CUSTOMER SERVICE * INTEGRITY ~ ACCOUNTABILITY
Ensuring clean and safe water
EPA Region 9 Must Continue
Oversight Throughout the
Decontamination and Closure
of the Red Hill Facility
Report No. 23-E-0015
April 25, 2023
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Report Contributors:
Steve Hanna
Lauretta Joseph
Jayne Lilienfeld-Jones
Alicia Mariscal
Abbreviations:
AOC Administrative Order on Consent
DLA Defense Logistics Agency
EPA U.S. Environmental Protection Agency
Hawaii DOH Hawaii Department of Health
Honolulu BWS Honolulu Board of Water Supply
JBPHH Joint Base Pearl Harbor-Hickam
OIG Office of Inspector General
TPH Total Petroleum Hydrocarbons
Cover Image:
Red Hill lower access tunnel where the incident occurred. (U.S. Navy
photo)
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Office of Inspector General
U.S. Environmental Protection Agency
At a Glance
23-E-0015
April 25, 2023
EPA Region 9 Must Continue Oversight Throughout the Decontamination
and Closure of the Red Hill Facility
Why We Did This Evaluation
The U.S. Environmental Protection
Agency Office of Inspector General
conducted this evaluation to determine,
by analyzing the sequence of events that
led to drinking water contamination at the
Red Hill site on Joint Base Pearl Harbor-
Hickam, whether the EPA's oversight of
relevant authorized state programs has
effectively addressed the potential for
contamination at the site. The facility,
which the U.S. military uses, contains
20 underground tanks that can store up
to 250 million gallons of fuel.
In November 2021, a petroleum release
at the facility contaminated drinking
water and sickened people. EPA
Region 9 authorized the Hawaii
Department of Health to implement
various environmental programs, and the
Department of Health used its authorities
under those programs to respond to the
incident. The EPA works with the
Department of Health to ensure the
programs perform consistent with federal
laws and regulations.
This evaluation supports EPA
mission-related efforts:
• Ensuring clean and safe water.
• Cleaning up and revitalizing land.
This evaluation addresses a top EPA
management challenge:
• Enforcing environmental laws and
regulations.
Address inquiries to our public affairs
office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
Decontamination and
closure of the Red Hill
facility requires
transparency and
accountability to
protect the Oahu
aquifer—the primary
drinking water source
on the island.
What We Found
The EPA's regulatory oversight of authorized state
programs for underground tanks or drinking water quality
would not reasonably have identified the sequence of
events that led to the drinking water contamination
incident. According to the Navy, an improperly executed
fuel transfer resulted in pipe joint ruptures and a
subsequent fuel spill. Since the EPA does not regulate
operations like this, its oversight of the underground tanks
or drinking water quality would not reasonably have
identified the events that led to the drinking water
contamination. EPA Region 9 provided oversight of authorized Hawaii state programs
prior to the incident. Additionally, Region 9 has worked with the Hawaii Department of
Health, known as the Hawaii DOH, and the Navy to respond to the incident. However,
the planned defueling—or fuel removal—process and decontamination efforts will
require significant coordination between Region 9, the Hawaii DOH, and the Navy to
minimize potential contamination and clearly communicate health and environmental
risks to the public.
As part of Region 9's continued oversight, the region will need to address staffing,
clearly communicate data, and maximize stakeholder involvement. First, Region 9 will
need a sufficient number of staff to oversee the defueling process and address long-
term remediation efforts. Second, Region 9 will need to collaborate with the Hawaii DOH
and the Navy to clearly communicate risk and remediation information. Third, Region 9
will need to work with the Hawaii DOH and the Navy to maximize stakeholder
involvement in Red Hill working groups to ensure that it hears all perspectives and
instills public confidence in the defueling process, remediation efforts, and related
outcomes.
After the defueling and closure processes are complete, consistent oversight of the
remediation efforts will be necessary. Specifically, Region 9 will need to oversee the
groundwater monitoring and contaminant migration information, as well as the
communication of related information to the public.
Recommendations and Planned Agency Corrective Actions
We recommend that the regional administrator for Region 9 develop a plan to define and
provide appropriate levels of resources and oversight during defueling and closure,
collaborate with the Hawaii DOH and the Navy to clearly communicate information to the
public, and work with the Hawaii DOH and the Navy to develop a plan to increase
stakeholder participation. Region 9 agreed with all three recommendations and provided
ten corrective actions with completion dates. The region completed two of the actions.
We consider all of the recommendations resolved with corrective actions pending.
List of OIG reports.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
April 25, 2023
MEMORANDUM
SUBJECT: EPA Region 9 Must Continue Oversight Throughout the Decontamination and Closure of
the Red Hill Facility
Report No. 23-E-0015
This is our report on the subject evaluation conducted by the U.S. Environmental Protection Agency
Office of Inspector General. The project number for this evaluation was OSRE-FY22-OQ75. This report
contains findings that describe the problems the OIG has identified and corrective actions the OIG
recommends. Final determinations on matters in this report will be made by EPA managers in accordance
with established audit resolution procedures.
Region 9 is primarily responsible for the issues discussed in this report.
In accordance with EPA Manual 2750, your office completed two of four corrective actions for
Recommendation 1. Your office also provided acceptable planned corrective actions and estimated
milestone dates for the remaining two corrective actions for Recommendation 1, the four corrective
actions for Recommendation 2, and the two corrective actions for Recommendation 3. All
recommendations are resolved with corrective actions pending, and no final response to this report is
required. If you submit a response, however, it will be posted on the OIG's website, along with our
memorandum commenting on your response. Your response should be provided as an Adobe PDF file
that complies with the accessibility requirements of section 508 of the Rehabilitation Act of 1973, as
amended. The final response should not contain data that you do not want to be released to the public; if
your response contains such data, you should identify the data for redaction or removal along with
corresponding justification.
FROM
Sean W. O'Donnell
TO
Martha Guzman, Regional Administrator
Region 9
We will post this report to our website at www.epa.gov/oig.
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EPA Region 9 Must Continue Oversight
Throughout the Decontamination
and Closure of the Red Hill Facility
23-E-0015
Table of C
Purpose 1
Background 1
The Red Hill Drinking Water Contamination Incident 1
The Red Hill Bulk Fuel Storage Facility 2
The Administrative Order on Consent 3
The EPA's Role and Response to the 2021 Incident 3
The Defueling and Closure of the Red Hill Facility 5
The Impact on the Community 6
Responsible Offices 7
Scope and Methodology 7
Results 8
Region 9's Oversight of Authorized State Programs Related to Red Hill 8
Data Are Not Clearly Communicated to the Public 11
Robust Stakeholder Participation Is Needed 12
Additional Observation 13
Recommendations 14
Agency Response and OIG Assessment 14
Status of Recommendations 16
Appendixes
A Agency Response to Draft Report 18
B Distribution 23
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Purpose
The U.S. Environmental Protection Agency Office of Inspector General initiated this evaluation to
determine, by analyzing the sequence of events that led to drinking water contamination at the Red Hill
site on Joint Base Pearl Harbor-Hickam, whether the EPA's oversight of relevant authorized state
programs has effectively addressed the potential for contamination at the site.
Top Management Challenge Addressed
This evaluation addresses the following top management challenge for the Agency, as identified in the OIG's U.S.
Environmental Protection Agency Fiscal Year 2023 Top Management Challenges report, issued October 28, 2022:
• Enforcing environmental laws and regulations.
Background
The Red Hill Drinking Water Contamination Incident
The Red Hill Bulk Fuel Storage Facility is a fuel repository that the U.S. military uses at Joint Base Pearl
Harbor-Hickam, or JBPHH, in Oahu, Hawaii. According to the EPA About Red Hill Fuel Releases webpage:
On May 6, 2021, a pressure surge event occurred during routine fuel movement
operations at the Red Hill Bulk Fuel Storage Facility. The pressure surge event caused
a pipeline joint failure that released over 19,000 gallons of JP-5 jet fuel onto the
tunnel floor located between the underground storage tanks. The fuel ran down the
tunnel floor into containment trenches and into a fire suppression system fluid sump.
The sump pushed fuel down the tunnel in a fire suppression system fluid drain
pipeline, where the fuel remained until the drain pipeline ruptured on November 20,
2021. This ruptured pipeline resulted in fuel spilling into the tunnel system near the
Red Hill drinking water system shaft.
According to the Navy, the November spill
occurred when "a watch stander
inadvertently struck a low point drain with
the passenger cart of a train, cracking the
pipe and spilling the fuel." This video,
obtained by a Hawaii news outlet
purportedly from a military source,
illustrates the event. Figure 1 shows the
timeline of events as reported by the
Hawaii Department of Health, or Hawaii
DQH. In late November 2021, residents of
JBPHH reported petroleum odors from their
tap water, then reported health symptoms
from drinking the contaminated drinking
water. On November 29, the Hawaii DOH
issued a drinking water advisory, and on December 2, the Navy identified petroleum in the Red Hill well.
The Navy determined the fuel leak to be the result of the May 6, 2021 event.
Cracked Low Point Drain Train Passenger Cart
(U.S. Navy photos)
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Figure 1: Red Hill events from the 2014 release to the 2021 drinking water contamination incident1
January 13, 2014: Navy
reported release of
approximately 27,000
gallons from Tank 5
March 17 & June 2, 2020:
Navy notifies DOH of
release into surface water at
Hotel Pier
May 6, 2021:
Navy reported
approximately 38 gallons of
JP-5 was released into the
environment from pipeline
releases near Tanks #18
and #20
July 23, 2021:
Navy reported
release of
approximately 150
gallons at Kilo Pier
2014
2015
2016
2017
2018
2019
2020
2021
May 2015:
DOH, EPA and Navy enter
into Administrative Order
on Consent
November 28, 2021:
The Navy and DOH
received complaints
about fuel-like odors
in drinking water.
November 20, 2021:
Navy reported approximately
14,000 gallons of water and JP-
5 were released from a cracked
valve in a fire suppression drain
line at a location approximately
%-mile downhill of the bulk fuel
tank and contained in a sump
located in close proximity to
Red Hill Shaft.
Source: Hawaii DOH. (Hawaii DOH image)
The Red Hill Bulk Fuel Storage Facility
The Red Hill Bulk Fuel Storage Facility was constructed during World War II and is located under a
volcanic mountain ridge known as Red Hill, or KapukakI in Hawaiian. It contains 20 underground storage
tanks that hold up to 250 million gallons of fuel and connect to three pipelines that run 2.5 miles
through a tunnel to Pearl Harbor fueling facilities. These tanks are located above Oahu's sole-source
aquifer, a "lens-shaped body of fresh water that exists within Oahu's porous volcanic rock."2 The aquifer
helps provide water to almost 25 percent of Oahu residents.
The U.S. Department of the Navy manages the Red Hill facility. The Hawaii DOH is responsible for
managing EPA-authorized environmental programs, such as the underground storage tank and drinking
water programs. EPA Region 9 oversees programs in the Pacific Southwest, including Hawaii, and is
responsible for oversight of the authorized state programs that pertain to the Red Hill facility and the
JBPHH drinking water system. Region 9 provides funding to the Hawaii DOH for the underground storage
tank and drinking water programs and meets annually with the program staff to determine program
commitments for the upcoming year.
The Navy developed a groundwater protection plan in 2008, at the request of the Hawaii DOH, to
address risks associated with inadvertent releases of fuel from the Red Hiil facility. No releases were
reported until 2014, when approximately 27,000 gallons of jet fuel were released from one of the tanks.
The Navy subsequently drained the tank and collected samples from existing monitoring wells that it
installed as specified in the 2008 groundwater protection plan. Results from samples taken in and
around the tank indicated increased hydrocarbons in soil vapor and groundwater. After this release,
Region 9, the Hawaii DOH, the Navy, and the Defense Logistics Agency or DLA, developed an enforceable
agreement, known as an administrative order on consent or AOC, that was issued in 2015.
1 The Hawaii DOH estimate in Figure 1 references 14,000 gallons. According to the Navy, about 19,000 gallons were
released on May 6, 2021, and about 14,000 gallons were recovered on November 20, 2021.
2 Board of Water Supply, Hawaii's Water Cycle (last visited Oct, 31, 2022).
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The Administrative Order on Consent
According to Region 9, the AOC required the Navy and the DLA to take actions, which would be subject
to EPA and Hawaii DOH approval, to address fuel releases and implement infrastructure improvements
to protect human health and the environment. The AOC also required the Navy and the DLA to evaluate
and improve procedures and practices to maintain the integrity of the tanks, evaluate structural
upgrades, and use the best technology to detect leaks. In addition, the AOC required the Navy and the
DLA to further develop models to better understand groundwater flow in the area around the facility, to
evaluate the fate and transport of contaminants in the subsurface around the facility, and to address the
investigation and remediation of the January 2014 release and any future releases at the Red Hill Bulk
Fuel Storage Facility. Region 9 and the Hawaii DOH conducted oversight of deliverables specified under
the AOC. For example, the Navy and the DLA:
• Implemented numerous infrastructure improvements, including more frequent leak detection
testing, increased operator accountability, enhanced inspection and maintenance procedures,
and additional quality assurance and control practices. Region 9 and the Hawaii DOH received
and reviewed many infrastructure reports, which are available on the EPA website.
• Prepared groundwater flow model reports in 2018 and 2020 for review by Region 9 and the
Hawaii DOH. The regulatory agencies disapproved the 2020 groundwater flow model report in
March 2022 and provided the Navy and the DLA the opportunity to respond to their concerns.
As of July 1, 2022, the Navy and the DLA were working on a new groundwater flow model to
address Region 9 and Hawaii DOH comments.
• Installed 12 groundwater monitoring wells, three directly under the tanks and nine in areas
around the facility. The purpose of the wells is to provide regular data on contaminant
concentrations in the groundwater under and around the facility.
• Prepared a decision document in September 2019 on tank upgrade and release detection
alternatives for review by Region 9 and the Hawaii DOH. The regulatory agencies disapproved
the document and issued a notice of deficiency in October 2020 to provide the Navy and the
DLA the opportunity to respond to their concerns. The Navy and the DLA tried to address the
concerns in a supplemental decision document sent to the regulatory agencies in August 2021.
Since the Navy decided to defuel the tanks, the actions described in the tank upgrade
alternatives are no longer relevant.
The EPA's Role and Response to the 2021 Incident
The underground storage tank and drinking water programs are the major environmental programs
involved in the incident and incident response. The EPA authorized the State of Hawaii to implement
these programs in lieu of the EPA. Region 9 works with the Hawaii DOH to ensure that the programs
perform consistently with federal laws and regulations.
Given its oversight responsibility for the authorized Hawaii state drinking water program, Region 9
responded to the 2021 drinking water contamination incident. First, it mobilized on-scene coordinators,
who arrived on December 5, 2022, to help coordinate efforts and provide technical support. Region 9
also temporarily assigned staff from its Superfund and Water Divisions to assist with the incident
response. Additionally, Region 9 worked with the Hawaii DOH and Navy staff to establish the
Interagency Drinking Water System Team to restore safe drinking water to the affected residents and
23-E-0015
3
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workers. The team began work in December 2021 and completed work to restore the drinking water
system in March 2022.
Drinking water contamination was a major concern after the fuel release incident. The Navy provided
drinking water health advisory statuses, like the one shown in Figure 2, to keep the public informed. To
test drinking water, Region 9 mobilized a portable EPA laboratory to Seal Beach, California. The lab
tested the water for total petroleum hydrocarbons, or TPH. This was necessary because no drinking
water labs in Hawaii were certified for TPH analysis.
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In April 2022, Region 9 performed a public water
system inspection of the JBPHH water system to
determine compliance with Safe Drinking Water Act
requirements. The inspection report documented the
Navy's failure to adequately operate and maintain its
system. According to Region 9, the Navy has submitted
documentation for many of the corrective actions
taken as a result of Region 9's April 2022 public water
system inspection. The proposed consent order discussed below will, if finalized, require the Navy to
address additional items. According to Region 9, "Over the next two years, the Navy is required to
The Safe Drinking Water Act
According to the EPA, "Congress passed the Safe
Drinking Water Act in 1974 to protect public health
by regulating the nation's public drinking water
supply." The law authorizes the EPA to set national
health-based standards to protect against both
naturally occurring and man-made contaminants
that may be found in drinking water.
23-E-0015
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continue testing the affected drinking water area and continue work to clean up the Red Hill drinking
water well and impacted soil and groundwater."3
As of March 6, 2023, the EPA is not pursuing an enforcement action for failure to comply with past spill
and drinking water contamination reporting requirements. However, the EPA entered into a proposed
consent order that, if finalized, will require the Navy and DLA to take actions to safely defuel and close
the Red Hill Bulk Storage Facility and will require the Navy to perform activities related to the delivery of
a safe and resilient supply of drinking water to the JBPHH drinking water system. The EPA is evaluating
the public comments on the proposed consent order. The EPA reports that it continues to work with the
Hawaii DOH, the Navy, and the DLA to ensure the safe and timely defueling of the facility during the
public comment process on the proposed consent order.
The Defueling and Closure of the Red Hill Facility
On December 6, 2021, the Hawaii DOH issued an emergency order
immediately suspend operations; install water treatment
systems; and develop work plans to defuel, or remove fuel from,
the facility and assess operations and system integrity. The Navy
appealed the emergency order in federal and state courts in
February 2022. On March 7, 2022, U.S. Secretary of Defense
Lloyd Austin directed the Navy to defuel and permanently close
the facility.
In April 2022, the Navy withdrew its appeal of the emergency
order, and in May 2022, the Hawaii DOH issued a new
emergency order that required continued suspension of
operations, groundwater treatment system maintainance, and
the submission of defueling and facility closure plans for Hawaii DOH review and approval. The
Department of Defense published a defueling plan on June 30, 2022, but the Hawaii DOH rejected it on
July 22, 2022. The Hawaii DOH stated that the plan "lacks the requisite details and specificity necessary
for the [Hawaii] DOH to fully evaluate how the Navy will execute safe and expeditious defueling."4 The
Navy submitted responses to the Hawaii DOH in September 2022 to address EPA and Hawaii DOH
comments and provide additional information. The Navy submitted a facility closure plan to the EPA and
the Hawaii DOH on November 1, 2022.
Almost three miles of pipelines linking the facility to Pearl Harbor needed to be drained or unpacked
before the Navy could implement repairs needed to safely defuel the tanks. The Navy began the
unpacking process on October 25, 2022, and successfully removed more than one million gallons of fuel
from the pipelines on November 3, 2022.
directing the Red Hill facility to
"The contamination of drinking water
from the Red Hill Shaft was the result of
the Navy's ineffective immediate
responses to the 6 May and 20
November 2021 fuel releases at the Red
Hill Bulk Fuel Storage Facility (Red Hill),
and failure to resolve with urgency
deficiencies in system design and
construction, system knowledge, and
incident response training."
Rear Admiral Christopher J. Cavanaugh
June 13, 2022
3 EPA, Drinking Water Incident Response at Joint Base Pearl Harbor-Hickam, Honolulu, Hawai'i (November 2021-
March 2022) (last visited Oct. 31, 2022).
4 Press Release, Hawaii DOH, DOH Disapproves DoD's Red Hill Defueling Plan (Jul. 26, 2022).
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The Impact on the Community
The Hawaiians say, "Water is
life." According to the State of
Hawaii Division of Aquatic
Resources website, fresh water is
so valuable and precious to them
that they call it wai to indicate
wealth. To signify abundance and
prosperity, Hawaiians say waiwai.
On December 8, 2021, the Honolulu Board of Water Supply, or BWS,
learned of the contamination and immediately shut down two nearby
wells. Figure 3 shows the location of the Halawa shaft and the Red Hill
facility.
About 93,000 Navy water system users were impacted by the
contaminated drinking water and many were relocated to temporary
housing during the crisis. Hundreds of
families, according to the EPA,
reported petroleum odors from their
tap water, and residents also reported
symptoms arising from the
contaminated water. According to the
Hawaii DOH, health effects of exposure
to petroleum hydrocarbons in water
include itching, rash, nausea, vomiting,
diarrhea, headaches, and dizziness. The
Hawaii DOH further stated that people
exposed to contaminated water from
the incident are not expected to
experience long-term health effects.
On November 29, 2021, the Hawaii
DOH advised all Navy water system Crisis at KapukakT, Ka Wai Ola, January 1, 2022. (Photograph credited to
users to avoid using the water for Jason Lees)
drinking, cooking, or oral hygiene. In addition, the Hawaii DOH advised that if residents detected a fuel
odor, they should avoid using the water for bathing, dishwashing, and laundry. The incident
subsequently resulted in public protests and demands to close the facility.
Figure 3: Location of the Honolulu BWS's Halawa Shaft and the Navy's Red Hill facility on Oahu
Source: Honolulu BWS. (Honolulu BWS image)
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Responsible Offices
The Region 9 office implements and enforces federal environmental laws in Arizona, California, Hawaii,
Nevada, the Pacific Islands, and 148 tribal nations. Within Region 9, multiple divisions are involved with
the Red Hill facility:
• The Enforcement and Compliance Assurance Division administers compliance inspections, case
development, state oversight, and compliance data management and analysis. The division also
processes tips and complaints.
• The Land, Chemicals, and Redevelopment Division administers programs related to the Resource
Conservation and Recovery Act and underground storage tanks.
• The Superfund and Emergency Management Division administers programs related to site
cleanup, emergency response and planning, and oil pollution.
• The Water Division administers programs under the Clean Water Act and the Safe Drinking
Water Act.
Scope and Methodology
We conducted this evaluation from March to November 2022 in accordance with the Quality Standards
for Inspection and Evaluation published December 2020 by the Council of the Inspectors General on
Integrity and Efficiency. Those standards require that we perform the evaluation to obtain sufficient and
appropriate evidence to support our findings. We initiated this project following an OIG inquiry to
review the drinking water contamination incident.
This evaluation focused on Region 9's oversight of authorized Hawaii state programs for underground
storage tanks and drinking water quality and the response to the Red Hill incident. We coordinated our
project efforts with the Department of Defense OIG. The Department of Defense OIG is focusing on the
Navy's operation, maintenance, safety, and oversight of the facility. During the evaluation, we met with
Department of Defense OIG staff every two months to discuss progress and avoid duplication of efforts.
We reviewed the sequence of events that led to the incident, as described by the Navy,5 to determine
whether these should have been addressed through implementation of EPA-authorized Hawaii state
programs. We also achieved this through document reviews, interviews with relevant stakeholders, and
participation in public forums, as described below.
As part of the evaluation, we reviewed the 2021 Consumer Confidence Report for the JBPHH water
system—which includes the Waiawa, Halawa, and Red Hill water sources—to determine the presence of
contaminants such as TPH. Consumer Confidence Reports are required annually under the Safe Drinking
Water Act.6 According to Region 9, the Act does not require water systems to include TPH test results in
these reports, but since at least 2017, the Navy has included TPH test results from voluntary monitoring
5 COMMAND INVESTIGATION INTO THE 6 MAY 2021 AND 20 NOVEMBER 2021 INCIDENTS AT RED HILL BULK FUEL
STORAGE FACILITY. June 13, 2022.
6 Pursuant to section 1414(c)(4) of the Safe Drinking Water Act, 42 U.S.C. § 300g-3(c)(4), community water systems
are required to deliver a Consumer Confidence Report, also known as an annual drinking water quality report, to
their customers. These reports provide Americans information about their local drinking water quality.
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of the Red Hill Shaft due to a January 2014 fuel release at the Red Hill Bulk Fuel Storage Facility. As the
Navy water provider in the state, the Naval Facilities Engineering Command Hawaii primarily supplies
water to military housing and installations. We also reviewed the mechanisms Region 9 has in place to
oversee the integrity of Red Hill operations and underground storage tanks.
Additionally, we interviewed staff and managers from Region 9 and the EPA Office of Water; the EPA
Office of Enforcement and Compliance Assurance, including its Federal Facilities Enforcement Office; the
Hawaii DOH; the Honolulu BWS; and the Hawaii Commission on Water Resource Management. During
our interviews with Region 9 and Hawaii DOH staff, we sought to determine compliance with drinking
water monitoring and reporting regulations. We also met with selected stakeholders, including a
nongovernmental organization, to learn about the native Hawaiian perspective on the Red Hill incident.
Further, we visited Red Hill in April 2022 and attended the May 2022 virtual public forum on the Navy's
defueling plan.
Results
Region 9 provided adequate oversight of authorized Hawaii state programs prior to the Red Hill drinking
water contamination incident. The EPA's regulatory oversight of authorized state programs for
underground tanks or drinking water quality would not reasonably have identified the sequence of
events that led to the drinking water contamination incident. Additionally, Region 9 has continued to
work with the Hawaii DOH and the Navy to respond to the November 2021 incident. However, the
pending defueling and decontamination efforts at Red Hill will require continued significant
coordination between Region 9, the Hawaii DOH, and the Navy to minimize potential contamination of
the Oahu drinking water aquifer, ensure accountability, and provide clear and transparent
communication to the public on health and environmental risks.
Region 9's Oversight of Authorized State Programs Related to Red Hill
According to the Navy, improper execution of a fuel transfer procedure caused the May 2021 pressure
surge event, which resulted in two pipe joint ruptures and a subsequent fuel spill. Since the EPA does
not oversee regular operations like this, its statutory and regulatory oversight of the underground tanks
or drinking water quality would not reasonably have identified the events that led to the drinking water
contamination incident. As detailed in the next section, EPA and Hawaii DOH oversight activities focus
on tanks and potential tank leaks, not operations such as fuel transfers. Region 9 has provided oversight
of authorized Hawaii state programs.
Underground Storage Tank Program
For the underground storage tank program, the EPA and Hawaii DOH meet throughout the year to plan
the activities they will perform. Examples of the activities include:
• In May 2016, Region 9 requested that a team of subject matter experts conduct a baseline
inspection of the underground storage tank systems and peripheral equipment at the Red Hill
facility. According to the inspection report, published in June 2017, "The evaluation team
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generally found that systems and management practices in place at the Red Hill Facility meet or
exceed best practices for petroleum terminals and bulk fuel storage facilities."7
• From September 28 to October 9, 2020, the Hawaii DOH performed an underground storage
tank inspection. As a result of this inspection, the Hawaii DOH issued a Notice of Violation in
October 2021. The notice detailed five violations and assessed an administrative penalty of
about $325,000. The violations were for failures to:
o "[Ojperate and maintain ongoing corrosion protection to metal components of the
portion of the Navy's tank and piping that contain regulated substances and are in
contact with the ground."8
o "[P]erform line tightness testing of repaired piping before return to service."9
o "[P]erform an annual liquid tightness test on spill prevention equipment to prevent
releases to the environment."10
o "[P]erform an adequate visual walkthrough inspection of hydrant pits."11
o "[M]aintain adequate release detection for two double-walled underground product
recovery storage tanks."12
• According to Region 9, it has frequent calls with the Hawaii DOH and the DLA, including monthly
principals calls to elevate AOC issues; weekly project coordination calls on AOC deliverables and
regulatory review; and weekly environmental coordination calls on environmental investigation,
remediation, monitoring, and modeling efforts.
Drinking Water Program
Similar to the underground storage tank program, the EPA and the Hawaii DOH jointly determine the
drinking water program activities they will perform during the year. According to Region 9:
• Region 9 and Hawaii DOH program managers and assistant directors hold monthly calls.
• Region 9 and Hawaii DOH program staff and managers have quarterly calls.
• Region 9 and Hawaii DOH program staff, managers, and assistant directors hold midyear and
end-of-year program performance reviews and issue an annual program evaluation report. The
Region 9 Water division director attends the end-of-year performance review meeting.
• Since the Red Hill incident, calls between Region 9 and the Hawaii DOH have increased and are
now held every week or two.
• The Hawaii DOH performs sanitary surveys every three years. A sanitary survey is a review of a
public water system to assess its capability to supply safe drinking water. The Hawaii DOH
7 Underground Storage Tank System Evaluation Final Report, Red Hill Bulk Fuel Storage Facility Joint Base Pearl
Harbor-Hickam, June 13, 2017.
8 Press Release, Hawaii DOH, Red Hill NOVO [Notice of Violation and Order] (Oct. 27, 2021).
9 Id.
10 Id.
11 Id.
12 Id.
23-E-0015
9
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performed surveys of the JBPHH in 2014 and 2017. The 2020 survey was delayed due to the
coronavirus pandemic. According to EPA, the Hawaii DOH completed its sanitary survey of the
JBPHH water system November 14-15, 2022.
Inspections and Analyses
Since the November 2021 incident, the EPA and the Hawaii DOH have conducted additional inspections.
Region 9 performed an underground tank inspection from February 28 through March 4, 2022. The
inspection team included Region 9 inspectors, a subject matter expert from the EPA Office of
Underground Storage Tanks, the EPA Red Hill project coordinator, and Hawaii DOH inspectors. The
purpose of the inspection was to determine the JBPHH operational compliance with the Hawaii DOH's
underground storage tank regulations. The inspection identified six areas of noncompliance.
Additionally, in April 2022, the EPA National Environment Investigations Center performed a Safe
Drinking Water Act inspection of the JBPHH Public Water System. According to Region 9, National
Environment Investigations Center staff performed the inspection because they are technical experts
with experience inspecting complex public water systems. The inspection found that the Navy failed to
adequately operate and maintain its water system. In response, the Navy has taken steps to address the
concerns identified in the report and has submitted plans to address the concerns.
Finally, the 2021 Consumer Confidence Report, an analysis of local drinking water quality that was
prepared by the Navy in accordance with federal Safe Drinking Water Act and Hawaii state regulations,
showed no TPH contamination in the water.
Groundwater Monitoring Wells
Per the 2015 AOC, Region 9, in collaboration with the Hawaii DOH, has participated in oversight of the
Red Hill Bulk Fuel Storage Facility to address fuel releases and implement infrastructure improvements
to protect human health and the environment. Development of an adequate groundwater monitoring
well network near Red Hill is a key requirement of the AOC. Since the November 2021 incident, the Navy
installed additional monitoring wells and plans to install more. According to the Hawaii DOH, the
additional wells are intended to improve confidence in the preliminary interpretation of perimeter
detections, detect for potential migration beyond the historical region of impact, and provide
monitoring to protect public drinking water supplies. According to Region 9, there were more than
30 monitoring wells in the area as of March 6, 2023.
Region 9 and the Hawaii DOH shared the results of monitoring at these wells with the public and
stakeholders. For example, the Hawaii DOH shared the illustration of the TPH contamination shown in
Figure 4 with the Fuel Tank Advisory Committee, a committee comprised of representatives from
Region 9, the Hawaii DOH, Navy, the Honolulu BWS, Hawaii Commission on Water Resource
Management, members of the Hawaii State Legislature, and Hawaii's congressional delegation.
According to the Hawaii DOH, the TPH contamination is diminishing in mass. The Hawaii DOH also stated
that sentinel wells and robust sampling are key to monitoring the contaminants.13 The Hawaii DOH
shares committee meeting minutes and presentations on its website.
13 According to the Navy, sentinel wells are monitoring wells installed between Red Hill and neighboring drinking
water sources in order to provide a warning if any contamination in the aquifer were to migrate.
23-E-0015
10
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Figure 4: TPH contamination at the Red Hill site as of April 2022
Source: Hawaii DOH presentation to the Fuel Tank Advisory Committee on May 13, 2022. (Hawaii DOH image)
Defueling Process
Defueling the facility will be a multiyear process. The longer the fuel remains in the system, the greater
the possibility of groundwater contamination from leaks. Region 9 will need sufficient staffing resources
to provide necessary oversight. Since May 2022, Region 9 has temporarily assigned three additional staff
to work with the region's Red Hill AOC project coordinator and existing staff; contractors; and
management in the Land, Chemicals, and Redevelopment Division. The project coordinator is stationed
full-time in Oahu; the other staff are in San Francisco and travel to Oahu as needed. The temporary
assignments were based on workload expectations from the November 2021 incident and defueling, the
latter of which is not expected to be complete before 2024. Residual TPH contamination will still require
oversight after the defueling process is complete. Region 9 has started the process to hire a team of
three permanent staff. The team will partner with the Hawaii DOH "to focus on reducing risk from
recent drinking water/aquifer contamination and future defueling operations."
Data Are Not Clearly Communicated to the Public
EPA Administrator Michael S. Regan's message to EPA employees, Transparency and Earning Public Trust
in EPA Operations, issued April 12, 2021, states that public trust requires transparency.14 The EPA Risk
Communication website describes "[effectively communicating science and potential health risk [as]
one of the most important jobs [it has]" and states:
EPA's mission is to protect human health and the environment. This important
mission cannot be accomplished without communicating about risk with
communities, individuals, businesses, the media, and state, local, and tribal partners.
Risk communication is fundamental to the work we do. When we communicate risk,
14 EPA, Administrator Michael Regan Message to EPA Employees - Transparency and Earning Public Trust in EPA
Operations, Aprii 12, 2021.
23-E-0015 11
-------
it is our goal to provide meaningful, understandable, and actionable information to
our many audiences, [emphasis in the original]
As part of its state program oversight, Region 9 should ensure that information the state communicates
to the public is easy to understand. While the Hawaii DQH website includes Red Hill monitoring data, the
state communicates this information through large spreadsheets with groundwater and soil vapor
monitoring data, chemical names, and detection values. An example of this is shown in Figure 5. The
website does not have concise or easy to understand information on risks to the public. Additionally, the
extent of known TPH soil contamination, potential impact of the contamination on drinking water, and
remediation information are not clearly communicated. The lack of clearly communicated data may
cause the public to be unaware of or confused about existing and potential groundwater contamination
at the Red Hill facility. Clear communication about potential health effects and drinking water
contamination is essential.
Figure 5; Soil vapor sample results from July 2022 (partial view)
Date
A3<-3CC
A3'250
A3*200
A3*150
A3+100
A3«050
A3a+000
A3b*000
12/17/2021
67
101
55
43
39
40
24
33
12/20/2021
235
178
88
%
67
85
65
79
12/21/2021
NT
NT
NT
NT
NT
NT
NT
NT
12/22/2021
55
106
51
62
62
37
45
60
12/23/2021
106
350
192
233
205
138
215
203
12/24/2021
120
281
282
131
462
101
448
471
12/27/2021
NT
240
79
160
141
99
180
181
12/29/2021
Wet
Wet
76
117
103
45
101
110
12/30/2021
Wet
Wet
74
109
85
45
87
87
12/31/2021
Wet
Wet
175
341
278
65
342
387
1/6/2022
Wet
614
233
426
415
95
497
544
1/12/2022
628
550
184
386
64
3jS
410
1/19/2022
654
531
148
313
343
65
316
344
1/26/2022
Wet
667
157
335
320
64
334
386
2/2/2022
Wet
598
159
391
389
41
400
414
2/9/2022
664
498
135
298
341
50
293
325
2/18/2022
369
295
77
187
181
30
186
180
2/23/2022
442
383
104
220
236
41
253
255
3/2/2022
508
424
125
290
298
37
307
330
Source: Section of the Hawaii DOH's soil vapor monitoring data from July 22, 2022.
Robust Stakeholder Participation Is Needed
The AOC states that the intent of the Navy, the DLA, the Hawaii DOH, and Region 9 is to include subject
matter experts "for scoping and review of key deliverables" required by the order. However, some
stakeholders told us that they declined to participate because the Navy required a nondisclosure
agreement. The reason for the nondisclosure requirement is in the introductory paragraph of the
agreement:
I have been invited to participate as a technical advisor or consultant on matters
related to the Red Hill Administrative Order on Consent (AOC). These matters are
expected to result in contracts for work involving a significant expenditure of public
funds. Information and discussions related to these matters may also include details
regarding infrastructure that is critical to national defense, which, if disclosed, could
adversely affect national interests.
23-E-0015
12
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One stakeholder stated that it was not in the public interest for them to sign away their right to be
transparent about the Red Hill facility and risks to the public. The Honolulu BWS, Hawaii Commission on
Water Resources Management, and U.S. Geological Survey said that they did not participate due to the
nondisclosure agreement requirement. Without direct involvement from relevant stakeholders, valuable
perspectives on the defueling and decontamination process may not be considered in decision-making.
Further, limits on information sharing could result in the public not being informed of all monitoring and
remediation efforts.
We attempted to obtain the Navy's perspective on the AOC nondisclosure agreement requirement, but
the Navy declined to engage with us and referred us to the EPA. Some stakeholders expressed concerns
about difficulties in working with the Navy, including delays in communication, which could result in
delays to informing the public. Stakeholders attributed some of the difficulties to turnover in senior
Navy officials and the associated loss of institutional knowledge.
The Red Hill Remediation and Restoration Action Plan—which the Hawaii DOH presented to the Fuel
Tank Advisory Committee on May 13, 2022—lists tentative membership of the action plan committee to
include Region 9 and the Hawaii DOH, the Navy, the Honolulu BWS, the Hawaii Commission on Water
Resources Management, and U.S. Geological Survey. According to Region 9, the region and the Hawaii
DOH convened the committee, later called the roundtable, to gather stakeholder agency expertise and
input to help inform regulatory agency decision-making and make remediation efforts more efficient
and effective. Figure 6 shows the Red Hill Remediation and Restoration Action Plan Roundtable
objectives.
Figure 6: Red Hill Remediation and Restoration Action Plan Committee objectives
Prevent
Investigate
and Assess
Protect
Remediate
Communicate
• Prevent
further
releases of
fuel or other
contaminants
from the Red
Hill facility
• Investigate
and assess the
env. condition
of the site and
impacts of
prior releases
• Protect
drinking water
and surface
water
resources
• Remediate the
contamination
• Communicate
progress and
results to
public
Source: Joint Region 9 and Hawaii DOH presentation to the Fuel Tank Advisory Committee on May 13, 2022.
The reduction of potential barriers to participation, like nondisclosure agreements, and inclusion of
relevant stakeholders are critical to the action plan's success. However, the Navy declined to attend the
September 2022 roundtable. In Region 9's technical comments in response to our draft report, the
region noted that the Navy participated in the February 2023 roundtable and a groundwater subject
matter expert meeting in January 2023, and that the EPA continues to work with the Navy to provide
additional venues for stakeholder input.
Additional Observation
According to the EPA, Guam, a U.S. territory, has field-constructed fuel tanks at two military facilities.
The tanks can hold over 60 million gallons of fuel and have the potential for leaks like most tanks. The
EPA authorized the Guam Environmental Protection Agency to implement the underground tank
program. In Region 9's technical comments in response to our draft report, the region indicated that, in
23-E-0015
13
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2018, the Guam program expressed concerns to Region 9 about the field-constructed fuel tanks being
above a sole-source aquifer, similar to Red Hill. Region 9 noted that the Guam program requested
training on field-constructed tank inspections. In November 2019, the EPA, the Guam Environmental
Protection Agency, and contractors conducted site visits and regulatory evaluations at the two military
facilities. Region 9 is planning additional inspections for 2023 to fully assess the facilities' level of
compliance with federal and Guam regulations.
Recommendations
We recommend that the regional administrator for Region 9:
1. Develop a plan to define and provide appropriate levels of resources and oversight, including
maintaining adequate EPA staffing levels in Oahu, during the defueling and closure of the Red
Hill facility.
2. Collaborate with the Hawaii Department of Health and the Navy, as appropriate, to clearly
communicate risk and remediation information to the public.
3. Work with the Hawaii Department of Health and the Navy to develop a plan to increase
regulatory agency and nongovernmental organization participation in Red Hill working groups.
Agency Response and OIG Assessment
Appendix A includes Region 9's March 6, 2023, response to our draft report. Region 9 also provided
technical comments, which we considered as we finalized this report. Region 9 concurred with our
recommendations and proposed corrective actions with planned completion dates.
On Recommendation 1, Region 9 proposed four corrective actions to address Red Hill staffing, including
developing a staffing plan, increasing Red Hill staff in Hawaii, adding one staff person to work directly
with the Hawaii DOH to support the state's capacity to oversee the drinking water program, and hiring
to backfill vacant positions and permanently fill positions previously filled by temporary details.
Additionally, Region 9 committed to identifying funding needs for defueling, closure, and remediation of
the Red Hill facility, and working to address those needs through the annual budget process, including
considerations in Region 9's 2024 President's Budget request. Region 9 further stated that it will
continue to engage with the Navy on the appropriate allocation of oversight costs. When completed,
these corrective actions should address the intent of Recommendation 1.
On Recommendation 2, Region 9 proposed four corrective actions to enhance communication of Red
Hill risk and remediation information with the public, including requiring the Navy and the DLA to host
quarterly public updates on defueling and closure, developing a web-based application to make
groundwater monitoring data more easily available to the public, developing a community involvement
plan with input from the Hawaii DOH to improve public communication, and collaborating with the
Hawaii DOH to host webinars to share information with the public on what the agencies are doing to
address impacts to human health and the environment. When completed, these corrective actions
should address the intent of Recommendation 2.
On Recommendation 3, Region 9 proposed two corrective actions to increase participation in Red Hill
working groups, including establishing a schedule of remediation roundtable and groundwater subject
23-E-0015
14
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matter expert meetings convened by Region 9 and the Hawaii DOH with participation by the Navy, the
Honolulu BWS, the Hawaii Commission on Water Resource Management, and the U.S. Geological
Survey; as well as developing a community involvement plan with input from the Hawaii DOH. When
completed, these corrective actions should address the intent of Recommendation 3.
We verified that Region 9 completed two of its proposed corrective actions to develop a cross-divisional
staffing plan and Fiscal Year 2023 resource request for oversight of the Red Hill facility, and to increase
the number of Oahu-based staff. The eight remaining corrective actions are pending. We consider all
three recommendations resolved with corrective actions pending.
23-E-0015
15
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Status of Recommendations
RECOMMENDATIONS
Planned
Rec.
Page
Completion
No.
No.
Subject
Status1
Action Official
Date
1
14
Develop a plan to define and provide appropriate levels of
R
Regional Administrator
10/1/23
resources and oversight, Including maintaining adequate
for Region 9
EPA staffing levels In Oahu, during the defueling and
closure of the Red Hill facility.
Corrective Action 1.1- Develop cross-divisional EPA staffina
plan and Fiscal Year 2023 Region 9 resource request for
C
9/1/22
oversight of the Red Hill facility, including environmental
investigation and remediation pursuant to the 2015
Administrative Order on Consent (AOC) and defuel, closure,
completion of the implementation of the Drinking Water Long
Term Monitoring Plan pursuant to proposed 2023 Consent
Order.
Corrective Action 1.2 - Increase the number of Oahu-based
EPA staff, including hiring a dedicated Red Hill EJ Community
Engagement Coordinator on temporary detail to work directly
with the community and relocating three people to oversee
spill prevention and response, environmental investigation and
remediation, and provide drinking water support to the Hawaii
Department of Health.
Corrective Action 1.3 - Embed an EPA staff person at the
Hawaii Department of Health through the Intergovernmental
Personnel Act Mobility Program (IPA) to further support the
state's capacity to oversee the remaining drinking water long-
term monitoring efforts underway.
Corrective Action 1.4- Complete additional hiring needed to
backfill 2015 AOC Project Coordinator (vacant March 3, 2023)
and Underground Storage Tanks Supervisor (vacant
December 1, 2023) and permanently fill remaining positions
previously filled by temporary details. One of the details was
permanently filled on February 27, 2023.
3/1/23
8/1/23
10/1/23
14 Collaborate with the Hawaii Department of Health and the
Navy, as appropriate, to clearly communicate risk and
remediation Information to the public.
Corrective Action 2.1 - Require Navy/DLA to host quarterly
public updates on defueling, closure, completion of the
implementation of the Drinking Water Long Term Monitoring
Plan, and environmental investigation and remediation work
with participation from EPA and Hawaii Department of Health
pursuant to proposed 2023 Consent Order.
Corrective Action 2.2 - Develop a web-based application to
make Red Hill groundwater monitoring well data more easily
available to the public
Corrective Action 2.3 - With input from Hawaii Department of
Health, develop a Community Involvement Plan, which will
include a section on improving public communication through
website updates and FAQs.
Corrective Action 2.4 - Collaborate with Hawaii Department of
Health to host a three-part webinar series to share information
with the public on what agencies are doing to address impacts
to human health and the environment from Red Hill releases.
The first webinar was completed January 12, 2023, and is
posted on EPA's Red Hill website.
Regional Administrator
for Region 9
12/1/23
6/1/23
8/1/23
12/1/23
12/1/23
14 Work with the Hawaii Department of Health and the Navy to
develop a plan to Increase regulatory agency and
Regional Administrator
for Region 9
8/1/23
23-E-0015
16
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RECOMMENDATIONS
Planned
Rec.
Page
Completion
No.
No.
Subject
Status1
Action Official
Date
nongovernmental organization participation In Red Hill
working groups.
Corrective Action 3.1 - Establish a schedule of Red Hill
Remediation Roundtable and Groundwater Subject Matter
Expert Meetings to be convened by EPA/Hawaii Department
of Health, with participation by Navy, Board of Water Supply,
Commission on Water Resource Management, and USGS.
Since the report, a Groundwater Subject Matter Expert
meeting was held on January 2023 and Red Hill Remediation
Roundtable meeting February 2023 with full participation.
Corrective Action 3.2 - With input from Hawaii Department of
Health, develop a Community Involvement Plan (also
mentioned in 2.3), which will include a section on community
involvement activities.
5/1/23
8/1/23
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
23-E-0015
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Appendix A
Agency Response to Draft Report
e
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105-3901
OFFICE OF THE
REGIONAL ADMINISTRATOR
March 3, 2023
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report "Region 9 Must Continue
Oversight Throughout the Decontamination and Closure of the Red Hill Facility,"
Project No. OSRE-FY22-0075, dated February 6, 2023
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. The U.S. Environmental Protection Agency, Region 9 (EPA) agrees with the
recommendations identified in the report and had already started acting in accord with some of
the recommendations. (See, for example, the discussion on p. 11 about the Region hiring a team
of three senior permanent project managers and staff to work on Red Hill-related issues.) Below
is a summary of the proposed corrective actions and estimated completion dates and attached are
EPA's Technical Comments on the Report to supplement this response.
Agency resources are provided through annual appropriations and allocated across the Agency to
Headquarters and Regional Offices by National Program Managers following Congressional
direction and decisions made by Agency Senior Leadership to support the EPA's mission.
Funding needs for priority activities such as the oversight of defueling, closure, and remediation
of the Red Hill facility are identified and needs are met to the maximum extent possible through
that annual process. The Red Hill facility work is important to EPA and the Agency will
maintain adequate resources for that work, including consideration in our FY 2024 President's
Budget request. In addition, the Agency will continue to engage with the Navy on the
appropriate allocation of oversight costs, including specific obligations for federal contractors
where appropriate.
FROM: Martha Guzman
Regional Administrator
Region 9
ACEVES
Date: 2023.03.05
17:11:05 -OS'OO'
TO:
Lauretta Joseph, Director
Programs, Offices, and Centers Oversight Directorate
Office of Special Review and Evaluation
Office of Inspector General
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
23-E-0015
18
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Agreements
No.
Recommendation
High-Level Intended Corrective
Action(s)
Estimated Completion
Date
1
Develop a plan to define
and provide appropriate
levels of resources and
oversight, including
maintaining adequate
EPA staffing levels in
Oahu, during the
defueling and closure of
the Red Hill facility.
1.1 Develop cross-divisional
EPA staffing plan and Fiscal
Year 2023 Region 9 resource
request for oversight of the Red
Hill facility, including
environmental investigation and
remediation pursuant to the 2015
Administrative Order on
Consent (AOC) and defuel,
closure, completion of the
implementation of the Drinking
Water Long Term Monitoring
Plan pursuant to proposed 2023
Consent Order. Organizational
chart below.
Completed September 1,
2022
1.2 Increase the number of
Oahu-based EPA staff, including
hiring a dedicated Red Hill EJ
Community Engagement
Coordinator on temporary detail
to work directly with the
community and relocating three
people to oversee spill
prevention and response,
environmental investigation and
remediation, and provide
drinking water support to the
Hawaii Department of Health.
Completed March 1,
2023
1.3 Embed an EPA staff person
at the Hawaii Department of
Health through the
Intergovernmental Personnel Act
Mobility Program (IPA) to
further support the state's
capacity to oversee the
remaining drinking water long-
term monitoring efforts
underway.
In process to be
completed by August 1,
2023
1.4 Complete additional hiring
needed to backfill 2015 AOC
Project Coordinator (vacant
March 3, 2023) and
In process to be
completed by October 1,
2023
23-E-0015
19
-------
Underground Storage Tanks
Supervisor (vacant December 1,
2023) and permanently fill
remaining positions previously
filled by temporary details. One
of the details was permanently
filled on February 27, 2023.
2
Collaborate with the
Hawaii Department of
Health and the Navy, as
appropriate, to clearly
communicate risk and
remediation information
to the public.
2.1 Require Navy/DLA to host
quarterly public updates on
defueling, closure, completion of
the implementation of the
Drinking Water Long Term
Monitoring Plan, and
environmental investigation and
remediation work with
participation from EPA and
Hawaii Department of Health
pursuant to proposed 2023
Consent Order.
June 1, 2023
2.2 Develop a web-based
application to make Red Hill
groundwater monitoring well
data more easily available to the
public
June 1, 2023
2.3 With input from Hawaii
Department of Health, develop a
Community Involvement Plan,
which will include a section on
improving public
communication through website
updates and FAQs.
August 1, 2023
2.4 Collaborate with Hawaii
Department of Health to host a
three-part webinar series to share
information with the public on
what agencies are doing to
address impacts to human health
and the environment from Red
Hill releases. The first webinar
was completed January 12, 2023
and is posted on EPA's Red Hill
website.
In process to be
completed by December
1, 2023
3
Work with the Hawaii
Department of Health
and the Navy to develop
a plan to increase
3.1 Establish a schedule of Red
Hill Remediation Roundtable
and Groundwater Subject Matter
Expert Meetings to be convened
May 1, 2023
23-E-0015
20
-------
regulatory agency and
nongovernmental
organization
participation in Red Hill
working groups.
by EPA/Hawaii Department of
Health, with participation by
Navy, Board of Water Supply,
Commission on Water Resource
Management, andUSGS. Since
the report, a Groundwater
Subject Matter Expert meeting
was held on January 2023 and
Red Hill Remediation
Roundtable meeting February
2023 with full participation.
3.2 With input from Hawaii
Department of Health, develop a
Community Involvement Plan
(also mentioned in 2.3), which
will include a section on
community involvement
activities.
August 1, 2023
23-E-0015
21
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o^'0SX
f Q \
i££ZQ!
\ X?
4t PR(j&
EPA Regulatory Program Oversight of Red Hill
EPA Region 9
Martha Guzman (Regional Administrator)
Kerry Drake (Acting Deputy Regional Administrator)
Updates & Contact Us
EPA's Red Hill Website
https://www.epa.gov/red-hill
Environmental Investigation
& Remediation
Claire Trombadore
{Acting Director. Land, Chemicals, Si
Redevelopment Division [LCRD])
Alison Fong
(Asst. Director, RCRA Branch, LCRD)
Spill Response, Defuel &
Closure
Amy Miller
(Director, Enforcement & Compliance
Assurance Division [ECAD]}
Alison Fong
(Asst. Director, RCRA Branch, LCRD]
Kaoru Morimoto
(Asst. Director, Air, Waste, Chemicals
Branch, ECAD)
Roberto Rodriguez
(Asst. Director, Water Branch, ECAD)
Pete Guria
(Asst. Director, Emergency Response
Branch, SEMD)
Drinking Water
Tomas Torres
(Director, Water Division [WD])
VACANT
(Asst. Director, Permitting, Drinking
Water, and Infrastructure Branch, WD)
Roberto Rodriguez
(Asst. Director, Water Branch, ECAD)
Public Involvement
Laura Ebbert
(Director, Tribal, Intergovernmental
and Policy Division [TIPD])
Mike Alpern
(Director, Public Affairs Office [PAO])
1
Office of Regional Council
Sylvia Quast
(Director, Office of Regional Counsel
[ORC])
Thomas Butler
(Assistant Director, ORC)
O
E
VACANT
Jamie Marincola
Corine Li
(Manager, UST Program, LCRD)
(2023 Consent Order Project
(Manager, Drinking Water Program,
Grant Scaveilo
Coordinator, Manager of Oil Program,
WD)
•etoil: 2015 AOC Project Coordinator,
ECAD)
Barry Pollock*
LCRD)
VACANT
(Drinking Water Program, WD)
Lynn Bailey*
[Manager, UST Program, LCRD)
Anna Yen
(Environmental Lead, LCRD)
Evan Osborne
(Hawaii Drinking Water Program, WD)
VACAMT
[Detail: Defuel & Closure Lead, LCRD)
Lawrence Torres
(Environmental Team, LCRD)
Rick Sakow
(Manager, Drinking Water Inspection
Nicole Palazzolo
(Manager, Haz Waste and Chemicals
& Enforcement, ECAD)
{Part-xime: Environmental Team,
Program, ECAD)
Christopher Chen
Engineer, LCRD)
Bobby Ojha
(Inspector, SDWA, ECAD)
Mark Duffy
(Inspector, UST Program, ECAD)
Bill Piatt**
[Part-time: Environmental Team,
Pete Reich*
(Subject Matter Expert, HQ OGWDW)
Geologist, LCRD}
(Inspector, Oil Program, ECAD)
Steve Allgier**
Lyndsey Tu
Janice Witul
(Subject Matter Expert, HQ OGWDW)
(Hawaii UST Program, Contracts
(Inspector, Oil Program, ECAD)
Management, LCRD)
Lynn Keller
Patrick Wilson
(Manager, Emergency Response &
(Toxicologist, LCRD)
Facility Response Plan, SEMD)
Ben Castellana
(On-Scene Coordinator, SEMD)
Russ Brauksieck**
(Subject Matter Expert, HQ OUST)
Mark Howard**
(Subject Matter Expert, HQ OEM)
Troy Swackhammer**
(Subject Matter Expert, HQ OEM)
Dominique Smith*
{Detail: Red Hill EJ Community
Engagement Coordinator, TIPD)
Alejandro Diaz*
(Media Inquiries, PAO)
VACAMT
(Community Involvement Coordinator,
LCRD)
Chris Sebastian
(Web Team Lead, PAO)
Ben Leers
(Public Affairs-Congressional, PAO)
Rebekah Reynolds
(Attorney Advisor, ORC)
Dusty Minor
(Attorney Advisor, ORC)
Rich Campbell
(Attorney Advisor, ORC)
Sally Dalzell**
{Senior Counsel
Federal Facilities Enforcement Office,
HQOECA)
Rebecca Ringler
(Attorney Advisor, ORC)
Maddy Gallo
(Attorney Advisor, ORC)
Main Contacts
•Based in Honolulu at EPA Region 9's Pacific Islands Contact Office
*• EPA Headquarters Staff
CONTACT INFORMATION
If you have any questions regarding this response, please contact Mendy Guan, Region 9's Audit Follow-
Up Coordinator at 415-972-3749 or guan.mendvPepa.gov, or Alison Fong, Assistant Director RCRA
Branch at 415-972-3065 or fong.alison(5)epa.gov.
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Appendix B
Distribution
The Administrator
Deputy Administrator
Chief of Staff, Office of the Administrator
Deputy Chief of Staff for Management, Office of the Administrator
Agency Follow-Up Official (the CFO)
Regional Administrator, Region 9
Deputy Regional Administrator, Region 9
Assistant Administrator for Enforcement and Compliance Assurance
Assistant Administrator for Land and Emergency Management
Principal Deputy Assistant Administrator for Enforcement and Compliance Assurance
Principal Deputy Assistant Administrator for Land and Emergency Management
Deputy Assistant Administrator for Land and Emergency Management
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Continuous Improvement, Office of the Chief Financial Officer
Director, Office of Resource Conservation and Recovery, Office of Land and Emergency Management
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Region 9
Audit Follow-Up Coordinator, Office of Enforcement and Compliance Assurance
Audit Follow-Up Coordinator, Office of Land and Emergency Management
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