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POLSTORAGE TANK PROTOCOL OPERATIONAL IMPACT

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					         Course 090


                              POL/STORAGE TANK PROTOCOL - LESSONS LEARNED


                                                      MSGT TERESA BOYD

                                      HEADQUARTERS AIR COMBAT COMMAND
                                         LOGISTICS READINESS DIVISION
                                             FUELS MANAGEMENT


INTRODUCTION: There is a misconception when it comes to the Petroleum, Oils, and Lubricants (POL) and
Storage Tank protocols. It is assumed they only apply to the fuels community and are over looked by several
organizations also affected by these protocols. Through this course I hope to help clarify this misconception. This
course is designed to educate organizational managers and individuals on their responsibilities handling fuels, used
oils, and hydraulic fluids under the POL and Storage Tank protocols. Base organizational responsibilities will be
discussed including training requirements, management, operations, and environmental compliance. Special
emphasis will be placed on compliance with and development of a comprehensive Spill Prevention Control and
Countermeasure (SPCC) plan and organizational tank custodial responsibilities. Sources of training for personnel
and spill prevention will be included. Case studies from previous Environmental Compliance Assessment
Management Program/ Environmental, Safety, & Occupational Health Compliance Management Program
(ECAMP/ESOCAMP) assessments will be discussed. Format will include a “Top Ten List” with examples of
findings as well as solutions. The intended audience is Air Force management and shop-level personnel, including
military, appropriated/non-appropriated civilians, and contractor staff who handle fuel, used oils, and hydraulic
fluids with storage capacity over 55 gallons.

TRAINING: Training is one of the easiest things to fix when it comes to correcting the majority if not all the
findings identified during an assessment. The base CE environmental office and base Fuels Management can help
with providing some of the training or at least get you pointed in the right direction. The base SPCC is probably the
best place to reference training requirements as it identifies annual training that must be met in order to be compliant
with your base spill plan. Another required training is tank custodian training that is provided by Fuels Management.
Tank custodian training is required by every base and tenant organization using and managing organizational fuel
tanks. Contact the Fuels Management Flight to schedule this training.

During previous ESOHCAMP assessments, it was evident there were several reoccurring areas of concern. Many
bases were experiencing similar problems. To help educate personnel with correction of these problems and
eliminate future occurrences I have developed a list of common ESOHCAMP findings. The list contains five items
each from the POL and Storage Tank protocols. A brief description of each finding and action taken to correct the
problem is provided.

The first five findings are under the POL protocol.

1. Under this protocol is the management of used oils. When storing used oils in a collection container for turn-in,
it must be properly marked. IAW 40 CFR 279.22, all containers must be marked “USED OIL.” Majority of the
time the container is marked with different verbiage, isn’t marked directly on the container, or is missing markings
altogether. Most of the time these findings are fixed on the spot or before the assessment is over. It doesn’t seem to
matter how minor this finding seems and how easy it is to correct, this makes the top 10 every year.

2. The Spill Prevention Control and Countermeasure (SPCC) plan is where a good portion of findings were
identified. The plan covers a large portion of the organizations on an installation and if these organizations had
better understanding of what this plan is, these findings could be prevented. Several of the sites that were visited did
not realize they had to have the SPCC. The base CE environmental office will be able to assist you as to whether an
SPCC needs to be readily available and can provide a copy to the shop. A copy of the SPCC must be maintained at
organizations that are manned at least four hours per day.

         3. Secondary containment is needed to prevent the contamination of soil and water in the event of a spill.
         At several base assessments, it was identified that off-loading facilities did not have adequate secondary
        Course 090


        containment. 40 CFR 112.7 requires that fuel unloading areas be equipped with secondary containment
        systems or diversionary structures capable of containing at least the largest compartment on the tank truck.
        If there are off-loading facilities that do not have the required secondary containment, coordinate with base
        Civil Engineering or CE Environmental to submit a work order.

        4. Training was previously discussed, but the specific finding identified concerns spill prevention/spill
        response training. 40 CFR 112.7 requires that installation personnel who handle POL have periodic spill
        prevention/spill response training. A review of the base SPCC will indicate required training needed. Most
        if not all training can be acquired locally and in many cases can be tailored to fit anyone’s needs.

        5. 29 CFR 1910.106 requires emergency shutoff switches be clearly marked and easily accessible. On a
        few occasions the placement of the switch was correct but was not marked correctly. At other times the
        sign was there but so badly faded you could not make out what it said. Your base sign shop (CE) or several
        vendors accessible through the internet can provide the necessary signage needed.

        The next five findings are from the Storage Tank protocol. It may appear that the findings are similar,
        however they only deal with the storage of large quantities of fuel and also cover portable storage tanks.

        1. When it comes to secondary containment for storage tanks, several things have been identified. For
        example, CE often uses portable tanks for generators out in the field. 40 CFR 112.7 requires that mobile or
        portable storage tanks be positioned to prevent spilled fuel from reaching navigable waters. There are
        portable catch basins that can be used or position tanks in an area that will eliminate the possibility of fuel
        from reaching water if there would happen to be a leak. This finding also includes flight-line bowsers.
        When being used, bowsers do not require secondary containment, however, when finished they must be
        parked in an area that provides secondary containment.

        2. The next finding is easily overlooked. Tanks need to be labeled with what the contents of the tank are
        and warning signs posted i.e. “No Smoking within 50 Feet” or “No Smoking Beyond This Point” which
        ever is applicable to your site. The signs must also be visible from all approachable sides. AFI 23-204
        requires all organizational tanks be labeled to indicate the contents and warning signs. The CE
        environmental flight can assist with the proper product or warning signs that are required but they will need
        to be procured by the using organization.

        3. When it comes to leak detection, there is a problem with record keeping and improper leak detection
        procedures. 40 CFR 280 requires that records of monitoring and maintenance of underground storage tanks
        (USTs) be maintained for three years. Tightness testing must be performed at least once every five years.
        To perform proper inventory reconciliation, product inputs, withdraws, and amount remaining in the tank
        must be recorded daily. Good record keeping is the key for eliminating this finding.

        4. The problem of open dike drains is an ongoing problem. 40 CFR 112.7 states that drains on dikes that
        provide secondary containment for storage tanks must be kept closed and locked except when actively
        draining water. When draining water from the dike area, the drain must be monitored at all times.
        Personnel have a tendency to open drains and start on other project, forgetting about the drain. Doing this
        makes the secondary containment ineffective. This is easily fixed by making sure drains are monitored at
        all times and closed and locked when done. The amount of water released must also be tracked.

        5. To prevent pilferage and contamination of fuel in a tank, all access points on tanks outside of a secure
        area must be locked. AFI 23-204 requires all access points enabling access to the contents of the tank be
        secured when unattended. After filling these tanks, make sure locks are place back on these access points
        and locked. Several access points were found to have locks in place but not latched.


CONCLUSION: Training and self assessment are the best way to prevent and eliminate ESOHCAMP findings. It
is everyone’s responsibility to protect the environment and prevent the contamination of our natural resources. By
using the list from previous ESOHCAMPs, we can all learn how to run successful programs. Learn from someone
else’s mistakes and make needed corrections before the environment is damaged forever.
Course 090



REFERENCES:

33 Code of Federal Regulations (CFR) 153, “Control of Pollution by Oil and Hazardous Substances,
Discharge Removal”

33 CFR 154, “Facilities Transferring Oil or Hazardous Materials in Bulk”

40 CFR 110, “Discharge of Oil”

40 CFR 112, “Oil Pollution Prevention”

40 CFR 279, “Standards for the Management of Used Oils”

40 CFR 280, “Technical Standards and Corrective Action Requirements for Owners and Operators of
Underground Storage Tanks”

40 CFR 300, “National Oil and Hazardous Substances Pollution Contingency Plan”

Air Force Instruction (AFI) 23-201, “Fuels Management”

AFI 23-204, “Organizational Fuel Tanks”

AFI 23-502, “Recoverable and Unusable Liquid Petroleum Products”

AFI 32-7044, “Storage Tank Management”

Unified Facility Criteria (UFC) -3-460-03

Technical Orders (TO) 35-1-3, 36-1-3, 37-1-1, 42B-1-1, 42B-1-23, and 00-25-172

AF Underground Storage Tank Management Strategy letter, 30 May 1990

National Fire Protection Association (NFPA) 30, “Flammable and Combustible Liquid Code”

Applicable state and local regulations

DISCLAIMER: “The opinions and conclusions in this paper are the authors’ alone and do not necessarily
reflect those of the United States Air Force or the Federal Government.”

AUTHOR INFORMATION: MSgt Teresa Boyd, phone number (DSN 574-7121 COMM. 757-764-
7121), email (teresa.boyd@langley.af.mil)

				
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