Public comments are being accepted up to July 1, 2015.  You can send them to RedHill@epa.gov.  You can also go to http://health.hawaii.gov/shwb/ust-red-hill-project-mail/ or call Thu Perry at DOH Solid and Hazardous Waste Branch at 586-4226 for more information.

TESTIMONY OF SENATOR LAURA THIELEN

SUMMARY

The 20 Red Hill underground storage tanks are 72-75 years old and well beyond their original service life. Current repairs and inspections are inadequate to restore the aged tanks, as demonstrated by the recent spill of approximately 27,000 gallons of fuel which occurred immediately after a maintenance, repair and inspection of Tank 5.

These tanks sit a mere 100 feet above the major drinking water supply for the island of Oahu –serving one-quarter of urban Honolulu, from Moanalua to Hawaii Kai. They can hold a combined total of 250 million gallons of jet and marine diesel fuels – which contain chemicals harmful to human health and which do not readily degrade once they contaminate an environment.  Contamination of the aquifer would mean shutting down that water supply.

The proposed Administrative Order on Consent would give the Navy a minimum of 25 years to complete unspecified upgrades on the tanks – leaving 100-year old tanks still in operation.

It is only a matter of time before these tanks must be shut down and replaced. With all due respect, as the two departments which are charged with protecting human health and the environment, I ask that you make that time now.

Please amend the draft Administrative Order of Consent, and require the Navy and Defense Logistics Agency to embark upon a replacement schedule, with the new tanks meeting current underground storage tank regulatory design standards, within ten years.

 

The following information is from the draft Administrative Order on Consent, the attached Statement of Work and the December 2014 Report to the Legislature by the Red Hill Fuel Storage Facility Task Force.

BACKGROUND FACTS

The 20 Red Hill Fuel Tanks were built in 1940-1943, and are currently 72-75 years old.  Each tank stores up to 12.5 million gallons of fuel, for a combined total storage of 250 million gallons of fuel.  As of December 2014 only 15 tanks were in use (others being in stages of repair and inspection), storing over 180 million gallons of fuel.

Three types of fuel are stored in the Red Hill tanks, two kinds of jet fuel and marine diesel fuel. These fuels contain a broad, dynamic and heterogeneous mix of chemicals which are harmful to human health.  The rates at which these chemicals naturally degrade in the environment is highly variable.

The Red Hill Tanks are located 100 feet above one of the primary aquifers that serves Oahu’s drinking water supply. This aquifer provides fresh water to one-quarter of urban Honolulu – from Moanalua to Hawaii Kai.

If the aquifer were contaminated with this fuel, it could no longer be used to provide drinking water for Oahu. The Board of Water Supply would have to take extreme measures, including:

• Drawing water from other aquifers to service this area, thus spreading the impacts to all aquifers and residents across Oahu;
• Jeopardizing other aquifers by over pumping to meet the increased demand; and
• Damaging the riparian and near-shore ocean environment by requiring some water users to tap stream flows to service needs, thereby reducing the fresh water in streams and which reaches our oceans.

The Reports do not provide the original service life expectancy of the Red Hill tanks when they were built in 1940. However, they do state that the Navy opted to extend the service life of all or some of the tanks on at least three occasions since the 1940s:

• 1978, when the tanks were about 35 years old
• 1997, when the tanks were about 57 years old, and
• 2007, when the tanks were nearly 70 years old.

The Navy has stressed the amount of time and money it has spent on inspections, tests and repairs on these tanks over the past 75 years. However, despite these efforts, fuel has regularly leaked from these tanks.

“Navy studies and test reports show that the Red Hill tanks have a history of fuel releases dating back to 1947 and the presence of fuel contaminants in ground water and fractured rock beneath the tanks. Soil vapor and groundwater monitoring well data consistently show petroleum detections from 2005 to the present.

“Samples from Red Hill groundwater monitoring well 2 (RHMW02), located in the tunnel near tank 5 and tank 6, contain the highest levels of total petroleum hydrocarbons as diesel (TPH-d) at 12 to 50 times above the DOH environmental action levels.”

Red Hill Fuel Storage Facility Task Force Report, Appendix B.

While the Navy was aware of regular fuel leaks dating back to 1947, the Administrative Order on Consent states that the first report by the Navy to the State Department of Health of a release was in 1998, when petroleum-stained basalt cores were discovered beneath the tanks.  Over the early 2000s the Navy found petroleum stains in the basalt cores under 19 of the 20 tanks.

According to the Task Force Report (of which the Navy was a member), the Navy utilizes the best industry standards to inspect, repair and maintain the tanks.

“Since [1997] the Navy has implemented the most stringent tank inspection and repair practices consistent with the American Petroleum Institute’s (API) 653 standards that would apply to the Red Hill tanks. After each tank has been thoroughly inspected, improvements are completed to ensure the operability of the tank for an additional 20 years.”

At some point prior to December 2013 Tank 5 was taken out of service for one of these maintenance, repair and inspection services. In December 2013 Tank 5 was placed back into service and refilled.  In January 2014 the Navy discovered the loss of approximately 27,000 gallons of fuel from Tank 5.

That release is the event which triggered the US EPA and State DOH investigation and, subsequently, the draft Administrative Order of Consent.

PROPOSED ADMINISTRATIVE ORDER OF CONSENT

The US EPA and the State Department of Health have the authority to regulate underground storage tanks in order to protect drinking water, human health and the environment. This regulatory authority means either or both US EPA and State DOH can require the Navy to take steps to remediate past fuel releases, improve or replace the tanks or even to move the tanks from above the aquifer, and monitor for any future releases.

After lengthy negotiations, the draft Administrative Order on Consent proposes the following:

1. The Navy has at least 22 years to provide unspecified upgrades to the 20 tanks. The Navy can request an extension of time at any, or multiple points over this 22 years. The Navy can cease work or reduce the upgrades to the tanks if it determines it doesn’t have sufficient funds.
2. The Navy has at least 3 ½ years to develop some new method of testing the tanks, and then can begin implementation based on an unspecified schedule.
3. The Navy will test for metal fatigue and corrosion, but has nearly 3 years before it completes testing on one tank.
4. The Navy has nearly 3 years to investigate and report on the extent of the contamination from Tank 5, and then can start remediation based on an unspecified schedule.
5. The Navy has nearly 2 years to determine where to put new groundwater monitoring wells to check on the groundwater quality, and then can begin implementation based on an unspecified schedule.
6. The Navy has nearly 2 years to conduct a risk/vulnerability assessment on the Red Hill tanks.

CONCERNS

1. The Law of Diminishing Returns mean that repairs stop working at some point:

Stringent inspections and repairs of 75-year old 12.5 million gallon underground storage tanks don’t work.

Tank 5 underwent stringent repair and maintenance that was supposed to – according to the Navy – ensure its operability for an additional 20 years. Immediately after it passed inspection, it released 27,000 gallons of fuel.  It didn’t operate for even 20 days.

The tanks have been extended beyond their service lives three times over the past 75 years. The failure of Tank 5 immediately after an inspection demonstrates that the tanks have reached an age where their service lives can no longer be extended.

2. There are no other tanks in Hawaii like the Red Hill fuel tanks – every other operator has been brought up to modern standards.

According to the Department of Health, there are no other underground tanks in the state of Hawaii storing fuel that are this old.

The US adopted underground storage tank regulations in the 1980s to protect groundwater and human health. The Red Hill tanks didn’t meet the standards in the 1980s, and are well below current standards.  Every other operator of underground fuel tanks in Hawaii has been required to meet higher standards.

3. The Administrative Order of Consent does not once discuss the cost of the contamination of Oahu’s primary urban drinking water source.

A significant amount of consideration is given to the cost of upgrading the Red Hill tanks in various documents. Feasibility studies on upgrading the tanks were completed in 1998 and 2008, which presumably determined – from the Navy’s perspective – were not cost effective.

Nowhere, however, is there a cost analysis done or discussed regarding the cost of the contamination of the aquifer which provides one-quarter of urban Honolulu’s drinking water supply.

If that aquifer is contaminated with jet and/or marine diesel fuel, wouldn’t the cost of perpetual cleaning of any water withdrawn and/or switching to alternative water resources, including desalination, be greater than the cost of replacing the Red Hill tanks? Isn’t the federal government and US Navy better able to spread out the cost of replacing 20 storage tanks, than Oahu residents would be at handling perpetual costs of alternative drinking water?

4. Appreciation of and deference to the Navy for its service to our nation does not extend to turning a blind eye to the real potential of permanent contamination of Oahu’s drinking water supply.

The tanks have been leaking nearly their entire lifespan. Basalt rock cores under 19 of the 20 Red Hill tanks are contaminated with fuel.  Groundwater under the tanks is contaminated with fuel.

The draft Order proposes to allow these tanks to continue operation for at least another 22 years, beyond 100 years of age. While we don’t have the records of all the releases, it is safe to assume the leaks worsen as the tanks age.  The tanks are located only 100 feet above the aquifer.  Oahu’s aquifer is in real danger of being contaminated by fuel releases from the Red Hill tanks.

The only justification for this decision contained in the draft Order is that the Navy serves an important role in our nation’s defense system.

Yes, the Navy’s role is valued. But not to the point where we can ignore the inevitable contamination of our drinking water supply if these tanks are allowed to continue in operation another 25 or more years.

CONCLUSION

On behalf of the public health and safety and our environment, please amend the draft Administrative Order of Consent to require the Navy to replace the Red Hill fuel tanks with tanks that meet modern regulatory design standards within a ten year period. Any tank not upgraded or replaced within the timetable should be left out of service until it meets the standard.  Extensions of time should not be granted given the risk, and cost, of contamination of this aquifer.

Please also add a section that addresses the cost of contamination of the aquifer.