EPA, state health department reject Navy’s Red Hill work plan
The regulatory agencies found serious flaws in sections of the Navy plan to investigate and remediate leaks in the Red Hill Bulk Fuel Storage Facility, and to protect and evaluate the safety of groundwater feeding into Honolulu’s main aquifer.
The United States Environmental Protection Agency (EPA) and Hawaiʻi State Department of Health (DOH) sent a letter to the Naval Facilities Engineering Command today rejecting the Navy’s plan to deal with the water contamination risk posed by its fuel storage facility at Red Hill. The 70-year-old jet fuel tanks, which have leaked tens of thousands of gallons of fuel in the past, sit right above the primary aquifer for urban Honolulu.
In the letter, addressed to James A. K. Miyamoto, P.E. Deputy Operations Officer, Naval Facilities Engineering Command, Hawaiʻi, the federal and state regulatory agencies outline 11 main concerns with the plan and require that the Navy re-submit the plan with revisions within 30 days, as pursuant to Section 7(b) of the Administrative Order on Consent (AOC), which includes the Scope of Work (SOW).
“The work to be conducted under Sections 6 and 7 of the SOW is critical for bounding the risk to drinking water resources from past and potential future releases at the facility,” write the agencies. “To meet this objective, the Navy and the Defense Logistics Agency (DLA) will need to gather sufficient data and conduct an analysis of the data to establish likely groundwater flow directions beneath and around the facility in order to reasonably predict the movement of potential contamination. Achieving this objective in a manner that secures approval from the regulatory agencies and builds stakeholder acceptance will enable this analysis to be used to defensibly predict the probability of impact to drinking water resources from potential future releases.”
According to the agencies, the Navy’s work plan does not adequately describe the work that will need to be done in order to meet the objectives of sections 6 and 7 of the AOC’s SOW.
In order to revise the work plan, the Navy and DLA will need to address the following 11 primary concerns from the regulatory agencies, in addition to each of the detailed comments included in the Regulatory Agencies Detailed Technical Comments and Observations, as well as the External Subject Matter Expert Comments.
Illustration for a Young Progressives Demanding Action digital testimony gathering campaign // Will Caron
Primary Concerns
Below is a list of the primary concerns from the regulatory agencies.
The work described in the work plan is not structured in a manner that supports an iterative and scientifically robust approach for achieving the objective of adequately understanding subsurface conditions to characterize the consequences of leaks from the facility. The plan fails to adequately describe the process for implementing the AOC requirements in a manner that allows for sufficient review—by both the regulatory agencies and by external subject matter experts—of methods, decisions and assumptions used to develop the required products outlined in sections 6 and 7 of the AOC’s SOW. For example, the work plan is missing the following crucial elements:
A description of the process for constructing an initial conceptual site model;
A description of the process for compiling all relevant historic data and creating data summary report;
A description of the approach proposed to assess the quality of historic information;
A description of the proposed content and format of deliverables;
A description of the limitations and sensitivity of existing groundwater model;
A description of the approach proposed to make improvements to the numerical flow model;
A description of the approach proposed to assess degradation rates of fuel in the subsurface under the range of potential release scenarios;
A description of the approach that will be used to gather regulatory agency and external subject matter input at important decision points in the
process of implementing the work;A description of the approach proposed for assessing adequacy of sentinel network; and
A description of the process to be used to update the groundwater protection plan.
The conceptual site model presented in the work plan is an incomplete representation of existing data and does not adequately acknowledge uncertainty related to the conditions around the facility. The work plan should be revised to describe the process and approach that will be used to create a defensible initial conceptual site model, and subsequent updates to the conceptual site model, that acknowledges uncertainty and is based on all data available for the site. The regulatory agencies suggest that the Navy and DLA submit a stand-alone plan for developing and updating the conceptual site model rather than combining it in the overall work plan.
The conceptual site model fails to evaluate non-aqueous phase liquid (NAPL) movement in the saturated and unsaturated zones for the purposes of risk characterization. The plan for the conceptual site model must describe an approach for evaluating the potential migration rates and directions for NAPL movement from all areas of the facility. Estimation of NAPL migration from leaks identified as part of the Section 8 work is needed to characterize the consequences of potential future leaks. In order to do this, the plan must describe how the lithology data will be used to estimate the probable NAPL migration direction, the fraction of NAPL that is expected to be immobilized in the vadose zone, and the fraction of released NAPL expected to reach the water table either as light non-aqueous phase liquid (LNAPL) or dissolved phase contamination. The work plan fails to provide a plan for assessing the potential migration of LNAPL on the water table.
The work plan fails to adequately describe the existing data available to be used for the modeling effort and fails to assess the adequacy of the data to achieve the objectives of the AOC. The Navy and DLA must compile all existing data including, but not limited to, groundwater chemistry data, water table elevation data, precipitation data, groundwater production data, aquifer test data, boring logs, tank barrel logs, and other relevant data into a standalone deliverable for the regulatory agencies’ review and approval. This document should not only present the existing data, but assess the quality and limitations of the data for the purposes of satisfying the objectives of the AOC.
The work plan fails to describe how groundwater flow paths will be determined since groundwater gradients and groundwater flow direction are not always coincident. Anisotropy, formation heterogeneity, and subsurface structures can result in groundwater flow paths not adequately characterized by groundwater gradient. The work plan needs to specify how these factors will be evaluated and their impact on groundwater flow patterns assessed.
The work plan fails to adequately describe how the groundwater flow model will be updated, recalibrated, assessed for sensitivity, and ultimately utilized as a tool to inform future work to be performed. The work plan should be revised so that the model refinement effort is transparent and can provide appropriate opportunity for regulatory agency and external subject matter expert involvement. During this effort, the regulatory agencies expect that numerous professional judgements will be exercised. The work plan must describe how these professional judgements and other assumptions will be incorporated and documented as the model is refined. Given the model’s importance in future work to be performed under the AOC, the modeling effort should strive to achieve a team approach that involves individuals with demonstrated expertise and experience. The desired expertise is described further in attached Regulatory Agency Detailed Technical Comments.
The work plan does not adequately describe how the assessment of attenuation rate of fuel in the vadose zone and saturated zone will be evaluated as part of this effort. The Navy and DLA must present a plan for collecting and analyzing data to evaluate and bound the likely rate of fuel attenuation in the subsurface from the range of releases that could occur at the facility. Understanding the likely range of attenuation rates is important for both the development of the conceptual site model and for the fate and transport modeling effort. Adequate understanding of attenuation of hydrocarbon relative to releases at the facility is important for accurate characterization of the consequences of leaks.
The work plan fails to sufficiently describe how an adequate sentinel monitoring well network will be established for early detection of contaminants from the facility that may threaten drinking water production facilities. The Navy and DLA must present a plan for evaluating and establishing a sentinel network for the existing groundwater production points that will provide sufficient certainty that any contaminants approaching these production points can be detected adequately and in a timely manner to allow for execution of contingency measures in a manner that will prevent contaminated groundwater from entering the drinking water distribution networks.
The work plan fails to describe how the results of the groundwater investigation and resulting modeling will be used to establish risk-based decision criteria. The Navy and DLA must present a plan to integrate the risk assessment of Section 8 of the AOC’s SOW with the data collected and models generated by Section 7 to establish risk-based criteria for the Groundwater Protection Plan and any emergency response plans that are developed to mitigate or prevent impact of groundwater resources by a fuel leak.
The work plan does not present an adequate process to assess the quality, sensitivities and potential uncertainties of the current groundwater model that the Navy and the DLA are proposing to update in order to satisfy the objectives of the AOC. The Navy and DLA must submit a groundwater model evaluation plan that describes a process for review of the existing groundwater model in a manner that identifies uncertainties and describes options for reducing uncertainty. This plan must include an evaluation of the benefits of additional aquifer tests to further reduce uncertainty. The work plan should also analyze how the most recently collected data fits the previously calibrated groundwater model.
The work plan does not adequately describe the content and organization of deliverables, project schedules or opportunities for regulatory agencies and external subject matter expert review of assumptions and information used to develop deliverables. The Navy and DLA must provide an outline of deliverables to be produced including an outline of groundwater monitoring reports, investigation reports, modeling reports and other relevant reports. This outline of deliverables must identify the tables, graphs, charts and figures proposed for these deliverables. The Navy and DLA must also provide a project schedule describing the work to be performed under Sections 6 and 7 of the AOC’s SOW with a schedule for activities that includes, but is not limited to, data collection events, interim deliverables, final deliverables, comment periods and decision meetings. In developing this schedule, the Navy and DLA must make a good faith effort to reduce as much as possible the duration of time between sample collection and data reporting to the regulatory agencies.
An acceptable work plan will need to go much further into detail about deliverables, and do a much better job of describing the process for making decisions related to data quality and data accuracy. It must also describe the expected content and format for the deliverables, and describe the schedule for creating the deliverables.The fact that all of this was missing from the work plan the Navy turned in is extremely concerning. The longer these tanks sit there while the Navy dithers, the greater the risk to the public health and safety of the people of urban Honolulu.
