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STATE OF HAWAII
DEPARTMENT OF HEAL TH
P. 0. BOX 3378
HONOLULU, HI 96801-3378

UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105

October 26, 2020

Captain Gordie Meyer
Commander Navy Region Hawaii
850 Ticonderoga St., Suite 110
Joint Base Pearl Harbor Hickam, Hawaii 96860-5101
Re:

Notice of Deficiency for the Tank Upgrade Alternatives Decision Document and
New Release Detection Alternatives Decision Document, for Red Hill Administrative
Order on Consent Statement of Work Sections 3.5 and 4.8

Dear Captain Meyer,
The United States Environmental Protection Agency ("EPA") and the Hawaii Department of
Health ("DOH"), collectively the "Regulatory Agencies," have reviewed Red Hill Bulk Fuel
Storage Facility Administrative Order on Consent Tank Upgrade Alternatives("TUA '') and
Release Detection ("RD'') Decision Document ("Decision Document") dated September 2019
submitted by the U.S. Department of the Navy ("Navy") and Defense Logistics Agency ("DLA")
to satisfy the requirements in sections 3.5 and 4.8 of the Red Hill Administrative Order on
Consent ("AOC") Statement of Work ("SOW").
Subsequent to submittal of this Decision Document, the Navy hosted a public information
workshop on October 15, 2019, and the Navy presented their Decision Document at the Fuel
Tank Advisory Committee Meeting on October 17, 2019. The Regulatory Agencies published
the Decision Document on our websites, solicited public comments on the TUA and RD
Decision Document from September 9, 2019 through December 9, 2019, and held a public
hearing on November 19, 2019 at Moanalua Middle School.
Pursuant to section 7(b) of the AOC, the Regulatory Agencies disapprove this submittal and are
providing this Notice of Deficiency on the Decision Document. We are granting the Navy and
DLA an opportunity to cure the deficiencies and resubmit the decision document. The
Regulatory Agencies have determined that the TUA Decision Document lacks detail, clarity,
rationale and justification to demonstrate that the actions described in the Decision Document are
the best available practicable technology ("BAPT") for the tanks and operations at the Red Hill
1

 facility. While the selection of technologies for release detection seems appropriate, the RD
section of the combined Decision Document is deficient because it does not clearly identify how
each of the release detection methods will collectively work together to trigger response; what
those response actions will be to minimize risk and impact to the drinking water resource; and
how the multiple systems will improve overall monitoring, accuracy, redundancy.
The expectations for the Decision Document were discussed among the parties during our
Decision Meetings held pursuant to sections 3.4 and 4.7 of the AOC, as well as provided in
letters dated March 7, 2018, May 21, 2018 and May 16, 2019 for TUA and letters dated August
30, 2018 and November 29, 2018 for RD. For example, we discussed the need for analysis of
relative environmental performance of upgrade options, expected life of upgrade and
improvement options, demonstration that the selected option is protective of the drinking water
resource, and optimization of release detection and release response measures to bound
maximum volume of fuel released to the environment in the event of an emerging leak. We also
asked the Navy to consider contingency measures such as water treatment that can be
implemented to assure clean available drinking water as a precaution, regardless of TUA
selection. These issues were not adequately addressed in the Decision Document. Therefore, we
are providing this Notice of Deficiency and opportunity to cure the TUA and RD Decision
Document. The list of deficiencies associated with the TUA and RD portions of the Decision
Document is included as Attachment A.
The primary objective of the work required by the Red Hill AOC is to identify the BAPT to
improve the Red Hill facility, which is supported by various studies (as provided for in Sections
2, 4, 5, 6, 7, and 8). Greater integration and understanding of the overall objective in completing
the individual studies will help the Navy and DLA reach this overall objective. As addressed in
AOC page 2, "The primary objectives ofthis AOC are to take steps to ensure that the
groundwater resource in the vicinity ofthe Facility is protected and to ensure that the Facility is
operated and maintained in an environmentally protective manner. " The Regulatory Agencies
believe that the most important improvements are those procedural changes and infrastructure
upgrades that mitigate risk to the drinking water resources from future releases.
During the public comment period, the Regulatory Agencies received approximately 411 written
comments along with 45 oral comments presented at the public hearing. Most comments were
not in support of the Navy and DLA's proposed tank upgrade alternative with a few comments
on release detection. Nearly half of the comments suggested relocating the fuel storage. Other
comments indicated that the proposal does not call for major changes, or stated that the tanks are
leaking, are at the end of service life, will leak under the current operational and repair protocol,
and/or that the proposal does not address the risk to drinking water. A document summarizing
the comments we received along with our overall response to these comments is included as
Attachment B.
The Regulatory Agencies believe that certain near-term aspects of the Decision Document
submitted in September 2019 are prudent, and we recommend the Navy move forward to
implement those actions that reduce risk at the facility. Examples of the near-term proposed
actions include installation of high precision leak detection hardware in each tank and
2

 decommissioning of the smaller tank nozzles as part of the ongoing tank inspection and repair
process. Although these actions alone are not considered BAPT by the Regulatory Agencies, the
Regulatory Agencies encourage the Navy to implement presumptive risk reduction actions once
identified on an ongoing basis in order to strive for continuous risk reduction.
Pursuant to AOC section 7(b), the Navy and DLA are being given the opportunity to cure and
resubmit the Decision Document. The Regulatory Agencies recognize that many of our issues
with the collective Decision Document may require substantial effort and time to address beyond
the standard thirty (30) day opportunity to cure established in the AOC. Therefore, if preferred,
the Navy/DLA may choose to submit the revised RD Decision Document separately from the
TUA Decision Document provided that actions specified in the RD Decision Document are not
dependent on the TUA selection, and any TUA dependent RD options are discussed specifically
in the TUA Decision Document. If the Navy and DLA cannot correct the deficiencies and
resubmit the Decision Document within thirty days, the Regulatory Agencies require the Navy
and DLA to participate in a meeting with the Regulatory Agencies within thirty days to review
this decision letter to present a plan and schedule for addressing the deficiencies for Regulatory
Agency Approval.
If you have any questions, please contact us.

Sincerely,

Steven Linder, P .E.
Red Hill Project Coordinator
EPA Region 9

Enclosures:

Roxanne Kwan
Interim Red Hill Project Coordinator
State of Hawaii, Department of Health

1. Attachment A - Identified Deficiencies, Tank Upgrade Alternatives and
Release Detection Decision Document
2. Attachment B - Red Hill Tank Upgrade Alternative and Release Detection
Proposal, Response to Comments

3

 ATTACHMENT A
IDENTIFIED DEFICIENCIES
TANK UPGRADE ALTERNATIVES AND RELEASE DETECTION
DECISION DOCUMENT
Part 1: Comments Related to the Tank Upgrade Decision Document
No Clear Nexus Between Proposed Decision and Protection to Drinking Water Aquifer
The objective of the Administrative Order on Consent (AOC) is to study the Red Hill facility and its
environmental setting to determine the best available practicable technology (BAPT) and practices that
should be used at the facility to mitigate risk from potential future releases and provide the best protection
to drinking water resources. In the Environmental Protection Agency (EPA) and Hawaii Department of
Health (DOH) (Regulatory Agencies) letters dated March 7, 2018 and reiterated in May 16, 2019, we
specified that the proposed BAPT must demonstrate that groundwater and drinking water resources are
protected. The Navy in the proposed TUA Decision Document has not demonstrated to the Regulatory
Agencies that the proposed alternative is the most protective of the groundwater and drinking water
resources and other options are either less protective or impractical; and that the proposed alternative
adequately mitigates release risk. Evaluations utilizing information gained from other sections of the
AOC, such as release detection, groundwater, and risk assessment should be incorporated into the
justification.
Instead, page 28 of the Decision Document states, “In the unlikely scenario of a Significant Release from
the Facility, there is a high probability of the Red Hill Shaft being directly impacted within a short period
of time. The environmental modeling predicts that for any Significant Release to be captured and
prevented from entering the public drinking water source, the Red Hill Shaft would need to maintain
continuous pumping, and thus would require a water treatment plant to ensure the quality of the drinking
water being supplied to Joint Base Pearl Harbor-Hickam (JBPHH).” Page 97 of the Decision Document
defines Significant (Gradual) Releases as those that occur at rates above 0.5 gallons per hour. The
Regulatory Agencies consider the water treatment to be a contingency release response measure and
therefore, for the purposes of comparing TUA options, discussion on the related impacts to groundwater
and drinking water resources should be provided without this reliance.
Insufficient Comparison of Environmental Performance and Justification of BAPT
The Navy has not adequately discussed the environmental performance of the proposed decision in
comparison with the other TUA options. In other words, the Navy has not adequately discussed potential
mitigation measures of the proposed alternative in comparison with other alternatives related to protection
of groundwater. For a TUA option to be considered BAPT, the Navy needs to demonstrate in the
Decision Document that the proposed decision outperforms the other practicable options considered. For
example, if secondary containment options outperform single walled options, then to eliminate the
secondary containment options, including new tank option, the Navy needs to demonstrate that each of
1

 these secondary containment options are impracticable. If an option is determined impracticable, then the
corresponding trade-offs with respect to environmental protection should be discussed.
As discussed in the Regulatory Agencies’ letter dated March 7, 2018, we requested that the comparison of
environmental performance not only consider the tank vessel and other aspects of the fuel management
system, but also the environmental performance during all modes of operation (i.e., recommissioning,
static storage, transient storage), and from different release initiating events. This assessment of
environmental protection should be more detailed and include a discussion of how each alternative would
perform relative to risks of minor, significant, and catastrophic releases and under all modes of operation.
Some of this information is provided in a qualitative manner in Appendix C of the Decision Document,
explaining that minor releases are better contained in secondary containment options than the single wall
options, but did not expand in detail significant releases or catastrophic releases or attempt to
quantitatively demonstrate potential impact or consequence to groundwater. Use of hypothetical release
scenarios for the various modes of operations and type of release (affecting release rates), could be used
to assist in estimating potential release volumes (bounding estimates) for each TUA options for
comparison purposes.
In addition, the Regulatory Agencies note that not all similar options will have the same environmental
protection and should be discussed. For example:
• Per Red Hill Repair Tanks Options Study FISC Pearl Harbor, Hawaii, Final Report, September
2008, page 13, “Visual detection of a leak is the fastest way to detect leaks. Detection by
electronic leak detection systems may have a significant time delay before a leak is detected.”
Only one TUA option provides this capability to visually inspect the outer tank wall and provide
secondary containment.
• Additionally, two of the assumptions the Navy has applied to the TUA Decision Document (page
14 of the Decision Document), infer that all proposed TUA options, including new construction,
would have the same environmental performance during both a kinetic attack or a major seismic
event without justification. More supporting information and engineering justification need to be
given before these assumptions can be made.
Information gained from all other sections of the AOC should be utilized to best complete the
comparison. Where there is uncertainty regarding potential impact, especially with incomplete work in
other sections, greater conservatism is warranted in the selection of the TUA proposal and identification
of BAPT. Following are more specific comments regarding the TUA evaluation.
Incomplete Analysis of Alternatives and Missing Information
Limitations of the NDE Process and Concerns Related to Corrosion Should Be Addressed
The Navy’s Tank Inspection Repair and Maintenance (TIRM) program depends on Non-Destructive
Evaluation (NDE) to locate areas of the steel liner that requires repair. Among the assumptions the Navy
has applied to the TUA Decision (page 14 of the Decision Document), is that the “4. NDE is a reliable
method for detecting corrosion in the tank liner.” However, the Navy noted on page 86 of the Decision
Document that, “Given the destructive testing results, the Navy is investigating alternatives to improve
scanning. The report contains additional recommendation which will be considered by Navy’s experts in
the continual improvement of TIRM Procedures, including:
2

 1. Analysis of the corrosion rate calculation procedures and recommendations for
improvement;
2. Evaluation of results against current corrosion mitigation practices;
3. Recommendations for modification or improvements to TIRM Procedures; and
4. Recommendations for additional destructive testing.”
The Regulatory Agencies in our Response to Corrosion and Metal Fatigue Practices, Destructive Testing
Results Report, Red Hill Bulk Fuel Storage Facility (Red Hill), Joint Base Pearl Harbor-Hickam, Oahu
Hawaii, dated March 16, 2020 letter in response to the Navy’s Corrosion and Metal Fatigue Practices,
Destructive Testing Results Report, Red Hill Bulk Fuel Storage Facility report dated July 7, 2019
(“Destructive Test Report”), did not agree with the Navy’s conclusion that the NDE results are validated,
both by Destructive Testing and thorough, case-by-case analysis, and are requiring additional studies.
The additional studies that the Regulatory Agencies are seeking are related to improvements on the NDE
process, analyses on the condition of the concrete structure and imbedded steel, evaluation of potential
causes for corrosion and possible mitigative actions to reduce corrosion rates, and reassessment of repair
thresholds to account for inaccuracies in the NDE process, corrosion rates, and possible delays in repair
cycles.
While this work is being performed, the concerns raised in our March 16, 2020 letter should be addressed
in evaluating TUA options and comparing environmental performance. For example, the Decision
Document should explain:
• How the risk due to limitations of the NDE process to detect back side corrosion and weld flaws
that could develop into a leak through the steel lining will be addressed; and
• How risk from potential increased back side corrosion of the steel liner, which may be due to
lower pH and concrete passivation loss (indicative of a corrosive environment) will be mitigated.
Military and Industry Standards Do Not Necessarily Equate to BAPT
Standards, such as API 653 And MIL-STD-3007F can be useful guidelines in efforts to design, operate,
and maintain fuel storage facilities. However, in order to meet the AOC objective of implementing the
BAPT at Red Hill, the Decision Document needs to clearly describe the nexus between these standards
and the BAPT, considering the Red Hill facility is a unique facility where many of these standards are not
directly applicable.
Evaluation of Operational Life and Associated Cost Estimates
The selection of the alternative that represents BAPT shall be based on several factors listed in the AOC
Statement of Work (SOW) section 3, including but not limited to “… (3) the anticipated operational life
of the technology; and (4) the cost of implementing and maintaining the technology.” The anticipated
operational life of each of the options were not discussed in the Decision Document, except for the brief
mention on page 32 of an asset study, which to our understanding has not yet been performed. The cost
estimates provided on page 31 of the Decision Document only include the initial costs incurred for the
implementation of each of the options and does not consider the operational life of each alternative or
operation and maintenance (O&M) costs. Incorporating the amortization of capital costs over the
operational life of each option, as well as all O&M costs, including those for tank inspection and repair,
into the cost analysis will likely provide a better comparison of costs.
It is possible that the New Tank option could be the most cost-effective approach to achieving long-term
fuel storage and environmental protection goals. Although the Navy does include a discussion of new
3

 tanks in Appendix C, this evaluation is limited and does not identify all potential environmental
protection advantages of new infrastructure. A cost comparison that is not limited to capital costs is
particularly important when comparing the New Tanks alternative to the alternatives that utilize the
existing tanks as either primary or secondary containment since new tanks would have greatly reduced
O&M costs and reduced potential for resource damage costs.
Implementation Schedule for BAPT
Section 3.5 of the AOC SOW states, “The TUA Decision Document shall define and specify the:…(4)
plan and schedule for implementation of the BAPT setting forth the order and schedule that Tanks shall
receive BAPT, including a schedule for the start of each tank’s budget planning cycle…” While we have
a schedule from the TIRM decision document, the TUA decision document does not clearly state the tank
order and schedule for implementation, in relation to contract. The Regulatory Agencies note that the
TUA Decision Document may be revised under Section 3.7 of the AOC SOW, and tanks that have
already begun their budget planning cycle for a previously approved BAPT, but have not completed
installation of that BAPT, shall continue with installation of the previously approved BAPT unless all
parties agree to a revised schedule for installing the new BAPT on those tanks. Given the relationship
between the implementation of the selected BAPT to the current contract schedule, and to the planned
update to the TUA Decision Document, a schedule with all of these components shall be provided in the
TUA Decision Document.
Performance Criteria for BAPT
Similarly, Section 3.5 of the AOC SOW states, “The TUA Decision Document shall define and specify
the: … (5) overall performance criteria for successful application of BAPT. The TUA Decision
Document shall either incorporate the TIRM Procedures Decision Document approved by the Regulatory
Agencies in Section 2 above, or, consistent with the BAPT identified, incorporate a modified TIRM
Procedures Decision Document.” Because only a general assessment of environmental performance is
provided, the performance criteria for the proposed BAPT or a comparison with other alternatives have
not been provided. In addition, with the information provided, it is unclear the specific changes to the
currently approved TIRM Report that the Navy is seeking. This should be more clearly defined.
Experimental Pilot Project to Fully Coat Interior Surface of a Tank Requires Detail
On page 13 of the Decision Document, under “Additional Improvement—Mid-Term/Long-Term,” the
Navy proposes to evaluate fully coating the interior surface of one tank as a pilot, if laboratory testing, to
be completed by the end of September 2019, indicates the coating could act as a hydraulic barrier/liner
and provide corrosion resistance. The Regulatory Agencies recognize that this is not a commitment to a
proposal, nor a formal request for a pilot program. Should the Navy decide to pursue a pilot, information
required under Section 3.6 of the AOC SOW shall be submitted for review by the Regulatory Agencies.
Such information includes but is not limited to the overall operational design of the pilot program; the
technology and procedural aspects of the pilot; and the performance criteria and method of evaluating the
success of the pilot program. Any proposal for a pilot shall also describe how the action will mitigate risk
to the environment.
The Regulatory Agencies note that the proposed epoxy coating will not address backside corrosion
concerns on the steel liner but may potentially seal porous welds and other small defects, as is currently
applied to new weld joints during the clean, inspect, and repair process.

4

 The Navy’s “Double-Wall Equivalency Secondary Containment Or Remove Fuel From Red Hill In
Approximately the 2045-Time Frame” Requires Further Discussion
This proposal is provided under “Studies Concerning the Future of the Facility,” on page 31 of the
Decision Document. It is not tied to any TUA option currently before us, and therefore is not clear how
this plan is intended to be implemented. If the Navy wants to incorporate this concept in a future
submission as a new TUA option, please consider the following:
1. Double-wall equivalency secondary containment needs to be defined. There are regulatory
definition and requirements for secondary containment. The objective of secondary containment
for underground tanks is risk mitigation. Secondary containment has the potential to contain both
acute and chronic releases. As we have previously specified as our expectation for comparative
environmental performance, the Navy must present a detailed comparison of how the proposed
secondary containment equivalency will perform against the other options, including the
secondary containment options. If equivalent risk mitigation measures cannot achieve that of
secondary containment, then the Navy needs to clearly define and justify their alternative plan
and schedule to achieve risk mitigation adequate to protect the water supply. All other required
information necessary to compare this option with the other proposed TUA options must also be
provided.
2. Section 3.5 AOC SOW specifies that all tanks in operation shall have deployed Regulatory
Agencies’ approved BAPT by September 2037 or be taken out of use, temporarily closed, and
emptied of all regulated substances or permanently closed pursuant to applicable regulations or as
approved by the Regulatory Agencies. Currently, the 2045-time frame does not appear to comply
with section 3.5 AOC SOW agreed upon deadline for BAPT tank compliance.
3. State of Hawaii UST regulations (section 11-280.2-21(c)) for airport hydrant fuel distribution
systems and UST systems with field-constructed tanks require by July 15, 2038, that “…tanks
and piping installed before the effective date of these rules must be provided with secondary
containment that meets the requirements of section 11-280.1-24 or must utilize a design which the
director determines is protective of human health and the environment…”. Similarly, there is no
information to support that this proposal will comply with state regulations.

Part 2: Comments Related to the Release Detection Decision Document
Justification on the Selected Combination of Release Detection Systems is Required
Release detection is a critical aspect of risk management at all underground storage tank facilities. The
AOC requires the Navy and DLA to summarize their current release detection practices and investigate
opportunities to improve their release detection practice to better the Red Hill Bulk Fuel Storage
Facility’s ability to operate in an environmentally protective manner. The Navy has proposed the
following as their improved release detection system:
•

•
•
•

Install permanent enhanced release detection equipment in order to have the ability to run as
many tank tightness tests as desired. Currently the facility is conducting tank tightness testing at
a semi-annual frequency.
Install slots in stilling wells to improve precision of existing automatic tank gauging (ATG)
system with automatic fuel handling equipment (AFHE).
Conduct a real-time soil vapor monitoring pilot project.
Continue to install additional groundwater monitoring wells.
5

 •

Continue environmental sampling—soil vapor, oil/water interface measurements, and
groundwater samples.

Release detection methods should provide the earliest possible detection of a release in order to quickly
implement mitigation (release response) measures and minimize impact to the environment. Thus,
detection and mitigation of the release is preferred to be addressed before impact to groundwater. The
Decision Document does not clearly describe release detection options explored and the basis for the
selection of these collective systems.
Greater Detail on the Integration of Release Detection Systems is Needed
The Decision Document should clearly describe how the new enhanced release detection will be
implemented and integrated with the other release detection systems (inventory and soil vapor
monitoring). This should include specifics on monitoring hardware, data collection, and operations. The
proposal should also describe the performance goals of the system and how this new system, along with
other existing and proposed systems that provide indications of a suspected release, will be used as
multiple lines of evidence in an overall release detection and response system, and comply with UST
regulations.
Similarly, the inventory monitoring system is a critical component of the Release Detection at the facility,
the Decision Document should include greater detail that describes the improvements to the inventory
system, its performance goals and how this improved system will be integrated with the overall release
detection and response system.
In addition, the Navy should explain how vapor monitoring will be used as another line of evidence for
release detection, which the Regulatory Agencies believe is more sensitive than inventory monitoring and
can be used more frequently than precision static tightness testing.
The frequency of precision release detection tests (tank tightness tests) and the basis for this frequency
need to be clearly defined and justified in the Decision Document. Higher frequency will result in a
greater degree of risk mitigation; however, in order to conduct a precision test, the tank being tested needs
to be isolated to insure an accurate test. This testing interrupts normal operations, so the Navy needs to
evaluate the trade-off between frequency and operations to justify proposed frequency. Additionally, the
Decision Document also needs to clearly describe the types of conditions or indications that would
require additional precision testing (for example, in response to alarms and when soil vapor
measurements show an increasing trend). UST regulations require all suspected releases to be confirmed
within seven days. Investigations and confirmation require a system test (tanks and piping tightness test)
or another procedure approved by the Department of Health.
The Decision Document should present clear release detection and response decision trees that establish
inspectable and auditable records of release detection system alarms or other indications of a suspected
release. This should include the details of causative research that is triggered with alarm, actionable
thresholds or unusual operating conditions. The decision tree should describe what actions are automatic
versus what actions rely on the judgement of specialized operators. The Decision Document should
describe how data indicating suspected and confirmed releases will be shared with the regulatory
implementing agency (DOH). The proposed decision should analyze the timeline for providing this
information to the implementing agency and clearly describe the causative research (tests) completed as
timely as possible, including an option for real-time alarm reporting.

6

 Effectiveness of the Improvements to the Overall Release Detection System Should be Quantified
The Decision Document should describe the effectiveness of the integrated system. For example,
describe how the integrated release detection system affects precision and accuracy and how they will be
used to reduce thresholds for alarms and action triggers such as in unscheduled fuel movement alarm
thresholds. This discussion should include any limitations on the system such as limitations during
transient conditions after a fuel movement and limitations caused by the unique hemispherical tank
bottom.
Explanation of New Soil Vapor Concentration Thresholds and Basis to Discontinue Trend
Evaluation is Needed
The Navy proposes to continue monthly soil vapor monitoring (SVM), but with reduced soil vapor
thresholds from 280,000 parts per billion of volatile organic compounds by volume (ppbv) to 50,000 ppbv
for tanks with jet fuel and from 14,000 ppbv to 8,000 ppbv for tanks with marine diesel. Based on the
2014 release, the Regulatory Agencies agree that the existing 280,000 ppbv action level is too high and
needs revision; however, the selection of the new values and how they will be used to trigger action
requires further discussion.
Page 23 of the Decision Document states, “The existing protocols for evaluation of soil gas monitoring
events uses a concentration trend methodology to trigger causative research.” The document does not
define what “causative research” entails. The document further states, “In addition, the 2014 release
from Tank 5 was detected as part of inventory control reconciliation. The leak would not have been
detected for several months using only the trend-based soil gas monitoring. Use of the 50,000 and 8,000
ppb thresholds for jet fuel and diesel fuel, respectively, would have allowed the release to be detected
sooner and independent of inventory control measures. Based on 10 years of monitoring, the
concentration trend evaluations do not appear to be useful for identification of possible fuel releases, and
therefore will be discontinued.”
The Regulatory Agencies agree that soil vapor monitoring with improvements can potentially provide
early detection of a release. For example, on December 9, 2013, Tank 5 refill operations started. On
December 23, 2013, routine SVM showed a four to five-times increase in soil vapor levels in SV-5M and
SV-5D (the middle and deep probes) in comparison to the average of the previous six months’ data. On
December 10, 2013, the first Unscheduled Fuel Movement (UFM) alarm went off. From January 13 -17,
2014 the tank was drained. On January 15, 2014 and January 31, 2014 SVM levels were as much as 350
times higher than the December 23, 2013 results. Therefore, SVM can provide another line of evidence
of a release, and if done more frequently, could be more sensitive than inventory monitoring.
However, it is unclear why concentration trend evaluation will be discontinued. The Navy, in the
Decision Document should explain the basis for this change. Rather than a fixed action level (thresholds),
it appears that comparison of soil vapor measurements for a specific probe to the statistical background
concentration for the specific probe that accounts for variations in existing conditions, similar to a
concentration trend evaluation, would better account for the varying environmental conditions
surrounding each probe (porosity, historic fuel release) that could impact the data, and its interpretation.
Then, similar to the description in the Decision Document, any detection above a statistically significant
increase would trigger the collection of a soil vapor sample to determine whether the detected vapor is
fresh or weathered. An on-site gas chromatography/mass spectrometry unit could expedite results and
associated release response actions, as needed.
In addition, based on our review of data collected since 2005, DOH observations of the current SVM
program, and upon discussions with the Navy’s contracting Officer Technical Representative, we believe
7

 that current data collection can be improved. While a detailed discussion of the deficiencies in the current
monitoring program is outside of the scope of this letter, the rehabilitation of inoperable probes and
implementation of a better quality assurance protocol will reduce random and systematic sampling and
analytical errors.
Greater Detail on The Real-Time Soil Vapor Continuous Monitoring Pilot Study is Needed.
Real-time soil vapor monitoring can be an important source of information for an overall leak detection
system and the Navy proposed implementing a continuous soil vapor monitoring pilot test. The pilot will
consist of a monitoring system for one to three tanks using an auto-sampler PID. Results would be
documented over six months to one year. However, the goals and details of a pilot program are not
provided with sufficient detail.
•
•
•

•
•

The Navy should develop goals and procedures for this pilot study in consultation with the
regulatory agencies and other critical stakeholders.
The performance criteria and method of evaluating the success of the pilot program; and a plan
for terminating the pilot program should be clearly defined.
The pilot proposal should clearly define the details of causative research tests or actions. For
example, what constitutes an “outlier” versus what is statistically significant? More frequent
readings will certainly give more volatility than a monthly sampling, which may be addressed
through statistical calculations. How will the pilot study handle inconsistencies with monthly
monitoring? What would a causative decision tree look like with a continuous monitoring
approach compared to the monthly monitoring?
The Regulatory Agencies’ comments on the current SVM program should be considered in
developing the scope of the pilot project.
A proposed implementation schedule should be provided.

A Detailed Release Response Action Plan Needs Be Included in the Decision Document
Ability to identify and respond rapidly to indications of a release is critical to effective risk mitigation. In
the event of a confirmed release, the Navy will need available ullage to quickly drain the tanks and
prevent more fuel to release into the environment. The Decision Document mentions having available
ullage, but is silent on how this response process will be implemented.
The Decision Document should describe in quantitative terms the response procedures and timelines, and
how these procedures are optimized in order to achieve effective risk mitigation. For example, this
description should include:
•

•

When a drain down is warranted or when a tank tightness test should be initiated. This should
include how the multiple lines of evidence related to release detection will be utilized in an
objective manner to trigger an immediate response action such as drain down, or how the
integrated release detection system consisting of vapor monitoring, inventory monitoring, visual
inspections, manual gauging, will trigger one another or the initiation of a tank tightness testing.
New procedures that allow operators to transfer fuel out of a tank within 36 hours. Although
mentioned on page 11 of the Decision Document, there is no information to substantiate this
duration. Contradictory to this claim, on page 183 of the Navy's New Release Detection
Alternatives Report, dated July 25, 2018, two hypothetical release response scenarios referenced
longer time frames for emptying a tank (96.3 hours and 118.6 hours). A clear description of the
improvements made/proposed that allow for this significant improvement should be provided.
8

 •
•

After the 2014 release from Tank 5, the draining process took approximately 5 days, January 1317, 2014. If spare ullage is not available, draining could take longer.
Bounding estimates of possible release volumes based on the release response plan for various
release scenarios (minor, significant, and catastrophic).
A detailed description of training and drills to be implemented to assure that the release detection
and response procedures are effective and will perform as planned.

Evidence is Needed to Support the Claim that Minimal Contamination will Result from a Minor
Release.
The Navy claims that even in the unlikely event of a minor release, the multiple layers of release
detection listed in the Decision Document will be able to detect releases and, because of their response
action plans, there will be minimal contamination allowed into the environment. The Decision Document
does not provide sufficient information to make this case and should be revised to provide quantitative
analysis and evidence of this risk mitigation achieved through these improvements. Bounding estimates
of possible release volumes based on the release response plan for various release scenarios, as mentioned
in the previous comment, can help with this illustration. In addition, if damages occur, what plans are in
place to address potential resource damages?
Minor releases are defined on page 97 of the Decision Document as releases occurring at rates less than
0.5 gph (or 4,380 gallons per year). Questions remain about how quickly the Navy would be able to
respond to various types of releases and mitigate the release.
Significance of Slow Chronic Fuel Seepage Below the Tank Tightness Testing Threshold is not
Addressed.
The Navy’s release detection testing demonstrated that commercial technologies exist that can detect
releases at rates as low as 0.5 gallons per hour or 4380 gallons per year. The release that occurred in 2014
was much larger than this, with a loss of about 27,000 gallons in a month or an average rate of around 37
gallons per hour. Along with the tank tightness testing on a periodic basis, other information that allows
for detection of leaks includes the near continuous inventory monitoring system along with periodic soil
vapor measurements.
However, even with all these release detection systems, slow chronic leaks can go undetected. This
concern is most significant with single walled systems. The Decision Document does not adequately
analyze the significance of this concern and describe the potential environmental consequences of this
limitation and potential mitigation measures.
Response Actions and Related Environmental Impact from a Significant Release is Needed.
The Decision Document, page 97 states, “The early detection and mitigation of a Significant (Gradual)
Release is critical for minimizing the overall volume and subsequent impact of any release. Currently,
groundwater modeling suggests any Significant (Gradual) Release could eventually be treated at a Red
Hill Shaft water treatment plant without posing risk to the public drinking water source.” The document
does not attempt to quantify potential volume of release based on release response measures but relies on
a water treatment system at Red Hill to ensure available drinking water. Because of this reliance, the RD
Decision Document should include specifics about the timeframe for evaluation, design, and construction
9

 of the water treatment system. If the Navy cannot proceed directly to design of a system, the Decision
Document must adequately describe the uncertainty related to the ability to design and construct a
treatment system that justifies the need for a feasibility study, and discuss the related impacts for not
having a water treatment system in response to a release.
The Regulatory Agencies note that the degree of capture at Red Hill Shaft for a range of possible release
scenarios has not yet been fully evaluated and remains unclear whether it is an adequate measure to
prevent impact to other receptors.
Increase Transparency of Data Related to Release Detection to Build Greater Public Confidence in
the Operational Integrity of the Red Hill System.
Navy should consider publishing data on groundwater monitoring and release detection on their website
on an ongoing basis to increase transparency to build public confidence.

Part 3: Fail-Safe Water Protection Strategy
The Overall Strategy Needs to Provide a Fail-Safe Plan for Water Protection
The overall objective of both DOH’s and EPA’s underground storage tank programs is to protect human
health and the environment from releases at underground storage tank facilities. This is accomplished by
requiring prevention, detection and response systems. Our objective is to prevent all releases, but this is
not always possible.
Given the importance of the aquifer below the Red Hill tanks as a major source of drinking water for
Honolulu, the Navy needs to establish a contingency strategy to assure no impairment of drinking water
quality and no disruption in drinking water availability. This fail-safe protection strategy should be
presented in the TUA and Release Detection Decision Documents.

10

 ATTACHMENT B
RED HILL TANK UPGRADE ALTERNATIVE AND RELEASE
DETECTION PROPOSAL, RESPONSE TO COMMENTS

Contents
Tank Upgrade Alternatives (Tank Upgrade) Option Comments ................................................................... 2
General Proposal Comments ................................................................................................................... 2
Reject Proposal / Not 1A (over 50% of the comments)............................................................................ 2
Secondary Containment ........................................................................................................................... 2
Timeline too long ...................................................................................................................................... 3
Risk Assessment and TIRM........................................................................................................................ 4
Shut Down the Facility .............................................................................................................................. 5
Environmental Concern ............................................................................................................................ 5
Relocation ................................................................................................................................................. 6
Other TUA Alternative .............................................................................................................................. 6
Cost ........................................................................................................................................................... 7
Release Concerns .......................................................................................................................................... 7
Release Detection Concerns / NDE ............................................................................................................... 8
Environmental............................................................................................................................................... 9
Hawaii Regulations...................................................................................................................................... 11
AOC ............................................................................................................................................................. 11
Additional.................................................................................................................................................... 12

1

 Tank Upgrade Alternatives (Tank Upgrade) Option Comments
General Proposal Comments
Proposed decision document lacks discussion of alternative courses of action – The Regulatory
Agencies seek a revised Decision Document that adequately evaluates alternatives and compares the
relative environmental benefits/risk reduction of the various options along with other factors to frame
the basis for a decision.
The Navy’s tank upgrade proposal fails to meet the requirements of Federal and State law – The EPA
does not agree that the proposal would lead to an option that violates federal law. However, if the
Navy is unable to demonstrate the proposal is protective of human health and the environment, then
they may be in violation with state regulations if they continue operation without secondary
containment after July 2038.
The Navy’s Decision Document suggests the proposed tank upgrade should provide sufficient
protection – What is meant by sufficient protection is not clear in the comments. The Regulatory
Agencies suggest that sufficient protection is engineering, operational, and institutional safeguards that
prevent adverse consequences to the drinking water supply and minimize future releases from the Red
Hill facility.
National Security is not a justification for maintaining the presence of the Red Hill tanks – Determining
the need for National Security assets is outside of the scope of EPA’s or DOH's responsibility.

Reject Proposal / Not 1A (over 50% of the comments)
The Regulatory Agencies should reject the Navy’s proposed option 1A for upgrade of the tanks – The
Regulatory Agencies are requiring the Navy to revise and resubmit the submitted document, as the
Decision Document does not provide adequate justification that the proposed improvements to the tank
and leak detection systems are the best available practicable technology (“BAPT”). Therefore, the
Regulatory Agencies are instructing the Navy and DLA to conduct additional analysis and submit a
revised Decision Document to present a BAPT approach that is protective of the environment.
However, several aspects of the proposal do contain actions that will likely reduce threat to the
environment. The Regulatory Agencies are encouraging the Navy and DLA to implement these actions
as soon as possible.
The tanks have leaked and will continue to leak under option 1A actions. Many of the actions in the
proposal are already occurring independent of the AOC. And more significant actions are not planned
and are limited to studies and pilot projects. – The Regulatory Agencies agree that more specificity and
clear commitments are necessary for risk reduction actions such as the Navy’s mention of continuous
leak detection, water treatment, and tank liner improvements. The Regulatory Agencies do believe that
many of the ongoing improvements are a direct result of the work required under the AOC. The
Regulatory Agencies have and will continue to encourage the Navy to make continuous improvements
to the facility and not wait for approval under the AOC.

Secondary Containment
The Regulatory Agencies should require Red Hill to upgrade with secondary containment – The Navy
must first demonstrate the relative environmental benefits of each option as well as present a
2

 discussion on each option’s viability. Based on this evaluation, the Navy then selects the BAPT for the
Regulatory Agencies’ approval. Based on the Decision Document submitted, the Regulatory Agencies
believe that the Navy did not provide adequate analysis or justification for their selection. The Navy has
only provided generalized statements that there are substantial constructability risks associated with
retrofitting secondary containment into the existing tanks.
Therefore, the Regulatory Agencies are seeking greater analysis on design and implementation issues
related to a secondary containment retrofit in order to understand how environmental performance of
this approach compares with other approaches to safeguarding drinking water supply and quality.
The term “double wall equivalency” needs to be clearly defined – The Regulatory Agencies agree that
for the purposes of a proposed tank upgrade decision, the document needs to include a clear definition
of what is meant by “double wall equivalency.” Underground storage tanks with double walls are
typically designed to meet regulatory secondary containment requirements. Secondary containment
means a release prevention and release detection system for a tank or piping. Typically, this type of
system has an inner and outer barrier with an interstitial space that is monitored for leaks.
The Navy needs to implement the Fuel Tank Advisory Committee recommendation to select either the
double wall or tank in a tank options – The Fuel Tank Advisory Committee is an important meeting to
provide legislators, the public and other stakeholders an update of the work performed and the status
of ongoing studies. Although some members of the committee may have concluded that the double wall
or tank in a tank option is the best upgrade for the facility, it is not an official determination made by the
committee.
Short of relocation, secondary containment is the most protective way to contain a release from a
tank and provides the best chance of surviving a catastrophic event – Under certain conditions, such as
degradation of the internal liner, secondary containment would likely improve performance. But many
other operating conditions need to be assessed in order to understand how secondary containment may
perform compared to single containment. The Decision Document does not adequately compare the
relative environmental performance among the single and secondary containment options and
therefore, is one of the reasons for which we are requiring the Navy revise and resubmit their Decision
Document.
Adding a second wall to the inside of the tanks will not stop the corrosion of the outer wall – If double
walled tanks becomes the proposed decision, the Navy needs to clearly address how the exterior
corrosion will be controlled and managed long-term, and if double wall will be constructed, how the
exterior corrosion will impact construction and long term operation and maintenance.

Timeline too long
The process to select upgrade requirements and improve Red Hill is taking too long – The Regulatory
Agencies agree that the process to develop Red Hill studies and select plans for improvements is taking
longer than anticipated. Progress has been slowed by Federal contracting constraints, personnel
turnover, and quality issues with studies. However, many risk reductions actions have already been put
in place at Red Hill in response to the AOC process and public stakeholder concerns. For example, repair
quality assurance and tank monitoring during the fill process after repairs has been significantly
improved to prevent the failures that contributed to the size of the 2014 release.
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 Implement improvements sooner than 28 years – The AOC indicates that all tanks in operation will
deploy Regulatory Agencies’ approved BAPT by September 15, 2037. Thus, the Regulatory Agencies are
also concerned about the extended time frames the Navy is suggesting to implement a tank upgrade
option and we will be working diligently with the Navy to implement BAPT at Red Hill as quickly as
practicable.
It should be noted that the Regulatory Agencies are working with the Navy to institute numerous risk
reduction improvements at Red Hill on an ongoing basis. Changes to the tank vessel itself is just one of
many issues being evaluated for risk reduction improvements. In 2014, the leak was primarily caused by
human error. Many changes have already been implemented to reduce chances that human error will
cause a significant release during tank filling and operations.

Risk Assessment and TIRM
The current tank inspection, repair, and maintenance (TIRM) protocols are not sufficient to address
risk – The Regulatory Agencies continue to instruct the Navy to study their TIRM and propose changes in
order to improve its efficacy in managing risk and strive for continuous improvement. For instance, the
Regulatory Agencies in our Response to Corrosion and Metal Fatigue Practices, Destructive Testing
Results Report, Red Hill Bulk Fuel Storage Facility (Red Hill), Joint Base Pearl Harbor-Hickam, Oahu
Hawaii, dated March 16, 2020 letter in response to the Navy’s Corrosion and Metal Fatigue Practices,
Destructive Testing Results Report, Red Hill Bulk Fuel Storage Facility report dated July 7, 2019
(“Destructive Test Report”), are seeking improvements on the non-destructive examination (NDE)
process, an integral part of the TIRM protocol. While important, TIRM is only one of several risk
management aspects of the Red Hill risk management practices that are a focus for improvements.
The Navy neglects to consider tank degradation – The Regulatory Agencies agree that tank degradation
(operational life of the tanks) needs to be considered in the decision-making process. The Navy should
do a more thorough analysis of how potential degradation in the future will impact tank performance.
The Navy’s Proposed Tank Upgrade Decision is inconsistent with their risk assessment – The Navy’s
Phase I risk assessment provided limited insight into risk at the facility. Further risk assessment is
ongoing. However, some of the insights gained from the Phase I assessment have been used to develop
mitigation measures described in the Decision Document such as decommissioning of the smaller tank
nozzles. The Regulatory Agencies agree that the Proposed Decision Document should address and
incorporate findings from all studies that have been performed under the AOC, which is one of reasons
that the agencies have found that the document requires revision and resubmission.
The Navy’s risk assessment provides release probabilities that justify rejection of proposal – The Navy’s
Risk Assessment is based on infrastructure and operations that were in affect as of July 27, 2017. The
Regulatory Agencies agree that for comparison purposes, having the identified component failures
described in the Navy’s Risk Assessment, with a description of the improvements made and proposed,
and how the corresponding actions have or will reduce potential risk and release probabilities for future
releases, would be useful.
Tank tightness testing was not effective because the 2014 release occurred
Tank tightness testing in general is an effective method of release detection, but only during static fuel
storage conditions.
4

 During the 2014 release, Tank 5 was in the process of being filled with fuel after the repairs were
completed. Tank Tightness testing cannot be done during dynamic filling. The flaw in repairs leading to
the leak was discovered during the filling process as the tank was being brought back into service. At
that time, the filling process did not have adequate safeguards in place.
The Navy has since updated their filling and return to service procedures, with the addition of
incremental filling, fuel level stabilization, and multiple tank tightness testing at multiple stages.

Shut Down the Facility
The Regulatory Agencies should require relocation of the Red Hill tanks / the Regulatory Agencies
should require shutdown of the tanks – The objective of the AOC is to conduct studies to guide
improvements to the Red Hill Facility to reduce risk of impact to the environment. The Navy has
expanded the tank upgrade options to include new tanks at a different location.
Under Hawaii Revised Statutes 342L-9 Emergency powers & procedures, the governor or director of
health can take immediate action in response to an imminent peril to human health or the environment
if the situation at Red Hill were to ever meet this criterion. In addition to these emergency powers,
environmental regulatory agencies are provided the authority under federal and state law to regulate
activities that present environmental risk by requiring monitoring, permits, inspections, testing, and
response plans designed to adequately protect the environment. Cost of environmental compliance
along with liability can also play a role in facility owner’s decision to shut down or relocate. The
Regulatory Agencies have commented on the Navy’s cost analysis of the tank upgrade options and have
requested that it be revised and resubmitted.
Tanks should not be put in strategic ready reserve and should be retired - Temporary closure rules
would apply to Red Hill Tanks, and they would remain subject to regulatory requirements while
temporarily closed pursuant to Hawaii Administrative Rules 11-280.1-70.

Environmental Concern
Regulatory Agencies required Navy to compare relative environmental performance of each Tank
Upgrade alternative which was not done – The Agencies agree that an in-depth comparison of relative
environmental performance of all tank upgrade alternatives is necessary in order to determine the
appropriate alternative.
The proposed tank upgrade decision should have compared environmental performance during all
modes of operation and from different initiating events – The Regulatory Agencies agree that a more
thorough comparison of alternatives during all modes of operation and from different initiating events is
needed to inform decisions.
Proposal cannot rely on treatment plant that does not exist and no timeline or commitment to build.
Treatment should be last resort. – The Regulatory Agencies agree that a treatment plant is a last resort,
but we do not object to the construction of additional safety (contingency) measures to protect
consumers of the drinking water. The Regulatory Agencies agree that in order to rely on a treatment
plant as a contingency measure, the treatment system needs to be in place.
Upgrades that only detect releases is not enough to protect sole source aquifer – Release detection is a
critical component of an environmental protection strategy because it can significantly limit the size and
5

 duration of a release by early detection that will allow for mitigative actions. The Regulatory Agencies
agree that release detection is only one component of an overall environmental protection strategy in
managing a fuel storage facility, and that other components such as risk mitigation (design and
operation) and maintenance, are also important factors in identifying the BAPT for this facility.
Comments expressed concerns that proposal comes before final CSM, GW model, fate and transport
model, and further Risk Assessment – The AOC requires the Navy to seek continuous improvement of
the facility and reassessment of the Tank Upgrade Alternatives at least once every five years as
inspections and repairs are made to the next set of tanks. Although more information can improve
decision making, taking actions sooner to reduce risk is also desirable. Therefore, the Navy and the
Regulatory Agencies need to balance how and when decisions are made to strive for continuous
improvement.
The Navy does not acknowledge the groundwater monitoring network near the Red Hill tanks is
limited so the assessments of tank upgrade alternatives needs to account for monitoring limitations –
The Regulatory Agencies agree that uncertainty, including uncertainty related to the efficacy of the
groundwater monitoring network, need to be taken into account during decision making related to the
proposed tank upgrade decision.

Relocation
The Decision Document does not make the argument that the tank within a tank and relocation
options are impractical – The Regulatory Agencies agree that insufficient information is presented to
conclude a tank within a tank option would be impractical (see Attachment A). Relocation of the fuel is
not an upgrade option to the current system but could be a long-term fuel storage approach pursued by
the Navy if continuing to upgrade and maintain the current facility can no longer be done effectively.
Relocation is only option that protects Oahu Drinking water – Although relocating fuel storage would
ultimately eliminate the risk of fuel released from these tanks in their current location, the tanks are
expected to continue to operate for the immediate future. Therefore, actions over the short term to
reduce risk are very important in an overall risk management approach for the Red Hill Facility.
Moving the tanks to an area where a release could potentially impact the shore is not acceptable
Hawaii Revised Statutes, 342L-4.5, states, “(a) The department shall not issue a permit for a new
underground fuel storage tank within one hundred yards of the shoreline; provided that a permit may be
issued by the department for purposes of repairing or replacing an existing underground fuel storage
tank…(c) Beginning January 1, 2045, no person shall operate an underground fuel storage tank within
one hundred yards of the shoreline, and no permit for an underground fuel storage tank within one
hundred yards of the shoreline shall be renewed.”
The alternative locations study referenced in option to remove fuel by 2045 should be cited in the
proposed decision – The Navy’s proposal of secondary containment equivalency or relocation by 2045
lacks detail. The Regulatory Agencies are seeking clarification.

Other TUA Alternative
Encourage the use of polymer coatings – Polymer tank coatings can be an effective tool to reduce
interior corrosion if the coating is applied effectively but would not directly address backside corrosion
of the steel tank lining. The Navy is currently using coatings in the lower dome and repair areas, such
6

 as welds, which may reduce risk from corrosion and seepage due to weld porosity or small cracks. The
Navy is considering a pilot test to apply coating on majority of the interior of the tanks. In our response,
the Regulatory Agencies are requesting clarity and additional information on their pilot proposal.

Cost
The Proposed Decision is the least expensive option and least protective of options studied – The
Regulatory Agencies acknowledge that the Navy proposal appears to be the least expensive option, but
the Navy has not provided a comprehensive comparative cost analysis that considers the operational life
of the tank options, nor a comprehensive comparative analysis under all operational modes to compare
degree of environmental protection. The Regulatory Agencies are seeking revisions to the Decision
Document to include this information.
Do not provide leniency if upgrade costs are too high – The Regulatory Agencies will not approve a plan
that does not adequately mitigate risk to the drinking water supply. If the cost to achieve adequate
protection is deemed by the Navy to be too high, then the Navy can choose to close the facility.

Release Concerns
The Regulatory Agencies should take action to address the concern that a catastrophic release can
occur due to condition of the tanks – The Regulatory Agencies are requiring further evaluation on how
this tank system will perform in the event of a seismic event and other plausible initiating events that
could cause structural failure of the tanks or impacts to other features, such as nozzles, valves and
piping. These issues will continue to be investigated as a part of the Section 8 work on facility
vulnerabilities.
The likelihood of chronic and potentially catastrophic releases is unacceptably high and cannot be
mitigated by actions described in the proposal – The Regulatory Agencies agree that the Decision
Document does not clearly describe how the proposal adequately addresses risk from the range of
potential releases. Further analysis is needed to identify appropriate mitigation measures for the range
of potential future releases.
There is a greater concern over catastrophic releases than smaller releases. There should be a public
warning of a catastrophic release, a disaster recovery plan, and a plan to assure drinking water safety
– We agree that emphasis needs to be focused on prevention of damage due to potential catastrophic
releases. And even though the probability may be low, consequences of a catastrophic release can be
much greater. We agree that the Navy needs to have a mitigation plan for catastrophic releases in order
to assure that drinking water quality and availability is not impacted by a catastrophic release at Red Hill.
Not enough known about fate of releases to justify status quo practices – The Regulatory Agencies
agree that status quo practices are not justified, and improvements are needed. Numerous changes to
practices have already occurred since the 2014 release. The Regulatory Agencies have instructed the
Navy to examine a range of release scenarios. Given the very complex geology at Red Hill, a limited
ability exists to determine the precise 'fate' of releases; however, there are several magnitudes of
releases that should be examined for their potential fate and transport. We agree that further analysis is
needed to evaluate the consequences of a range of release scenarios and identify appropriate mitigation
measures.
Pathways and rate of movement of releases cannot be predicted – The Regulatory Agencies agree that
it is not possible to predict exactly how future release will move through the environment. But the
7

 ongoing efforts to collect data and study the environment is meant to identify the potential range of
possibilities, including the more likely and less likely scenarios.
The Proposed Decision does not meet the zero future release standard – The goal is zero releases from
all fuel storage facilities, not the standard. The Regulatory Agencies and the Navy are striving to meet a
zero-release goal.
At least 200,000 gallons of fuel have been released at Red Hill – The total fuel loss from the facility
from when the tanks started operating in the 1940s to present cannot be accurately determined.
Environmental data, anecdotal operational reports describing fuel loss prior to promulgation of
environmental regulations, along with contemporary release reports all have a high degree of
uncertainty. The amount of residual fuel that is trapped in the subsurface below the tanks is also very
difficult to determine due to uncertainty associated with naturally attenuation, including dispersion and
degradation.
Use of tanks beyond service life presents a danger to drinking water supply – The Decision Document
did not discuss service life of the facility, which is one of the comments provided by the Regulatory
Agencies. The document mentions that the Navy intends to complete an asset study, which will identify
the remaining “life” of the existing tanks. This information, as well as the anticipated operational life of
each of the other TUA options, is needed to fully assess the options.
The primary concern of Honolulu residents is proximity of fuel to a primary drinking water aquifer –
The mission of the Regulatory Agencies is to protect human health and the environment; therefore, our
mission is also to protect drinking water from potential pollution sources. We recognize the proximity of
the Red Hill Tanks over the drinking water aquifer and therefore, the Regulatory Agencies’ goal is to
assure adequate prevention and mitigation of risk from the underground storage tank system.
Spills from Red Hill are difficult if not impossible to cleanup – The Regulatory Agencies agree that due
to the geologic setting at Red Hill, cleanup is extremely difficult. Therefore, greater focus on prevention
and mitigative measures are preferred.
Limited ullage to move fuel from leaking tank is significant risk factor – The Regulatory Agencies agree
that the Navy should have adequate processes, infrastructure, procedures, and training to rapidly
respond to leaks and reduce potential damage. This includes available ullage to drain a leaking tank.
Human error including reluctance to report problems to superiors is a concern – The Regulatory
Agencies recognize human error contributed to the 2014 release both at the tank repair and operational
levels. The expectation is that the Decision Document will address human factors as a contribution to
risk, in its overall strategy.

Release Detection Concerns / NDE
The current Non-destructive examination (“NDE”) process is unreliable – The Regulatory Agencies
agree that, based on the destructive testing study, further work is needed to study the reliability of the
Navy's NDE process and seek opportunities for improvement. The NDE shortcomings appear to limit the
ability to identify smaller scale corrosion defects that could lead to emerging small-scale releases. The
Regulatory Agencies acknowledge that NDE will never be 100% accurate, so other layers of protection
such as aggressive leak detection and leak response and/or secondary containment are likely necessary
as part of an option that relies on NDE to assure tank liner integrity.

8

 Corrosion mechanisms creates reliance on non-destructive evaluation (“NDE”) to inspect liner – The
Regulatory Agencies agree. Due to the way Red Hill is constructed, the only way to investigate the
condition of the exterior of the steel liner is using NDE.
Tanks do not meet corrosion protection requirement due to gap between steel liner and concrete in
areas – The Navy’s “Red Hill Bulk Fuel Storage Facility Destructive Testing Results Report, AOC/SOW
Section 5.3.3,” dated January 7, 2019 identified some void space between the steel liner and the
concrete structure in about eight of the ten coupon sample locations. The presence of moisture was
also noted on the exterior portion of the steel liner on about five of the ten coupons. The Regulatory
Agencies will work with the Navy to further investigate potential causes for corrosion and evaluate
potential options for addressing this concern.
The heavily redacted report on leak detection does not allow for the public evaluate if leak detection
meets requirements – The Regulatory Agencies continues to work with the Navy to make as much
information as possible available to the public in order to have transparency. Redactions are used to
protect national security, trade secrets, and to assure integrity of future procurement. Stakeholders
with subject matter experts on these leak detection technologies may be able to gain greater access to
information by entering into non-disclosure agreements.
Nozzle decommissioning for smaller nozzle is already approved, but larger nozzles present larger risk
that is not being addressed – The Navy suggests that risk reduction on the larger nozzle can be
adequately addressed via improved internal inspections using NDE technology and human visual
inspection, but the Regulatory Agencies are seeking clarification and justification from the Navy of the
proposed mitigation measures in a revised document.
Release detection is only reactionary and does little to address concerns regarding fuel above drinking
water aquifer – Although release detection identifies releases of fuel from the tank system, aggressive
release detection and response can limit the magnitude of a release.

Environmental
Water Security should not be compromised by Red Hill – The Regulatory Agencies agree that the
availability of drinking water on Oahu should not be compromised by the Red Hill facility. The
Regulatory Agencies believe that the Decision Document should clearly and defensibly demonstrate how
the actions and safeguards proposed will guarantee water quality and availability for consumers on
Oahu.
The Regulatory Agencies should require the Navy to clean up past contamination at the facility –
When an underground storage tank leaks, the typical regulatory approach is investigation and cleanup
of the release. In response to the 2014 release at Red Hill, the Regulatory Agencies took an alternative
approach to not only require investigation and assessment of the 2014 release but also improvements
to the facility to minimize future releases. The facility's unique construction, terrain, and extremely
complex geologic setting does not allow for typical cleanup activities. Fortunately, the 2014 release,
although unacceptable, has not had significant impact to drinking water quality. The Navy recently
submitted the “Investigation and Remediation of Releases Report, Red Hill Bulk Fuel Storage Facility”
dated March 25, 2020, which discusses their plans for remediation of the 2014 release as well as future
releases. The Regulatory Agencies are currently reviewing this document.
9

 The Groundwater Modeling being done by the Navy is flawed – Groundwater modeling work is
ongoing. The Navy recently submitted a report describing their multi-model approach to flow modeling
titled, “Groundwater Flow Model Report” dated March 25, 2020. The objective of the multi-model
approach was to create several models to better account for uncertainty in this very complex setting.
The Regulatory Agencies are currently reviewing this document.
The environmental modeling efforts are deficient – Accurately modeling groundwater movement at the
scale of interest for the Red Hill project is very challenging due to the complexity of the subsurface and
data density. Continuing data collection and modeling are improving the utility of this effort, but the
Regulatory Agencies will not inappropriately rely on the modeling effort to guide decision making.
Navy is creating models to produce preferred outcomes – Models are interpretation of data. The
Regulatory Agencies have and will continue to review the modeling developed by the Navy and will
make our own interpretations that will help guide the Regulatory Agencies' decision making.
The Navy unrealistically assumes large storage capacity of vadose zone, no preferential groundwater
flow pathways, high biodegradation rates, and recent releases have not reached groundwater – The
Navy’s current assumptions relating to vadose storage capacity, existence of preferential groundwater
flow pathways, biodegradation rates, and whether or not fuel has reached the groundwater are
currently under review by the Regulatory Agencies as part of the review of other deliverables required
by the AOC.
Navy CSM is deficient in characterization of features and conditions such as hydraulic gradients and
aquifer properties of preferential flow and saprolite – The Hawaii Department of Health reiterated in
the letter, “Response to Conceptual Site Model, Investigation and Remediation of Releases and
Groundwater Protection and Evaluation, Red Hill Bulk Fuel Storage Facility, Joint Base Pearl HarborHickam, Oahu Hawaii,” dated March 30, 2020 that, “we continue to disagree with fundamental
conclusions made in the 2019 CSM.” The Regulatory Agencies recognize that the CSM continues to
evolve as new information is obtained. Work completed as part of another AOC deliverable, the
“Groundwater Flow Model Report” dated March 2020, that further refines the CSM is currently being
reviewed and evaluated by the Regulatory Agencies.
Improve monitoring of groundwater, vapor, and improve release detection – The Regulatory Agencies
agree. Many of the improvements already made in these areas since the 2014 release are documented
in the Decision Document, along with extra proposals that are under consideration by the Navy.
Additionally, the Regulatory Agencies are recommending even more improvements, listed in
Attachment A.
The Regulatory Agencies should seek input from USGS, USACE and BWS on adequate monitoring
network – The Regulatory Agencies have been and will continue to seek input on the groundwater work
from experts from USGS, BWS, Department of Land and Natural Resources, University of Hawaii, as well
as our own experts and consultants.
Treating drinking water does nothing to alleviate concerns about long-term health and environmental
impacts of permanently contaminating Oahu's drinking water with fuel – The Regulatory Agencies
agree that the solution at Red Hill should not require the need for a drinking water treatment system.
But treatment should be considered as a safeguard or contingency measure for low probability yet high
consequence events (e.g. catastrophic failure of tank, pipeline, or nozzle).
10

 The Navy's interpretation of existing data and analysis are not conservative, often unsupported, and
should be rejected – Although the data collected by the Navy, for the most part, has been very useful to
help guide further work and decisions, the analysis and interpretation of this data by the Navy does not
always match that of the Regulatory Agencies. The Regulatory Agencies have provided multiple
comment letters to the Navy on their environmental work. The Regulatory Agencies will continue
reviewing new information as it comes in and will make our own interpretations that will help guide the
Regulator Agencies' decision making.

Hawaii Regulations
State law requires USTs to be upgraded and operated to prevent releases for operational life of tank
or tank system – Prior to July 2018, Hawaii UST regulations required owners and operators of field
constructed tanks to comply with release reporting, investigation and confirmation of releases, release
response actions, and closure requirements. In July 2018, the Department of Health revised their UST
regulations to also require underground storage tank systems with field constructed tanks and airport
hydrant fuel distribution system have: release detection, spill and overfill protection, financial
responsibility, operator training, a permit, -and for these tanks and piping installed prior to July 15,
2018, must be provided with secondary containment or a design which the director determines is
protective of human health and the environment by July 15, 2038.
Allowing any amount of fuel released from the Red Hill tanks violates Hawaii law and fails to comply
with the AOC – Neither Hawaii law nor the AOC permit fuel releases. The goal of the Regulatory
Agencies’ regulations and the AOC is to prevent future releases.

AOC
Do not extend the upgrade deadline in the AOC – The Regulatory Agencies do not have any intention to
extend the deadline at this time. The Regulatory Agencies seek improvements to the tanks as soon as
practicable. But the Regulatory Agencies also need to balance the assurance that improvements are
done in a way that is meticulous and avoids mistakes that could happen if the work is rushed.
Do not provide extension of time to relocate fuel. At Point Loma, California and Manchester,
Washington State the Navy was able to address issues with tanks much faster – The Red Hill facility
cannot be directly compared with the tank facilities in California and Washington State. Red Hill is a
unique facility, with very different issues than what was seen at these other locations. Red Hill is much
larger, the tanks are constructed much differently, and the alternatives to Red Hill are much more
limited due to land use and availability. The Regulatory Agencies are urging the Navy to move forward
and take actions to reduce risk.
Data and tests collected since the AOC was signed affirm the concerns expressed in April 2015 – The
Regulatory Agencies agree that much of the information collected affirms our general understanding of
issues and risk at Red Hill, but the work has been very useful to further identify risk drivers and risk
mitigation options.
The AOC legitimatizes non-action – The AOC has been an important tool to get the Navy to conduct
studies and analysis to inform decisions on where to reduce risk at the facility. Although an overall tank
upgrade decision has not yet been made, many actions have already been taken to reduce the risk of
future releases at the facility.
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 Additional
Above Ground Storage Tank (“AST”) American Petroleum Institute (“API”) standards are not
appropriate for Red Hill Tanks – The Regulatory Agencies agree that the API Standards cited by the Navy
were developed as inspection, maintenance and repair guidelines for standard above ground storage
tanks. The Navy modified these standards in order to create a unique inspection, repair, and
maintenance procedures for the Red Hill tanks. The Regulatory Agencies continue to evaluate the
Navy’s procedures to identify areas for improvement.
Children have had health impacts from Red Hill Tanks – Based on the environmental monitoring at Red
Hill and surrounding wells, we have no evidence of any potential for exposure from the environmental
conditions at Red Hill.
Navy should trade Waiawa wells for Moanalua and Halawa wells – This is outside of the scope of the
AOC and authority of the Regulatory Agencies.
Navy should utilize their top experts to come up with solution at Red Hill – The Regulatory Agencies
believe the Navy is using their top expert engineers who are responsible for fuel storage to improve
conditions at the Red Hill Facility. Additionally, the Regulatory Agencies are utilizing internal and
contracted experts to oversee the Navy’s effort.
The Hawaiian creation story is important on framing the value of the land and water – The Regulatory
Agencies acknowledge this consideration, and it is our goal to ensure protection of our environment.
Install reinforced concrete spillways under tanks – Numerous experts explored a very large range of
options to improve the tanks. Unfortunately, construction of a bathtub-type secondary containment
under the current tanks in the basalt was deemed impracticable due to extreme complexity and cost
involved in mining out a space below the tanks.

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