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Volume 6, Issue 4 - April/May 1999
Examining Common POL Problems

This article is the first in a series that will examine various ECAMP protocols. Over the next several issues, we will examine common findings cited during ECAMP assessments and will offer solutions and suggestions for improvements. This first article discusses ECAMP findings related to the petroleum, oils, and lubricants (POL) protocol.

Many regulations govern the use, transportation, and disposal of POL. ACC installations face the challenging task of managing large quantities of POL to assure compliance with a number of regulations. During external ECAMPs, assessors carefully examine the handling of POL to help bases maintain effective management practices. Assessors sometimes find areas that need process improvements or physical maintenance, and they use these findings as an opportunity to suggest solutions.

The ECAMP Environmental Management System (EEMS) is a tool ECAMP team members use to track findings. A compilation of ECAMP findings under the POL protocol reveals common problems that can be classified into seven categories (shown below). By studying these common findings, base personnel can consider their own programs and avoid making similar mistakes. 

Inadequate Containment and Spill Kits at Loading Areas

Examinations of loading areas at installations indicate inadequate POL secondary containment in bulk fuel loading and off-loading operations. In fact, these types of findings are the most numerous in the POL protocol. 40 CFR 112 requires that truck fill stands have secondary containment in place. Loading and unloading areas are required to have spill equipment that is designed to hold at least the maximum capacity of any single compartment of a tank truck loading or unloading at the site. ECAMP findings often cite the lack of secondary or spill containment or damaged containment materials during assessments. Common problem areas include tank truck loading and unloading racks, ground product stations, bulk storage fill stands, and bulk transfer pumps.

Inadequate Pipelines

Buried fuel pipelines and transfer lines must be inspected annually and monitored for corrosions and leaks. ECAMP findings cite inadequate cathodic protection on POL pipelines as the most common area of concern. In some cases, lack of cathodic protection has resulted in pipe corrosion and leaks. Annual inspections and AFI-required monthly checks need to be conducted and documented to prevent corrosion problems that result from lack of preventive maintenance.

Inadequate Spill Training

Some ECAMP assessments have found problems in the area of spill response training. The Spill Prevention Control and Countermeasures (SPCC) Plan and the Facility Response Plan require training and spill response exercises. Each facility must have a designated person, trained in spill response, who is accountable for line management and responsible for oil spill prevention. Workers who are responsible for handling POL regularly, such as refueling
maintenance individuals, should remain current on their spill response training. Base fire department personnel are required to complete semiannual POL familiarization training. Documentation of training is required. ECAMP assessors commonly site a lack of training, documentation, and overdue refresher course completion as findings during assessments. 

Drew Francis of HQ ACC/LG acts as a POL assessor during many ACC ECAMPs. He says that ACC's HAZWOPPER training is a valuable educational tool for POL handlers. "We have found some problems with troops not being aware that equipment is needed in close proximity to all potential large spill areas. Training is not always performed as soon as a new troop is assigned," Mr. Francis said.

Inadequate Used Oil Management

Inadequacies in used oil management are, by and large, due to insufficient or incorrect labeling of used oil containers. 40 CFR Part 279 requires that any container holding used oil be clearly labeled with the words "used oils." Some findings cite that used oil containers are labeled with the oil type; such labeling does not comply with federal regulations without the words "used oil." Fill pipes, drums, and oil containers used in filter crushing processes are common containers that are found without "used oil" labeling.

Another problem is the lack of signs reading "No Smoking Within 50 Feet" in areas where used oil is stored.

Service Station Deficiencies

ECAMP assessors often cite base service stations that are in need of repair or lacking in required protective measures. OSHA requires that pump collision barriers be placed to prevent automobiles from colliding with fuel pumps. All fuel dispensing devices should be protected from damage that can potentially be caused by vehicles. Dispenser nozzles must be regularly checked for leaks, and leaks should be repaired quickly.

Spill Cleanup Deficiencies

Improper disposal of spilled used oil has been frequently cited during ECAMP assessments. When used oil is spilled onto the ground, it must be cleaned up and properly disposed. The used oil generator takes responsibility for spill cleanup and disposal management. 

Spill Plan Deficiencies

40 CFR 112.3 requires that facilities meeting certain thresholds of oil storage prepare and implement a SPCC Plan. Inadequate SPCC Plans are the second most frequent ECAMP assessment finding. Assessors cite incomplete plans, out-of-date plans, and hard-to-find plans as the most common deficiencies. 

Planners should follow the CFR requirements while compiling their plans. Many findings have resulted from plans that lacked required components. Also, plans should be periodically reviewed and amended to reflect material changes that have occurred since the plan was last issued. It is also important that the SPCC Plan be made available to personnel. ECAMP findings cite occasions when a SPCC Plan existed, but workers did not know how to access it. A copy of the plan should be distributed to a variety of shops around the base.

Mr. Francis explains, "The SPCC must be updated whenever things change, reviewed at least every three years, and the review must be documented."

Other spill plan deficiencies are related to inadequate Facility Response Plans (FRPs). 40 CFR 112.20 requires that a facility evaluate its need for an FRP and either prepare a plan or certify, pursuant to 40 CFR 112.20, that a plan is not required. A facility must present either a plan or a certification of exemption to ECAMP assessors. Also, once a facility has created a plan, it must submitted to the U.S. EPA for approval. ECAMP findings have cited facilities for neglecting to submit FRPs to the EPA.

Point of Contact:
Mr. Drew Francis, HQ ACC/LG
Langley AFB
(757) 764-9930, or DSN 574-9930