¦SEPA
United States Environmental Protection Agency
Office of Enforcement and Compliance Assurance
Office of Criminal Enforcement, Forensics and Training
NEICVP1463E02
NEIC CIVIL INVESTIGATION REPORT
Aliamanu Military Reservation Public Water System
Schofield Barracks, Hawaii 96857
Investigation Date:
April 7, 2022
HANNAH
BRANNING
Hannah Branning, Project Manager, NEIC
Digitally signed by
HANNAH BRANNING
Date: 2022.05.23
08:00:44 -060CT
Authorized for Release by:
REBECCA
CONNELL
ACONNELL
8 J2H2 lBXQICa 100 ! l»tt0C13e3STtM
b V03 OS 71 is » i? -oo-oir
Rebecca Connell, Field Branch Chief, NEIC
Report Prepared for:
EPA Region 9/Roberto Rodriguez
75 Hawthorne Street
San Francisco, California 94105
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
P.O. Box 25227
Building 25, Denver Federal Center
Denver, Colorado 80225
Page 1 of 12
-------
CONTENTS
INVESTIGATION OVERVIEW 3
PROJECT OBJECTIVE 3
FACILITY CONTACT INFORMATION 3
BACKGROUND 4
FACILITY OPERATIONS SUMMARY 5
FIELD ACTIVITIES SUMMARY 6
INVESTIGATION OBSERVATIONS 7
TABLES
Table 1. PROJECT TEAM MEMBERS... 3
Table 2. FACILITY CONTACT INFORMATION 3
APPENDICES (*NEIC-created)
A *NEIC Inspection Photographs (18 pages)
B Opening and Closing Conference Attendees (1 page)
C 2016 HDOH Sanitary Survey Report (42 pages)
D 2021 HDOH Sanitary Survey Report (80 pages)
E AMR PWS Certified Operators (1 page)
This Contents page shows al! the sections contained in this report
and provides a clear indication of the end of this report.
NEICVP1463E02
Page 2 of 12
AHamanu Military Reservation Public Water System
Schofieid Barracks, Hawaii
-------
INVESTIGATION OVERVIEW
PROJECT OBJECTIVE
U.S. Environmental Protection Agency (EPA) Region 9 (Region) requested EPA's National
Enforcement Investigations Center (NEIC) to conduct a Safe Drinking Water Act (SDWA)
compliance investigation of the Aliamanu Military Reservation public water system (AMR PWS),
located at 745 Wright Avenue, Schofieid Barracks, Hawaii 96857. The investigation assessed the
AMR PWS's compliance with SDWA regulations found in 40 Code of Federal Regulations (CFR)
Part 141.
Table 1 lists the project team members.
Table 1. PROJECT TEAM MEMBERS
Team Member
Organization
Project Role
] Hannah Branrting
NEIC
Project manager
1 David Parker
NEIC
Field team member
FACILITY CONTACT INFORMATION
Table 2 lists the primary facility contacts.
Tdble 2. FACILITY CONTACT WFQRIWATJON ]
Name, Title
Phone No.
Email Address J
us
Garrison Hawaii Directorate of
Public Works (USAG-HI-DPW),
Director
—
Engineering Division Chief
¦¦¦¦
Environmental Division Chief
mtmm
Acting Utilities Chief
mmam
¦¦^¦1 USAG-HI DPW,
Water Treatment Plant Supervisor
USAG-HI-DPW, Water
Systems Engineer
USAG-Hi-DPW, Water
Plant Work Leader
USAG-HI-DPW,
Safe Drinking Water Program
Manager
USAG-HI-DPW,
Safe Drinking Water Program
Specialist
NEICVP14G3E0Z
Page 3 of 12
ABamanu MEBttry Reservation Public Water System
Schofieid Barracks, Hawaii
-------
BACKGROUND
The AMR PWS is a community water system (PWS identification No. HIQ00Q337) located on a
U.S. military housing base adjacent to Joint Base Pearl Harbor-Hickam serving approximately
6,406 people with 1,090 service connections. The system serves the residents of the Aliamanu
and Red Hill housing areas located on AMR. USAG-HI-DPW owns and operates the AMR PWS.
The Hawaii Department of Health (HDOH) administers the Public Water System Supervision
Program in Hawaii and has been granted primary enforcement responsibility (i.e., primacy)
under the Safe Drinking Water Act.
The AMR PWS consecutive system receives wholesale treated drinking water from the Joint
Base Pearl Harbor-Hickam PWS (JBPHH PWS). The AMR PWS consists of a distribution system
with three AMR-owned ground storage tanks.
According to EPA's Enforcement and Compliance History Online (ECHO), the AMR PWS has not
experienced a regulatory violation since January 2019. Violation data prior to January 2019 is
not available in ECHO.
According to NAVFAV Hawaii staff, on May 6, 202.1, a valve opening operation was incorrectly
executed during a fuel mixing operation between tank IS and tank 20 in the Red Hiil bulk fuel
storage facility. A compression wave caused the end of the main fuel line to violently displace,
which caused the lateral line for tank 20 to shear off. spilling an unknown amount of jet
propellant-5 (JP-5) fuel. The spilled JP-5 fuel reached a sump pump for collecting aqueous
firefighting foam (AFFF) and was pumped into the 14-inch overhead AFFF polyvinyl chloride
(PVC) recovery pipe system.
According to the NAVFAC Hawaii "initial Release Response Report," on November 20, 2021, a
worker operating a trolley in the lower access tunnel ("Adit 3") of the Red Hill bulk fuel storage
facility cracked a clean-out valve for the overhead AFFF recovery pipe approximately 400 feet
east of the Adit 3 Red Hiil pumping station, spilling an estimated 9,000 gallons of JP-5 fuel and
water mixture. The JP-5 fuel mixture poured onto the concrete tunnel floor to the trolley tracks
and traveled approximately 750 feet over the underlying water development tunnel to a low
spot in the tunnel. The JP-5 fuel mixture accumulated in a groundwater sump that prevents
flooding in the access tunnel. The JP-5 fuel mixture was then transferred via a sump pump to
the groundwater sump drain holding tank and a connected sump drain leach tank located
outside the Adit 3 tunnel. At some point, the JP-5 fuel mixture in the Adit 3 tunnel entered a
nearby Hume drain, leaching the JP-5 fuel mixture into the underlying basalt bedrock, and
entered the Red Hill water development tunnel.
On November 21,2021, the Navy public affairs office issued a media release to the public and
AMR regarding the JP-5 fuel spill, stating that "personnel responded to what was initially
UEICVW463E02
Page 4 of 12
Aliamanu Military Reservation Public Water System
Schofield Barracks, Hawaii
-------
assessed as a water leak shortly after 1700 (5:00 pm) on November 20, 202:1. This pipe is not
connected to the Red Hill Fuel tanks or main fue! pipelines, all of which arc secure. Overnight,
the release began to contain some amount of fuel which increased into Sunday (November 21,
2021) morning. Approximately 14,000 gallons of a mix of water and fuel was contained in the
lower tunnel (Adit 3) and has been recovered and transferred to an above-ground storage tank
as of midday Sunday. The Navy made initial notification to the Department of Health Saturday
night (November 20, 2021) and is providing updates Sunday. There are no signs or indication of
any releases to the environment and the drinking water remains safe to drink,"
According to the NAVFAC Hawaii "Initial Release Response Report," on December 2, 2021,
tubing connected to a photoionization detector (PID) was lowered into the Red Hill shaft,
resulting in a maximum reading of 110 parts per million by volume (ppmv) of volatile organic
compounds (VOCs). A bailer sample was also collected from the Red Hill shaft and a sheen with
fuel bubbles floating on the surface was noticed, indicating fuel had reached the water
development tunnel. The Navy public affairs office issued a media release to the public and
AMR that petroleum products had been detected in the Red Hill well and the level of the
petroleum hydrocarbons in the well were roughly 4 to 10 times below the HDOH action level.
On December 2,2021, the Army authorized evacuation of personnel, dependents, and
employees impacted by the water contamination in the AMR and Red Hill housing areas.
On December 1.1, 2021, AMR PWS staff stated that USA6-HI met with the U.S. Army Corps of
Engineers (US-ACOE} to discuss additional water treatment options.
In late December of 2021, AMR PWS staff stated that USAG-HI and US-ACOE decide to move
forward with installation of granulated activated carbon (GAC) filters on the entry points to the
AMR PWS distribution system from the JBPHH PWS.
On February 28, 2022, HDOH approved the installation of the GAC filter system on the entry
point from JBPHH PWS's S-l and S-2 tanks.
On March 16, 2022, the GAC fitters were in placed into operation.
On March 28, 2022, HDOH approved the installation of the GAC filter system on the entry point
from JBPHH PWS's Red Hill tanks.
FACILITY OPERATIONS SUMMARY
The AMR PWS is a consecutive system that receives wholesale treated drinking water from the
JBPHH PWS. Under normal conditions, water for the Aliamanu and Red Hill housing areas is
chlorinated and fluorinated at three JBPHH PWS sources (Waiawa shaft, Halawa shaft, and Red
WEICW14S3E02
Page S of 12
Allamariu Mttttary Reservation Public Water System
Schofield Barracks, Hawaii
-------
Hill shaft) and then stored in two JBPHH PWS 6-million-gallon ground storage tanks (S-l and 5-
2) and two JBPHH PWS 250,000-gailon Red Hill ground storage tanks. Treated water then
passes through a master meter on the outlet pipe from the tanks and enters the AMR
distribution system.
Currently, treated water from the JBPHH PWS's S-l and S-2 tanks enters the AMR PWS point of
entry and undergoes additional treatment through two-stage GAC filtration, with two
treatment units operating in paraliei. Once the water passes through the filters, it is disinfected
with sodium hypochlorite before it is split between two storage tanks. The GAC filters on the
entry point from the JBPHH PWS Red Hill tanks were not in service at the time of the inspection.
AMR PWS is currently testing the filters, as the JBPHH PWS has concerns about water pressure
in the event water is needed for the AFFF system at the Red Hill bulk fuel storage site.
FIELD ACTIVITIES SUMMARY
NEIC conducted the on-site inspection on April 7, 2022. The NEIC inspection team consisted of
Hannah Branning and David Parker. Maria Alberty and Emma Young from EPA Region 9 also
participated in the inspection. Whit Somerall from HDOH was also present during the
inspection. Photographs taken by NEIC during the inspection are found in Appendix A. NEIC
conducted an inspection of the JBPHH PWS from April 4-8, 2022 (report NEICVP1463E01).
On April 7, 2022, NEIC inspectors conducted an opening meeting and presented credentials to
USAG-HI-DPW director. On April 7, 2022, NEIC inspectors conducted a closing
meeting with USAG-HI-DPW and HDOH representatives. Lists of the meeting attendees are
found in Appendix B.
NEIC assessed the AMR PWS's compliance with the SDWA. The assessment included detailed
discussions about and field observations of the distribution system, finished water storage,
pumps, pumping facilities and controls, monitoring, reporting, data verification, system
management and operation, and operator compliance with state requirements. The
assessment also included a review of records, including system maps and schematic diagrams,
monitoring records, customer complaint logs, public notifications, engineering evaluations, and
standard operating procedures.
N EICVPMC3EQ2
Page 6 of 12
AKamanu Military Reservation Public Water System
Schofiek* Barracks, Hawaii
-------
INVESTIGATION OBSERVATIONS
NEIC identified the following observations during the SDWA compliance inspection. NEIC field
team members discussed ail observations with facility representatives during the closeout
meeting.
These observations are not final compliance determinations. EPA Region 9 will make the final
compliance determinations based on its review of this report and other technical, regulatory,
and facility information.
[ Observation 1
I Observation Summary: NF1C inspectors observed the GAC treatment supports on the base of
; the S-l tank, unlabeled pipes indicating direction and flow, unlabeled chemical injection
| points, and improperly stored chemicals.
Citation:
Title 11 Chapter 2G Hawaii Administrative Rules Section 38 (§11-20-38)
Additives
(d) The use of any chemical, material, or product in drinking water treatment or supply shall
conform to the manufacturer's instructions or recommendations for use, maximum dosage,
application rates., installation, restrictions, and any other conditions imposed by the product
certification organization accredited by the American National Standards Institute or the
director.
Evidence:
NEIC inspector observations
AMR PWS staff interviews
Appendix A - NEIC Inspection Photographs
Description of Observation: The AMR PWS installed GAC treatment in response to the
November 20, 2.021, JP-5 fuel spill and contamination of the Red Hill shaft (Appendix A-
; Photo P4070074.JPG). NEIC inspectors observed the support beams for the influent piping to
: the GAC filters sitting on the foundation for the JBPHH PWS S I tank (Appendix A - Photo
P4060055.JPG). On May 2, 2022, HDOH notified NEIC inspectors that the supports had been
removed from the tank foundation.
NEIC inspectors observed no labeling of pipes indicating contents, direction of flow, or
chemical injection points (Appendix A - Photo P4070075.JPG and Photo P4070076.JPG). The
contractor for the AMR PWS stated the new ductile iron piping would indicate flow direction
and chemical injection points once installed.
NEIC inspectors observed two sodium hypochlorite tanks sitting in direct sunlight (Appendix
A - Photo P4070077.JPG). During the NEIC inspection, the AMR PWS contractor stated that
sun shields would be installed to protect the tanks from sunlight in the next 3 weeks.
NEIC inspectors observed a biack trash bag taped to the influent and effluent booster pump
connections in an attempt to maintain a sanitary seal (Appendix A - Photo P4070078JPG).
NEtCVP1463f02 Page 7 Of 12 AWamanu MilHaiy ieservation Publir Water System
6 Schofielti Barracks, Hawaii
-------
1ObscrvailoiiT _____
Observation Summary: NEIC inspectors observed multiple instances of tank integrity issues,
erosion issues, vegetation growth, corrosion of pipes, and access issues that were noted on
previous HDOH sanitary surveys.
^ ^ "
i Title 11 Chapter 20 Hawaii Administrative Rules Section 29.5 (§11-20-29.5)
\ Capacity demonstration and evaluation
i (b) A public water system with adequate technical capacity has at least the following items:
(4) An adequate infrastructure replacement plan which includes estimates of the
useful life and plans for the eventual replacement of the public water system's
infrastructure, including:
(A) Wells;
(B} Pumping facilities;
(C) Storage tanks;
(D) Treatment facilities; and
(El Distribution system (pipes, valves, meters, etc.)
Evidence:
NEIC inspector observations
AMR PWS staff interviews
Appendix A - NEIC Inspection Photographs
Appendix C - 2016 HDOH Sanitary Survey Report
Appendix D - 2021 HDOH Sanitary Survey Report
Description of Observation:
Central Tank (referred to as the "Middle Tank" in HDOH sanitary surveys)
NEIC inspectors observed exposed rebar from the tank walls (Appendix A - Photo
P4Q70Q82.JPG). This observation was noted on the 2016 HDOH sanitary survey (Appendix C).
NEIC inspectors observed severe pitting in the concrete walls of the tank (Appendix A -
Photo P4070083.JPG). This observation was noted on the 2016 HDOH sanitary survey
(Appendix C).
NEIC inspectors observed vegetation with a root system growing in the wall seam (Appendix
A - Photo P4Q7QQ84.JPG),
NEIC inspectors observed the combined inlet and outlet pipe was severely corroded with rust
and pitting and thick vegetation growing around the foundation of the tank (Appendix A -
Photo P4070085.JPG). This observation was noted on the 2021 HDOH sanitary survey
(Appendix D). On May 9, 2022, EPA Region 9 notified NEIC inspectors that the AMR PWS had
applied a rust inhibitor to the central tank piping to slow down corrosion as an interim
remedy on April 29, 2022.
NEIC inspectors observed erosion around the base of booster pump #1 and that booster
pump piping to both pump #1 and #2 was rusted and pitting (Appendix A - Photo
P4070086.JPG). This observation was noted on the 2021 HDOH sanitary survey (Appendix D).
On May 9, 2022, EPA Region 9 notified NEIC inspectors that the AMR PWS had applied J rust
NEKVP14SJE02
Pages of 12
Aliamanu Military Reservation Public Water System
Schofield Barracks, Hawal
-------
Observation 2
inhibitor to the centra! tank piping to slow down corrosion as an interim remedy on April 29,
2022.
NEIC inspectors observed that the access ladder hatch hinge was broken and could not be
closed and that the ladder hatch had no lock (Appendix A Photo P4070087.JPG). This
observation was noted on the 2021 HDOH sanitary survey (Appendix D). On May 9, 2022,
EPA Region 9 notified NEIC inspectors that the AMR PWS had repaired the access ladder
hatch and secured it with a new lock on May 3, 2022.
NEIC inspectors observed that the tank overflow was full of debris and a hole in the screen
had been previously repaired with silicone (Appendix A - Photo P4070088.JPG). This
observation was noted on the 2021 HDOH sanitary survey (Appendix D).
North Tank
NEIC inspectors observed floating particles on the surface of the finished water in the tank
(Appendix A - Photo P4070080.JPG). This observation was noted on the 2021 HDOH sanitary
survey (Appendix D}. On May 9, 2022, EPA Region 9 notified NEIC inspectors that the AMR
PWS staff had rerroved floating particles from the north tank on April 29, 2022.
Erosion of the hillside behind the tank has resulted in partial coverage of the tank roof and
walls with soil and grass. NEIC inspectors also observed vegetation growth around the base of
the tank (Appendix A - Photo P4070081.JPG). AMR PWS staff stated a contractor was going
to assess the tank roof and the hillside erosion issues.
NEIC inspectors observed exposed rebar on the roof of the tank. This observation was noted
on the 2021 HDOH sanitary survey (Appendix D).
South Tank
NEIC inspectors observed exposed rebar on the roof of the tank (Appendix A - Photo
P4070090.JPG). This observation was noted on the 2.021 HDOH sanitary survey (Appendix D).
Observation 3
Observation Summary: The AMR PWS is unable to isolate ground storage tanks from service
for cleaning or repairs due to a lack of redundancy iri the system.
Citation:
Title 11 Chapter 20 Hawaii Administrative Rules Section 29.5 (§11-20 29.5}
Capacity demonstration and evaluation
(b) A public water system with adequate technical capacity has at least the following items:
(2) Adequate water source(s), including:
(A) Sufficient water available to serve all customers or water users based on
the public water system's average daily and peak water usage, and the
system's treated water output;
| Evidence:
NEIC inspector observations
Description of Observation: The AMR PWS cannot isolate the north, centra!, and south tanks
from service for cleaning or repairs due to a lack of redundancy in the system.
HHEKVP14&3E02
AHamanu Miliary Reservation Public Water System
Schofield Barracks. Hawaii
-------
1 Observation 4 _
| Observation Summary: NEiC inspectors observed severely corroded high-pressure pumps to
the south tank.
Citation:
Title 11 Chapter 20 Hawaii Administrative Rules Section 29.5 (§l l-2 J-29.5)
Capacity demonstration and evaluation
(b) A public water system with adequate technical capacity hjs at least the fallowing items:
(4) An adequate infrastructure replacement plan which includes estimates j/ the
useful life and plans for the eventual replacement jf the public water system's
infrastructure, including:
(A) Wells;
(B) Pumping facilities;
(C) Storage tanks;
(D) Treatment facilities; and
(E) Distribution system (pipes, valves, meters, etc.) ______________
i Evidence:
j NEIC inspector observations
! Appendix A NEiC inspection Photographs
I Appendix D - 2021 HDOH Sanitary Survey Report
Description of Observation: NEiC inspectors observed that the high-pressure pumps that
push treated, finished water to the south tank were severely corroded with rust and pitting.
; Evidence of previous oil leaks from the pumps was present (Appendix A - Photo
: P4070Q79.JPG). This finding was noted on the 2021 HDOH sanitary survey {Appendix D).
| Observation 5
Observation Summary: The AMR PWS does not have an emergency interconnection or a
valve exercise program,
Citation:
Title 11 Chapter 20 Hawaii Administrative Rules Section 29.5 (§11-20-29.5)
Capacity demonstration and evaluation
(b) A public water system with adequate technical capacity has at least the following items:
(2) Adequate water source(s), including:
(A) Sufficient water available to serve all customers or water users based on
the public water system's average daily and peak water usage, and the
system's treated water output;
(B) Sufficient water resources for the future, based on the maximum flow or
pumping capacity of each source and a five year or more projected growth rate
study which shall be submitted;
(C) Adequate protection of water source(s) or watershed(s), based on the
identification of existing and potential contamination hazards as required
under the source water protection program and a description of how a
protective area will be maintained around the source(s) or the watershed(s);
and
(D) Contracts or agreements to obtain water when the water source(s) are not
owned by the public water system, and contracts or agreements for
supplementary water sources for systems affectedbydrought. The contracts
NEICVMA63E02
Page 10 of 12
AHamanu MRtary imenratloB Public Water Syttwn
Scbofield Barracks, Hawaii
-------
(oteeirealioiiS
and agreements shall be identified, end copies shall be provided if requested
by the director
i Evidence;
NF.IC field inspection notes
AMR PWS staff interviews
Description of Observation: The AMR PWS does not have an emergency interconnection
with another water system. All water is purchased from the JBPHH PWS, which is currently
utilizing one source.
Observation 6
Observation Summary: The AMR PWS could not produce a distribution system valve exercise
program. ___
; Citation:
Title 11 Chapter 20 Hawaii Administrative Rules Section 29.5 (§11-20-29.5)
Capacity demonstration and evaluation
(b) A public water system with adequate technical capacity has at least the following items:
(4) An adequate infrastructure replacement plan which includes estimates of the
useful life and plans for the eventual replacement of the public water system's
infrastructure, including:
(A) Wells;
(B) Pumping facilities;
(C) Storage tanks;
(D) Treatment facilities; and
(E) Distribution system (pipes, valves, meters, etc.);
(5) An adequate operation plan which shows that the public water system has:
(C) Adequate preventive and corrective maintenance program to identify,
schedule, perform, and record inspections, repairs, and replacements in a
timely manner.
Evidence:
NEIC inspector observations
AMR PWS staff interviews
Description of Observation: ArxonJi^tcT^^BBH^BBB^TjSAG^HI-DPW acting utilities
chief, the AMR PWS does not have a current distribution system valve exercise program. The
last time jj^^^HBrecalled exercising the distribution system valves was in 2008.
Observation 7
Observation Summary: The AMR PWS has only five certified water treatment plant operators
and only three certified distribution operators to cover the Army's four PWSs. _
Citation:
Title 11 Chapter 25 Hawaii Administrative Rules Section 2.50 (§11-25-2.50)
Public water system operation and management
(a) This chapter applies to all community and non- transient noncammunity public water
systems.
(1) Each public water system covered by this chapter shall be under the responsible
charge of an operator(s) holding a valid certification equal to or greater than the
classification of the water treatment plant (WTP) or distribution system (DS};
NEtCVP1463E02
Page 11 of 12
AKanunu Military Reservation Public Water System
Schofield Barracks, Hawaii
-------
f Observation 7 _
(2) All operating personnel making daily process control or system integrity decisions
about water quality or quantity that affect public health shall be certified; and
(3) A designated certified operator shall be available for each operating shift,
(b) This chapter applies to all WTPs in community and non-transient noncommunity public
water systems and ail WTPs serving surface water or ground water under the direct influence
of surface water. All WTPs covered by this chapter shall be operated by certified WTP
operators. Each WTP shall at all times be under the responsible charge of an operator holding
a valid certification equal to or greater than the WTP classification.
(c) Ail fluoridation facilities shall be operated by certified operators who have received board-
approved fluoridation training.
(d) Each DS shall at all times be under the responsible charge of an operator holding a valid
certification equal to or greater than the DS classification.
Evidence:
NEIC field inspection notes
AMR PWS staff interviews
Appendix E - AMR PWS Certified Operators
Description of Observation: According to AMR PWS records, only five certified water
treatment plant operators and one supervisor cover the Army's four PWSs, If a certified
water treatment plant operator is out for an extended period of time, the AMR PWS does not
have an adequate number of operators to run the Army's four PWSs. At the time of the NEiC
inspection, two certified water treatment piant operators were out.
According to AMR PWS records, only three certified distribution system operators and one
supervisor cover the Army's four PWS distribution systems. The number of distribution
system operators is not adequate to cover the Army's four PWS distribution systems. _
NE1CWM63E02
Page 12 of 12
ABwrMHtu MWtary Reservation Public Water System
Sthofield Barracks, Hawaii
------- |