The home heating oil industry has a long and proud history, and Fuel Oil News has been there supporting it since 1935. It is an industry that has faced many challenges during that time. In its 77th year, Fuel Oil News is doing more than just holding
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B U L K PL A N T S lation, calibration, and maintenance. For that reason, plant owners who base their safety programs on static compliance with minimum published guidelines are put- ting themselves at risk. And even minimum compliance is a moving target since the regulations them- selves may change over time to keep up with advances in methods and materials. For example, although EPA has for decades required plant opera- tors to have a Spill Prevention Control and Countermeasure plan, a recent amendment to the Code of Federal Regulations (40 CFR 112) resulted in a significant change. Operators can face new fines for insufficient recordkeep- ing and employee 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 react- ing to change is not enough. “It’s a mistake to act only when you’re required to do so,” advises Savage, “or only when something breaks, because the problem will usually compound itself.” By contrast, a proactive stance helps operators avoid fines, avoid costly incidents, attain peace of mind, “and often save money on insurance pre- miums—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 service? EPA and OSHA operations often regulate differently by regions and zones of the country,” reports Savage. “Which prod- ucts 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 www.fueloilnews.com | FUEL OIL NEWS | JUNE 2011 19 answers, you can tackle environmental and safety issues.” Good design starts with system ques- tions because good designers must see the big picture. “You should think in systems,” Savage recommends. “How will a meter complement what is already installed? Who is offloading your product? How will you reconcile the inventory? What can cause build-up? Remember that pushing 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 metal- lurgy 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 recommendations from independent inspectors,” he adds, “once you implement the changes then you market these upgrades to your insur- ance 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, ergonomics becomes more important in protecting your employees from injury. And tying someone to a harness won’t necessarily provide fall protection if the equipment is old or inferior.”