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)
Service calls for rental companies of diesel equipment which involve hard starts, black smoke ( CA) and fuel injector problems is a royal pain in the butt. Steel Camel has put forth a presentation which explains the role of water management in Tier 4, High Pressure Common Rail Engines. The presentation review common best practices as well as some common mistakes fleet owner make.
Oh Vey!!! Another sump and spill bucket water alarm goes off after a big rain or snow melt means another phone call from the gas station to the contractor. Unfortunately for the station owner, this means unwanted money spent on removal, storage, transporting and disposal of Petroleum Contact Water or PCW. Additional headaches for the station owner include
In the old days, station owners could just pump the water out and pour into the flower bed. But have many stations have learned the hard way…….contaminated flower beds and the soil underneath the beds is not only bad news from state environmental regulators, but big money when it comes time for an environmental assessment from banks and property owners. Additionally, many states a local government flat out forbid this practice and heavy fines or citations can be issued. If one takes a look at the EPA standard - 40 CFR Part 280, there is a specific section, 280.36, which states containment sumps and spill buckets shall be kept free of liquid and debris. And for those who inspect and maintain such equipment, they must make notes if liquid and debris are present.
To reduce these problems, today’s savvy station owners are upgrading lids, leveling parking lots, raising concrete and containment areas, building new fuel pads etc. to combat water intrusion. That is great if the station has plenty of money, but even still, mother nature can wreak havoc. Fortunately, there is new technology from Steel Camel in the forms of water blocking gels, doughs and impregnated gaskets that offers a new and safe method to block water. The products are easily and safely applied by hand, and also easy to dispose of. This technology allows station owners either to have trained employees apply the product, or hire the service contractor supplying 30-day inspection services to apply the product.
But What About the Contractors Who Make Money Removing, Storing, Transporting and Disposing of Water?
Yes, there are some really good and reputable service and environmental companies that do a great job of removing, hauling and properly disposing water. Some make over $1.75 a gallon and have minimum charges of $600.00, and up to $800.00 in large metropolitan areas. While this may look good to the contractor from a billing standpoint, there are several problems with this model. Let’s take a look at just a few:
So… What Is The Answer for Contractors……….to pick up or block the water?
Since the implementation of EPA 40 CFR 280 standard and the introduction of Steel Camel water blocking technology, many of today’s savvy contractors are finding it more economical and a lot less headaches to provide blocking products and services rather remove and haul services. This is particularly true for those contractors who perform a) 30 day inspections, and b) see value in selling products off the truck during the service calls or inspections. And example of this is a contractor who see’s current and forecasted rain and they know they won’t be returning for 30 days, they sell a few tubes of Steel Camel AquaBlok Gel to Independent owners and operator who are willing to take 15 minutes to apply the product in exchange for no alarms going off and no bills for removal and disposal.
For more information and the Steel Camel guide to blocking water, please contact 813-877-4665.
Rubber Mats vs. Steel Camel to Block Water Intrusion in Sumps & Spill Buckets.
Since the first containment sumps were required some 30 years ago, station owners, inspectors and contractors have struggled to keep water out of the sumps during big rains and snow melts……….particularly in our home state of Florida where it rains ping pong ball droplets for 4o minutes…….all summer long. This matter has increased importance since state and federal rules 40 CFR Part 280 now mandate that containment sumps must be kept free of all liquids and debris.
The simplest answer is for a station owner to obtain a well-made lid and a matching well-made rubber gasket and then forget about it! Unfortunately, that situation doesn’t always work for a variety of reasons including:
Even with well made lids and matching gaskets, there are other issues such as excessive temperatures that cause expansions and cracks of concrete and metal. Some station owner are going to the lengths of rising the concrete an inch or two…….still, big rains are no match.
So with water intrusion station owner have to take extra steps to avoid compliance violations, alarms and the high cost of water removal, storing, transporting and disposal. Speaking of disposal fees, In today’s world the larger “Vac Trucks” are requiring a $500 minimum to come pump out a 100 gallons.
In todays world, there are a few options, 1) Rubber mats that act as a physical topical barrier. And 2), water blocking gels, doughs and gaskets where go underneath the lids and block water through both physical attributes and chemistry. Lets explore further.
Rubber Mats can be purchased online and run anywhere form $50-80 for one 44” mat They weigh about 25 pounds and have a tendency to get heavier the more they soak up rain.
The benefits are they will block the water over a long time if left un disturbed and everything works according to plan…………..but we are talking gas stations and lots of traffic.
The drawbacks of rubber mats are many including:
Steel Camel Water Blocking Products
Seeing that the rubber mats were not working very well, Steel Camel create water blocking products with its patented water blocking technology https://www.youtube.com/watch?v=QLj95QLErDs&t=10s .
Each products works by suing the water blocking principals in the chemistry. The more it rains, the more they each block water. Three products are currently on the Steel Camel roster.
How Long Do the Products Last?
The longevity of each product is different. The AquaBlok Gel is averaging 2-3 week at a normal station and 1-2 weeks at a super busy station. The application with a caulking gun is quite simple and costs about $9.00 per application.
The Dead Snakes are lasting 3-4 months even during harsh winters and heavy rains. They products are meant to be used by contractors, store owners and inspectors who are maintaining the station and typically the ones to open lids.
In summary, rubber mats look great on the surface…….until mother nature or the public kicks in……..both unavoidable. Steel Camel products have both innovative technology and innovative applications to solve this complex problem of water intrusion. For more information, please contact Steel Camel at 813-877-4665.
It is a given that UST sumps contain lots or dissimilar metals, often which are porous. It is also a given that there are going to some forms of water or humidity in the sumps. Also, some fuel vapors, primarily ones with organics (corn) excrete a bacteria that creates an acid. This combination results in rust that can wreak significant havoc and cause component to failure.
One of the first attempts to combat this problem by industry contractors and station owners was to go to some form of paint or coating. The main reason is these products are readily available. The theory is that one can cover or smother the metal to cut off the oxygen, thus prevent rust. After seeing the results of rust coming back after six months, many contractors and station owners moved to more aggressive / durable coating and more aggressive preparation. Unfortunately, paint prep often involves removing metal, which ultimately weakens the metal. Another attempt by industry was to use an acid as preparation product such as Naval Jelly. The problems with this preparation is it requires a rinse, which creates a hazard waste. Also using acids in sumps can have negative effects on metal if not rinsed properly.
The next problems contractors encountered with paints & coating was adhesion problems. The metals are porous, the surfaces are imperfect and not all metals readily accept paints and coatings. So many contractors tried to overcoat the surfaces and really smother the surfaces. What happens is the rust underneath the paint expands and causes blisters and paint no longer to adhere creating another set up problems. One problem is inspectors could not see rust hidden by the paint. Another problem was it became very difficult to remove fasteners and other components during repairs or replacement, thus increasing labor and safety concerns. Furthermore, removing paint in confined spaces is a major headache.
Another problems with paints and coatings in sumps is they often the cure hard and become rigid. The problems with such characteristics is the pumps vibrate, and metals expand and contract during temperature swings. This can lead to cracks, which allow the water to creep under the paint and due further damage.
In summary, paints and coatings simply du not hold up well in confined spaces with humidity and vibration. Contractors and station owners are better off with corrosion treatments, such as the one Steel Camel offers.
For additional information alternative products to paint to slow down corrosion, please contact Steel Camel at 813-877-4665
Dan Jenkins: Tampa, FL
Long before electronic surface mount technologies were invented, moisture caused corrosion problems on metallic surfaces. From ancient swords and armor, to Egyptian jewelry to early telephone cable, metal components always want to return to its original state and the oxidation / corrosion problems process began. Early attempts to preserve and protect metal included animal fats, organic oils and coatings made from ashes, minerals and tree sap etc.
In today’s world of surface mounted technology, the problems are no different. Metal components are placed in confined spaces and when temperatures change, humidity happens. When this liquid or vapor lands and sits on the metal, general corrosion occurs. Corrosion on boards causes failures, and failures cost the industry millions of dollars to fix. To protect these boards from failure moisture induced corrosion, manufacturers, assemblers and packagers have turned to different technologies to solve this issue. One way is with a conformal coating which is thin film. Often times they work great and there are no problems. Other times, the crack and cause all types of problems, including removal.
In this article we will focus on different types of drying agents or desiccants. In another article we will cover other types of corrosion occur such as pitting, galvanic and stress.
Let’s start of my understanding what a desiccant is and does. A desiccant is basically a drying agent. Most folks are accustomed to seeing them in pill bottles, vitamins and beef jerky. Today, many in the surface mount technology community are seeing them show up in individually packaged components.
One of the reasons for this is the Military Specification D-3464. This specification was written in 1967 with minor revision in 1987….that was a long time ago. This spec calls for a desiccant which acts as an adsorbent, not be confused with an absorbent. While the words sound the same, they have different meanings. An adsorbent works by moisture sticking to the surface of desiccant. An absorbent works by the moisture being soaked up and held by the substrate. A baby diaper works on this principle; however, a baby diaper will not grab moisture from the air.
If you get deeper into industry specs and industry standards such as the Joint Electron Device Engineering Council (JEDEC) Institute for Printed Circuits IPC, you will find they too reference the Mil-D-3464 spec, which includes a placement of adsorbent desiccant and a Humidity Indicator Card.
So, what’s the problem? If the spec is good enough for the military and good enough for the two leading PCB / electronic associations, why should I care?.....Here is why…
The adsorbent, often times referred to as Silica Gel Beads or Molecular Sieves are basically dried sand or Silica, baked in an oven. The baking creates tons of miniature cracks that help adhere the moisture to the surfaces. Sounds great on the surface, but let’s look a little deeper.
Disadvantages of Silica Gel
There are two main problems. First, due to the material being rigid, the beads do not hold much moisture. So, if your boards are sitting in a hot warehouse or on a ship with lots of temperature changes, the Silica Gel beads can’t handle the volume of moisture and the HIC is triggered.
The second main problem is knockoffs and quality checks. Due to the low cost of raw materials, many bags are made overseas and in large volumes which makes quality control difficult.
Advantages of Silica Gel
They are incredibly inexpensive. A simple 2”x2’ bag can be as low as .25 cents and if you purchase them in China, you can get them for .12 cents. Another advantage of Silica Gel beads are they are treated with chemical dye which will provide a color change to alert the operator when to change out. There are some who claim Silica Gel beads can be regenerated in an oven, but with that low of price, why bother.
Advantages of Absorbents
Absorbents, such as the Moisture Hog sold by Steel Camel, not only feature an expandable surface to grab more moisture, but they also hold the water by converting water into a non-water element and make it dry. See video youtube.com/watch?v=kli3OMrFUD4) Another advantage of Moisture Hog absorbent is will seek out moisture lurking in the package. Due to these features, the operator will be able to desiccate a much greater volume of air, thus put more board in per package. Often 10 to 15 time more volume. This feature saves labor and packaging material.
Another advantage of Moisture Hog absorbent is the change indicator. Instead of a color change, the Moisture Hog bag will change shape and texture. Depending on the situation, it will either blow up like a pillow, or get hard like a rock to notify the operator a change is needed.
Disadvantage of Absorbents
The Steel Camel Moisture Hog price per bag is more expensive compared to Silica Gel and Molecular Sieves. Often 10-15 times more (which offset by the volume of air desiccated) Another disadvantage is they chemistry cannot be regenerated. Finally, availability. Steel Camel is not Walmart or Amazon. Expect 5-7 days for delivery in the US, 8-12 days abroad.
If you are not having and moisture problems, rejected shipments or component failures due to moisture, stick with Silica Gel Beads and Molecular Sieve adsorbents. If you are having such moisture problems, consider trying the Moisture Hog by Steel Camel…..particularly for your expensive critical moisture sensitive devices.
Dan Jenkins, principal at Steel Camel can be reached at 813-877-4665 or firstname.lastname@example.org