2015 Red Hill AOC: Corrosion and Metal Fatigue Practices

The tanks at Red Hill are constructed of concrete with an internal lining of steel ranging in thickness from 1/4 inch to 1/2 inch. Each tank lining consists of hundreds of steel plates, connected by thousands of feet of welds. The steel lining was originally installed at the time of the tanks' construction in the early 1940s. Evaluating the condition of these plates is critical in determining the tanks’ ability to store fuel. The condition of the existing steel is also important in determining the suitability of various tank upgrade alternatives.

To date the Navy and Defense Logistics Agency have submitted several reports and plans required by the 2015 Red Hill Administrative Order on Consent regarding the condition of the tanks’ steel liners. The Corrosion and Metal Fatigue Practices Report, submitted in April 2016, describes the Navy’s current practices for assessing the condition of the steel used in the tanks and associated fuel containment infrastructure.

Destructive Testing Results Report and Joint Regulatory Agency Response

In June 2018, small samples of steel and concrete were physically removed from one of the Red Hill tanks (Tank #14) to determine whether the tank maintenance program can accurately predict the presence of corrosion before repairing tanks and bringing them back into service. These samples were visually inspected and then sent to a laboratory for more thorough analysis. The results of this exercise are available in the Navy’s Destructive Testing Results Report which is available for viewing below.

The Regulatory Agencies disapproved the Destructive Testing Results Report because EPA and Hawai'i Department of Health (DOH) do not concur with the finding that the destructive testing validated the non-destructive testing (NDE) process specific to the Red Hill tanks.

The Regulatory Agencies required the Navy to conduct further evaluation and improvements to the tank inspection process. In response, the Navy’s submitted a revised Execution Plan that describes a suite of corrosion and tank integrity-related studies that will lead to recommended improvements to the Red Hill tank inspection, repair and maintenance procedures. For details, please see the reports and correspondence below.

Documents

• Section 5.4 Execution Plan: Decision on Need for and Scope of Modified Corrosion and Metal Fatigue Practices Amendment #1 (REDACTED) (pdf) (14.54 MB, August 18, 2021)
  Navy submittal dated August 18, 2021 in response to EPA and Hawai'i DOH May 2021 request for revised or supplemental scope of work.
• Regulatory Agencies Response to Navy's December 4, 2020 Execution Plan (pdf) (931.04 KB, May 10, 2021)
  Regulatory Agencies letter dated May 10, 2021 responding to Section 5.4 execution plan for additional studies related to corrosion and metal fatigue practices.
• Section 5.4 Execution Plan: Decision on Need for and Scope of Modified Corrosion and Metal Fatigue Practices (REDACTED) (pdf) (9.11 MB, December 4, 2020)
  Navy submittal describing additional work to be performed to aid in identification of improvements to corrosion and metal fatigue practices.
• Regulatory Agencies Response to Navy's June 2, 2020 Letter (pdf) (624.26 KB, July 7, 2020)
  Regulatory Agency Response to Navy Letter Acknowledging Agency Disapproval of the Navy's Corrosion and Metal Fatigue Practices, Destructive Testing Results Report, Red Hill Bulk Fuel Storage Facility (Red Hill), Joint Base Pearl Harbor-Hickam, Oʻahu, Hawai'i.
• Navy's Response to Regulatory Agencies Disapproval of March 16, 2020. (pdf) (75.79 KB, June 2, 2020)
  Navy's Response to Regulatory Agencies Disapproval of Corrosion and Metal Fatigue Practices, Destructive Testing Report.
• Joint Regulatory Agency Response to Corrosion and Metal Fatigue Practices, Destructive Testing Results Report (pdf) (13.51 MB, March 16, 2020)
  EPA and Hawai'i DOH Response to the Navy’s Destructive Testing Results Report for the Red Hill Bulk Fuel Storage Facility, Joint Base Pearl Harbor-Hickam, Oʻahu, Hawai.
• Destructive Testing Results Report (pdf) (45.87 MB, 07/07/2019)
  Results from the Navy’s destructive work inside Tank 14 and an interpretation of results.
• Revised Conditional Approval of Destructive Testing SOW - August 2017 (pdf) (2.85 MB, 08/10/2017)
  Revised conditional approval by EPA and DOH of Destructive Testing Scope of Work.
• Red Hill Destructive Testing Scope of Work (pdf) (600.32 KB, 05/30/2017)
  Plan to conduct destructive testing at the Red Hill Facility. May 30, 2017
• Additional Documents