Lee, 19, a former world No.1 ranked amateur who won in her rookie LPGA season in 2015, mixed six birdies with two bogeys on the Ko Olina course in Kapolei on the island of Oahu.
She also had seven birdies in the opening round, to go with a bogey and double bogey. Lee admitted luck had a little to do with her score in the gusts.
"You got to have some luck with it, too," Lee said.
"It's not just all your skill. You never know. Mother Nature can throw anything at you. I think I judged it really well today so I'm happy."