By Dan Jenkins, Accident Prevention Specialist for Steel Camel.
Short of a fueling station blowing up and / or catching on fire, there is nothing worse for station owners than a release of fuel into the public drinking water supply. Although it is very infrequent that these events occur, it does happen. So therefore, it is best for UST regulators stay aggressive and encourage “best preventative maintenance practices” so the chances of release are significantly minimized. This is particularly true in today’s environment with the advent of new fuels that have not been fully demonstrated to perform against corrosion in both new and old tank equipment. There is a saying amongst accident investigators, “small problems turn into big problem and small corrosion spots can turn into corrosion holes.”
We have compiled a list of seven tips to help regulators and inspectors identify and correct commonly found corrosion issues….all of which are directly or indirectly related to water intrusion and many found in the latest version of 40 CFR 280.
For reference purposes, we have taken some meaningful text from both the EPA OUST website and specific language from the standard itself.
When a test or inspection occurs, owners and operators may find problems with the UST system. When a test or inspection indicates a problem, owners and operators must repair the problem to remain in compliance with this final UST regulation. Section 280.33 of this final UST regulation describes repair requirements for UST systems.
§ 280.36 Periodic operation and maintenance walkthrough inspections. (a) To properly operate and maintain UST systems, not later than October 13, 2018 owners and operators must meet one of the following: (1) Conduct a walkthrough inspection that, at a minimum, checks the following equipment as specified below:
§ 280.43 Methods of release detection for tanks
(6) The measurement of any water level in the bottom of the tank is made to the nearest one-eighth of an inch at least once a month.
§ 280.50 Reporting of suspected releases. Owners and operators of UST systems must report to the implementing agency within 24 hours, or another reasonable period specified by the implementing agency, and follow the procedures in § 280.52 for any of the following conditions: (a) (b) Unusual operating conditions observed by owners and operators (such an unexplained presence of water in the tank,
TIP #1 – Better Understand thE Definition of Damage
The 40 CFR 280 standard states owners must check for damage, but standard does not define what damage is………only if the equipment isn’t working properly and in need of repair. Also, the standard does also does not identify a measurement for corrosion, it left up to owners and inspectors to make that call. Here is a good rule of thumb to use that was eloquently explained by federal judge Potter Stewart as he attempted to explain "hard-core" pornography, or what is obscene, by saying, "I shall not today attempt further to define the kinds of material I understand to be embraced... “but I know it when I see it “...
TIP #2 – MAKE CONNECTIONS WITH THE STATE DEPARTMENT OVERSEEING FUEL QUALITY INSPECTIONS
This department is generally handled by Departments of Agriculture and they are important because these inspectors conduct tests for both free water and suspended water under the standard of National Institute of Standards and Technology (NIST) 130.
This test calls for inspector to execute a test which draws fuel from the tank and inspect for clarity. If the fuel is not clear, it is primarily due to suspended water. Suspended water causes corrosion problems to both the tank, internal parts, piping and risers…..both in steel and FRP tanks. When regulators find station owners who repeatedly fail these visual tests, it makes sense to dig deeper why are these tanks having suspended water issues.
Tip #3. Dig Deeper into Alarms Caused by Free Water
While many contractors and station owner report all the alarms for high water level that go off, it is a good practice for regulators to investigate why such alarms do go off. 40 FR 280.50 requires that station owners explain the presence of excessive free water in the tank? Remember, if water can get into a tank, there are chances fuel can be release from a tank.
Tip# 4. Dig Deeper to Why There is Excess Water in Sumps?
Section 280.36 states sumps and spill bucket container must have liquid removed and if one digs deeper into the EPA OUST writings, they imply spill containers must be free of liquid. Inspectors should attempt to determine what percentage is water and what percentage is fuel.
Is the lid or receptacle damaged?, was the lid improperly installed? Is there a crack in the lining? Or does the situation call simply for water blocking agents? Whatever the problem, regulators should do their best to help station owner correct the problem.
Tip# 5. Dig Deeper to Why There is Excess Water in Spill Buckets?
Just like tip #4, Excess water in spill buckets leads to problems. The same goes for inspection and installation of lids, however this tip features a whole new dynamic….delivery drivers. While the majority of drivers are professional, there is always a few bad apples who do not put lids on correctly or allow water to enter into openings. While these drivers are regulated under the Department of Transportation, its wise to find and interact with all delivery drivers and educate them on the importance of keeping tanks and containment devices free of water.
TIP #6 – Advocate to Avoid Paint or Coatings in Sumps
While it is perfectly legal for contractors to repaint turbine motors and piping to make them “oh so pretty,” there are often times numerous problems with paint in containment sumps.
Tip # 7 Ask to The See Used Fuel Filters Bin.
While inspectors typically do not go this far, it might be wise to investigate these filters particularly if the station has history of alarms, repairs and fuel quality issues etc. The insides guts of filters can tell you a lot such as
If you are interested to learn more about the problems and solutions related to water and USTs, please contact Steel Camel at (813-877-4665). At Steel Camel we want to help regulators, contractors and tank owner avoid the most common and costly tank problems that can lead to a release.
Since water and moisture hover all around us, as well as hover around our computer boards and electrical parts, Circuit Board and Microelectronic manufacturers, assemblers and end users around the world are concerned about the effects of moisture causing corrosion on their products. There are many reasons for this concern, but the main one is board failure which can cause a major accident and or shutdown. So today, technology savvy companies turn to organizations like the Joint Electron Device Council (JEDEC) and Institute of Printed Circuit (IPC) to build some standards of performance which will help them:
Today, JEDEC publishes a standard, J-STD-033, which provides guidance for reducing moisture during the handling, shipping, and storing on Moistures Sensitive Devices (MSD). In this standard, it states that MSDs must be stored in dry packs consisting of desiccant material and a Humidity Indicator Card (HIC), sealed with the MSD packaged inside a Moisture Barrier Bag (MBB).
Additionally, the J-STD-033 goes on to reference which type of desiccant material should be used in the Dry Pack by referencing the desiccant referenced by the US Military specification, Mil-d- 3464. If one digs deep into this mil spec, as this author has done, one will find the spec refers to an adsorbent type of desiccant, not an absorbent type of desiccant………………….big difference! Also, for those who wish to dig a little deeper into the desiccant, you find out that Mil Spec d-3464 was written in 1967……………a lot has changed in circuit boards and microelectronics since that time……….so has the technology in desiccants. So, it wise for engineers to perform comparison tests to determine efficacy and performance.
In previous posts and videos we have highlighted the differences and characteristics of adsorbents and absorbents: https://www.youtube.com/watch?v=0U6kIsGj9X8&t=15s. This post / article will examine how engineers and quality control managers can test and evaluate the performance of each desiccants bag technology so they can make the best decisions when it comes time package, store and maintain critical MSDs.
What Tests Should Engineers Perform?
There are basically four main tests that should be performed to determine the efficacy of different desiccant bags.
Test the materials at 25 degC (=/- 1degC) at a range of humidity from 20-80%RH. Start at 20% increments (20-40-60-80) and retest if there is any concern with smaller increments. The humidity tolerance will be +/- 2%RH. **
The tester should take equal weight Silica Bead and Expanding Polymeric bags and test for and record the following.
**This test procedure was supplied to Steel Camel by the engineer at the US Army.
2. Windowsill or Heat Lamp Test In this test, the engineer should take an absorbent bag (Polymeric) and adsorbent bag (Silica), the secure them both to two separate jar lids (tape or string) and then deposit a ¼ teaspoon of water in the bottom of the jar and close the lid. Let the jars sit in a windowsill that gets sun for three to five days and record the findings.
3. Shipping TestIn this test, you take an absorbent bag and adsorbent bag and place them in an MBB along with a HIC. Additionally, you introduce a few drops of water in the bag. You then mail the bags to various facilities in your organization or vendors you trust and ask them to open the MBB and record the findings of the HIC and the condition of the bag and its insides. Then ship the same set up back to your facility and record the findings. This test is valuable for companies that have multiple shipments of parts, particularly if they ship overseas.
4. Specific Environment Test In this test, the engineer would test the different bags in the MBB’s in harsh environments which their equipment will encounter. For example, a non airconditioned in warehouse in Florida can get quite humid in the summer times. Additional scenarios in include locations where temperatures can change over 35 degrees in a single day such as Denver, CO, or Chicago IL. Marine environments, glass atriums and frozen climates like Alaska can all be great places to conduct tests to help determine what type of bag offers the greatest control of moisture. The engineer should use the HIC card and the changes of weights of the different bags to help determine which bag provides the best results.
Additional comparison tests engineers can perform:
I think we all can agree that desiccants play an important role in protecting critical parts from moisture causing corrosion in enclosed spaces. And, I think we can all agree that new technology comes around from time to time which proves to increase performance and productivity of specific processes…….remember the automobile replacing the horseless carriage and the cell phones maps replacing the paper maps? Finally, I think we call agree that marketers and advertisers can stretch the truth and use words that prove to be a contradictory in terms.
Therefore, it is up to engineers to use their skills to determine the performance of specific products for specific applications to help their companies increase productivity and reliability, as well as reduce risk. We hope the above described tests will prove valuable to individual companies and the entire industry.
Mil Spec D 3464
US Army Packaging, Storage, and Containerization Center (PSCC)