This document is protected under the Freedom of Information Act (FOIA). FOIA 5 

U.S.C. § 552, is a federal freedom of information law that allows for the full or partial 

disclosure of previously unreleased information and documents controlled by the United

States government. Access to information is a prerequisite for transparency and 

accountability of governments, as facilitating consumers' ability to make informed 

choices, and as safeguarding citizens against mismanagement and corruption

The Administrative 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 sustainability cost of a new facility versus repair and sustainability of Red Hill.

Is the DoD is exaggerating the importance of fuel storage at RH? DoD needs to explain to the 

taxpayer why they would spend100'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 over 70 yrs. old. 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. Shafts for ventilation and tank 

exhaust systems have large chunks of concrete breaking out. Once there is a crack in the 

concrete the rebar gets wet, rusts and expands, exasperating the situation.

Here is a statement from the Red Hill Bulk Fuel Storage Facility Final Groundwater Protection 

Plan approved 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 included 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 approximately 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 aging 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, the 

concrete containment cannot be maintained.”

Red Hill is a “money pit”. There 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 side benefit may be the quantification of fuel 
losses for part of the Leak Detection solution. Here are 2 pictures that help to make a case. 

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

connects these tanks. The UG vents 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 from 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 committee 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, Diego Garcia, Kwajalein, Okinawa, or even Wake Island!

DLA Support Points from DLA 2013 Fact Book – Existing Fuel Storage Locations
Approx. 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!

Don’t expect the Navy and DLA to follow 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 indicates 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 

trying 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). Therefore 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

• Total loss in gallons = 1,184,654
These 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 should 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 needs 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:

Reviewed 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 Experts (SME)’s. Quite frankly, it is amazing 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 comprehensive 

SOW. Inventory data was included in this report because this 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 experts. A comprehensive Leak Detection solution will be very costly.

Note: Not proposing 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.