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.”
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Department of Health proposes changes to weaken 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.
No automatic approval for Navy’s Red Hill tanks
The previous version of the Health Department’s rules also directed that all underground storage permits be automatically approved if no action was taken by the Department within 180 days after a permit application is submitted. Automatic approval of operating permits is problematic because it undermines a robust permit review process, which is fundamental to state agencies fulfilling their responsibility to protect the public. It is unacceptable that a permit to operate something as dangerous as the antiquated Red Hill tanks could be issued without a full review of the permit conditions or the risks posed by these high-risk storage tanks.
In November, the Sierra Club filed suit to prevent the automatic approval of the Red Hill tanks. In January 2020, the Health Department amended its rules to prevent the automatic approval of underground storage tank permit applications. This means the Navy’s permit application to the Health Department for the Red Hill tanks will not be automatically approved.
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.
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.
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.
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 years. The preliminary findings are astonishing. The 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.
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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.
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.
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
- Column: Military can’t delay on Red Hill fuel tanks, Honolulu Star-Advertiser, December 15, 2019
- David Shapiro: Enough lollygagging on upgrading old Red Hill fuel tanks, Honolulu Star-Advertiser, December 8, 2019
- Health Officials OK With 2045 Deadline For Red Hill But Many Call For Action Sooner, Hawaiʻi Public Radio, December 3, 2019
- Critics still not appeased by state’s proposed changes for Red Hill fuel tanks, Hawaiʻi News Now, December 2, 2019
- Editorial: No more delays on Red Hill tanks, Honolulu Star-Advertiser, December 2, 2019
- Community Calls For Red Hill Tanks To Be Moved Now, Hawaiʻi Public Radio, November 20, 2019
- Navy says their plan to reduce risk from Red Hill fuel tanks will take some time, Hawaiʻi News Now, November 20, 2019
- Public input sought on fix for Red Hill fuel tanks above aquifer, KHON, November 18, 2019
- Sierra Club Sues To Stop Automatic Approval Of Red Hill Fuel Tanks, Civil Beat, November 7, 2019
- Navy’s Proposed Fuel Tank Upgrades Get Cold Reception, Health Officials Seek Tougher Standards, Hawaiʻi Public Radio, October 29, 2019
- Honolulu committee rejects Navy’s fuel tank upgrade proposal, Hawaiʻi News Now, October 25, 2019
- Council resolution advises rejection of Navy’s proposal for Red Hill tanks, Honolulu Star-Advertiser, October 24, 2019
- Editorial: Don’t stall on Red Hill fuel tanks, Honolulu Star-Advertiser, October 19, 2019
- Navy Resists Calls To Relocate Or Strengthen Red Hill Fuel Tanks, Civil Beat, October 18, 2019
- Navy eyes new 2045 deadline for Red Hill tank improvements, Honolulu Star-Advertiser, October 18, 2019
- Navy’s Proposal To Upgrade Red Hill Fuel Tanks Drawing Opposition, Hawaiʻi Public Radio, October 15, 2019
- Worried about ‘catastrophic’ spill, state wants U.S. Navy to move its Red Hill fuel tanks, Hawaiʻi News Now, April 12, 2019
- Health director wants Navy to move Red Hill fuel tanks, Honolulu Star-Advertiser, April 12, 2019
- Red Hill Fuel Storage, KITV, April 11, 2019
- Name in the News: Bruce Anderson, Honolulu Star-Advertiser, March 29, 2019
- Council calls on regulators to better protect against Red Hill fuel tank leaks, Hawaiʻi News Now, March 9, 2019
- Editorial: Be vigilant about Navy fuel tanks, Honolulu Star-Advertiser, March 4, 2019
- Council committee OKs Red Hill resolution, Honolulu Star-Advertiser, February 28, 2019
- Council committee set to vote on Red Hill resolution, Honolulu Star-Advertiser, February 27, 2019
- Fuel tank tests back assessments, says Navy, Honolulu Star-Advertiser, February 26, 2019
- Navy lab data to be assessed for potential corrosion in Red Hill fuel tanks, Hawaiʻi News Now, February 26, 2019
- Navy seeks to reassure water is safe from tanks at Red Hill, Honolulu Star-Advertiser, November 2, 2018
- Red Hill Fuel Storage Facility Update, Hawaiʻi Public Radio, November 1, 2018
- Navy points finger of Red Hill fuel on human error, community uneasy over future problems, KITV, November 1, 2018
- BWS balks at study that says sizable leak of Red Hill fuel tank wouldn’t harm water supply, Hawaiʻi News Now, October 31, 2018
- Navy Responds to Concerns Over Red Hill, Hawaiʻi Public Radio, October 2, 2018
- Officials to give updates on aging Red Hill tanks, Honolulu Star-Advertiser, September 30, 2018
- Red Hill fuel tank corrosion worse than expected, Honolulu Star-Advertiser, September 26, 2018
- Upon closer inspection, corrosion may be eating away at Red Hill storage tanks, Hawaiʻi News Now, September 24, 2018
- U.S. Navy Favors Lowest-Cost Fix for Red Hill Fuel Tanks, September 11, 2018
- Navy plan for Red Hill tanks in question, Honolulu Star-Advertiser, September 10, 2018
- Sierra Club criticizes state Health Department proposal for Red Hill fuel tanks, Honolulu Star-Advertiser, June 4, 2018
- My Tour Of The Red Hill Fuel Facility That Threatens Oahu’s Water, Community Voices by Colleen Soares, Civil Beat, May 24, 2018
- Legislature Pondering Red Hill Fuel Storage Tank Upgrades, Hawaiʻi Public Radio, March 20, 2018
- Safety measures for fuel tanks could take billions — and decades, Navy says, Honolulu Star-Advertiser, March 19, 2018
- Bill pushes for tank upgrades at Red Hill to prevent fuel leaks, Honolulu Star-Advertiser, March 14, 2018
- Navy’s Red Hill Analysis Concerns Environmental Regulators, Associated Press, March 13, 2018
- Judge Rules in Red Hill lawsuit, Hawaiʻi Public Radio, March 8, 2018
- Red Hill fuel ruling must quicken fixes, Honolulu Star-Advertiser, February 26, 2018
- Judge: State’s exemption to Navy for fuel tanks violated law, US News, February 22, 2018
- Judge sides with Sierra Club on Red Hill tanks, Honolulu Star-Advertiser, February 22, 2018
- State rules for Sierra Club in lawsuit over aging military fuel tanks, Hawaiʻi News Now, February 21, 2018
- Dismissal of suit over Red Hill fuel tanks sought, Honolulu Star-Advertiser, September 28, 2017
- Threat of Red Hill fuel spill ignored, Editorial by Colleen Soares, September 27, 2017
- Lawsuit Seeks Stronger Rules for Hawaii Fuel Storage Tanks, Associated Press, September 27, 2017
- Arguments will be heard in lawsuit over Red Hill storage tanks, Hawaiʻi News Now, September 27, 2017
- Group Sues Over Leaky Tanks, Honolulu Star-Advertiser, August 22, 2017
- Lawsuit: Hawaii Fails To Ensure Safety Of Underground Tanks, Civil Beat, August 23, 2017
- Lawsuit takes on Red Hill fuel tanks, Honolulu Star-Advertiser, August 23, 2017
- Sierra Club suing DOH over underground storage tanks, Hawaiʻi News Now, August 23, 2017
- Threat To Drinking Water Remains As Navy Studies Options For Fuel Tanks, Civil Beat, July 13, 2017
- Speed up work on Red Hill tanks, Honolulu Star-Advertiser, June 29, 2017
- Navy dodged queries at Red Hill meeting, Letter to the Editor by Joshua Noga, Honolulu Star-Advertiser, June 27, 2017
- Navy didn’t answer Red Hill questions, Letter to the Editor by Nate Yuen, Honolulu Star-Advertiser, June 26, 2017
- Red Hill Cocktail Hour: Mixing War Fuel with Water, ThinkTech Hawaiʻi, June 23, 2017
- Beneath Red Hill, Flux Hawaiʻi Magazine, June 22, 2017
- Public meeting will give update on Red Hill fuel tanks, Honolulu Star-Advertiser, June 22, 2017
- Old Law Could Lead to New Development in Red Hill Fuel Tank Saga, Hawaiʻi Public Radio, June 5, 2017
- Red Hill tanks need swift remedy, Honolulu Star-Advertiser, May 27, 2017
- Sierra Club presses for upgrade of Navy fuel tanks at Red Hill, Honolulu Star-Advertiser, May 25, 2017
- Lawmakers advance bill to speed up improvements at Red Hill fuel facility, Hawaiʻi News Now, February 8, 2017
- Red Hill has “high potential for catastrophic environmental loss”, The Hawaiʻi Independent, October 6, 2016
- EPA: Fuel from Red Hill leak probably won’t reach drinking water, Hawaiʻi News Now, October 6, 2016
- EPA, state reject Navy’s plan to deal with Red Hill fuel spills, KITV, October 3, 2016
- Huge Navy fuel tanks worry Hawaiʻi farmers, utility officials, Associated Press, August 4, 2016
- Flint-ing with Disaster, ThinkTech Hawaiʻi, April 8, 2016
- Navy’s Insistence on Red Hill Fuel Tank Secrecy Raises Alarms, Civil Beat, January 28, 2016
- Red Hill fuel spill poses threat to water supply, officials conclude, Hawaiʻi News Now, October 30, 2015
- Navy, EPA, state outline steps to upgrade Red Hill fuel storage facility, KHON, October 1, 2015
- EPA Posts Information on Red Hill Fuel Storage, Hawaiʻi Public Radio, August 27, 2015
- Navy, State Reach Deal on Red Hill Fuel Storage Site, Hawaiʻi Public Radio, June 2, 2015
- More tiny holes found in leaking Red Hill fuel storage tank, Honolulu Star-Advertiser, June 22, 2014
- In aftermath of Red Hill fuel leak, tests find drinking water still safe, Honolulu Star-Advertiser, January 21, 2014
- Navy investigates possible fuel leak at Red Hill, Hawaiʻi News Now, January 15, 2014
- Sierra Club of Hawaiʻi Red Hill Water Security Fact Sheet
- EPA and DOH Letter Regarding the U.S. Navy’s Tank Upgrade Alternative Considerations (March 2018)
- EPA and DOH Letter of Disapproval of U.S. Navy Red Hill Groundwater Flow Studies (February 2018)
- EPA and DOH Letter of Disapproval of U.S. Navy Red Hill Data Summary and Data Gap Analysis (June 2017)
- EPA and DOH Letter of Disapproval of U.S. Navy Red Hill Scope of Work (September 2016)
- Honolulu Board of Water Supply: Red Hill Community Page
- U.S. Navy Historical Data of Tank Releases
- U.S. Navy Red Hill Bulk Fuel Storage Facility Groundwater Protection Plan
- Environmental Protection Agency: Red Hill Bulk Fuel Storage Facility
- Environmental Protection Agency: Underground Storage Tank Systems