Red Hill Remediation Roundtable
Purpose
EPA and Hawaiʻi Department of Health (DOH) convened the Red Hill Remediation Roundtable (Roundtable) to bring together water protection public trust agencies to discuss active and planned work to investigate and remediate contamination caused by the Red Hill Bulk Fuel Storage Facility.
Invitees to the Roundtable include senior leaders from the Honolulu Board of Water Supply, Hawaiʻi State Department of Land and Natural Resources - Commission on Water Resource Management, and U.S. Geological Survey. The U.S. Navy also participates in Roundtable meetings.
Discussions held at the Roundtable provide EPA and DOH with information that supports regulatory agencies in making decisions under the 2015 Administrative Order on Consent and state of Hawaii authorities. EPA and DOH do not solicit group advice and recommendations from the Roundtable as a whole. Instead, the individual Roundtable participants provide subject matter expertise and input that relates to each individual participant’s areas of responsibility and interest.
While roundtable meetings are not open to the public, meeting summaries are published on this webpage for the public to view.
Meeting Summaries
April 11, 2024
EPA and DOH convened a meeting of the Red Hill Remediation Roundtable on April 11, 2024. Attendees included leadership from the Navy Closure Task Force – Red Hill (NCTF-RH) Honolulu Board of Water Supply (BWS), Department of Land and Natural Resources - Commission on Water Resource Management (CWRM), and U.S. Geological Survey (USGS).
Participants provided further information on a range of topics that were raised at the February 8, 2024 Roundtable meeting, including:
- Rear Admiral Barnett is expected to remain in charge of the NCTF-RH through spring/summer of 2025
- The Department of Defense is working on removing the Red Hill facility’s Defense Critical Status (so that associated reports do not require the same level of redactions). There is no set timeline for its removal from this status.
- The Navy’s Restoration Advisory Board (RAB) is redoing its Charter, which will include instructions on how community members may apply to join. RAB members are selected by the RAB Co-Chairs, including Henry Curtis who serves at the public co-chair. The next RAB meeting is tentative scheduled for late June 2024.
- The Navy has not determined how its per- and polyfluoroalkyl substances (PFAS) investigation documents will be shared with the public. An update will be provided at the next Roundtable meeting.
- BWS is still drafting its PFAS sampling plan.
The NCTF-RH will submit a draft Site Assessment Plan to DOH and EPA in June 2024 and seeks regulatory agency concurrence by October 2024. The tentative schedule is to conduct field work from January – Fall 2025 and complete a site assessment report by mid to late 2026. Site investigation would start in 2027.
The EPA requested more time to review the initial and subsequent versions of the Site Assessment Plan and asked if the NCTF-RH can submit certain portions of it earlier than scheduled. The NCTF-RH confirmed data from previous releases will be discussed in its June 2024 Plan submittal and that it will include a high-level schedule for assessment, investigation, and remediation.
DOH requested input and recommendations from Roundtable participants on the NCTF-RH’s Consolidated Groundwater Sampling Plan, which includes a request to reduce Red Hill Shaft pumping rates. Participants said they were not prepared to provide comments and recommendations at this time.
EPA discussed their recently promulgated PFAS Maximum Contaminant Levels (MCLs) in drinking water. In response to an EPA/DOH letter requesting the NCTF-RH to continue PFAS sampling past the initial baseline investigation period, NCTF-RH agreed to prioritize the Red Hill PFAS investigation. They will respond to the Regulatory Agency request within two weeks and will meet with them on April 12 to discuss sampling approaches, the conceptual site model, and schedule. A draft PFAS sampling plan will be submitted in June 2024 and sampling would start in September 2024 at the earliest. BWS confirmed their desire to have monthly sampling to provide more data and detect any abnormalities earlier than less frequent sampling.
NCTF-RH reported on monitoring well installations. They have experienced progress on negotiations with private landowners thanks in large part to the efforts of Hawaii Legislative House Special Committee on Red Hill members. Roundtable participants will be submitting comments to the NCTF-RH’s Monitoring Well Installation Plan Update.
EPA and DOH proposed to hold Roundtable meetings on a quarterly basis going forward, and there were no comments or objections. The next Roundtable meeting will be in July 2024. The next Roundtable Subject Matter Expert quarterly meeting will likely be in June 2024.
February 8, 2024
EPA and DOH convened a meeting of the Red Hill Remediation Roundtable on February 8, 2024. Attendees included leadership from the Navy Closure Task Force – Red Hill (NCTF-RH) Honolulu Board of Water Supply (BWS), Department of Land and Natural Resources - Commission on Water Resource Management (CWRM), and U.S. Geological Survey (USGS). Personnel from the University of Hawai’i also attended to brief Roundtable participants about research relevant to Red Hill remediation.
NCTF-RH representatives provided a brief overview of their organization’s structure and status of development. NCTF-RH will have approximately 200 staff, primarily civilian personnel. Roundtable members would like to know how long Admiral Barnett will continue to lead the NCTF-RH and if there is an update organizational chart. NCTF-RH will respond to both requests.
The EPA and DOH discussed their written expectations for the NCTF-RH Red Hill Closure Site Assessment Plan. (See DOH-RH-UST-Closure-Site-Assessment-Expectations (pdf) and EPA Letter: Request for Closure Plan for Site Assessment and Release Response Actions (pdf) ). DOH and EPA emphasized that site assessment must address the entire Red Hill fuel storage system, include associated pipelines and adjacent areas impacted by prior fuel releases. DOH and EPA are conducting a series of scoping meetings with the NCTF-RH to further define the requirements for site assessment. BWS requested copies of the NCTF-RH responses to DOH and EPA site assessment expectation letters and asked that there be no redactions since the Red Hill facility is no longer a national security matter. NCTF-RH will discuss the redaction question with their legal counsel. NCTF-RH has concerns about providing a remediation schedule at this point, although EPA responded it can be high-level and updated as work progresses. EPA and DOH noted they will no longer update the 2015 Administrative Order on Consent (AOC) with respect to site assessment requirements and will rely on the State’s 2022 Emergency Order and the EPA/Navy/DLA 2023 Administrative Consent Order.
BWS asked how DOH and EPA will specify PFAS testing requirements for Red Hill monitoring wells. DOH and EPA will oversee Navy’s Red Hill PFAS investigation under the Federal Facility Agreement (FFA). DOH and EPA are drafting letter defining additional PFAS sampling requirements. DOH asked if BWS is testing for PFAS, and specifically at Halawa Shaft. BWS responded that Halawa shaft’s cable car is broken which prevents testing, but other nearby well tests are posted on BWS’ website.
NCTF-RH’s updated Monitoring Well Installation Workplan will be presented and discussed at the February 22, 2024 Red Hill Remediation Roundtable Subject Matter Expert Workshop.
DOH conveyed that their most recent letter disapproving NCTF-RH’s request to reduce pumping rates at Red Hill Shaft include the need to know how NCTF-RH will reuse the effluent from the Granulated Activated Charcoal (GAC) filtration system. While DOH supports the proposal to use the water for cleaning the Red Hill tanks during closure, that is a relatively minor amount. NCTF-RH noted they are looking into other options for reusing the water.
NCTF-RH discussed the Baseline PFAS Sampling Results (pdf) conducted in September 2023, noting there were some Environmental Action Level (EAL) exceedances. There was broad recognition among Roundtable participants that further investigation should consider a range of potential sources, including cleaning products and fuel releases. DOH requested links to all Roundtable participants’ PFAS data. NCTF-RH will confirm how PFAS data can be exported from the Safe Waters website. BWS noted that PFAS data and investigations seem to be too siloed for easy access, and that it should be more centralized in the Navy.
In further discussion, it was noted that NCTF-RH needs to set dates for Remedial Investigation (RI) and Remediation Advisory Board (RAB) meetings. BWS requested to be included in the RAB meetings, which NCTF-RH will follow up on.
DOH and EPA discussed revisions to the Roundtable Charter based upon comments received from Roundtable participants. USGS noted that some fairly minor proposed revisions should still be considered, and EPA/DOH said they would review and consider these. EPA and DOH noted that several USGS suggestions had already been incorporated. BWS expressed disappointment that some of their suggestions were not incorporated, although EPA and DOH noted that many of BWS’ recommendations were incorporated.
December 14, 2023
EPA and DOH convened a meeting of the Red Hill Remediation Roundtable on December 14, 2023. Attendees included leadership from the U.S. Navy, Honolulu Board of Water Supply (BWS), Department of Land and Natural Resources - Commission on Water Resource Management (CWRM), and U.S. Geological Survey (USGS). Navy on-island principals were unable to attend this meeting and provide updates on the agenda, however Office of the Deputy Assistant Secretary of the Navy attended to relay the discussion and follow-up items.
With the defueling of Red Hill tanks and pipelines and the pending closure of the UST system, EPA and DOH are focused on the comprehensive site assessment, release investigation, and remediation that are required by closure. EPA and DOH outlined their requirements and expectations for the Navy’s pending Red Hill Site Assessment Plan, which will guide the Navy’s work to identify the date, location, and types and quantities of all prior known releases into the environment from the entire UST system (including the tanks and associated pipelines). The Site Assessment Plan will also identify the hydrogeological and soil characteristics beneath and adjacent to the UST system. The Site Assessment will then inform the approaches and plans for remediation. The Site Assessment Plan will be prepared by the Navy Closure Task Force-Red Hill (NCTF-RH) and be subject to review and approval by both EPA and DOH. Roundtable participants sought assurance that the scope of assessment and remediation not be limited to the physical boundaries of the Red Hill Bulk Fuel Storage Facility. EPA responded that the Site Assessment must address historic releases from the entire UST system, and any geological features that may contribute to the migration of contaminants beyond the physical boundaries of the Red Hill Bulk Fuel Storage Facility.
EPA and DOH summarized input received from a recent series of Subject Matter Expert (SME) workshops regarding proposed additional monitoring well locations. The workshops yielded specific recommendations for the location and types of monitoring wells needed to provide additional data on the migration of contaminants in groundwater, with a focus on protecting existing aquifer uptake facilities for drinking water. The Navy is preparing a draft Monitoring Well Installation Plan Update which will be forwarded to EPA and DOH for review.
DOH discussed its opposition to the Navy’s request to reduce current pumping rates at the Red Hill Shaft’s GAC filtration system that began in January 2022 to help contain the migration of contaminants in the aquifer. DOH stated that the Navy lacks sufficient other measures to effectively contain such migration should another release occur during the remainder of the defueling process. Roundtable participants asked at what point of defueling and closure would DOH permit the reduction of Red Hill Shaft pumping rates, since extracting all the fuel from the facility may take a few years. DOH has not yet made a determination since there are still too many unknowns, including the extent of prior releases and the specific operations and procedures to be done before closure is complete.
EPA discussed its ongoing investigation into complaints by some Navy housing residents about possible fuel in the premise plumbing of their domestic water supply. The EPA is finalizing a report to be issued within the next week summarizing their findings and recommendations.
EPA staff reviewed the list of analytes the Navy is required to test for in the groundwater sampling program and requested that the Navy test for additional analytes contained in fuel additives, cleaning products used to help contain prior fuel releases, and per- and polyfluoroalkyl substances (PFAS).
EPA/DOH briefly reviewed the Navy’s results from PFAS baseline sampling in groundwater undertaken at 21 monitoring wells around Red Hill in September 2023. The Navy reported that the concentration of one type of PFAS, perfluorooctanesulfonic acid (PFOS), exceeded the screening criteria in several wells near Red Hill Shaft and one well that is south of the freeway. This is a different type of PFAS from the PFAS that were detected in groundwater after the November 2022 Adit 6 release. EPA and DOH have asked for the full sampling report to determine what other PFAS compounds were detected, and we are working with the Navy to define the parameters and requirements for future PFAS testing. EPA/DOH also shared the Navy’s progress towards scoping a Red Hill PFAS Remedial Investigation and anticipate a workplan in 2024.
Roundtable participants reviewed recent proposed revisions to the Roundtable Draft Charter. Some participants would like to revisit aspects of the Draft Charter that address public outreach. The Draft Charter will be further discussed at the next Roundtable meeting in February 2024. Other suggested topics for discussion include the Navy’s ability to send alternates to future Roundtable meetings should any of their principals be unable to attend; the Navy’s PFAS Sampling Plan; and the revised environmental Scope of Work.
August 10, 2023
EPA and DOH convened a meeting of the Red Hill Remediation Roundtable on August 10, 2023. Attendees included leadership from the U.S. Navy, Honolulu Board of Water Supply (BWS), Department of Land and Natural Resources - Commission on Water Resource Management (CWRM), and U.S. Geological Survey (USGS). EPA and DOH updated Roundtable members that Navy is working on scoping a Red Hill PFAS Investigation, as part of the Joint Base Pearl Harbor Hickam PFAS Investigation. In advance of that investigation, the regulators asked that the Navy conduct a one-time baseline sampling of all Red Hill monitoring wells for PFAS. The Navy confirmed they will begin PFAS testing at their monitoring wells within the next two months.
EPA and DOH also summarized the July 6, 2023, Subject Matter Expert (SME) quarterly workshop, where the Roundtable SMEs reviewed and discussed ongoing analyses based on groundwater sampling and were briefed on a University of Hawaii study using a range of geophysical and geochemical surveys and analyses to improve understanding of groundwater flows in the area surrounding Red Hill. EPA and DOH briefed Roundtable participants on recent and upcoming public engagement activities, including the Community Representation Initiative (CRI) which is a component of the 2023 Consent Order. The next Fuel Tank Advisory Committee (FTAC) meeting will be in November 2023.
BWS’ SMEs presented a hydrogeological assessment of impacts from Red Hill releases. The assessment focused on the BWS’ interpretation of the geological complexity in the vicinity of Red Hill and how it could factor into contaminant flows and transport. Several Roundtable participants expressed interest in studying the information presented in more detail before commenting. The assessment will likely be further discussed at the next SME Quarterly Meeting, and at the next Roundtable meeting.
EPA staff reviewed the list of analytes the Navy is required to test for in the groundwater sampling program, and requested that the Navy test for additional analytes contained in fuel additives, cleaning products used to help contain prior fuel releases, and PFAS.
The Navy provided updates on site investigation and remediation work and noted that some activities will be temporarily halted during defueling scheduled to begin in October 2023. A draft Red Hill Shaft Flow Optimization Study will be completed by August 17, 2023. EPA noted that they will be issuing a disapproval letter for the Navy’s request to reduce flow rates through the Red Hill Shaft Granular Activated Carbon (GAC) system. The Navy noted that for the 22 new monitoring wells being installed, 12 are complete and another 4 are underway. The remaining 6 are in planning stages. EPA and DOH are organizing a workshop in October 2023 to determine where monitoring wells are needed to address Red Hill contamination. The workshop will discuss priority locations for the Navy’s next phase of well installations in 2024, and the types of wells that should be installed to collect groundwater samples that will help us understand where contamination is and how groundwater flows in certain locations. Roundtable participants and their SMEs will be invited. CWRM emphasized that the Navy should submit monitoring well permit applications as soon as possible so they can adhere to their installation schedules.
The Navy reviewed recent work they conducted to explore resuming the use of the Navy Aiea Halawa Shaft for emergency use water supply. They are working closely with the DOH Safe Drinking Water Branch on the testing protocols needed and conditions under which the water from the shaft could be used. The Navy is also reviewing bids for design of a water treatment plant at the Red Hill Shaft and confirmed the treatment plant site would be relatively far away from the contamination area. CWRM expressed interest in the status of the Navy’s Pearl Harbor Water Resources Management Plan which was initiated in early 2022. Other Roundtable members requested more information about the Beneficial Reuse study for filtered effluent from the Red Hill Shaft pumping operations. The Navy will provide updates on both items.
Roundtable participants recognized that October 2023 will be a particularly busy month for most agencies involved with Red Hill due to the commencement of defueling and the need to identify optimal locations for the remaining monitoring well installations. EPA and DOH will consider alternative dates for the next Roundtable meeting.
June 8, 2023
EPA and DOH convened a meeting of the Red Hill Remediation Roundtable on June 8, 2023. Attendees included leadership from the U.S. Navy, Honolulu Board of Water Supply, Department of Land and Natural Resources - Commission on Water Resource Management, and U.S. Geological Survey. EPA and DOH confirmed their intent to not delay the expedited defueling schedule. EPA also updated Roundtable members on the recently finalized 2023 Consent Order between EPA and the Navy/Defense Logistics Agency.
EPA and DOH summarized the discussion at the May 11, 2023, Subject Matter Expert (SME) quarterly workshop, where the Roundtable SMEs discuss technical details in greater depth. It was noted that the Board of Water Supply (BWS) had raised questions about the purpose of the groundwater tracer study being conducted by University of Hawaii faculty, which was discussed in greater detail at the July 6, 2023, SME quarterly workshop. EPA and the Navy each provided updates on their recently created separate groundwater mapping online applications EPA Groundwater Sample Results App and Navy’s Safe Waters JBPHH Groundwater Monitoring Dashboard App. The BWS suggested that the applications focus on making information understandable to laypersons. EPA and DOH expressed interest in the BWS’ previous offer to have BWS’ groundwater sampling data incorporated into EPA’ groundwater mapping application.
The Navy provided updates on several investigation and remediation activities, including the installations of new monitoring wells. The Navy is open to recommendations from regulators and SMEs about new well locations. The Commission on Water Resource Management (CWRM) expressed concerns that all new monitoring wells should be designed to avoid becoming conduits for groundwater contamination.
EPA and DOH briefed members on recent and upcoming public engagement activities. It was noted that compared to 2022, there are significantly more public engagement events in 2023. EPA will launch a new Community Representation Initiative (CRI) in summer 2023 as a new public engagement approach related to the 2023 Consent Order. Another Fuel Tank Advisory Committee (FTAC) meeting is being planned in November 2023, coupled with another Red Hill Open House involving multiple stakeholder agencies and groups.
April 13, 2023
EPA and DOH convened a meeting of the Red Hill Remediation Roundtable members on April 13, 2023. Attendees included leadership from the U.S. Navy, Honolulu Board of Water Supply, Department of Land and Natural Resources - Commission on Water Resource Management, and U.S. Geological Survey. The meeting began with EPA and DOH providing updates on clarifying the 2015 Administrative Order on Consent (AOC) Statement of Work with Navy. Navy then provided an update on their remediation actions schedule, and there was discussion of priorities for Navy to complete prior to defueling. EPA presented a preliminary demonstration of a GIS groundwater application and gathered initial feedback from the Roundtable members. Discussion on investigation and remediation followed, and topics included aqueous film forming foam (AFFF) release response, per- and polyfluoroalkyl substances (PFAS) monitoring, expansion of Navy’s groundwater monitoring well network, and the status of the Red Hill Shaft flow optimization study. BWS recommended that PFAS testing related to Red Hill should be expanded to monitoring at all monitoring wells including Red Hill Shaft. The conversation concluded with discussion of upcoming public engagement events.
In this May 15, 2023 letter, the Navy committed to investigating and responding to PFAS at Red Hill under a combination of the 2015 AOC and 1994 CERCLA Federal Facility Agreement for Joint Base Pearl Harbor Hickam.
February 23, 2023
EPA and Hawaiʻi Department of Health (DOH) convened a meeting of the Red Hill Remediation Roundtable on February 23, 2023. Attendees included leadership from the U.S. Navy, Honolulu Board of Water Supply, Department of Land and Natural Resources - Commission on Water Resource Management, and U.S. Geological Survey. EPA and DOH provided updates on the status of the 2015 Administrative Order on Consent (AOC), discussed a recently issued AOC scope clarification letter, and discussed regulatory agency priorities for Red Hill remediation over the next six months. The U.S. Navy provided updates on its work on the November 2022 Aqueous Film Forming Foam (AFFF) release response, per- and polyfluoroalkyl substances (PFAS) monitoring in soil and groundwater, monitoring well network expansion, Red Hill Shaft Granulated Activated Carbon (GAC) flow optimization, and groundwater monitoring data format and availability. Throughout 2023, EPA and DOH plan to convene the Roundtable every other month and hold quarterly groundwater subject matter expert workshops.