Overview of Red Hill Administrative Order on Consent
The Red Hill Administrative Order on Consent is an enforceable agreement involving the U.S. Environmental Protection Agency, the State of Hawaii Department of Health, the U.S. Navy, and the Defense Logistics Agency. Its primary objectives are to protect the groundwater near the Red Hill Facility and ensure environmentally protective operations and maintenance of the facility. The agreement involves various parties responsible for overseeing and implementing actions related to tank infrastructure improvements, environmental investigation, remediation, and more.
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Red Hill Administrative Order on Consent Role, Function, and Status Fuel Tank Advisory Committee October 28, 2021 1 Red Hill Administrative Order on Consent
Administrative Order on Consent and State of Hawai i Underground Storage Tank Program DOH July 15, 2018 Hawaii s UST regulations (Chapter 11-280.1, HAR) were amended in response to EPA s 2015 update of the federal UST regulations. EPA, DOH, Navy, DLA AOC Administrative HAR Hawaii Administrative Rules In response to 2014 release Order on Consent July 8, 2021 HAR amended to clarify July 2018 regulations 2 Red Hill Administrative Order on Consent
What is the Red Hill Administrative Order on Consent? An enforceable agreement between: U.S. Environmental Protection Agency State of Hawai i Department of Health U.S. Navy Defense Logistics Agency The primary objectives of the AOC are to take steps to ensure that the groundwater resource in the vicinity of the Red Hill Facility is protected and to ensure that the facility is operated and maintained in an environmentally protective manner. 3 Red Hill Administrative Order on Consent
AOC Parties U.S. Navy and Defense Logistics Agency U.S. EPA and Hawai i DOH Owner/operator of the Red Hill facility Regulatory Agencies Enforce environmental laws and regulations Responsible for the design, operation, maintenance, monitoring, and release response actions Oversee implementation of the Administrative Order on Consent 4 Red Hill Administrative Order on Consent
AOC Scope of Work Section 1 Project Management Sections 2-5, 8 Tank Infrastructure Improvements Section 2: Tank Inspection, Repair, Maintenance Section 3: Tank Upgrade Alternatives Section 4: Release Detection / Tank Tightness Testing Section 5: Corrosion and Metal Fatigue Practices Section 8: Risk and Vulnerability Assessment Sections 6-7 Environmental Investigation and Remediation Section 6: Investigation and Remediation of Releases Section 7: Groundwater Protection and Evaluation 5 Red Hill Administrative Order on Consent
AOC Scope of Work Updates HISTORY 2019 Navy/DLA Submitted Tank Upgrade Alternatives and Release Detection Decision Document Section 1 Project Management Sections 2-5, 8 Tank Infrastructure Improvements 2019 EPA/DOH Solicited Public Comments Section 2: Tank Inspection, Repair, Maintenance Section 3: Tank Upgrade Alternatives Section 4: Release Detection / Tank Tightness Testing Section 5: Corrosion and Metal Fatigue Practices Section 8: Risk and Vulnerability Assessment 2020 EPA/DOH Issued a Notice of Deficiencies Letter 2021 Navy/DLA Submitted a Tank Upgrade Alternatives and Release Detection Decision Document Supplement Sections 6-7 Environmental Investigation and Remediation Section 6: Investigation and Remediation of Releases Section 7: Groundwater Protection and Evaluation NEXT STEP EPA/DOH Issue Decision 6 Red Hill Administrative Order on Consent
AOC Scope of Work Updates HISTORY Section 1 2019 Navy/DLA submitted a Destructive Testing Results Report to the Regulatory Agencies Project Management Sections 2-5, 8 Tank Infrastructure Improvements Section 2: Tank Inspection, Repair, Maintenance Section 3: Tank Upgrade Alternatives Section 4: Release Detection / Tank Tightness Testing Section 5: Corrosion and Metal Fatigue Practices Section 8: Risk and Vulnerability Assessment 2020 EPA/DOH disapproved report 2021 Navy/DLA submitted 5.4 Execution Plan: Decision on Need for and Scope of Modified Corrosion and Metal Fatigue Practices Amendment #1 Sections 6-7 Environmental Investigation and Remediation Section 6: Investigation and Remediation of Releases Section 7: Groundwater Protection and Evaluation NEXT STEP EPA/DOH issue decision 7 Red Hill Administrative Order on Consent
AOC Scope of Work Updates HISTORY Section 1 2019 Navy/DLA submitted Quantitative Risk and Vulnerability Assessment Phase 1 Project Management Sections 2-5, 8 Tank Infrastructure Improvements 2019 EPA/DOH Approved Phase 1 RVA with Requirements to Complete Additional Work Section 2: Tank Inspection, Repair, Maintenance Section 3: Tank Upgrade Alternatives Section 4: Release Detection / Tank Tightness Testing Section 5: Corrosion and Metal Fatigue Practices Section 8: Risk and Vulnerability Assessment 2020 Navy/DLA Submitted Risk/Vulnerability Assessment Phase 2 Scope of Work Sections 6-7 Environmental Investigation and Remediation Section 6: Investigation and Remediation of Releases Section 7: Groundwater Protection and Evaluation 2021 EPA/DOH Notice of Deficiency NEXT STEP: Navy/DLA to submit a revised Phase 2 Scope of Work 8 Red Hill Administrative Order on Consent
AOC Scope of Work Updates Section 1 Project Management Sections 2-5, 8 Tank Infrastructure Improvements HISTORY Section 2: Tank Inspection, Repair, Maintenance Section 3: Tank Upgrade Alternatives Section 4: Release Detection / Tank Tightness Testing Section 5: Corrosion and Metal Fatigue Practices Section 8: Risk and Vulnerability Assessment 2020 Navy/DLA submitted Investigation and Remediation of Releases Report & Groundwater Flow Model Report Sections 6-7 Environmental Investigation and Remediation Section 6: Investigation and Remediation of Releases Section 7: Groundwater Protection and Evaluation NEXT STEP EPA/DOH issue decision 9 Red Hill Administrative Order on Consent
2037 2038 2045 AOC Potential 5 Yr Extension (2042) Signed 2015, BAPT Upgrade Deadline Sept 2037 HAR Revised 2018, Secondary containment or utilize a design which the director determines is protective of human health and the environment by July 15, 2038 Navy/DLA Secondary Containment or Defuel Commitment 10 Red Hill Administrative Order on Consent
Regulatory Agency Contacts Roxanne Kwan Interim Red Hill Coordinator Hawai i Department of Health (808) 586-4226 Roxanne.Kwan@doh.hawaii.gov health.hawaii.gov/shwb/ust-red-hill- project-main/ Gabriela Carvalho Red Hill Coordinator EPA Region 9 (808) 541-2723 Carvalho.Gabriela@epa.gov www.epa.gov/red-hill 11 Red Hill Administrative Order on Consent
