For at least a year, workers at the Navy’s Red Hill fuel complex were managing millions of gallons of petroleum – and welding with sparks flying – while the main fire suppression system was not fully functioning, according to records Civil Beat obtained via the Freedom of Information Act. 

The U.S. Occupational Safety and Health Administration and the Navy have different stories about what happened. But both parties agree that during a yearlong period, the system would automatically deploy only water on a fuel fire, which OSHA said would exacerbate and spread a blaze. Meanwhile, the mechanism for automatically deploying firefighting foam was disengaged. 

The Navy said its systems were “never insufficient” and that fires could be extinguished manually, but OSHA said the main system was totally “disabled” and that workers were left vulnerable. 

“Alternative firefighting measures were not put in place, exposing employees to fire hazards,” the agency wrote in inspection records. 

Federal inspectors told the Navy in March that it had engaged in two serious violations of workplace safety standards that, combined, would have resulted in nearly $30,000 in fines if they had happened in a civilian agency: one for failing to provide adequate fire control equipment and another for neglecting to inform its employees about the situation.

However, the first violation was later withdrawn on a technicality. The Navy said that the violation it was accused of didn’t apply because its jet fuel didn’t meet the specific definition of a “Category 1 or 2 flammable liquid” under the law. The Navy’s system would’ve been deemed legally inadequate if the flashpoint of its fuel – the temperature at which it ignites – was just seven degrees lower, the records show.

The Federal Fire Department wrote in a memo to OSHA that firefighting foam is essential for so-called Class B fires, which involve flammable liquids generally. Water alone is “not effective in combating a fire consisting of Class-B or hydrocarbon fuels,” the fire department said.

In the end, the Navy accepted the second OSHA violation for failing to tell its employees its fire suppression system was deficient.

David Henkin, a senior attorney for Earthjustice, called OSHA’s findings disturbing. 

“The lack of concern for public safety including the safety of workers is just unconscionable,” he said. “It just drives home the point that we need to get the fuel out and the facility shut down as quickly as humanly possible.” 

Red Hill is a sprawling underground complex of 20 fuel storage tanks – each 250 feet tall – and a series of pipelines and tunnels that deliver fuel to Pearl Harbor, among other places. The facility, which can hold up to 250 million gallons of fuel, poses a “high potential for fire,” according to the military’s own assessment in 2014.

According to OSHA, the mechanism for using firefighting foam – known as Aqueous Film Forming Foam, or AFFF – in the area of the fuel tanks was completely turned off for more than a year. The lines were drained, and its valves were locked, inspectors observed.

In the fuel facility’s pump house, makai of the Red Hill tanks, the system had been in manual mode for at least a year at the time of the inspection, OSHA found.

Navy officials shut down the firefighting foam pipelines after the discovery of a leak and amid fears the foam would contaminate the environment around the massive World War II-era facility, according to the OSHA records. The Red Hill facility is just 100 feet above Oahu’s primary drinking water source.

By removing the firefighting foam to address an environmental concern, officials took a major risk with worker safety, according to OSHA.

The Navy declined to be interviewed for this story but sent a statement disputing OSHA’s findings. According to the Navy, the firefighting foam pipelines were put in “manual mode” but were not shut off completely.

“The system was switched from automatic mode to manual mode, and remained operational,” the Navy said.

The Navy also said when hot work is done inside Red Hill, workers clear the area of any potential hazards.

“Hot work does not occur in the immediate vicinity of fuel,” the Navy said.

OSHA identified the fire suppression problems during an inspection at Red Hill on Nov. 10.

Just a few weeks later, families on the Navy’s water system would complain of illnesses and a fuel smell in their water, kicking off a contamination crisis that residents say is ongoing. The major leak on Nov. 20 that allegedly caused the contamination came from the fire suppression system, according to the Navy. 

Whether the system’s problems were a factor in the catastrophe is not yet publicly known. The investigation into the contamination been been “under review” at the Pentagon for weeks and has not been released to the public.

Following news of the water contamination, the Navy initially fought to keep Red Hill running, despite a state health department order to shut it down. But in March, the secretary of defense ordered its permanent closure, which could take years. 

Despite the fire hazards, workers at the facility were not aware of the problem, according to OSHA. Red Hill is staffed 24 hours a day, seven days a week by a minimum of 15 civilian employees per day, the Navy said, although another five to 10 may be present for construction, repairs or other work. 

“The lead engineer was made aware of the AFFF system being locked out during our on site inspection,” OSHA wrote in its violation notice. “Shift workers and contractors who continuously occupied the tunnel were not aware the AFFF system was locked out and disabled.”

For at least six months before the inspection, contractors had been performing welding that can produce sparks and flames when done near flammable material on the Red Hill fuel tanks and other infrastructure. 

“The general contractor overseeing the welding hot work was not aware the AFFF system was locked and learned of the system’s status as a part of our inspection,” according to the violation worksheet. 

Even a Naval Supply Systems Command supervising engineer didn’t know, OSHA said. He was under the impression the tank gallery’s fire suppression system was in manual mode, but OSHA inspectors found all the AFFF valves were locked, the agency’s records show. 

For management to allow that to happen is pure negligence, according to Damien Kim, the business manager and financial secretary for the International Brotherhood of Electrical Workers, whose members work at Red Hill.

“That is really alarming, especially in a fuel facility, workers not being told that the main fire system was out of commission,” he said.

Kim added that the union would have “demanded they get some kind of coverage, an alternative system or backup,” had it been informed about the decision. But it’s a moot point now.

After the OSHA inspection, a standard operating procedure was developed to have both fire suppression systems in manual mode, the OSHA documents said. Starting Nov. 23, an attendant was supposed to be stationed 24/7 in the tank gallery’s AFFF pump house “due to safety concerns and concerns for delayed response in the event of a fire,” OSHA wrote. 

As of April 26, repairs to the AFFF system were completed and the main system was returned to automatic operation, according to a letter Navy Rear Adm. Tim Kott sent to the U.S. Department of Labor. 

In another letter, Kott told OSHA that signs were placed at the entrances to the facility advising employees of the “fire suppression system deficiency.”

‘An Environmental Concern’  

Military officials decided to drain the main fire suppression system of AFFF because of a leak in the system, according to the OSHA documents. 

“The AFFF leaking was an environmental concern,” Roger Forstner, OSHA’s Honolulu officer director, wrote in notes summarizing his meeting with Navy leaders. 

According to the Navy, the leak occurred in an AFFF pipeline that is contained inside another pipe, and the material did not escape the facility.

While the type of AFFF used by the military, called C6, was at first thought to be safer than previous iterations, experts are starting to question that conclusion, according to Diana Felton, Hawaii’s state toxicologist. 

“The thought was that those are less toxic, but the data is starting to show that is probably not true, at least in some situations,” Felton said in an interview.

According to Felton, AFFF C6 still contain PFAS, per-and polyfluoroalkyl substances, which are a class of “forever chemicals” that don’t break down in the environment and are associated with a variety of negative health impacts. 

A leak in the fire suppression system — which was installed in 2017 and expanded in 2019 — was previously mentioned in a Naval Facilities Engineering Systems Command memo written last year to justify the hiring of a contractor to fix the problems. The memo said the Navy didn’t know the leak’s specific location. 

The fire suppression system at Red Hill is just one part of the 80-year-old complex that has fallen into disrepair. 

A report by a Navy consultant released last week recommended some 200 repairs, some of which it said will have to be completed before the military can safely drain fuel from the facility. Those repairs could take up to two years to complete.