Hydrostatic testing and purging of fuel tanker equipment in USAREUR.
The European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) has controlled the transport of dangerous goods within European Union countries since 1999. Since the ADR applies only to commercial transport, U.S. military vehicles are exempt from complying with ADR fuel tanker structural standards and system integrity certification requirements.
The German Government enforces ADR requirements on both commercial and German Army fuel tanker vehicles. Since it would be impossible for tactical equipment to comply with commercial standards and still be able to function in a tactical or combat environment, Germany developed the Gefahrgutverordnung Strasse und Eisenbahn (GGVSE) (the Regulation for Dangerous Goods, Road and Rail), which is based on the ADR and applies to German military vehicles. The Status of Forces Agreement between the United States and Germany requires U.S. forces in Germany to comply with the GGVSE.
Meeting GGVSE Standards
The GGVSE requires military fuel tanker vehicles and equipment to be hydrostatically tested and certified every 3 years in order to carry fuel on European road and rail systems. The USAREUR and Seventh Army G-4 Maintenance Division has been working with the German Ministry of Defense and the U.S. Army Tank-automotive and Armaments Command (TACOM) to finalize plans for hydrostatically testing and certifying USAREUR fuel tanker vehicles and equipment to meet GGVSE requirements.
Initially, TACOM and German engineers established a bilingual technical engineering package (TEP). Completed in 2002, the TEP identified several engineering differences between U.S. and ADR standards. Using the approved TER TACOM began developing prototype compliance kits, or "Euro" compliance kits, for M967- and M969-series 5,000-gallon fuel semitrailers and M978-series 2,500-gallon fuel trucks. Once the plans for testing and certifying the tankers are complete, USAREUR will acquire Euro kits and establish a program to install them and hydrostatically test each tanker for fuel leaks every 3 years as required by the GGVSE.
TACOM program managers do not consider application of the Euro kits to require a modification work order for two reasons. First, application of the kits is limited to USAREUR vehicles, not the Army-wide fleet. Second, the Euro kit does not significantly change the structure of the M967, M969, and M978 fuel tankers. Without a modification work order, USAREUR is obliged to use operations and maintenance, Army (OMA), funds to purchase and install the Euro kits, which cost about $1,675 each and take approximately 40 man-hours to install per fuel tanker. After the Euro kit is installed, the fuel storage tank and related plumbing and components are hydrostatically tested to certify the integrity of the complete system.
Depending on the facility performing the hydrostatic test, purging (removing fumes and residual fuel from the tanker to make it nonhazardous) may be required as part of the testing. Currently, two facilities in Germany can perform hydrostatic testing of fuel tankers: Maintenance Activity Mannheim (MAM), General Support Center-Europe, 21st Theater Support Command, and Industriewerke Saar GmbH, a German firm located near Ramstein. The method used by MAM requires purging of the tanks; Industriewerke Saar does not. It is not known at this time if both facilities will be needed to install Euro kits in 222 M967s and M969s and 335 M978s and hydrostatically test them.
TACOM will add a note to applicable fuel tanker technical manuals informing major Army commands worldwide that the Euro compliance kit is an authorized variation only for units located in Germany. Validation of prototype compliance kits and vehicle testing began in the second quarter of fiscal year 2003.
Deployment Lessons Learned
When the 1st Armored Division and the 1st Infantry Division (Mechanized) deployed to Southwest Asia, the International Maritime Dangerous Goods Agreement required both divisions to have their fuel tankers hydrostatically tested before they could deploy their full fuel tanker vehicles from Germany via ocean-going transport. The USAREUR G-4 obtained a waiver to this testing requirement, which was valid through calendar year 2003, from the U.S. Department of Transportation (DOT). The DOT waiver allowed USAREUR units to transport bulk fuel tankers three-quarters full without a current hydrostatic testing certificate, which afforded the transporters greater flexibility in transport load planning. The governments of Belgium, Germany, Italy, and The Netherlands approved the DOT waiver.
V Corps transportation specialists chose to purge most of their deploying bulk fuel tankers in order to maximize ship load-planning flexibility. Ship captains generally insist on carrying hazardous cargo on the weather deck, rather than in the hold below deck. Purging the fuel tankers allowed them to be stowed as inert (nonhazardous) cargo either on the weather deck or below deck.
In USAREUR, MAM was the primary resource for purging and hydrostatically testing bulk fuel tankers. The V Corps' decision to purge most of their fuel tankers created an unscheduled surge requirement for MAM. To meet deployment timelines, MAM began operating 24 hours a day, 7 days a week. Between the beginning of January and the middle of April 2003, MAM purged 611 pieces of fuel-carrying equipment and performed hydrostatic testing on 68 M969 trailers and 50 M978 trucks in support of deployments.
As a result of V Corps' decision to purge most of their fuel tanker equipment, deploying 1st Infantry Division units loaded spare fuel filters and other associated parts in the cabs of their fuel tankers. Storing and shipping these spare parts with the tankers would have given unit maintenance mechanics the ability to easily remove residual fluid left in the fuel tankers after the purging process and install new fuel filters at the seaport of debarkation after the vehicles were unloaded from the ship. However, when the fuel tankers were processed at a European seaport of embarkation, the Military Traffic Management Command (MTMC) required the filters and associated parts to be removed from the cabs of the fuel tankers and placed in a separate shipping container. [MTMC recently was renamed the Military Surface Deployment and Distribution Command.] Unfortunately, the shipping container with the filters and parts did not arrive at the port of debarkation in Iskendrun, Turkey, with the fuel tankers. It took a week and a half to locate replacement filters and arrange for their transportation. This problem was eliminated in subsequent deployments through closer and more timely coordination between the USAREUR G-4 and MTMC.
Although USAREUR was able to obtain a waiver from the German Government to deploy fuel tankers without a current hydrostatic certificate, this exemption will not continue indefinitely. USAREUR units are required to comply with the Status of Forces Agreement, changing European transport requirements, and the GGVSE. V Corps units can help themselves to be more in control of their future by developing a local purging capability. Doctrinally, purging fuel tanks is a unit maintenance responsibility.
Army-wide, personnel involved in transportation, hazardous materials, and maintenance should look again at their fuel tanker deployment procedures. As transportation standards evolve to include safe, environmentally sound procedures, the military will have to be prepared to complete missions while meeting these new standards. Army units that plan to deploy with fuel-carrying vehicles need to include purging and hydrostatic testing in their deployment training and planning.
PAUL A. BELL IS THE WESTERN REGION PROGRAM MANAGER FOR U.S. ARMY FORCES COMMAND CLASS VII AND IX CONTRACT MAINTENANCE FACILITIES. HE WAS AN AUTOMOTIVE EQUIPMENT SPECIALIST WITH THE U.S. ARMY EUROPE AND SEVENTH ARMY DEPUTY CHIEF OF STAFF, G 4, MAINTENANCE DIVISION, WHEN HE WROTE THIS ARTICLE. HE HAS A B.S. DEGREE IN BUSINESS ADMINISTRATION AND HAS WORKED FOR THE ARMY FOR MORE THAN 22 YEARS.
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|Author:||Bell, Paul A.|
|Date:||Jan 1, 2004|
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