Hydrostatic testing and purging of fuel tanker equipment in USAREUR

Army Logistician,  Jan-Feb, 2004  by Paul A. Bell

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Preparing hundreds of pieces of fuel tank equipment for deployment by road, rail, barge, and ship from Europe to Southwest Asia for Operation Iraqi Freedom was a significant logistics challenge and an intense learning experience for U.S. Army Europe (USAREUR). The equipment included 5-ton tractors with M967 and M969 5,000-galloon semitrailers; M978 2,500-gallon heavy, expanded mobility tactical trucks; 1,200-gallon tank and pump units; and 600-gallon fuel pods mounted on trailers.

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.