Comment on the 

Administrative Order on Consent In the Matter of Red Hill Bulk Fuel Storage Facility 

EPA Docket No: RCRA 7003-R9-2015-01, DOH Docket No: 15-UST-EA-01 

I would like to see the current version of the AOC renegotiated. The current version should not be signed 

by EPA and DOH. 

The threat to Oahu’s drinking water from these tanks leaking is imminent. The tanks are over 70 years 

old, and neither steel nor concrete will last forever. 

The Navy has reported leaks dating back to 1998. Just last year, Tank 5 leaked a significant amount of 

fuel (27,000 gl) due to a hole in the quarter-inch steel liner. Immediate action should be taken to upgrade 

the tanks in order to prevent any further leaks. 

I do not propose shutting down and emptying all the tanks now, as that would create major problems for 

the Navy. But the timelines in this version of the AOC Statement of Work do not show a sense of 

urgency to mitigate the dangers of these old tanks. 

20 years is too long to finish upgrading all of the 20 (18 active) tanks. Mechanical failure and/or 

geological events such as earthquakes, could cause the tanks to rupture. Human error could cause the 

tanks to overflow. 

The timeline for upgrading the tanks should be changed to 5 or 6 years. It would not significantly affect 

the activities of JBPHH if the Navy took 4 or 5 tanks a year off-line and upgraded them. This would 

allow the remaining tanks to still be used. 

Also, rather than taking 2 years to develop a Tank Upgrade Alternative report, use the recommendations 

in the 2008 study. Adding another layer inside the tanks, rather than outside the existing steel, would be 

less costly and much quicker than removing the existing steel liner. 

If an existing tank were to leak or rupture and contaminate the groundwater found 100 feet below the 

tanks, Oahu would face a severe water shortage. As the Board of Water Supply states, the Navy’s Red 

Hill Shaft would be shut down. JBPHH would not have any water and that would jeopardize their 

mission as well as “national security”. 

All parties to the AOC need to realize that the people of Oahu will blame them for contaminating their 

drinking water. This may likely cause unrest amongst the local population. One needs only look at the 

current events happening at the Mauna Kea observatory to see what could happen to the Navy here. 

Both EPA and DOH have the authority to enforce immediate action by the Navy to address current 

contamination and shut down or upgrade the tanks, but instead, the agencies have chosen to work with the 

Navy to correct this problem over time. However, I feel that the proposed timeframe in this AOC is 

entirely too long. Too much can happen in 20 years. Be safe. Once the groundwater is contaminated, it 

is too late to fix anything. Thus I urge EPA and DOH to reject and/or renegotiate the AOC, shortening 

the timeframes for upgrading the tanks. 

Sincerely, 
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Change the following verbiage in Paragraph 2 of the Introduction in Attachment A, Statement of Work: 

The major components of the Work under this SOW are summarized below. 

 

(1) Navy and DLA will improve upon their existing tank inspection and repair process to ensure 

that the tank infrastructure prevents releases of fuel. 

(2) Navy and DLA will undertake a comprehensive study to investigate the feasibility of 

upgrading the tank structures including, but not limited to, installing secondary containment. 

This study will evaluate several technologies, building on similar efforts conducted by Navy 

in 1998 and 2008. After completing the study, a technology or technologies will be approved 

by DOH and EPA (“the Regulatory Agencies”) and implemented by Navy and DLA. 

Implementation will occur in phases so that all Tanks in operation will deploy BAPT, as 

approved by the Regulatory Agencies, within five (5) years of the effective date of the AOC 

or as otherwise provided for in the AOC or this SOW. 

Then change the verbiage and timeline in Sections 3 to meet the new deadline of 5 years.