Polution Situation Report

U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
ASIG Sand Island - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IX

Subject:

POLREP #3
ASIG Sand Island

Honolulu, HI
Latitude: 21.3168235 Longitude: -157.8900084

To:

From:

Donn Zuroski, osc

Date:

2/1/2015

Reporting Period:

1/30-2/1/15

1. Introduction

1.1 Background

Site Number:		Contract Number:
D.O. Number:		Action Memo Date:
Response Authority:	OPA	Response Type:	Emergency
Response Lead:	EPA	Incident Category:	Removal Action
NPL Status:		Operable Unit:
Mobilization Date:	1/25/2015	Start Date:	1/25/2015
Demob Date:		Completion Date:
CERCLIS ID:		RCRIS ID:
ERNS No.:		State Notification:
FPN#:	E15901	Reimbursable Account #:

1.1.1 Incident Category
OPA Response

1.1.2 Site Description

The site includes the area in and adjacent to the tank farm that supplies fuel to the Honolulu International Airport. This tank farm facility includes 16 above ground storage tanks (used to store Jet a fuel) and pipelines to receive product form the Kapolei Refinery (located in Campbell Industrial Park) or product directly from oil tankers in Honolulu Harbor, as well as pipelines running form the tank farm directly to the airport. The tank farm sits on land owned by the State of Hawaii Department of Transportation Airports Division. The tanks, piping, structures and associated equipment are owned by Hawaii Fueling Facilities Corporation a consortium of (22?) airlines. The facility is operated by aircraft Service International group (ASIG).

1.1.2.1 Location
The tank farm is situated on the main road between Honolulu and Sand Island. Honolulu Harbor and Ke'ehi Lagoon are both in near proximity. A smaller tank farm operated by Hawaiian Independent Energy Co. is located adjacent to the South.

1.1.2.2 Description of Threat
On December 22, 2014, the staff at the ASIG tank farm noted a substantial shortage in the inventory of Tank #2. The storage capacity of tank #2 is approximately 2.8 million gallons. On January 21, 2015, ASIG notified the HI DOH that they had a release of 1000 bbls of Jet fuel (42,000 gallons) at their facility.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
The HI DOH Hazard Evaluation and emergency Response Office deployed one of the State On-Scene Coordinators who noted that the facility had ongoing fuel recovery from two pits dug into the ground inside the contained area of the facility. The State OSC immediately notified the NRC.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative
This facility is immediately adjacent to both Honolulu Harbor and Ke'ehi Lagoon, and has a history of tank releases. The tank farm contains 16 ASTs with a combined capacity to hold 44 million gallons of fuel. Although the facility is surrounded along the perimeter by a concrete wall, the area around the tanks is not paved or sealed from downward migration of fuel should it get out of the tanks. The soil underlying the tanks is sand with layers of crushed coral and fill material. The water table beneath the facility is tidally influenced. In 1996, there was a sizable tank release inside the facility. In 2008, there was (another) release from piping/appurtanances related to a tank or tank, again inside the facility. As a result of the 2008, event the facility owners installed a bentonite slurry barrier wall along 3,000 linear feet of the perimeter.

According to the engineering firm that installed the barrier wall, "this barrier system will last for centuries". However, a substantial amount of jet fuel has escaped the slurry wall and has been found in the near surface outside the facility within 50 yards of Ke'ehi Marina.

At present, the Jet fuel is being pumped directly from two extraction trenches and a few small open pits inside the facility directly into vac trucks and taken offsite for processing at the Honolulu Airport fuel storage farm. An average of 1,800 gallons of pure jet fuel per day have been recovered.

2.1.2 Response Actions to Date
The EPA ERT rep, the EPA OSC, and the SOSC have a collaborative working relationship with the RP and the RP's environmental contractors. At the end of each day they hold a debrief and have a "brainstorming" session to develop the path forward for the next day's effort. Careful attention is being paid to ensure that the emergency response actions are consistent with the long-term remedy.

In the past week 18 exploratory trenches and 5 bore holes have been dug inside the tank farm. Two (of several planned) extraction trenches have been installed inside the tank farm. Forty one exploratory bore holes (with several more to come) have been dug outside the tank farm in an effort to delineate the offsite jet fuel plume.

Development of a strategy to capture the offsite fuel, and the design of an interceptor trench to insure that the jet fuel plume does not reach the water's edge, are soon to be completed.

1/25/15
The ERT hydro, the FOSC and the SOSC conduct a site recon, meet with the facility rep and response crew and discuss the OSC's expectations.

The RP continues to pump jet fuel from pits on site. Initial estimates were in the order of 4,000 to 6,000 gallons captured and hauled away per day. Note that these number have since been revised downward.

1/26/15
ERT,FOSC and SOSC on site. The FOSC conducts the morning safety briefing along with the RP response contractor.  At the FOSC's direction the RP begins to conduct offsite boring installation. Eight borings are installed. Three contain jet fuel. Five additional test pits are dug on-site.

The FOSC asks the local FD to visit the site to identify any fire threats related to the jet fuel extraction effort. Approximately 25 firefighters tour the operation. Additional air tox/ fire/explosion
monitoring is recommended. A more robust air monitoring regime is implemented. No fire threat is identified. Tox monitoring shows low levels but none that require a change in PPE.

ERT, the FOSC and the SOSC meet with the USCG to discuss site status and identify any concerns that the COTP may have. EPA is reaffirmed as the lead for this response effort.

ERT, and the FOSC meet with the DOH HEER managers to discuss the status and identify any concerns they may have. The DOH HEER Director notes that DOH will be happy for EPA to take the lead in issuing a CWA
order.

1/27/15
ERT,FOSC and SOSC on site. The FOSC conducts the morning safety briefing along with the RP response contractor.  Off-site boring installation. Additional test pits are dug on-site.
Capture and removal of jet fuel on-site continues.

1/28/15
ERT,FOSC, two START and SOSC on site. The FOSC conducts the morning safety briefing along with the RP response contractor.   Additional test pits continue to dug on-site.  Capture and removal of jet fuel on-site continues. Two START and SOSC and the DOH RPM assigned to the stank farm

The FOSC meets with DLNR to discuss the impact and mitigation possibilities for the area between the tank farm and Ke'ehi Marina. DLNR requests air monitoring for their offices adjacent to the tank farm.

The FOSC holds a collaborative brainstorming meeting at Clean Island Council. the event is attended by the FOSC ERT, two START, the SOSC, the DOH RPM assigned to the tank farm, the RP rep, and the RP's tech lead contractor. The focus was to: refine the conceptual model of the plume; to discuss the most effective capture methods; and,to develop the design for the extraction trenches.

1/29/15
ERT,FOSC, two START and SOSC on site. The FOSC conducts the morning safety briefing along with the RP response contractor.  START initiates the DLNR air monitoring program. Off-site boring installation continues. six of the off-site borings hold jet fuel, some as much as three feet thick. Installation of the first engineered extraction trench begins. Capture and removal of jet fuel on-site continues.

1/30/15
ERT,FOSC, three START and SOSC on site. The FOSC conducts the morning safety briefing along with the RP response contractor.  START continues the DLNR air monitoring program. Off-site boring installation continues. Installation of the first engineered extraction trench begins. Capture and removal of jet fuel on-site continues. The first engineered extraction trench is completed. Excavation of the second extraction trench begins.The FOSC delivers a CWA 311(c) order to the RP. The FOSC requests and receives a ceiling increase from NPFC

1/31/15
ERT,FOSC, three START, the SOSC and the DOH RPM are on site. The FOSC conducts the morning safety briefing along with the RP response contractor.  START continues the DLNR air monitoring program. Off-site boring installation continues. The second engineered extraction trench is completed. Capture and removal of jet fuel on-site continues.
2/1/15
ERT,FOSC, three START, and the SOSC are on site. The FOSC conducts the morning safety briefing along with the RP response contractor.  START continues the DLNR air monitoring program, and collects fuel sample both on and off site for fingerprinting. . Capture and removal of jet fuel on-site continues.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Verbal Notice of Federal Interest was given by the OSC on his arrival at the site. Written copies of the NOFI are was hand delivered on 1/27/15. A CWA 311(c) order was issued and hand delivered by the OSC on 1/30/15.   Further Federal enforcement actions are TBD.

2.1.4 Progress Metrics

*Waste Stream*	*Medium*	*Quantity*	*Manifest #*	*Treatment*	*Disposal*
jet fuel	pure	approx.22,000g		oi/water sep	re-use

2.2 Planning Section

2.2.1 Anticipated Activities
The initial approach has been to aggressively extract the jet fuel, and to define the extent of the subsurface release. ASIG has excavated multiple pits along the wall adjacent to tank #2 (the source of the released the fuel). six of the pits have been utilized as extraction points.

In addition, an "air knife" has been used to drill several borings outside the facility along the wall. A geoprobe will be mobilized to the response (hopefully tomorrow) to augment the existing boring effort. It is evident that the bentonite barrier hasn't provided containment. A substantial amount of jet fuel has been noted in the borings within 50 yards of the Ke'ehi marina.

The first two of a series of engineered extraction trenches have been installed inside the facility. This series of trenches are designed to optimize capture of the fuel inside the perimeter wall. The borings being installed outside the facility wall will be used define the offsite migration of the fuel. Once the extraction trenches inside the facility are able to maintain hydraulic control of the release (demonstrate containment) an system to extract the fuel outside the tank farm will be built. this may include pumping from bore holes and/or an extraction trench or trenches. In order to ensure containment of the off-site plume, an interceptor trench will be installed the full length of the area of concern between the extraction trenches and the water front.

2.2.1.1 Planned Response Activities
Contain the release. Define the leading edge of the plume migrating toward the water. Prevent the fuel from entering the surface water.

2.2.1.2 Next Steps
Develop a long-term strategy.

2.2.2 Issues
TBD

2.3 Logistics Section