Protect Oʻahu’s Drinking Water

Video by Caitlin Rodgers, Sierra Club of Hawaiʻi intern, January 2017 

Kapūkaki, known today as Red Hill,

is a mountain ridge located between the ahupuaʻa of Hālawa and Moanalua in the ʻewa district of Oʻahu.

For more than 70 years the United States Navy has stored fuel inside this ridge a mere 100 feet about Oʻahu’s primary drinking water supply. In that time, the facility has leaked more than 30 times with the last known leak occurring in January 2014, when 27,000 gallons of fuel was released from a single tank. This leak resulted in a 20-year agreement between the U.S. Navy, Environmental Protection Agency, Defense Logistics Agency, and the Hawaiʻi Department of Health to study, monitor and consider improvements to the storage facility.

The U.S. Navy’s Red Hill Bulk Fuel Storage Facility

holds twenty fuel storage tanks, 18 of which are active. Total, these tanks store 225 million gallons of jet fuel or marine diesel—each tank big enough to fit Aloha Tower inside.

100 feet below this facility sits Oʻahu’s primary drinking water source, the Southern Oʻahu Basal Aquifer which serves over 400,000 residents and visitors. The Environmental Protection Agency determined in 1987 that this aquifer is the “principal source of drinking water” for the island, and that “if contaminated, would create a significant hazard to public health.”

At least 200,000 gallons of fuel have leaked into the surrounding environment from Red Hill and more is likely.

This includes the 27,000 gallons that last leaked in 2014. While the drinking water is currently safe to consume, U.S. Navy studies are detecting traces of petroleum chemicals in the groundwater near the tanks.

The U.S. Navy, Environmental Protection Agency, and Hawaiʻi Department of Health have released no plan for cleaning up the leaked fuel and cannot guarantee these tanks will not leak again.

It is clear that the Navy does not care about protecting the quality of Oʻahu’s drinking water:

In a 2019 report, the Navy cited that there is a 27.6% chance of an event resulting in a fuel release between 1,000 and 30,000 gallons. That is almost a 1 in 3 chance that another large leak—similar to the 2014 leak—would occur again in the future. Still yet, the Navy does not commit to relocating the fuel or making any substantive upgrades to the Red Hill tanks.

In a 2018 report, the Navy assumes that a sudden release of 120,000 gallons of fuel or a slow release of 2,300 gallons of fuel per year per tank “would have, at most, a minimal impact to groundwater.”

Sierra Club files new suit against Hawaiʻi Health Department

On November 6, the Sierra Club of Hawaiʻi sued to prevent the automatic approval of underground storage tanks like the antiquated leaking tanks at Red Hill. The Department’s rules allow permit applications to operate underground storage tanks—including those at Red Hill—automatically after 180 days. This is outrageous as a recent study shows that there is a nearly 30% chance that the Red Hill tanks will leak 30,000 gallons of fuel or more every year and that 6,000 gallons of fuel already leaks annually. The Department should not, in good faith, approve a permit while also knowing that the tanks in question serve a huge risk to the health of Oʻahu’s residents and environment.

Department of Health proposes new, weakened rules for Red Hill Tanks

In May 2019 we formally asked the Department of Health to re-do the state’s underground storage tank rules. Our suggested rules would require the Red Hill tanks be relocated to a location not above O‘ahu’s drinking water within 10 years. In November 2019, DOH finally released draft rules for public comments. Not only did the DOH not agree to requiring relocation of the tanks, but aligned the draft rules with the Navy’s preferred tank upgrade plan (secondary containment by 2045), which extends the deadline for tank upgrades to be completed. This is worse than the existing rules that require secondary containment at Red Hill by 2038. 

The Department of Health is accepting comments on the draft rules. Submit your written comments opposing DOH’s proposal to weaken the existing rules by extending the deadline for secondary containment until 2045 and support requiring the relocation of these tanks away from O‘ahu’s aquifer. Click and submit your comments here or email them directly to DOHustprogram@HawaiiOIMT.onmicrosoft.com. 

There will be a public hearing on DOH’s proposed rule change on December 2nd at 9 am in Pearl City. More information on the rules and upcoming hearing can be found here.

The Navy’s plan to “upgrade” the Red Hill tanks

In September 2019, the Navy released it’s preferred plan on how to upgrade the Red Hill tanks after studying six tank upgrade options. To no surprise, the Navy’s preferred choice—the least protective and least expensive option—is to keep the original (corroding, see below) steel tank liner, coat it with epoxy, and explore installing a water treatment plant to filter toxic chemicals from Oʻahu’s drinking water in the case of another major leak. The plan also commits to some undefined, undetermined “double-wall equivalency” solution or relocation of the tanks “around 2045″– which proposes to extend the deadline to upgrade the tanks another 7 years using some unknown, future technology that is not actually a double-walled solution. 

Public comments are currently being accepted by the U.S. Environmental Protection Agency and Hawai’i Department of Health on the Navy’s tank upgrade plan (read the Sierra Club’s comments here).

Your voice is needed to demonstrate objection to the Navy’s plan and support for relocating the Red Hill tanks. Written public comments should be emailed to redhill@epa.gov by December 9th, 2019.

A public hearing is scheduled for Tuesday, November 19, 6-8 pm  at Moanalua Middle School. 

No choice but to shut it down

The tanks at Red Hill were not meant to last forever. With thinning steel walls and no plan to update tank structure to ensure protection of our water, we are calling on the Navy to shut down the Red Hill facility and relocate the fuel away from the drinking water supply. Below you can see the six options the Navy considered.

 

Cutout from tank 14, showing corrosion on back side of steel tank liner. Photo by BWS.

Tank condition: Worse than anticipated

In 2018, the Navy conducted testing, mandated by the AOC, to verify their assumptions about how these unique fuel tanks have aged over the last 75 yearsThe preliminary findings are astonishingThe Navy predicted that there would be minimal corrosion and that the steel liner would have thinned from the original 0.25-inches to between 0.187-inches and 0.135-inches. However, half of the ten samples taken from tank 14 revealed extensive corrosion at the top and along the sides of the tank. Several samples indicate thinning more severe than predicted. One sample from the side of the tank was only 0.079-of-an-inch thick—less than a third of the width of the original quarter-inch steel lining. 

Protect Oʻahu’s water – sign our petition TODAY!

Honolulu City Council passes resolution supporting relocation of Red Hill tanks!

In March 2019 with a unanimous vote, the Honolulu City Council passed Resolution 18-266 CD1, urging the Hawaiʻi Department of Health and U.S. Environmental Protection Agency to reject the approval of any single wall tank upgrades and support the relocation of the Red Hill tanks in the case that secondary containment is not feasible. Over 75 testimony were submitted in support of the resolution. The Honolulu City Council is the first legislative body to publicly support the retirement of the World War II era tanks.

In November 2019, the Honolulu City Council reaffirmed its position by adopting Resolution 19-270 CD1.

In February 2018, the Sierra Club won their suit against the Hawaiʻi Department of Health—the court ruled that the exemption of the U.S. Navy’s Red Hill Fuel Tanks is a violation of state law. Read more here.

[READ THE COURT ORDER HERE]

Hawaiʻi’s Department of Health is responsible for regulating underground storage tanks and protecting our drinking water. State law specifically directs the Health Department to enact rules that require existing underground storage tanks be upgraded to prevent releases of petroleum into the environment. Their current regulations, however, do not ensure underground storage tanks are properly upgraded.

This suit comes after the Health Department continued to overlook the sense of urgency in mandating repairs to aging underground storage tanks. The Sierra Club previously delivered official notice to the Health Department that their regulations on underground storage tanks fail to comply with a 1992 state statute in May. The 1992 law states, “Existing underground storage tanks or existing tank systems shall be replaced or upgraded not later than December 22, 1998 to prevent releases for their operating life.” This requirement applies to all tanks storing hazardous material underground, including the U.S. Navy’s Red Hill Bulk Fuel Storage Facility.

Lawsuit Timeline

May 24, 2017  |  Sierra Club delivers official notice to the Hawaiʻi Department of Health
June 23, 2017  |  Department of Health responds to petition disagreeing with the Sierra Club’s reasoning for initiating an urgent rulemaking process
August 17, 2017  |  Sierra Club files suit against the Hawaiʻi Department of Health
September 5, 2017  |  Hawaiʻi Department of Health files a motion to dismiss
September 19, 2017  |  Sierra Club files response to Department of Health’s motion to dismiss
September 22, 2017  |  Hawaiʻi Department of Health replies to Sierra Club’s response
September 27, 2017  |  Hearing on the Department of Health’s motion to dismiss
December 2017  |  Judge Crabtree denies Department of Health’s motion to dismiss, lawsuit proceeds and court will evaluate state oversight of Red Hill Fuel Tanks
January 8, 2018  |  Sierra Club files motion for summary judgement
February 21, 2018  |  Hearing on Sierra Club’s motion for summary judgement
February 21, 2018  |  Judge Crabtree rules in favor of Sierra Club’s motion. Court finds that the state’s exemption of the Navy’s Red Hill fuel tanks violate state law

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