State, EPA reject key Navy plans for Red Hill fuel storage tank fix
By WILLIAM COLE | The Honolulu Star-Advertiser | Published: October 28, 2020
HONOLULU (Tribune News Service) — State and federal regulators have rejected key provisions of the Navy's plan to improve the Red Hill Bulk Fuel Storage Facility after 27, 000 gallons of fuel spilled in 2014 from the World War II-built tank farm.
In a letter dated Monday, the U.S. Environmental Protection Agency and state Department of Health said they reviewed the Navy's September 2019, plan to protect groundwater near the site and "disapprove " the submittal and are granting the Navy and Defense Logistics Agency "an opportunity to cure the deficiencies and resubmit the decision document."
The Navy in its proposed tank upgrade analysis "has not demonstrated to the regulatory agencies that the proposed alternative is the most protective of the groundwater and drinking water, " the letter states.
Among the concerns, the agencies said a Navy plan to have "double-wall equivalency secondary containment " or remove the fuel from Red Hill in approximately the 2045 timeframe "requires further discussion."
The Navy must provide a detailed comparison of how the proposed secondary containment equivalency will perform against other options, including secondary containment such as tank within a tank, the agencies said.
An "advisory order on consent " entered into by the parties specifies that all tanks in operation shall have approved leak improvements by September of 2037 or be taken out of use, and the Navy-specified timeframe of 2045 "does not appear to comply " with that agreement.
The Navy proposed a "comprehensive tank restoration " and decommissioning of nozzles that could be sources of leaks "combined with coating applications and improved testing, monitoring, modeling, sampling, and analysis throughout the facility's layers of protection."
The Navy said the 20 tanks within Red Hill represent "critical infrastructure for the nation's defense " and are steel-lined concrete up to four feet thick and store millions of gallons of jet or marine fuel used by the U.S. military.
Since 2006, the Defense Department has invested $260 million in Red Hill, with modernization continuing. "Public records confirm that all drinking water near Red Hill remains safe, " the Navy said.
But the Sierra Club of Hawaii said there is no better option for Oahu's water supply than relocation.
The Navy studied six tank upgrade options and "to no surprise, the Navy's preferred choice—the least protective and least expensive option—is to keep the original, corroding steel tank liner, coat it with epoxy and explore installing a water treatment plant to filter toxic chemicals from Oahu's drinking water in the case of another major leak, " the environmental group said.
Much of the concern over Red Hill centers on the tanks' location 100 feet above the water supply aquifer that is the principal source of drinking water for more than 750, 000 Oahu residents. The aquifer lies in saturated volcanic rock.
The Navy admitted its "double-wall equivalency " plan relies on future technology that does not now exist—which the Sierra Club said is "not actually a double-walled solution."
The regulatory agencies said 411 written and 45 oral comments were received at a public hearing on the Navy plan and most "were not in support of the Navy and DLA's proposed tank upgrade alternative."
In response to the assertion that the Navy should be required to provide secondary containment for the single-wall steel tanks, the regulatory agencies said the Navy must first demonstrate the relative environmental benefits of each option—which then will be subject to approval.
"Based on the decision documents submitted, the regulatory agencies believe that the Navy did not provide adequate analysis or justification for their selection, " the letter said. "The Navy has only provided generalized statements that there are substantial constructability risks associated with retrofitting secondary containment into the existing tanks."
The EPA and Health Department said they realize that "many of our issues with the collective ( Navy ) decision document may require substantial effort and time to address " beyond a standard 30 days, and the Navy can request a meeting within that time period to review the letter sent by the agencies.