Red Hill Fuel Storage Facility Contingency Plan – August 2007


Red Hill Fuel Storage Facility Contingency Plan – August 2007

This is the executive Summary of the original Red Hill Fuel Storage Facility Contingency Plan submitted for approval in August 2007. The DoD agency that funded this project did not agree with the Independent Contractors assessment of the Leak Detection portion of this Report. Highlighted in red is the portion of the report that was excluded from the final submittal in Jan 2008. The contractor was also forced to change the name to Red Hill Bulk Fuel Storage Groundwater Protection Plan. The Independent Contractor could not believe that the Government would make them change their analysis. They were given an ultimatum that they would not be paid if they did not include the Government edited final report.

EXECUTIVE SUMMARY This Groundwater Protection Plan was developed to mitigate the risk associated with inadvertent releases of fuel from the United States (U.S.) Navy Red Hill Bulk Fuel Storage Facility, Oahu, Hawaii (the Facility). Previous environmental Site Investigations (SIs) at the Facility showed that past inadvertent releases have contaminated the fractured basalt, basal groundwater, and soil vapor beneath the Facility with petroleum hydrocarbons. In response to these findings, the State of Hawaii Department of Health (HDOH) requested that the U.S. Navy:

  • Conduct a detailed environmental SI at the Facility;
  • Develop a groundwater model of the surrounding aquifers to evaluate the risk associated with petroleum releases to the groundwater; and
  • Prepare a contingency plan to protect the U.S. Navy well 2254-01, which lies down gradient from the Facility and provides drinking water to the U.S. Navy Pearl Harbor Water System (PHWS).

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.

Both the Facility and the U.S. Navy well 2254-01 are critical to the mission of the U.S. Navy in the Pacific and there are no alternative facilities to replace them. This Groundwater Protection Plan presents a strategy for ensuring that both the Facility and the U.S. Navy well 2254-01 can continue to operate at optimum efficiency into the future. This Groundwater Protection Plan focuses on long-term mitigation. It is not an emergency response plan.

The Facility USTs are deferred from many of the Federal and State UST regulations, including the requirement for release detection, because they are field constructed bulk fuel tanks. However, following the notification of releases from the Facility, HDOH strongly recommended Final: Red Hill Bulk Fuel Storage Groundwater Protection Plan Executive Summary Date: January 2008 Page: ES-2 the installation of a leak detection system to protect U.S. Navy well 2254-01. Due to the importance of the groundwater resource, the U.S. Navy has evaluated methods to detect leaks at the Facility in the past. (and continues to do so. A final recommendation is expected in FY2008.)

From these evaluations it was concluded that many of the sensors required are currently used to provide inventory control; however, upgrades to the telemetry, analysis, and user interface systems would be necessary, at a minimum, to implement a certifiable leak detection system at the Facility. A study conducted by FISC Pearl Harbor developed the draft conceptual schematic to implement a complete Tank Integrity Management Program-Red Hill (TIMP-RH) at the Facility that would include leak detection. In accordance with this Contingency Plan, the U.S. Navy will use the TIMP-RH as a basis for a release detection program at the Facility to ensure that future releases are detected in a timely manner that is protective of the groundwater resource. The goal for implementation of TIMP-RH is to conduct pilot testing in FY2008, and full implementation of TIMP-RH in FY2010. The goal of the TIMP-RH will be 95 percent detection of leaks greater than 0.2 gallons per hour and 5 percent false positive results

In addition, the U.S. Navy has installed three groundwater monitoring wells within the lower access tunnel of the Facility and conducted a soil vapor monitoring pilot study under seven of the 18 active USTs. In accordance with this Groundwater Protection Plan, the U.S. Navy has implemented a groundwater monitoring program in which groundwater samples are collected quarterly from three groundwater monitoring wells installed in the Facility lower access tunnel and the U.S. Navy well 2254-01. Samples are analyzed for specific petroleum compounds and mixtures in accordance with the HDOH EALs (HDOH, 2005). The U.S. Navy will:

  • Maintain a complete database of chemical results from the groundwater sampling events;
  • Evaluate concentration trends for chemicals of concern over time, evaluate chemical concentrations with respect to HDOH drinking water EALs;
  • Monitor the groundwater for concentrations that may indicate that liquid fuel may be in direct contact with groundwater beneath the tanks; and
  • Submit concentration trend data and comparisons of sampling results to drinking water EALs to HDOH quarterly.

In groundwater model simulations, an extended light non-aqueous-phase liquid (LNAPL) fuel plume of jet propellant (JP-5 or JP-8) within 1,099 feet of the U.S. Navy well 2254-01 infiltration gallery resulted in benzene concentrations greater than the Federal maximum contaminant level (MCL) of 5 µg/L in the infiltration gallery. It was estimated that a release as small as 16,000 gallons of JP-5 near Tanks 1 or 2 could result in this condition. The groundwater monitoring program provides Site-Specific, Risk-Based Levels (SSRBLs) for total petroleum hydrocarbons (4.5 mg/L) and benzene (0.75 mg/L). These are used as indicators that LNAPL is present. In addition, this Groundwater Protection Plan provides a table of recommended responses to contaminant levels and trends in each of the four wells that are sampled quarterly. In accordance with this Groundwater Protection Plan, the U.S. Navy will implement a soil vapor monitoring program using the existing boreholes beneath each of the active tanks in the Facility to support leak detection and the groundwater monitoring program. Soil vapor monitoring beneath each tank can provide quick confirmation of potential leaks identified by the automatic system. This will potentially limit the size of a hypothetical fuel release, by shortening the confirmation and response time. Soil vapor will be analyzed for total volatile hydrocarbons (TVH) with calibrated field instruments, and data will be evaluated for changes in concentration which would indicate a release of fuel from the associated tank. Along with confirmation sampling at suspected leaking tanks on an as needed basis, the U.S. Navy will collect soil vapor samples from slant borings beneath each tank quarterly. These data will also be provided to Final: Red Hill Bulk Fuel Storage Groundwater Protection Plan Executive Summary Date: January 2008 Page: ES-3 HDOH quarterly. The U.S. Navy will maintain a complete database of SVMP results to evaluate trends. The U.S. Navy will continue to conduct a rigorous maintenance schedule for all USTs in the Facility in accordance with the modified American Petroleum Institute (API) 653. The U.S. Navy will provide the results of the API inspections and maintenance reports to HDOH with the quarterly reports associated with groundwater and soil vapor monitoring. Finally, the Groundwater Protection Plan provides an overview of actions that would be required to remediate the basal drinking water aquifer if a large release of fuel were to migrate to the water table. Well head treatment facilities at the U.S. Navy well 2254-01 may be required to ensure that adequate water is available to meet the U.S. Navy mission at Pearl Harbor. The U.S. Navy estimated $28,300,000 would be required for a granular activated carbon water purification plant for the U.S. Navy Waiawa well shaft. This system was proposed to remove low levels of agri-chemicals for a system with a maximum pumping capacity of 18 million gallons per day (mgd), and included a testing laboratory (see Appendix E). The U.S. Army estimated costs for an air stripping water purification facility in Schofield Barracks to remove low levels of trichloroethylene for a system with a maximum capacity of 4.3 mgd including capital costs and operations for 30 years at $3,990,000 (see Appendix E). Under site conditions, remediation of a large fuel release would be extremely costly and technically difficult, due to the underground nature of the Facility, the steep ridgeline upon which the Facility in located, the distance from ground surface to the aquifer (between 400 and 500 feet on the Red Hill ridgeline), and finally because of the complex hydrogeology associated with the fractured basalt aquifers. Pump and treat methods could be implemented but would be costly and inefficient in this environment. Multi-phased extraction may be more efficient, but very complex at the depths required. Down gradient enhanced bioremediation was considered through the addition of dissolved oxygen to the groundwater. An array of wells between the Facility and the potable water infiltration gallery would be required as oxygen distribution points to create a reactive permeable barrier to the transmission of dissolved petroleum compounds. Air sparging, while economical, is inefficient in saturating the groundwater to enhance bioremediation. Oxygen release compounds or gas infusion technology could be considered to increase the efficiency of the barrier by increasing the dissolved oxygen content of the groundwater and the radius of influence.

The Following Highlighted in Yellow Sections were left out of the Table of Contents of the approved Red Hill Bulk Fuel Storage Groundwater Protection Plan:

TOC Contingency Plan

TOC Contingency Plan p2

 

Since I was Project Manager, the contractor, TEC, sent me this personal note!

Contingency Plan note from Frustrated Contractor

 

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.

 

 

 

 

 

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