Just Like keeping a car well tuned to get sound performance, checking under the environmental hood at tank wash facilities can help reduce pollution, improve regulation compliance, and enhance the bottom line.
That was the message presented at the National Tank Truck Carriers Tank Cleaning and Environmental Council Seminar March 30-31 in Savannah, Georgia.
Discussing the subjects were Howard Hill of R W Martin Process Water Solutions, Frank Reed of Benesch Friedlander, Coplan and Aronoff, Gary Carroll of The WCM Group Inc, and Marcel Debruge and John Coleman, both of Burr and Forman LLP.
Hill's presentation took a PowerPoint stroll through a typical tank wash facility, noting where energy was being wasted, and then defined ways to reduce the loss. He pointed out several trouble spots related to a boiler: flue (18% loss), radiation and convection (4% loss), blowdown (3% loss), resulting in a net boiler output efficiency of 75%-77%.
One way to cap energy loss is to insulate vats and storage tanks. Without insulation, three 1,000-gallon tanks could release enough energy that would add up to a loss of $950 per month. Steam pipes without insulation also discharge dollars into the air.
Hill noted that new equipment is on the market that can reduce energy loss and cost. He discussed a SuperHeater and a wastewater heat recovery system from Thermal Engineering of Arizona that are designed to improve efficiency.
Turning to regulatory issues, Reed reminded managers to stay on top of situations that can cause environmental challenges. He advised them to check for any potential violation of the Clean Water Act. Problem areas may develop in drainage ditches that can lead into streams and rivers. Site runoff can be from a discrete source, such as a pipe, an indirect conduit, or storm water. Equipment stored outdoors and exposed to rainfall can cause water pollution.
Waste such as used tires, paint cans, florescent light bulbs, and batteries require proper disposal. In addition, underground storage tanks should be on the list for evaluation.
Carroll pointed out that federal regulations require cleaning at an authorized facility for tank trucks that deliver certain hazardous air pollutants (HAP) to underground storage tanks. The tank wash must submit certification that it meets the requirements and demonstrate initial and continuing compliance with flare testing and record-keeping. A tank truck must be connected to a closed-vent system with a control device that reduces inlet emissions of HAPs by 90% by weight or greater. Carroll noted that this requirement (40 CFR Part 63) for control devices to vent HAPS is mandatory regardless of whether the state or federal agency requires a control device for the cleaning rack.
Coleman and Debruge emphasized the importance of regulatory compliance when entering confined spaces, including those that expose workers to harmful elements. They cited outcomes from various lawsuits and federal inspections by the Occupational Safety and Health Administration (OSHA).
Coleman noted that companies that document testing on tanks that have been thoroughly cleaned, dried, and vented may be able to justify testing only for oxygen and LEL before entry as long as atmospheric is the only potential hazard (no entrapment, etc) and there is continual forced air ventilation throughout the entry. Whatever the regulations and the procedures tank cleaning facilities follow for compliance, they must document all related actions, Coleman added.
Debruge said that the issue of toxicity testing must be addressed by each company engaging in tank entry because the gas meters currently in use may or may not test for traces of every substance cleaned at a given facility. Companies with multiple facilities should consider using the same or similar wash procedures and maintain documentation, usually consisting of air sampling data, showing that the wash process eliminates the possibility of toxic atmospheres. Doing so can enable a company to comply with OSHA toxicity testing requirements companywide. Rule violations come with serious penalty repercussions. Should a fatality occur as a result of violations, criminal charges can be filed, depending on the circumstances.
Debruge and Coleman said more federal wall-to-wall inspections are likely in the near future. When an inspector arrives, they recommended that all work be temporarily stopped and employees removed to a break area.
In addition, facility managers should:
Develop a plan for response to OSHA inspections.
Prepare supervisors and management for inspections.
Do not put on demonstrations of work processes at the request of the inspector.
Appropriately tell all personnel about their rights in an inspection process and before OSHA conducts any employee interviews.
Audit records and visible safety issues regularly.
Discipline personnel safety infractions consistently and document procedures.
Regulations related to environmental concerns continue to impact the tank cleaning industry, all of the speakers emphasized. However, taking a look at alternatives can be one way for improving operation efficiency.
Reed suggested considering wind and solar energy as ways to add a hedge in meeting today's demands. The options could give tank cleaning facilities a new way to handle cost control, energy savings, and regulation compliance that would keep the companies running smoothly into the future.