WHAT IS RAFS?

• Organized in 2004 to Assist Rural Alaskan Communities Manage Their Bulk Fuel Facilities.

• Not-for-Profit Corporation.

• Initial funding provided by Denali Commission

WHY RAFS?

– Must Follow all State and Federal Regulatory Requirements

• Sustainability Requirements Implemented for Bulk Fuel Facilities

– Must have a Business Plan

• Must demonstrate financial ability to operate facility

• Must set aside renewal and replacement funds

WHAT WE DO• Tank Farm Operation

– Training• HAZWOPER/Spill

Response• Bulk Fuel Facility

Operations/PIC

– Maintenance and Repair– Line Testing– Inspections and Non-

Destructive Testing– Spill Exercises

• Business Planning and Analysis

– Financial Review & Budgets

– Pricing

– Credit and Collections

• Decommissioned Tank Demolition

• OSHA Regulations

– Information Resource– Facility Response Plans

• STI Certified Tank Testing

• Tank Painting

REGULATORY REQUIREMENTS

• Spill Prevention, Control and Countermeasures (SPCC)– SPCC is required by the EPA– Must be signed off on by a Professional Engineer– Must be renewed and updated every 5 years– Must include a schedule for certified tank inspections, depending on the age and

condition of the tanks• If there is no documentation describing the age and specifications of the tanks, a non-

destructive (ultrasound) test must be done to establish a baseline

• Facility Response Plan (FRP)– The FRP is required by the Coast Guard– Must be kept current and have Coast Guard approval– Includes:

• Emergency contacts• Persons authorized to receive fuel• Spill response equipment list

REGULATORY REQUIREMENTS

• Training:– Annually all operators must have 8 hours of training– Persons receiving fuel should be trained in proper procedures– HAZWOPER certification is required of anyone responding to a spill– All training must be documented and available for Coast Guard review

• Spill Exercise Requirements– 4 spill exercises must be performed annually

• 3 can be tabletop or telephone exercises• 1 must be a full deployment exercise

– All exercises must be documented and available for Coast Guard Review– Spill response materials and equipment must be inventoried annually and kept in

compliance with the equipment listed in the FRP

• Tank Integrity Testing– Must be specified in the SPCC based on tank age and condition– May be certified visual inspection or non-destructive testing, depending on the

judgment of the Engineer

DEMOLITION OF DECOMMISSIONED BULK

FUEL TANKSWhy We Do It:• Environmental Hazard

– We have found as much as 400 gallons of fuel remaining in abandoned tanks

• Health and Safety– A child playing on an abandoned tank in Savoonga

fell in– Kids in Selawik found access to an already cleaned

tank and used it as a “huffing” station

WHO IS RESPONSIBLE

• Owners and operators of the tank farm may be held liable. The government may look to past owners if the current owners are unidentified or unable to pay for environmental remediation.

WHAT WE DO

• Tanks are checked for remaining fuel and pumped dry• Empty tanks are left open and vented for several days• Access is cut into the tank and the interior cleaned.

Sludge and absorbents are burned in a smart-ash burner • Tanks are tipped on their side and cut into sections and

then cross sections• Some tank bottoms are left intact and used as “buckets”

to stack scrap metal in• “Buckets” are moved to local landfill• If back haul becomes available at reasonable rates,

“Buckets” can be lifted to move to barge

What it Looks Like

TYPICAL CORROSION

KNOCK TANKS OVER TO PROVIDE ACCESS

CUT TO “MAN-SIZE” PIECES

LOAD IN “BUCKET”

BUCKETS IN THE DUMP

CHALLENGES

FUNDING SOURCES

• RAFS is actively seeking funding to remove these hazards through CAPSIS requests to the State of Alaska and funding through the Denali Commission. Other potential resources include CDQ organizations and Native Non-Profit Corporations.

HOW YOU CAN HELP

• INVENTORY OF DECOMMISSIONED TANKS– There is NO comprehensive inventory of decommissioned tanks in rural Alaska

• Forms are available from RAFS to identify and list tanks in your community• Inventory should include size, ownership and cleaned/uncleaned status of

tanks.– Letters of support from the City, Tribe and Village Corporation.

– All funding sources we have contacted expect contributions from the community and/or owners. Contributions may be “in kind”. These include:

• Use of heavy equipment• Authorization to store scrap until such time as a backhaul can be arranged at

a financially reasonable cost• Lodging for technicians doing the work

CONTACT US!

• CEO – Del Conrad– dconrad@rafs.net– (907) 227-1498

Rural Alaska Fuel Services, Inc.

6000 “C” Street, Suite 201

Anchorage, AK 995518