Health Department Staff Find Red Hill Fuel Tank Permit Insufficient
Hawaiʻi Environmental Health Administration concludes U.S. Navy failed to prove their antiquated tanks can be safely operated
HONOLULU, HAWAIʻI (Thursday, July 15) -- The Hawaiʻi Department of Health’s Environmental Health Administration has concluded that the Navy’s permit application to operate underground fuel storage tanks at Red Hill is full of holes.
In a filing on Tuesday in the contested case hearing on the Navy’s application, the state deputy attorney general noted that "given the documented history of releases at the site, the uncertainty associated with the Navy’s groundwater model, and the lack of treatment or recovery systems in place to date, the Navy has not met its burden of demonstrating that this facility is protective of human health and the environment from potentially ‘significant' future releases.”
“This is a notable change in the staff’s position at the Health Department. The evidence presented in this administrative hearing helped the staff to see that no matter how hard the Navy tries, it cannot safely operate the Red Hill tanks,” said Marti Townsend, Sierra Club of Hawaiʻi director. “The only reasonable thing to do now is shut down these dangerous tanks and require the Navy to find a better way to store their fuel.”
The Environmental Health Administration concluded the Navy’s current plans are unfit to operate the facility safely and any permit granted should include conditions to address the corrosion of the tanks, the theoretical status of secondary containment options, the uncertainty associated with the Navy’s groundwater model, and the lack of treatment or options for cleaning up fuel leaks.
The Department of Health’s Environmental Health Administration also concluded:
"the tanks are in fact not adequately clad or jacketed because there is space between the steel liner and the concrete, and corrosion is occurring." (Page 6, #16).
"there is not sufficient evidence that the tanks comply with corrosion protection requirements" (Page 8, #25)
the Navy’s conceptual site model that describes the hydrogeology of the area "is likely flawed and does not adequately reflect the flow and behavior of groundwater in the Site vicinity. . . . the groundwater model will not reliably reflect groundwater flow, contaminant transport, plume capture or other key risk-based considerations.” (page 9, #28)
“The antiquated Red Hill tanks have a long history of leaking and contaminating the groundwater in Oʻahu's primary aquifer,” reminded David Kimo Frankel, the Sierra Club’s attorney on this case. “The tanks at the Red Hill Bulk Fuel Storage Facility have leaked more than 178,434 gallons of fuel over the past 8 decades. The Navy’s own documents reveal the significant contamination that has already occurred. Its risk assessment reveals that the probability of a leak up to 30,000 gallons over the next year is 27.6%. Over the next five years, that risk is 80.1% and over the next ten years that risk is 96.0%.”
He added, “perhaps the Navy’s own internal audit says it best, and I quote: “[B]ased on the results of the audit work, we determined that the environment in the Pearl Harbor area has not been sufficiently protected” from the Red Hill Bulk Fuel Storage Facility.”
Despite expensive improvements and changes in procedure, the Red Hill tanks leaked again on May 6, 2021. The cause of the leak remains unknown but data shows that at least 1,000 gallons leaked and some of the fuel reached the soil beneath the tanks, which contradicts the Navy’s claims that it fully contained the leak. In 2014, tank 5 at the Red Hill facility released 27,000 gallons of fuel. Documents filed as part of this contested case indicate that “a portion of the 2014 JP8 release may have reached groundwater” in Oʻahu’s primary aquifer located 100 feet beneath the tanks.
“The Navy has wasted millions of our tax dollars and years of valuable time on studies and tweaks at Red Hill, and the tanks still leak and still threaten our water supply. It is time to call it,” said Townsend. “It is extremely disappointing that our congressional delegation has failed to seek the funding necessary to abandon these failing tanks, relocate the fuel, and secure our drinking water supply.”
The hearings officer in charge of the contested case hearing is reviewing this along with all of the filings from the parties to the contested case and will make a recommendation to the Department of Health Director, Libby Char, for final decision on whether to issue a permit for the Red Hill tanks, and if so what conditions to impose.
Tuesday’s filings are part of a 2019 contested case filed by the Sierra Club of Hawaiʻi and Honolulu Board of Water Supply on the Navy’s permit application to the Hawaiʻi Department of Health to operate its Red Hill Bulk Fuel Storage Facility. The Navy had previously operated the once top secret fuel tank facility without any oversight by the Department of Health. The Sierra Club challenged that exemption in 2017 and won a court ruling mandating the Health Department correct its regulations and require the U.S. Navy to follow the same process that every owner of underground fuel tanks must complete to secure a permit to operate such tanks.
“Now, the staff are telling the Health Department Director that the U.S. Navy failed to prove in an evidentiary hearing that it can operate the tanks at Red Hill safely,” Townsend added. “That is a big deal.”
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