1

Shalev, Omer

From: Linder, Steven

Sent: Wednesday, September 16, 2015 1:14 PM

To: Shalev, Omer; Pallarino, Bob

Subject: Fw: RED HILL AOC/SOW 22-YEAR TIMELINE

Steven Linder, P.E. 

Underground Storage tanks Program Manager US EPA Region 9 

415-972-3369 

________________________________________ 

From: Vogel, Burr M CDR NAVFAC HI, OP <burr.m.vogel@navy.mil>

Sent: Wednesday, September 16, 2015 12:53 PM 

To: steven.chang@doh.hawaii.gov

Cc: stuart.yamada@doh.hawaii.gov; Linder, Steven; Huetteman, Tom; Vogel, Burr M CDR NAVFAC HI, OP; Smith, Danae ; 

Daugherty, Steven A CIV NAVFAC Pacific, 09C; Miyamoto, James A CIV NAVFAC HI, DOP; Manfredi, Mark S CAPT CNRH, 

N04; Hommon, Rebecca M CIV CNRH, N00L; Doughty, Bill CIV CNRH, N00; Tufts, Dean A CAPT NAVFAC HI, 00 

Subject: RED HILL AOC/SOW 22-YEAR TIMELINE 

[Sending on behalf of CAPT Tufts] 

Steven - 

As promised, here is our input to help EPA/DOH answer the question of "why a 22-year timeline in the AOC/SOW". As 

we discussed last week, I recommend EPA/DOH edit this as you see fit, and include it on EPA's FAQs. 

Thanks. V/R, Dean 

=============================== 

Q: Why a 22-year timeline in the AOC/SOW? 

A: We estimate it will take, at a minimum, four years to begin construction on the first AOC-driven tank upgrade. 

Because of the unique nature and size of these tanks, there is no "off-the-shelf" solution. Different subject matter 

experts will likely have differing views on which technologies can be safely adapted to the Red Hill Facility, and which of 

those technologies is the best choice. Any project funding will likely require congressional authorization via the military 

construction (MILCON) appropriations. We anticipate that it will take 18-24 months to determine and approve a Best 

Available Practicable Technology (BAPT) through EPA/DOH, and then at least two additional years for funding, design, 

contracting, and background checks for workers. 

The magnitude and challenge of construction within a Red Hill tank is not easily communicated. Each tank is 250' tall 

and 100' in diameter (Aloha Tower could fit inside any one of the tanks), and located deep inside solid basalt rock only 

accessible through a narrow tunnel. If construction equipment, materials, or power for any new BAPT cannot be 

provided through the narrow tunnel and tank hatch, we will have to find other means to create a bigger opening 

through the top of each tank which will add layers of complexity to the solution. 
2

In order to upgrade the 18 active tanks in the following 18 years (in order to make the 22-year timeline), the Navy will 

have to complete one tank per year. A maximum of three tanks can be taken down for upgrades at once in order 

maintain operational capability, so each of the three tanks must be completed and returned to service in three years. 

Executing our current clean, inspect, repair cycle (modified-API 653 inspection/repair), without including future BAPT 

possibilities, is taking up to four years for every three tanks. We are concerned that future BAPT tank upgrades could 

require 5 years or more to safely complete the work. Because we are committed to the 22-year timeline, we are actively 

exploring ways to expedite all steps of the scoping, funding, permitting, contracting, design, and construction process. 

Success will require full collaboration and commitment from all stakeholders (including regulators) to ensure no delays. 

Significant challenges to accomplish this timeline include: 

* Initial requirement to upgrade electrical power 

* Environmental permitting 

* Coordination with ongoing Red Hill operations and tank maintenance 

* Security and access issues 

* Potential movement of vast amounts of steel and concrete (or other material) 

* Limited on-site storage space for materials and equipment 

* Statutory limits and requirements for specific Congressional appropriations for "military construction" 

Upgrading all tanks within 22 years will certainly require overlapping of tank acceptance and filling operations, with the 

early stages of the next phase of tank improvements, which in turn will require more than 3 tanks would be out of 

service, requiring a waiver approval by senior operational commanders. Compressing the timeline to any less than 22 

years would require even greater project overlap (and greater construction and operational risk) and would require 

periods where as many as 5 tanks would have to be out of service at once. Not only is this operationally untenable, but 

coordinating work in five tanks at once in the limited space available within Red Hill would be extremely challenging, if 

not impossible. 

================================ 

CAPT Dean Tufts 

Commanding Officer, NAVFAC Hawaii 

Regional Engineer (N4), Navy Region Hawaii 

(w) 808-471-3926; (c) 808-375-3792 

dean.tufts@navy.mil

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