Kwan, Roxanne S" <roxanne.kwan@doh.hawaii.gov>
Date: Fri, December 21, 2018 11:14 am
To: "carroll@carrollcox.com" <carroll@carrollcox.com>

 
In reply to your email, DOH responses are in blue:
 
My questions related to the DoH’s increasing of the EAL’s in earlier years from 2001 to 2016.  The letter to Mr. Earnest Lau regarding questions he had about Red Hill is insult
Updates to the EALs are carried out every few years to reflect new information and experience. The rationale for updates is summarized in Volume 2 of the EAL document.
 
Here are just a few questions the letter to Mr. Lau fell short?   I would greatly appreciate answers to them before the end of the day. 
 
Are the contaminates detected at any levels directly related to releases or leaks at the Red Hill Underground Fuel tanks?  Historic detections of fuel constituents found in the area of the Red Hill tanks are assumed to be associated with historic releases of the fuel from the facility.
 
Does the DoH independently conduct its own Testing and Sampling of the aquifer located beneath the Red Hill Underground Fuel tanks? If yes, are they available for public review? 
 
No, DOH does not independently sample the Navy’s Red Hill monitoring wells.  Groundwater sampling is currently being performed by the Navy’s contractor, AECOM.   EPA has analyzed split samples taken during groundwater sampling events at Red Hill.  The results were posted on our website in 2017:  http://health.hawaii.gov/shwb/ust-red-hill-project-main/red-hill-technical-documents-2017 .
 
How often are the tests or samplings conducted by the DOH or Navy?   
 
The Navy performs quarterly groundwater sampling and monthly sampling as needed, as in 2017.  The Navy performs drinking water compliance sampling in accordance with Hawaii Administrative Rules Title 11, Chapter 20, “Public Water Systems”.  HAR 11-20 can be found here: https://health.hawaii.gov/opppd/files/2018/02/11-20.pdf
 
The data is available to the public.  The Navy provides results of their UST release response groundwater sampling in quarterly monitoring reports and found on the DOH UST Red Hill page: http://health.hawaii.gov/shwb/ust-red-hill-project-main/ 
 
Contaminants detected as part pf the Safe Drinking Water Act compliance sampling can be found on our Groundwater Contamination Viewer at:  
 
The Navy also performs additional drinking water sampling for petroleum constituents related to the Red Hill release on a quarterly basis.  This is more frequent than required by regulations.  The additional analyses are:
 
Lead (more frequently than required)  - EPA Method 200.8
Volatile Organics - EPA Method 524.2
Semi-Volatile Organics - EPA Method 525.2
Total Petroleum Hydrocarbons - EPA Method 8015B
 
Did the DoH modify the EAL’s for Naphthalenes in earlier years? 
The drinking water action level for naphthalene of 17 ug/L was last updated in 2008. 
 
Are there any law enforcement actions taken against the United States Navy for the releases? 
The Administrative Order on Consent is an administrative enforcement action.  Please contact Deputy Attorney General, Mr. Wade Hargrove, if you have questions regarding the Administrative Order on Consent. 
 
 
Roxanne
 
 
 
 
My questions related to the DoH’s increasing of the EAL’s in earlier years from 2001 to 2016.  The letter to Mr. Earnest Lau regarding questions he had about Red Hill is insult
 
Here are just a few questions the letter to Mr. Lau fell short?   I would greatly appreciate answers to them before the end of the day. 
 
Are the contaminates detected at any levels directly related to releases or leaks at the Red Hill Underground Fuel tanks?
 
Does the DoH independently conduct its own Testing and Sampling of the aquifer located beneath the Red Hill Underground Fuel tanks? If yes, are they available for public review?
 
How often are the tests or samplings conducted by the DOH or Navy?
 
Did the DoH modify the EAL’s for Naphthalenes in earlier years? 
 
Are there any law enforcement actions taken against the United States Navy for the releases?Carroll

 

   
   
   
   
   
   

 

 

 
     

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