F u e l Ta n k M a i nt e na nc e & Ne w I ns pe c t i on ......Sub Based Tank Cleaning:...

N C H E A LT H C A R E E N G I N E E R S A S S O C I AT I O N

A N N U A L C O N F E R E N C E & E X H I B I T I O N

A U G U S T 9 , 2 0 1 8

F u e l Ta n k

M a i n t e n a n c e &

N e w I n s p e c t i o n

R e q u i r e m e n t s

Introductions

S T E V E B U R R I S

P E T R O L E U M RECOVERY S E R V I C E S

President

• 40 years of experience in oil &

chemical, tank cleaning & maintenance

business

• Certified STI Tank Inspector

• 25 years in fuel industry

• Owner of a fuel testing

production lab at the

forefront of the fuel testing

industry

Petroleum Recovery Services

L A R R Y S T E C K M A N

F O I L A B O R A T O R Y, N A T I O N W I D E

F U E L T E S T I N G

President

Today’s Discussion

• Fuel Quality Issues

• Corrosion

• Fuel Chemistry & Water in Fuel

• Floating Suction

• Generator warranties

• Sub Based Tank Cleaning

• Tank Inspections and Compliance



Investigation of Corrosion-

Influencing Factors in

Underground Storage

Tanks With Diesel Service

What is causing this onset of

corrosion?

Onset of corrosion reports began in 2007, also when

EPA started making changes in our fuel supply:

↓ Decreased sulfur in diesel fuel from 500ppm to

15ppm = ULSD

↑ Increased volume of ethanol and biodiesels

blended into fuel supply


Changes in national fuel supply

The Law of Unintended Consequences

Interface Layer

Microbiological Growth

Acidic

Atmosphere Humidity

Microbiological Influenced Corrosion (MIC)

Even if you have

fiberglass tanks, the

ethanol picked up during

transportation may have

already started the

delaminating process.


WATER

OXYGEN

Two Main Causes of Corrosion


Prevention & Treatment: Water in Tanks

• Water is the major cause of

contamination in fuel and fuel

tanks

• Without water, there is no life

• Monitor, Remove, Eliminate


Prevention & Treatment: Oxygen in Tanks

• Humidity promotes

condensation

• Keep tanks full

• Nitrogen blanketing

FUEL QUALITY ISSUES

& SOLUTIONS



Ultrasonic Fuel Sensor

• Current methods to determine water in a

fuel tank rely on floats connected to probes

within the tank, sticking tanks with water

detecting paste, and performing annual fuel

analysis. There are inherent problems with

all of these methods.

• What needs to be developed is a fuel quality

sensor capable of detecting particulate

matter, free and emulsified water. This has

been accomplished in other industries by

using ultrasonic equipment through the

transmission of sound.


FOI Trend Dashboard

• To develop a better understanding of this

aging fuel delivery infrastructure, FOI labs

recommends a baseline of testing of the fuel

to establish a systematic approach of

monitoring fuel.

• FOI recommends aligning with the EPA fuel

protocols used in the 2016 report to

compare/trend and share the infrastructure

data. Having data available in real time will

allow for the assessment and management

of fuel trends.


Fuel Chemistry & Water in Fuel

• Hydrogen atoms of water molecule electro-

chemically attach to atoms of hydrocarbon fuel

(diesel, gas, etc.).

• The oxygen atom stays attached to this new

molecule providing the additional benefit of

oxygenated fuel.

• This is considered a chemical reaction and

provides a permanent change to incorporate

the water into fuel.

• At this point, it is no longer considered water, it

will not freeze as water, it will not corrode as

water, bacteria and fungi cannot grow and it is

chemically stable, meaning it will not separate

or layer out.


Floating Suction


Floating Suction

• Changing the fuel intake to a floating suction line will

feed the engine clean fuel from higher in the column of

fuel which are void of contaminants.

• Using floating suction will be the only way to meet

CMS requirements of continual operation of

emergency power systems during water intrusion (as

seen in the flooding caused by the hurricanes in 2017).

• Floating suction lines are already mandated for tanks

storing aviation fuel. The standards for emergency

generators should be no different.

Generator Warranties

• Engines with an emissions certification must be operated using only diesel fuel having no more than 15 ppm maximum sulfur content.

• Failure to use the specified fuel can damage the engine and after treatment system within a short period of time.

• This damage could cause the engine to become inoperable attributable to the use of incorrect fuels & will be denied warranty coverage.

• Engine manufacturers are not responsible for failures caused by incorrect oil, fuel or exhaust fluid or by water, dirt or contaminants in the fuel, oil or exhaust fluid.


Excerpt from Cummins Generator Warranty

Currently, the preferred method of cleaning tanks is

through filtration.

The benefits include:

• Allowing the tank to remain in service.

• If generator is needed, you can quit processing.

To clean tanks through filtration, it is important to have

good access into the tank in order to reach the

contaminants on the bottom.


Sub Based Tank Cleaning

Sub Based Tank Cleaning: Difficulties

Sub-based Tanks are difficult to clean thoroughly due to their design and baffles that support the structure.

The issues with cleaning these tanks include:

• Limited openings

• Only cleaning the compartment with access

• Baffles are dams that trap contaminants behind each wall


Baffles in Sub Based Tank

• Install access points on all baffles to allow access

to each compartment

• Utilizing a system cleaner

• Empty tank – filter fuel to holding tank

• Circulate system

• Empty tank of cleaner, removing the loosened

deposits of sludge

• Filter fuel back in

• Recommended every 5 years


Sub Based Tank Cleaning: Solutions

Access plate

TANK INSPECTIONS

& COMPLIANCE


Regulatory Agencies

& Enforcement


Underground Storage Tanks (UST)

• Federal: U.S. Environmental Protection Agency (EPA)

• State: Florida Department of Environmental Protection (FDEP)

Aboveground Storage Tanks (AST)

• SPCC Plan – Spill Prevention, Control and Countermeasure (SPCC)

Plan with Steel Tank Institute (STI) Standards

A b o v e g r o u n d S t o r a g e Ta n k s ( A S T )


U n d e r g r o u n d S t o r a g e Ta n k s ( U S T )

AST – Aboveground Storage Tanks

A S T I n s p e c t i o n S t a n d a r d

• The Aboveground Storage Tank

Inspection Standard includes formal

external inspections (FEIs), monthly and

annual inspections.



F o r m a l E x t e r n a l I n s p e c t i o n ( F E I )

• A documented external inspection conducted by a certified inspector to assess the condition of the

AST and determine its suitability for continued service without entry into the AST interior.


• At a minimum, the following tank components shall be

inspected (as applicable):

• Primary tank

• Secondary Tank

• Tank supporters

• Tank anchors

• Tank foundation and external supports

• Tank gauges and alarms

• Overfill valves and alarms

• Insulation covering

• Tank appurtenances

• Normal vents

• Emergency vents

• Release prevention barriers

• Spill control systems


I n a d d i t i o n t o f o r m a l i n s p e c t i o n s :

• Monthly walkthrough or visual inspection

• Annual (periodic) inspection – a visual, documented

inspection conducted by an owner’s inspector, to

assess the AST’s general condition, without

suspending AST operations or removing the AST from

service.

W e r e c o m m e n d :

• FEI (formal exterior inspection) to create a baseline

• Annual periodic inspection

• 5 year FEI


UST – Underground Storage Tanks

G u i d e l i n e s :

Designated operators: 3 levels certified as tank

operators

• Class A Operator: persons having primary

responsibility for onsite operation &

maintenance

• Class B Operator: persons having daily onsite

responsibility for the operation and

maintenance

• Class C Operator: Daily, onsite employees

having primary responsibility for addressing

emergencies presented by a spill or release


UST – Underground Storage Tanks

G u i d e l i n e s C o n t i n u e d :

• Monthly walkthrough inspection of UST

• Yearly UST Inspection

• Annual release detection equipment operability test

• Automatic line leak detection or annual line

tightness test

• Annual overfill protection

• 3 year suction piping test

• 3 year spill bucket test

• 3 year sump test

• 3 year cathodic protection

• 5 year tank tightness test


Responsibilities of Tank Owners


• Know inspection standards and schedules for your tanks

• Hire and schedule a certified third-party inspector

• Follow through with inspector’s recommendations for repairs, etc.

• Maintain records for required amount of time

T H A N K Y O US t e v e B u r r i s

P e t r o l e u m R e c o v e r y S e r v i c e s

s t e v e @ f l o a t u b e . c o m

F u e l Ta n k M a i nt e na nc e & Ne w I ns pe c t i on ......Sub Based Tank Cleaning:...

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