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The Administrativ e Order on Consent (AOC) Statement of Work ( SOW) should include an economic analysis that makes the case that there are no economical alternatives to replace the Red Hill fuel storage capacity. It should compare the construction along with a 50 year sustai nability cost of a new facility versus repair and sustainability of Red Hill.

Is t he DoD is exaggerating the impo rtance of fuel storage at RH? DoD needs to explain to the taxpayer why they would spend 100's of millions to upgrade a facility that is over 70 years old.

Based on the 22 year timeline suggested by the AOC program these tanks will be approaching

100 years old when these projects are complete

.

Reinforced concrete in Red Hill is ov er 70 yrs. o ld. A major problem is that there is evidence of cracking in the concrete. Example, Fuel was pouring out concrete cracks in Tank 5

. The fuel lab had a flask under the leak to collect samples for verification. S hafts for ventilation and tank exhaust systems have large chunks of concrete breaking out. Once there is a crack in the

concrete the rebar get s wet, rusts and expands, exasperating the situation.

Here is a statement from the Red Hill Bulk Fuel Storage Facility Final Groundwater Protection Plan approve d by DLA in Dec 2007: ” The Facility consists of 20 underground storage tanks (USTs), each with the capacity to hold 12.5 million gallons (Mgal) of petroleum

- based fuel as a reserve for the U.S. Navy Pacific Fleet. It was constructed in the field, entirely underground within the Red Hill Ridge for security and confidentiality reasons and was activated in 1943 to maintain the war effort. At the same time, the U.S. Navy well 2254

- 01 was installed approximately 3,000 feet down gradient from the Facility, and in cluded a water tunnel, known as an infiltration gallery, which extends across the water table to within 1,560 feet of the Facility. The U.S. Navy well 2254

- 01 currently provides approximately 24 percent of the potable water to the PHWS, which serves approx imately 52,200 military consumers. Model simulations of the measured contaminant concentrations beneath the Facility did not show contaminants entering the infiltration gallery at measurable concentrations. However, similar simulations showed hypothetical future releases of the jet propellant (JP

- 5 and JP

- 8) most commonly stored in the Facility USTs had the potential to contaminate the water that enters the infiltration gallery, if they are not identified quickly. In addition, the SI concluded that the agin g of the Facility will increase the possibility that such a release could occur as a result of leaks breaching both the steel liners
and concrete containment of the tanks. While the tank steel liners have been repaired, 

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**concrete containment cannot be m aintained.”** 

Red Hill is a “money pit”. The re was a study to repair the ventilation shaft by tanks 17 to 20. According to HAWAIIAN DREDGING it was too dangerous and thus would cost a fortune

because of the working around unstable concrete in a confined space. It will cost a fortune to rebuild the tank exhaust system to bring it into compliance with the Clean Air Act to control emissions from the evaporation of fuels

. Red Hill Fuel Tank Vent Vapors exhaust to atmosphere

. A significant amount of Greenhouse Gas emissions could be recaptured through a newly designed Vapor recovery system. The s ide benefit may be the quantification of fuellosses for part of the Leak Detection solution. Here are 2 picture s that help to make a case.

N eed to add that there is an underground vent system not shown on these illustrations that

connects these tanks . The UG vent s connecting the tanks are completely decayed with possible standing fuel if not monitored frequently.RH Tanks store 3 types of fuel:

F76 (Diesel)

– Used primarily for auxiliary equipment and ground transportation vehicles

JP5

– Primarily used by Navy Aircraft

– especially any aircraft that land on carriers.

JP8

– Primarily used by Air Force Aircraft

– DLA’s largest customer

DLA owns the fuel until there is a “Custody Transfer”

– they get funding through a surcharge when selling fuel to the military services

. In the case of Pearl Harbor, DLA pays the Navy to manage DLA fuel and funds most of the projects that “touch” DLA owned fuel. Primary Pacific trouble spots in the news media are North Korea and China (may be other high concerns that the public is not aware) Hawaii is approx. 4,700 miles to North Korea and 6,000 miles to China. DLA has many sites in South Korea, Japan, and Guam which are all much closer to the primary hot spots. Extra capacity could be built in one of these countries. The Philippines have already built extra capacity for fuel up to DLA specifications. In Hawaii, there is a pipeline fr om the refinery to Pearl Harbor and there is a pipeline from Pearl to Hickam. New tank capacity at Barber Point or Hickam would probably be more feasible than trying to repair this facility plus the costs of sustainability.

DoD needs to explain to the com mittee why there is no suitable location for construction of a new Fuel storage facility on one of their numerous Pacific installations in Hawaii, Japan, Korea, Guam, Alaska, Die go Garcia, Kwajalein, Okinawa, or even Wake Island !

DLA Support Points from DL A 2013 Fact Book

– Existing Fuel Storage LocationsApprox. 70 to 80 Defense Fuel Support Points in the Pacific Area of Responsibility:Refinery has pipelines to Pearl:50 Acres Looks like plenty of room to build new Tanks for Navy?

Hickam Par 3 looks like a great place to add some Bulk Storage JP8 Tanks?Looks like another possible location right by Pearl Harbor Upper Tank Farm

– tunnel goes under this area already with plenty of pipelines!

D on’t expect the Navy and DLA to follo w any of these suggestions, merely pointing out that within the millions of acres of military property in the Pacific there must be another strategic

economic solution.

Up this point, the committee’s internet posting indicate s a frustration with the Navy’s slow response to this topic. DLA has Preponderant User responsibility for Real properties used to support their fuel. What does this mean? DLA cannot own the Real Property but is responsible

for maintenance and repair. So the Military services have ownership of property and if they do

not know what they own, it makes it difficult for DLA to keep their database updated. Bottom line is they don’t really know everything that they have Preponderant User responsibility. They are

tr ying but have not complied with auditability standards.

Next major issue is OOS (Out

- of

- service) tanks with over 700 existing tanks in the Pacific . DLA cannot accurately tell you accurately what tanks are OOS in the Pacific AOR (Area of Responsibility). Th erefore they cannot accurately quantify active available fuel capacity in the Pacific. The average time in the Pacific AOR for NAVFAC to execute an OOS contract is 877 days

– this includes clean, inspect and repair. Red Hill tank average is 1079 days. You begin to see why this is such a hard question for the Navy to properly evaluate. If NAVFAC does not improve its processes 22 years will not be time enough to complete project.Here is backup data with suggested solutions to resolve the Tank Management Program (TMP) :

Ultimately, the storage of up to 187 million gallons of fuel, 100 feet above a drinking water resource, is inherently dangerous to the environment. DLA Inventory accuracy tolerance is

0.25%.

• This means that for Red Hill the Navy could lose .0025 x 187,000,000 = 476,500 gallons before having to report a NOV (Notice of Violation) to DLA Inventory personnel.

• Inventory Records from July 2007 to July 2010 with no NOV’s

• Total loss in dollars = $3,490,219

• Tot al loss in gallons = 1,184,654These are probably legitimate Inventory losses within the Red Hill System (not Leaks) but it is

an indication that something is very wrong with the Red Hill Inventory processes. At the very

least they should investigate gains or losses after a transfer, issue or receipt! Leak detection
software s hould be a part of this process but this is not solely a technology issues

– It is a MANAGEMENT Issue! The AOC is proposing to spend millions on technology but leak

detection nee ds a holistic approach with qualified subject matter experts monitoring a real

- time

solution. Remember that the existing AFHE worked as designed when filling Tank 5 by showing
numerous Unscheduled fuel Movements!Summary:

R eviewed the AOC proposed Statement of Work (SOW) and the list of 403 reference
documents used as references for this SOW. This report includes some data that was not available to the AOC committee Subject Matter Expe rts (SME)’s. Quite frankly, it is amazin g that the Navy did not share the SPAWAR report of 40,000 gallon lost after being emailed to so many employees ! It is imperative to quantify the amount of lost fuel in order to write a compre hensive
SOW. Inventory data was included in this report because t his is part of the Leak detection solution. The present SOW stresses technology as the leak detection solution. Because of the large quantities involved Pearl rarely losses enough to qualify for an official Notice of Violation ( NOV ) to DLA Inventory expert s. A comprehensive Leak Detection solution will be very costly.

Note: N ot proposi ng using the Asternet System, merely pointing out that there are several retired military Fuel Directors who depended on this system because a major

Fuel leak could be the end of their career!

Finally, trying to educate the committee and the Hawaiian community to realize that they need to question the importance of storing fuel in Red Hill. There are plenty of alternatives but it appears that the Navy wants to protect their jobs and Pearl Harbors historic importance versus looking for a better alternative for the citizens of Hawaii. It is well known among DLA Engineers that Red Hill has the highest yearly sustainment costs in all of DLA.