Red Hill has “high potential for catastrophic environmental loss”

The Red Hill Bulk Fuel Storage Facility (RHBFSF) tanks put an enormous volume of fuel in close proximity to the Waimalu and Moanalua drinking water aquifers. The RHBFSF holds about 180 million gallons of fuel in 15 active tanks that are each around 250 feet tall. The bottom elevation of the Red Hill tanks is a mere 100 feet (approximate) above the groundwater source.

Although Honolulu’s drinking water is currently safe, letters sent by the city’s Board of Water Supply (BWS) to the Navy and its primary regulators in this case, the Environmental Protection Agency (EPA) and the Hawaiʻi Department of Health (DOH), make it clear that the city utility responsible for ensuring the safety of Oʻahu’s drinking water supply is concerned that the Navy isn’t doing nearly enough to remedy a situation where “the potential for catastrophic environmental loss is high.” The letters also make it clear that the BWS doesn’t feel that the EPA and DOH are doing enough to ensure that the Navy addresses the problem appropriately, or that it even complies with its own existing safety protocols.

“[P]rotection of the underlying, sole-source aquifer is not given a sufficiently high priority in the proposed assessment of risk at the RHBFSF; otherwise alternate fuel storage locations, continuing corrosion, and double-walled tanks would be more closely considered,” writes the BWS. “In short, the risk assessment work plan is almost entirely limited to issues that support continuation of the status quo and lacks the rigor and breadth necessary to evaluate the risk posed by the RHBFSF to our drinking water supply.”

Since June, the BWS has sent 34 letters to the Administrative Order on Consent (AOC) parties—the Navy, EPA and DOH—attempting to lend its expertise and resources in finding a solution that is in line with Article XI of the Hawaiʻi State Constitution, which holds all public natural resources in trust and protects these resources for the benefit of the people of Hawaiʻi. In keeping with the public trust doctrine, the BWS is maintaining a position of: 

1. accepting no more fuel leaks from the Red Hill tanks and requiring the restoration of the groundwater to its original, pristine condition by cleaning up the fuel contamination that exists there now and preventing future leaks, regardless of amount;
2. requiring zero further risk of fuel leaks to the environment;
3. relocating the fuel to a different facility at a different location or locations, or retrofitting all RHBFSF active tanks with double walls (tank-within-a-tank);
4. maintaining public transparency and rejecting any attempt to have parties sign a non-disclosure statement; and
5. finding the 2014 fuel leak by installing more groundwater monitoring wells to get the information needed to completely understand the groundwater contamination underneath and near the tanks.

The BWS has received only 11 responses from the AOC parties, and many of the agency’s suggestions appear to have been largely ignored.

Immediate Concerns

In January 2014, the U.S. Navy reported a 27,000 gallon leak of jet fuel from Tank 5 at its RHBFSF. The Navy owns 20 fuel tanks in the Red Hill area, each able to contain up to 12.5 million gallons of fuel. These tanks are located 100 feet above the groundwater aquifer. For comparison, 100 feet is the height of the State Capitol building. This aquifer is the same one that BWS uses to provide water to residents from Moanalua Valley all the way to Hawaiʻi Kai. 

“The BWS continues to be concerned about the petroleum contamination that is still present in the rocks and groundwater underneath and near the Red Hill fuel tanks and the risk for potential future, perhaps catastrophic leaks. The Navy has been testing the groundwater since 2005. However, tests conducted by the Navy from 2014 to 2016 indicate the amount of petroleum contamination in the groundwater underneath Tank 5 is rising,” writes the utility. “Navy studies and reports on the condition of the tanks also show many holes forming from corrosion of the steel tanks which is requiring the Navy to hire contractors to weld patch plates to cover the holes. Maintaining the inside of the tank but not the outside which cannot be reached is not reducing the risk of more leaks.”

Contamination of this water source would be disastrous for the East Oʻahu urban corridor, which is why the BWS is right to seek, in its letters, the most aggressive measures possible in securing the current fuel supply, cleaning up existing contamination in the rock below the tanks before it reaches the aquifer and strictly regulating Navy adherence to safety standards in the future.

According to the BWS, there are multiple lines of evidence indicating non-aqueous phase liquid (NAPL) fuel present in or near one of the Navy’s monitoring wells (RHMW02), yet the EPA and the DOH have not directed the Navy to remediate this contamination.

“Regardless of the AOC, the EPA and DOH remain responsible for enforcing the regulations for responding to contamination of Oʻahu drinking water by light non-aqueous phase liquids (LNAPLs) (HAR Subchapter 7 §11-281-74(5) and CFR Title 40, Chapter I, Subchapter I, Subpart F Part 280.62(a)(5)) and those actions required by the Navy’s own Groundwater Protection Plan (GWPP) (TEC, 2008; HOR, 2014),” writes the BWS.

Unfortunately, the BWS finds that the AOC parties appear to be ignoring agreed-upon aspects of the GWPP. As outlined in the GWPP, groundwater action levels used for decisions at the RHBFSF include general DOH Environmental Action Levels (EALs) for groundwater protection and Site-Specific Risk-Based Screening Levels (SSRBLs) for TPH-d and benzene (TEC, 2008; HOR, 2014). The actions to be taken for exceedances at specific monitoring wells and for specific categories are listed in the GWPP (TEC, 2008; HOR, 2014), and are dependent on the concentration of a compound at a specific well in relation to groundwater concentration trends. But the BWS has found no evidence that trend analysis of the data has been conducted using the appropriate and crucial Mann-Kendall nonparametric statistical test (as outlined in the GWPP).

“The Navy has been remiss in evaluating trends per the GWPP and should immediately begin evaluating for statistically significant trends for all contaminants of concern,” writes the BWS. “The BWS requests that either the DOH and EPA provide evidence of such analysis or require the Navy to follow their own GWPP and perform the analysis.”

Since 2005, TPH-d concentrations in monitoring well RHMW02 have exceeded SSRBLs six times, and four of those have occurred after 2014. According to the BWS, the response to an exceedance of the SSRBLs indicates very specific actions and responses that the Navy has, in part, neglected to implement.

“To our understanding, two of these required actions have not been addressed by the Navy, including [sending a Proposal for Groundwater Treatment to the DOH and preparing for an alternative water source at U.S. Navy Well 2254-01],” writes BWS. “This is indicative of a lack of initiative on the part of the Navy to act in good faith to protect the natural resources of Hawaiʻi, and to reduce the risk to the Navy’s own water supply at Red Hill Shaft (Navy Well 2254-01 ).”

The immediate concern is that there is currently contamination in the ground below the tanks, and the risk to our drinking water supply from future releases continues to be significant based on the BWS review of available evidence.

“Given that there is currently contamination in the groundwater and until the quantitative risk and vulnerability assessment (QRVA) is completed, the risk of future releases continues. The BWS would like the Navy to proceed with the design, construction, and operation of a groundwater treatment facility at the RHBFSF,” writes the utility. “ This will allow the treatment of current contaminants and provide the ability to clean up continuing or future releases … An active treatment system is the only reasonable action that the Navy could take to help ensure that potential receptors, e.g., public and military water supplies, are not exposed to contaminated groundwater.”

Upgrade Flaws

The BWS also identified a series of flaws with the part of the plan relating to upgrades at the fuel facility to prevent future leaks and any further possibility of contamination.

These flaws begin with a “lack of an adequate understanding” of Oʻahu’s geology, the differences between ʻaʻā and pāhoehoe lava rock, and of hydrologic and geologic scientific literature. Specifically, the AOC plan—based on a 2007 study by Rotzoll and El Kadi—exaggerates the widths of Hālawa valley fills by at least 50 percent beyond those shown in Sherrod et al. (2007) or Stearns (1939), and ignores previous work by Wentworth (1942) and lzuka (1992) that show the uncertainty about the depth of valley fill sediments in Hālawa valleys.

The plan also ignores “the most defensible groundwater flow model to date, Oki (2005),” which has shown that the groundwater head data available for flow model calibration cannot be used to determine whether valley fill sediments in Hālawa or Moanalua Valleys impede groundwater flow.

“It is our view that any flow and transport model built using this unjustified assumption about the extent and properties of the valley fill sediments in both North and South Hālawa and Moanalua valleys disregards the available site-specific scientific evidence and will likely lead to decisions and actions that endanger our water supply facilities and aquifer,” the utility writes.

There are also errors with the elevation measurements of existing monitoring wells, and the BWS wants the Navy to bring more online to shore up holes in its existing data through more extensive testing:

“Given the importance of understanding the direction of groundwater flow in and around Moanalua and Hālawa valleys, [the] EPA and DOH should direct the Navy to implement long-term monitoring of heads in the extended well network using transducers to provide sufficient data for model calibration,” writes the agency. “In the absence of defensible data about valley fill sediments, the flow model should conservatively assume that valley fill sediments do not significantly affect groundwater flow across Hālawa and Moanalua valley. Such an appropriately conservative flow model would be similar to the ‘no valley fill’ scenario in Oki (2005) or would reflect the available data and cross-section line A in Figure 25 of Wentworth (1942).”

The BWS also wants the list of contaminants of potential concern (COPCs) for the RHBFSF to be expanded (in February, 2016, the EPA and DOH approved a reduction in the number of COPCs). Specifically, the BWS wants the COPC list to include volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), dissolved lead, petroleum hydrocarbon biodegradation parameters (iron, manganese and sulfate) and chemical additives (including all antioxidants, not just phenol, and all fuel system icing inhibitors). The BWS also wants the Navy to disclose other fuel additives that may have been used over the past several decades.

Other problems include outdated seismic design principles, codes and methodologies and a lack of data and test results on the actual steel liners in the 20 RHBFSF tanks (which have been corroding from both the inside and outside since their construction in the early 1940s).

Lastly, the BWS wants the AOC parties to consider an obvious tank upgrade alternative that has been omitted from the plan: the option of tank relocation.

“Closure of the Red Hill Bulk Fuel Storage Facility and relocation of the tanks to another location such as Hickman Field should be considered as an option for comparison along with other tank repair and re-design options,” writes the agency. “This option, although potentially expensive, is one of the best options from the BWS’s viewpoint, as it has the greatest ability to reduce the risk of future leaks into the water supply.”

Going Forward

“The BWS is extremely concerned about the complete change of Navy leadership every two or three years. It does not foster strong continuity of institutional knowledge and commitment despite the best debriefing and orientation efforts. Each new commander, captain and admiral would have to repeat the learning process to become familiar with the very complex issues involved in this situation. This has been a major challenge to other communities in the United States dealing with similar groundwater contamination issues caused by the military,” writes the BWS.

But the agency has a good solution: Delegate full authority to the highest ranking civilian engineer at the Naval Facilities Engineering Command Hawaiʻi on all matters related to this facility and the AOC, including funding priorities to implement actions needed.

“Civilian Navy employees are not rotated and offer the best level of continuity and should be given full authority to make the decisions, take the necessary actions and approve the funding needed to implement the AOC work to its logical conclusion,” writes the BWS.

During scoping meetings, the BWS reports that Navy officers appeared to imply that obtaining the funds to improve the Red Hill tanks under the AOC would not be an issue, given the Navy’s seriousness in protecting the environment and preserving Oʻahu’s drinking water, and because of the facility’s strategic importance in the Pacific. “If so, cost should not be factor nor reason for not implementing the highest environmentally protective solutions at Red Hill,” the utility argues.

This leaves the BWS to determine two possible solutions going forward: Relocating the fuel to a different facility at a different location or locations that are not over drinking water-quality groundwater aquifers; or retrofitting all RHBFSF active tanks with double walls (tank-in-tank).

The Environmental Protection Agency’s mission is to “protect human health and the environment.” The Hawaiʻi Department of Health mission is to “protect and improve the health and environment for all people of Hawaiʻi.” Further, Article XI, Section 7, of the Hawaiʻi State Constitution says: “The State has an obligation to protect, control, and regulate the use of Hawaiʻi water resources for the benefit of its people.” The Navy’s mission, as it pertains to the environment, states, “the Navy has a responsibility to serve as a good steward of the environment. The Navy demonstrates that commitment by investing in programs that minimize, and in some cases eliminate, the effects of Navy operations on the environment.”

Groundwater in Oʻahu’s sole-source aquifer has already been contaminated by Red Hill fuel leaks, which have been recorded as far back as 1947. The aquifer will continue to be at risk from contamination caused by future fuel leaks until a serious solution is implemented. Fuel staining of the basalt rock beneath the tanks demonstrates that the steel liners are breached and that the concrete around the tanks is cracked, allowing fuel contaminants to migrate beyond the control of the Navy toward the precious water resource. Known fuel contamination exists surrounding and below the tanks and has caused significant impacts to groundwater, as shown in data from monitoring well RHMW02. Fuel contaminant concentrations in that monitoring well far exceed DOH Environmental Action Levels (EAL) and are increasing steadily as time passes. Contamination from leaked fuel was first detected at the Navy’s Red Hill Shaft drinking water supply in 2005. The AOC parties must take action now to prevent any additional contamination of our aquifer, and all current contamination should be remediated without delay.