Department of Defense (Dod) Underground Storage Tank (UST) Compliance Strategy Report
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OFFICE OF THE UNDER SECRETARY OF DEFENSE 3000 DEFENSE PENTAGON WASHINGTON, DC 20301-3000 ACQUISITION TECHNOLOG AND LOGISTI AUG 1 5 2006 The norable Stephen Johnson Admi istrator, United States Environmental Protection Agency 1200 ennsylvania Avenue, NW, MC0001 Wash ngton, DC 20460-0001 ursuant to Section 1528(b) of the Underground Storage Tank Compliance Act of 2005, enclosed is the report concerning the Department of Defense (DoD) underground stora tank (UST) compliance strategy. This report includes data from the Army, Mari e Corps, Navy, Air Force, and the Defense Logistics Agency on USTs owned by or opera ed on DoD installations, as well as for those non-DoD owned or operated USTs locate on DoD installations . As this report details, DoD continues to make progress in its en ironmental compliance programs . similar letter has been provided to the Committee on the Environment and Public of the Senate and the Committee on Energy and Commerce of the House of sentatives. If you or your staff have any further questions or need additional ation, please contact Mr. Edmund D . Miller at (703) 604-1765 (e-mail : d.miller u,osd.mil ) . Sincerely, ili . one Deputy Under ecre of Defense (Installations and Environment) Encl As st pFfEtt " A1% ~ ~ ~ ~~~ Kling - EPA C«~ :~1t~p~- r1~~ I HE EXEW I i vL SECHETAAIAT DoD Underground Storage Tank 1 DUSD (I&E) Compliance Strategy Report, August 2006 DoD Underground Storage Tank 2 DUSD (I&E) Compliance Strategy Report, August 2006 I. Introduction The Energy Policy Act of 2005, Public Law 109-58, was signed by the President on August 8, 2005. Title XV, Subtitle B, established the Underground Storage Tank Compliance Act (UST Compliance Act) of 2005. Section 1528 (b) of the UST Compliance Act requires, within one year, “each Federal agency that owns or operates one or more underground storage tanks, or that manages land on which one or more underground storage tanks are located, shall submit to the Administrator, the Committee on the Energy and Commerce of the United States House of Representative, and the Committee on the Environment and Public Works of the Senate a compliance strategy report that: (A) Lists the location and owner of each underground storage tank described in this paragraph; (B) Lists all tanks that are not in compliance with this subtitle that are owned or operated by the Federal agency; (C) Specifies the date of the last inspection by a state or Federal inspector of each underground storage tank owned or operated by the agency; (D) Lists each violation of this subtitle respecting any underground storage tank owned or operated by the agency; (E) Describes the operator training that has been provided to the operator and other persons having primary daily onsite management responsibility for the operation and maintenance of underground storage tanks owned or operated by the agency; and (F) Describes the actions that have been and will be taken to ensure compliance for each underground storage tank identified under subparagraph (B). This UST Compliance Strategy Report provides information about location, compliance status, regulatory inspections, violations, operator training, and follow-up actions of USTs owned or operated by Department of Defense (DoD) Component installations and for those not owned or operated by the DoD Component installations but located on DoD property. The DoD inventory information is summarized in this report. The DoD Component data are summarized in Appendix A. Appendices B through E contain the actual DoD Component data. II. Guidance for UST Compliance Strategy Report While developing this report, DoD consulted U.S. Environmental Protection Agency’s (EPA) “Guidance for Underground Storage Tank Compliance Act 2005 Federal Facility Compliance Reporting,” which established criteria for defining and reporting compliance data for federal agencies. There are several key guidelines that DoD used to develop this report. A. Definition of USTs: This report includes “federally” regulated USTs as defined in regulation 40 CFR 280.12 except for USTs excluded in 40 CFR DoD Underground Storage Tank 3 DUSD (I&E) Compliance Strategy Report, August 2006 280.10(b) and 40 CFR 280.10(c). B. DoD Component USTs: This report includes those USTs owned or operated, or on lands managed by the Military Services (Army, Marine Corps, Navy, and Air Force). USTs owned or operated by the Defense Logistics Agency (DLA) are included in the inventory for the Military Service that owns the real property. The Army inventory in Appendix B includes 166 state owned and operated Army National Guard USTs that are not located on DoD property. These are not included in the DoD summary tables (Section IV and Appendix A) because they are not DoD owned or operated. Army Corps of Engineers USTs are not included in the Army inventory, as a separate report will be submitted. Army and Air Force Exchange Service USTs are reported in accordance with their respective Military Service location; USTs on Army installations are reported in Appendix B and USTs on Air Force installations are reported in Appendix E. Navy Exchange Services USTs are also reported in accordance with their respective Military Service location. Navy Exchange Services USTs on Marine Corps installations are reported in Appendix C and USTs on Navy installations are reported in Appendix D. C. Non-Compliance Status: The date of March 31, 2006 was selected to provide a snapshot in time to determine the compliance status for each DoD UST. In addition, Army data included the compliance status of 46 Army owned/ operated USTs that were inspected after March 31, 2006. The non- compliance status of each UST was determined based on the last inspection of the UST and the status of any non-compliance. III. Data Collection Overview DoD Component data to support the requirements of the UST Compliance Act were collected from the Army, Marine Corps, Navy, Air Force, and DLA. Appendices B through E provides DoD’s Component data on: • UST Installation Name and Location • UST Identification Number • Owner and Operator • Date of UST Inspection • UST Status as of March 31, 2006 • Prevalent Violations • Actions Taken for USTs Out of Compliance • Action Status for USTs Out of Compliance The DoD operator training is summarized in Section IV. C. DoD Underground Storage Tank 4 DUSD (I&E) Compliance Strategy Report, August 2006 IV. DoD Summary This Section contains a summary of the federally regulated USTs located on DoD Component property, DoD owned/operated UST compliance status, and UST-related training. Detailed data collection results for the DoD Components are presented in the Appendices. A. USTs Owned or Operated By DoD Figure 1 and Table 1 show the distribution of USTs owned or operated by each DoD Component. There are 4,355 USTs on DoD property, and 4,314 are owned or operated by DoD. USTs operated by DLA are accounted for in the Army data. Out of the 4,355 USTs on DoD property, 41 are owned or operated by other non-DoD entities. Thirty-eight are non-federally owned and three are owned by another federal agency. One Navy non-DoD federal UST is owned by the U.S. Department of Energy at Naval Region Hawaii, one Air Force non-DoD federal UST is owned by the Federal Aviation Administration at Otis Air National Guard Base, Massachusetts, and one Marine Corps non-DoD federal UST is owned by the Federal Bureau of Investigation at Marine Corps Base Quantico, Virginia. Figure 1. DoD-Owned or Operated USTs Total: 4,314 DoD Underground Storage Tank 5 DUSD (I&E) Compliance Strategy Report, August 2006 Table 1 DoD USTs Total on Component Non-DoD Component DoD-Owned/Operated Property Owned/Operated Army 1,286 1,255 31 Marine Corps 143 136 7 Navy 812 811 1 Air Force 2,114 2,112 2 DoD Total 4,355 4,314 41 B. UST Compliance Status The current compliance status of DoD Component USTs is based on regulatory inspections on or before March 31, 2006. DoD has established three levels of compliance status for its USTs. 1. Compliance - Tanks inspected prior to March 31, 2006, and determined to be in compliance with state and federal regulations and having no written non-compliance record, or no unresolved non-compliance issues from the last regulatory inspection. 2. Non-compliance - Tanks inspected prior to March 31, 2006 and determined to be in non-compliance, based on the following unresolved written regulatory notices: a non-compliance checklist, a non-compliance letter, a Notice of Violation (NOV), or a warning letter. 3. Not inspected - Tanks that have not been inspected are not considered either in or out of compliance. Table 2 displays the total number of DoD USTs inspected on or before March 31, 2006. Seventy percent of the DoD USTs were inspected at least once by either a federal, state, or local regulatory agency. Table 2 DoD UST Regulatory Inspection Status Total DoD Total Percent Not Total Inspected Percent Inspected Owned/Operated Not Inspected Inspected 4,314 3,021 70% 1,293 30% Table 3 shows the total number and percentage of the inspected USTs and their compliance status as of March 31, 2006. Summary details on the compliance status for each DoD Component UST are in Appendix A. DoD Underground Storage Tank 6 DUSD (I&E) Compliance Strategy Report, August 2006 Table 3 Compliance Status for Inspected DoD USTs Total Total Percent In Total Out of Percent Out of Inspected In Compliance Compliance Compliance Compliance 3,021 2,956 98% 65 2% Of the USTs inspected by a regulatory agency, 65 USTs (2%) are out of compliance as of March 31, 2006. For these USTs, 19 are awaiting regulatory approval for completion, 35 are in the process of completing actions, and 11 have projects waiting final approval.