National Petroleum News (NPN) has been the independent voice of the petroleum industry since 1909 as the opposition to Rockefeller’s Standard Oil. So, motor fuels marketing and retail is not just a sideline for us, it’s our core competency.
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And even minimum compliance is a moving target since the regulations themselves may change over time to keep up with advances in methods and materials. For example, although EPA has for decades required plant operators to have a Spill Prevention Control and Countermeasure plan, a recent amend- ment to the Code of Federal Regulations (40 CFR 112) resulted in a significant change. Operators can face new fines for insufficient recordkeeping and employ- ee training. “This is just one example,” says Savage, “of how an old regulation can still be in effect, but you also need to know the impact of changes in order to remain compliant.” A static safety program is untenable because merely reacting to change is not enough. “It’s a mistake to act only when you’re required to do so,” advis- es Savage, “or only when something breaks, because the problem will usu- ally compound itself.” By contrast, a proactive stance helps operators avoid fines, avoid costly incidents, attain peace of mind, “and often save money on insurance premiums—which I’ve seen many operators do. Because when you improve safety, you reduce risk.” DESIGNS AND UPGRADES Plant safety starts with the right design—and good design begins with asking the right questions. “What geo- graphic areas will your terminal ser- vice? EPA and OSHA operations often regulate differently by regions and zones of the country,” reports Savage. “Which products will you store? Safety measures must sometimes be tailored to particular fuels and blends. And how do you plan to make transfers? You need to determine proper flow rates to ensure safety. When you have answers, you can tackle environmen- tal and safety issues.” Good design starts with system questions because good designers must see the big picture. “You should think in systems,” Savage recom- mends. “How will a meter comple- ment what is already installed? Who www.npnweb.com n NPN Magazine is offloading your product? How will you reconcile the inventory? What can cause build-up? Remember that push- ing one domino will have an effect on the rest. So you must look at the total picture of plant storage and transfer.” For example, to reduce the risk of fire and explosion operators must be aware of many factors. “Consider the velocity of product in the line as well as the metallurgy of the piping,” advises Savage. “The faster the product velocity, the more important it is to use the right size of piping in order to reduce static build- up.” In addition, specialized guidelines for dispensing flammable fuels are stipulated by the NFPA (National Fire Protection Association) Code. At a minimum, Savage suggests that sites be visually inspected at least once a year. “And as you get recommenda- tions from independent inspectors,” he adds, “once you implement the chang- es then you market these upgrades to your insurance company and request a reduction in your premiums.” Upgrades can likewise have important spinoff benefits. As SafeRack’s Semiklose points out, “A lot of equipment in use today at bulk plants is heavy and outdated. But as the workforce ages, ergo- nomics becomes more important in protecting your employees from injury. And tying someone to a har- ness won’t necessarily provide fall protection if the equipment is old or inferior.” Employees themselves may forego the use of fall protection and other safety equipment if they believe it makes their work more laborious and difficult. In choosing equipment, bulk plant operators should keep this fact of human nature in mind. For example, in choosing between load- ing rack options, Semiklose advises operators to “take into account how your employees need to open hatch- es and whether they will be inspect- ing the interior of the tank. A good understanding of what they’re actually MAY/JUNE 2011 17