Inspections and Enforcement

Red Hill Bulk Fuel Storage Facility Tour - Source USN

On this page:

Background
Inspections and Investigations
Enforcement Actions
Documents, Correspondence, Reports and Data

Background

As a result of the November 2021 fuel release, 2022 Aqueous Film Forming Foam (AFFF) release, and subsequent drinking water complaints, EPA has conducted several inspections and investigations to assess compliance at the Red Hill Bulk Fuel Storage Facility and nearby Joint Base Pearl Harbor-Hickam (JBPHH) Drinking Water System.

Based on the agency’s findings, EPA entered into an Administrative Consent Order in 2023 with the Navy and Defense Logistics Agency (DLA).

Inspections and Investigations

Defueling Completion Inspections

During the week of March 5, 2024, EPA conducted an inspection and evaluation of the Red Hill Bulk Fuel Storage Facility to confirm that the overwhelming majority of fuel had been removed from the facility consistent with assertions made by Joint Task Force-Red Hill and assess operations and environmental compliance at the facility at the time of transition to Navy Closure Task Force.

EPA sent a letter determination on March 21, 2024, to Joint Task Force-Red Hill (JTF-RH) that they had met all eleven exit criteria listed in Defueling Plan Supplement 3. The final Defueling Inspection Report is available below.

In the time between this inspection and the generation of the inspection report, authority over the RHBFSF has been transferred from Joint Task Force-Red Hill (JTF-RH) to Navy Closure Task Force – Red Hill (NCTF-RH).

Final Report: Red Hill Bulk Fuel Storage Facility Interim Defueling Completion Inspection (pdf) (4.61 MB, June 18, 2024)
[REDACTED] Final Interim Defueling Completion Inspection Report for Red Hill Bulk Fuel Storage Facility (RHBFSF) evaluating the status of the facility following completion of primary defueling operations conducted by Joint Task Force-Red Hill (JTF-RH).
EPA Letter to Joint Task Force-Red Hill: Exit Criteria Complete (pdf) (196.09 KB, March 21, 2024)
EPA letter to Joint Task Force-Red Hill (JTF-RH) with determination that they had met all eleven exit criteria listed in Defueling Plan Supplement 3.
EPA Letter to Joint Task Force-Red Hill: Interim Defueling Inspection Preliminary RFI (pdf) (201.18 KB, March 18, 2024)
Preliminary Request for Information Regarding the Interim Defueling Completion Inspection.

Spill Prevention and Underground Storage Inspections

EPA conducted Compliance Evaluation Inspections (CEIs) at the JBPHH from February 28 – March 4, 2022. The purpose of the inspections was to evaluate the United States Department of the Navy’s (the Navy’s) compliance with the Oil Pollution Prevention (OPP) Regulations, including Spill Prevention, Control and Countermeasure (SPCC) requirements under Section 311 of the Clean Water Act, and Hawaii’s approved Underground Storage Tank (UST) regulations pursuant to Subtitle I of the Resource Conservation and Recovery Act (RCRA). Review the findings of these reports at Joint Base Pearl Harbor Hickam Compliance Evaluation Inspections.

Drinking Water System Compliance

EPA has conducted several inspections of the Navy’s JBPHH and the U.S. Army’s Aliamanu Military Reservation (AMR) drinking water system as well as multiple complaint investigations from resident complaints. Review these inspections and investigations at Drinking Water System Compliance at Joint Base Pearl Harbor-Hickam.

AFFF Release Investigation

On November 29, 2022, the EPA was notified of a hazardous material release incident involving the release of Aqueous Film Forming Foam (AFFF) concentrate within the Red Hill Bulk Fuel Storage Facility and in the surrounding environment. EPA conducted an investigation of the release, available here at Fire Suppressant (“AFFF”) Spill.

Enforcement Actions

2023 Administrative Consent Order

On June 2, 2023, EPA finalized and signed the 2023 Administrative Consent Order (Consent Order) with the U.S. Department of the Navy (Navy) and the Defense Logistics Agency (DLA) that requires steps to ensure the safe defueling and closure of the Red Hill Bulk Storage Facility (Facility) at Joint Base Pearl Harbor-Hickam (JBPHH) in Honolulu, Hawaiʻi. Under the Consent Order, the Navy has committed to properly operate and maintain the JBPHH drinking water system to protect the health and safety of its consumers.

2015 Administrative Order on Consent

In response to the January 2014 fuel release from the facility, EPA and Hawai'i Department of Health (DOH) negotiated an enforceable agreement, also known as the 2015 Administrative Order on Consent (AOC), with the U.S. Navy and the Defense Logistics Agency (DLA). The Order required the Navy and DLA to take actions, subject to DOH and EPA approval, to address fuel releases and implement infrastructure improvements to protect human health and the environment.

Documents, Correspondence, Reports, and Data

Free viewers and readers are available to access documents on our website. If you encounter issues with assistive technology, please contact us.

EPA Letter to Navy: Red Hill Bulk Fuel Storage Facility Response Plan Redetermination (pdf) (2.36 MB, October 1, 2026)
EPA letter to Navy (JBPHH) approving their request to reclassify or redetermine the “Significant and Substantial Harm” status of the fuel piping at the Red Hill Bulk Fuel Storage Facility.
EPA Letter to Navy: September 2026 Review of the 2023 Red Hill AOC SOW Section 3.2.2 Soil Vapor Monitoring Modification Proposal (pdf) (174.27 KB, August 27, 2026)
EPA letter to Navy Closure Task Force – Red Hill (NCTF) approving their request to reduce from weekly to quarterly the frequency of conducting soil vapor monitoring (SVM) required under Statement of Work (SOW) Section 3.2.2, Soil Vapor Monitoring, of the 2023 Red Hill Administrative Consent Order (ACO).
EPA Letter: Disapproval of Extension Request #4 for Inspection and Cleaning of Red Hill Tank 685 (pdf) (258.8 KB, July 10, 2026)
EPA did not grant the Navy’s July 9, 2026, extension request to inspect, clean, and sample Red Hill Tank 685 by September 24, 2026. The deadline remains as July 17, 2026.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.5.7 Cross-Connection Control Program (pdf) (149 KB, June 4, 2026)
EPA reviewed the Navy’s Cross Connection Control and Backflow Prevention Program submittal and confirmed that the requirements of the 2023 ACO Statement of Work, Section 6.5.7 have been completed.
EPA Letter: Approval of Modification Proposal for the 2023 ACO Statement of Work, Section 6.5.7 Cross Connection Control Program (pdf) (148.52 KB, April 29, 2026)
EPA reviewed and partially approved Navy Closure Task Force - Red Hill (NCTF-RH) request to align the Cross Connection Control Program submittal with the requirements outlined in America’s Water Works Association Manual M14 instead of the Naval Facilities Engineering Systems Command (NAVFAC) manual, required under the 2023 ACO Statement of Work, Section 6.5.7.
EPA Letter: Conditional Approval of Extension Request #2 for the Submittal of Operator SOPs (pdf) (198.44 KB, March 10, 2026)
EPA conditionally granted the Navy’s March 5, 2026, extension request to submit the Operator SOPs by May 22, 2026, with the requirement that SOPs are submitted every two weeks until the final deadline of May 22, 2026.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.5.6.2.1 Valve Exercising Program (pdf) (116.64 KB, January 20, 2026)
EPA reviewed and approved the Navy’s Valve Exercising Program submittal, confirming that the requirements of the 2023 ACO Statement of Work, Section 6.5.6.2.1 have been completed.
EPA Letter: Approval of Navy Extension Request #3 for Inspection and Cleaning of Red Hill Tank 685 (pdf) (255.43 KB, December 18, 2025)
EPA granted the Navy’s December 17, 2025, extension request to inspect and clean Red Hill Tank 685 by July 17, 2026.
EPA Letter: Response to Navy’s Extension Request #2 for General Deliverables (pdf) (171.82 KB, November 21, 2025)
EPA reviewed the Navy Closure Task Force - Red Hill (NCTF-RH) November 19, 2025, request for an extension to submit Quarterly Frequently Asked Questions, Monthly Progress Report, and the Valve Exercising Program. EPA also established compliance deadlines for submission of the Cross-Connection Control Program Plan, revised Water Quality Concerns and Response Investigation Procedures, and Surveillance Response System, as well as responding to EPA’s Comments on Closure Plan Supplement 4.
EPA Letter: Response to Navy’s Extension Request #1 for General Deliverables (pdf) (107.98 KB, October 28, 2025)
EPA reviewed and did not grant NTCF’s October 27, 2025, request for a day-for-day extension due to the October 1, 2025, lapse in federal funding. EPA instead granted a temporary indefinite extension and required the Navy to submit updated dates for approval for each deliverable within five working days after federal appropriations resume.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.5.4 Unidirectional Flushing Plan (pdf) (115.1 KB, October 7, 2025)
EPA reviewed and approved the Navy’s Unidirectional Flushing Plan submittal, required under the 2023 ACO Statement of Work, Section 6.5.4.
EPA Letter to Navy: September 2025 Spill Incidents Obligations under 2023 Administrative Order on Consent (pdf) (138.68 KB, September 26, 2025)
EPA letter to Navy Closure Task Force – Red Hill documenting the importance of reporting any spill or release that has the potential to impact the environment or human at the Red Hill Bulk Fuel Storage Facility.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.5.5 Maintenance Flushing Program (pdf) (147.96 KB, September 15, 2025)
EPA confirmed receipt of the Navy’s measures taken toward implementation of the EPA approved Maintenance Flushing Program submittal and confirmed that the requirements of the 2023 ACO Statement of Work, Section 6.5.5 have been completed.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.5.5.2 Development of Maintenance Flushing Program (pdf) (113.34 KB, August 26, 2025)
EPA reviewed and approved the Navy’s Maintenance Flushing Program submittal, confirming that the requirements of the 2023 ACO Statement of Work, Section 6.5.5.2 have been completed.
EPA Letter: Partial Approval of Extension Request #2 for Inspection and Cleaning of Red Hill Tanks 316 and 685 (pdf) (256.09 KB, August 26, 2025)
EPA partially granted the Navy’s August 22, 2025, extension request to inspect and clean Red Hill Tank 685 by January 9, 2026, instead of the proposed February 2, 2026, date.
EPA Letter: Approval of Modification Proposal for the 2023 ACO Statement of Work, Section 6.5.5.2 Development of Maintenance Flushing Program (pdf) (194.46 KB, July 8, 2025)
EPA reviewed and approved Navy Closure Task Force - Red Hill (NCTF-RH) request to conduct unidirectional flushing annually, perform maintenance flushing on a rotating 20% of the system each year, complete the maintenance flushing for the entire system every five years, and review existing flushing areas and frequencies based on newly acquired data, required under the 2023 ACO Statement of Work, Section 6.5.5.2.
EPA Letter: Approval of Modification Proposal for the 2023 ACO Statement of Work, Section 6.3.1 Sampling of Finished Water Tanks (pdf) (223.66 KB, June 30, 2025)
EPA reviewed and approved Navy Closure Task Force - Red Hill (NCTF-RH) request to align submittal of sample results within 7 days of receipt from the laboratory, rather than within 7 days of cleaning finished water tanks, required under the 2023 ACO Statement of Work, Section 6.3.1.
EPA Letter: Approval of Modification Proposal #2 for the 2023 ACO Statement of Work Section 6.5.4 Unidirectional Flushing Plan (pdf) (366 KB, June 30, 2025)
EPA reviewed and approved Navy Closure Task Force - Red Hill (NCTF-RH) request to align the language with the Navy’s utilized methodology to develop the Unidirectional Flushing Plan while maintaining the intent of the original language, required under the 2023 ACO Statement of Work, Section 6.5.4.
EPA Letter: Approval of Modification Proposal for the 2023 ACO Statement of Work, Section 6.5.6.2.1 Valve Exercising (pdf) (366.76 KB, May 1, 2025)
EPA reviewed and approved Navy Closure Task Force - Red Hill (NCTF-RH) request to specify valve exercising exemption categories, submit annual metrics, and submit a schedule for valve replacement, required under the 2023 ACO Statement of Work, Section 6.5.6.2.1.
EPA Letter: Approval of Extension Request #2 for the Submittal of the Maintenance Flushing Program (pdf) (99.9 KB, April 21, 2025)
EPA granted the Navy's April 16, 2025, extension request to submit the Maintenance Flushing Program by July 31, 2025.
EPA Letter: Conditional Approval of Extension Request #6 for the Submittal of the Valve Exercising Program and Response to Modification Proposal (pdf) (210.18 KB, April 1, 2025)
EPA provided comments on the Navy’s March 25, 2025, modification proposal for 2023 Administrative Consent Order Statement of Work, Section 6.5.6.2.1 and granted the Navy’s extension request to submit the Valve Exercising Program. submission deadline has been extended to July 25, 2025, on the condition that the Navy incorporates EPA’s modification proposal comments no later than April 30, 2025.
EPA Letter: Approval of Modification Proposal for the 2023 ACO Statement of Work, Section 6.11 Complaint Investigation Procedures (pdf) (246.31 KB, March 28, 2025)
EPA reviewed and approved Navy Closure Task Force - Red Hill (NCTF-RH) request to rename the subsection from “6.11 Complaint Investigation Procedures” to “6.11 Water Quality Concern Response and Investigation Procedures” and to modify the language to better encompass the nature of the water quality complaints received by the Navy, required under the 2023 ACO Statement of Work, Section 6.11.
EPA Letter: Disapproval of Extension Request #5 for the Submittal of the Valve Exercising Program (pdf) (157.05 KB, March 21, 2025)
EPA did not grant the Navy’s March 18, 2025, extension request to submit the Valve Exercising Program. The deadline remains as March 31, 2025.
EPA Letter: Approval of Extension Request #2 for the Submittal of the Unidirectional Flushing Plan (pdf) (103.58 KB, January 22, 2025)
EPA partially granted the Navy’s January 13, 2025, extension request to submit the Unidirectional Flushing Program. The submission deadline has been extended to July 31, 2025, and further extension requests will not be approved unless the Navy completes the outlined interim milestones.
EPA Letter: Approval of Modification Proposal #1 for the 2023 ACO Statement of Work, Section 6.5.4 Unidirectional Flushing Plan (pdf) (170.33 KB, January 10, 2025)
EPA reviewed and approved Navy Closure Task Force - Red Hill (NCTF-RH) request to design the Unidirectional Flushing Plan solely for the Navy public water system (PWS ID. HI10000360), required under the 2023 ACO Statement of Work, Section 6.5.4.
EPA Letter: Approval of Extension Request #4 for the Submittal of the Valve Exercising Program (pdf) (305.88 KB, December 15, 2024)
EPA conditionally granted the Navy’s December 6, 2024, extension request to submit the Valve Exercising Program. The deadline has been extended to March 31, 2025, on the condition that the Navy submits a modification proposal to amend Statement of Work, Section 6.5.6.2.1 by March 18, 2025.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.5.2 Asset Management Program (pdf) (176.03 KB, November 15, 2024)
EPA reviewed the Navy’s Asset Management Program submittal and confirmed that the requirements under the 2023 ACO Statement of Work, Section 6.5.2 have been completed.
EPA Letter: Approval of Extension Request #3 for the Submittal of the Valve Exercising Program (pdf) (112.02 KB, July 17, 2024)
EPA conditionally granted the Navy’s July 8, 2024, extension request to submit the Valve Exercising Program. The deadline has been extended to December 15, 2024, on the condition that the Navy incorporates enforceable interim milestones and submits a modification proposal to amend Statement of Work, Section 6.5.6.2.1 by August 9, 2024.
asdf EPA Letter: Approval of Extension Request #2 for Inspection and Cleaning of Camp Smith Tanks S325, S326, and S327 (pdf) (146.14 KB, June 5, 2024)
EPA approved the Navy’s December 20, 2023, extension request to inspect and clean Camp Smith Tanks S325, S326, and S327 by May 13, 2024.
EPA Letter: Approval of Extension Request #1 for the Submittal of Operator SOPs (pdf) (98.2 KB, June 5, 2024)
EPA granted the Navy’s May 16, 2024, extension request to submit the Operator SOPs has been extended to March 13, 2026.
EPA Letter: Approval of Extension Request #2 for the Submittal of the Valve Exercising Program (pdf) (99.97 KB, April 3, 2024)
EPA granted the Navy’s March 8, 2024, extension request to submit the Valve Exercising Program by July 15, 2024.
EPA Letter: Approval of Extension Request #1 for the Submittal of the Unidirectional Flushing Plan and Maintenance Flushing Program (pdf) (106.99 KB, March 1, 2024)
EPA granted the Navy’s February 15, 2024, extension request to submit the Unidirectional Flushing Plan by January 20, 2025, and the Maintenance Flushing Program by April 20, 2025.
EPA Letter: Approval of Extension Request for the Implementation of the Cross-Connection Control and Backflow Prevention Program (pdf) (196.48 KB, February 9, 2024)
EPA granted the Navy's February 5, 2024, extension request to implement the Cross-Connection Control and Backflow Prevention Program by April 30, 2024.
EPA Letter: Approval of Extension Request #1 for the Submittal of the Valve Exercising Program (pdf) (97.78 KB, January 25, 2024)
EPA granted the Navy’s January 22, 2024, extension request to submit the Valve Exercising Program by March 15, 2024.
EPA Letter: Approval of Extension Request #1 for Inspection and Cleaning of Camp Smith Tanks S325, S326, and S327 (pdf) (147.54 KB, January 24, 2024)
EPA approved the Navy’s December 20, 2023, extension request to inspect and clean Camp Smith Tanks S325, S326, and S327 by May 13, 2024.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.2 Long Term Monitoring – Closed Inactive Water Distribution Lines (pdf) (135.68 KB, October 16, 2023)
EPA received the Navy’s Notice of Intent to repair the broken main for JBPHH, confirming that the requirements under the 2023 ACO Statement of Work, Section 6.2 have been completed.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.5.9 Chemical Use Storage and Handling (pdf) (158.26 KB, October 16, 2023)
EPA reviewed the Navy’s photo documentation submittal of the storage of treatment chemicals at JBPHH and confirmed that the requirements under the 2023 ACO Statement of Work, Section 6.5.9 have been completed.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.1.1 Source Water Protection Plan Phase I (pdf) (239.08 KB, September 25, 2023)
EPA reviewed the Navy’s Phase I Source Water Protection Plan submittal, confirming that requirements under the 2023 ACO Statement of Work, Section 6.1.1 have been completed.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.5.3 Hydraulic Model (pdf) (211.42 KB, December 11, 2023)
EPA reviewed and approved the Navy’s Hydraulic Model Report and demonstration, confirming that the requirements of the 2023 ACO Statement of Work, Section 6.5.3 have been completed.
EPA Letter: Approval of Extension Request for the Hydraulic Model Demonstration (pdf) (326.21 KB, December 11, 2023)
EPA granted the Navy’s June 28, 2023, extension request to demonstrate the Hydraulic Model by August 18, 2023.
EPA Letter: Approval of Extension Request for the Submittal of the Cross-Connection Control and Backflow Prevention Program (pdf) (149.5 KB, October 26, 2023)
EPA granted the Navy’s October 24, 2023, extension request to submit the Cross-Connection Control and Backflow Prevention Program by January 12, 2024.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.6 Public Notification (pdf) (157.27 KB, October 16, 2023)
EPA reviewed the Navy’s Public Notice and Certification submittal and confirmed that the requirements under the 2023 ACO Statement of Work, Section 6.6 have been completed.
EPA Letter: Close Out of 2023 ACO Statement of Work, Section 6.7.1 Certified Operators (pdf) (153.81 KB, October 16, 2023)
EPA reviewed the Navy’s submitted list of certified operators for JBPHH and confirmed that the requirements under the 2023 ACO Statement of Work, Section 6.7.1 have been completed.