Red Hill Bulk Fuel Storage Facility - Frequently Asked Questions

Why did EPA and DOH negotiate an Administrative Order on Consent with the Navy?

As a result of the fuel release from Tank 5 at the Red Hill Bulk Fuel Storage Facility in January 

2014, EPA and the Hawaii Department of Health (DOH) brought an enforcement action against 

the Navy and Defense Logistics Agency (DLA) to address past fuel releases and minimize the 

likelihood of future releases. In general, a negotiated agreement such as an Administrative Order 

on Consent is appropriate, and the best enforcement tool to solve complex environmental 

problems since it allows for flexible and innovative solutions. The Administrative Order on 

Consent also goes beyond the scope of merely complying with the current regulations. The 

proposed Red Hill Administrative Order on Consent is structured to establish a process for 

collecting the necessary data and evaluating the optimal technical solutions to address past fuel 

releases and prevent future releases.

What if new information indicates that the Facility poses a much greater risk than current 

data suggest? 

The proposed Administrative Order on Consent is flexible and work requirements will be 

tailored to the findings from studies of the Facility and the surrounding environment conducted 

under the Administrative Order on Consent. In addition, the EPA and DOH each reserve their 

rights to take additional actions if they determine, together or separately, that the Administrative 

Order on Consent is not sufficiently protective. Existing regulations require the Navy and DLA

to respond immediately to any emergency situation encountered at the Facility.

Why will it take such a long time to implement tank improvements under the proposed Red 

Hill Administrative Order on Consent?

The primary goal of the proposed Administrative Order on Consent is to ensure the long-term 

protection of groundwater resources in the vicinity of the Facility. Implementing the right 

solution for Red Hill is a significant engineering challenge. It will require technologies and 

procedures specifically designed for the Facility. The initial phases of the proposed 

Administrative Order on Consent focus on accomplishing the extremely complex and critical 

work of evaluating, designing, and selecting cleanup specifics and upgrade technologies for the 

massive, uniquely engineered tanks, which are believed to be the largest underground fuel tanks

in the world. Implementing an effective long-term solution will take time to ensure its success. 

However, much work will also be conducted within the first two years of the Administrative 

Order on Consent to ensure that the Facility is operated safely while a long-term solution is 

implemented. The proposed schedule requires the Navy and the DLA to hit the ground running, 

submitting within 120 days multiple plans ranging from improving inspection protocols and 

assessing groundwater contamination risk to addressing cleanup methods and tank upgrade 

alternatives. In all, the Navy and DLA are to complete approximately 40 tasks within the first 

three years. EPA and DOH anticipate opportunities to accelerate the current tank upgrade 

schedule, and the agreement includes penalties for the Navy and DLA if current schedules are 

not met. Ultimately, tanks not upgraded by the end of the current schedule will have to be taken 

out of service.
Can a double wall be added to the tanks at the Facility now?

In order to ensure the successful operation of such a major upgrade, further studies of the 

existing tank structure and engineering feasibility studies are necessary. The size and structure of 

the tanks at the Facility are unique. If not designed and constructed properly, a tank retrofit 

could increase the risk of future fuel releases.

Is my drinking water safe?

Yes, the drinking water is safe for human consumption for both Board of Water Supply 

customers and military communities. The water for Board of Water Supply customers and 

military communities is being tested every three months to assure the water is safe.

Contamination related to the Red Hill Facility has never been detected in the Honolulu Board of 

Water Supply drinking water sources.

What is the likelihood of a future catastrophic release at the Facility?

A catastrophic release from the Facility into groundwater is very unlikely. The tanks are 

constructed in solid rock and consist of 2.5 to 4 feet thick reinforced concrete and a steel plate. 

Major earth movement that would rupture a Red Hill tank is highly unlikely due to the 

construction of the tanks and the relatively low earthquake threat on Oahu. The most likely 

catastrophic release scenario would be a piping failure with a release into the lower access 

tunnel. This vulnerability is being addressed by the Navy and DLA with the installation of oil 

tight doors in the tunnel system, along with a new fire suppression system to reduce the threat of 

a release caused by fire. Furthermore, the piping in the lower tunnel system is not buried or 

concealed and is visually inspected daily.

Has contamination for Red Hill been found in the groundwater beneath the facility?

Some contamination has been found in the groundwater immediately below the facility. To date, 

some of these groundwater samples have exceeded the DOH’s screening levels, but no samples 

have exceeded federal drinking water standards. The characteristics of the geology surrounding 

the tanks and depth to groundwater (approximately 100 feet) may be significantly limiting the 

vertical migration of contamination at the Facility.

Is Tank 5 still leaking? Tank 5 released approximately 27,000 gallons of fuel in January 

2014. 

No, Tank 5 is not leaking. It is currently not in service. Following the confirmation of a fuel 

release from Tank 5 in January 2014, the tank was emptied of all fuel and has not been refilled. 

Why did Tank 5 leak in January 2014?

The cause of the release from Tank 5 was poor repair procedures and workmanship during the 

Navy and DLA’s scheduled maintenance of the tank that concluded in December 2013. The EPA 

and DOH have hired fuel storage tank experts to help review the Navy and DLA’s procedures 

and practices in order to minimize the likelihood of such errors in the future.

Is the Facility in compliance with federal and state regulations?

Yes, the Red Hill Bulk Fuel Storage Facility is currently in compliance with state and federal 

regulations for underground storage tanks. We do not have evidence that the Facility was ever 

out of compliance, even at the time of the release from Tank 5.
Will the fuel already released from the Facility eventually contaminate the Board of Water 

Supply drinking water sources?

The migration of existing Facility contamination to the Board of Water Supply wells is unlikely.

The predominant direction of groundwater flow beneath the Facility does not appear to be 

towards the nearby Board of Water Supply Halawa Shaft or the Moanalua wells. Additionally, 

over time naturally occurring bacteria typically degrade subsurface petroleum into harmless 

byproducts.

If contamination does get to drinking water supply locations, will these supplies be 

unusable?

No, petroleum related contamination can be easily and reliably removed from water. In the 

unlikely event petroleum from the Facility reaches drinking water sources, technologies such as 

granular activated carbon can be used to remove contamination. Granular activated carbon is a 

widely utilized technology that has proven effective at removing organic contaminants such as 

petroleum from water. This technology is currently being used by the Board of Water Supply to 

remove pesticide-related contamination from water used for drinking water on Oahu. In the 

unlikely event that fuel from Red Hill reaches drinking water supplies, the Navy and DLA will 

be liable for the cost of any treatment required.

Can fuel released from the Facility be easily found and removed from the subsurface?

Unfortunately, locating and removing fuel released from the Facility will likely be difficult. The 

fractured basalt rock geology surrounding the tanks at the Facility is one of the most difficult 

settings to conduct environmental assessments and cleanup. The rock is difficult to drill into and 

contamination often flows in hard to find fractures in the rock. In some cases the rock traps the 

contamination and drilling a well through that location can worsen the problem by allowing 

contamination to spread from the areas where it is trapped in the rock. EPA and DOH are 

currently working with experts with experience in fractured basalt geology to identify 

technologies that may be able to locate and remove or destroy contamination.

EPA just published new regulations that apply to the Red Hill tanks. What changes will 

these new federal regulations require?

On July 15, 2015, EPA finalized revisions to the underground storage tanks regulations that 

change the regulatory requirements for tanks such as those at Red Hill, known as “field 

constructed tanks.” The regulations include new requirements for leak detection, operator 

training, inspections, and testing of spill prevention equipment. EPA and DOH are currently 

evaluating the Navy’s leak detection systems, which may already meet the new federal 

requirements.

The new regulations do not require installation of secondary containment at the Red Hill Facility.

Secondary containment is only required for new tank systems. Metal corrosion control known as 

cathodic protection is required under the new regulations in certain circumstances. Because the 

Red Hill tanks are encased in concrete, cathodic protection is not required or effective at 

reducing corrosion of the Red Hill tanks.
Since Hawaii has a federally-approved underground storage tanks program, the new regulations 

will take effect when Hawaii changes their rules. Hawaii has up to three years to make the 

needed changes.

Is the Red Hill Facility inspected?

Yes, the Navy conducts inspections of the Red Hill facility regularly. EPA and DOH with the 

assistance of fuel storage tank experts are currently working on developing robust inspection 

procedures for the Facility. New inspections of the Facility by EPA and DOH are expected to 

begin in the near future.

What is Board of Water Supply’s role in addressing fuel releases from the Facility?

Board of Water Supply manages Oahu's municipal water resources and distribution system and is 

responsible for providing clean and safe drinking water to its customers. The Board of Water 

Supply is a key stakeholder for work under the Administrative Order on Consent and is listed in 

the Administrative Order on Consent as a subject matter expert whose technical advice will be 

routinely sought during implementation of work under the Administrative Order on Consent.

DOH is responsible for overseeing drinking water quality and is the agency with expertise in 

issues related to regulation of fuel storage, environmental assessment and cleanup within the 

State. EPA is working in partnership with DOH to address issues related to the Facility. Both 

DOH and EPA have regulatory authority to ensure protection of drinking water resources.

Where can I find more information on the Facility and the proposed Administrative Order 

on Consent?

More information on the Facility and the proposed Administrative Order on Consent, including 

contact information, can be found at http://www.epa.gov/region9/waste/ust/redhill/index.html or 

http://health.hawaii.gov/shwb/ust-red-hill-project-main/. If you would like to receive notices and 

other information regarding the proposed Red Hill Administrative Order on Consent, you can 

join our e-mail distribution list by submitting a form at http://www2.epa.gov/region-9-

documents/forms/red-hill-aoc-public-distribution-list.