THIS IS turning into another busy year for tank wash racks. It should be a profitable time for most tank cleaning operations across North America, but managers and tank cleaners will be kept jumping.
While it's good to be busy, there is a downside. When customers are lined up down the street, it can be tempting to take shortcuts to keep the tanks moving through the wash bays. There also is a tendency to sideline programs that aren't considered essential to the day-to-day effort of operating the facility.
Safety shortcuts are a very real possibility when wash racks are busy, but those shortcuts can have tragic consequences. Wash rack managers must be particularly vigilant to ensure that workers wear the necessary protective equipment and that confined-space and fall-protection procedures are followed religiously.
Safety meetings take on greater importance when wash racks are especially busy, but managers may be tempted to reduce the frequency or cut them out all together. These meetings don't have to be formal or lengthy, but they should be held frequently. Toolbox-type meetings may be just fine. The key objective is to keep the safety message in front of each worker.
Other programs likely to get short shrift include compliance with the federally mandated Spill Prevention, Control & Countermeasures (SPCC) rules and keeping security plans up to date. Ignoring these programs can be costly. For instance, the Environmental Protection Agency recently announced a $157,500 fine for a petroleum distributor that didn't have an SPCC plan in place.
On the SPCC side, wash racks need a plan if they have aboveground oil storage capacity greater than 1,320 gallons. They also are covered if they have underground petroleum storage of 42,000 gallons or greater, which might be found at a wash rack that is part of a truck terminal or truck stop.
When calculating the aboveground storage total, the following must be included: fuel tanks, other oil storage in tanks (such as storage trailers or tank containers), drums and/or totes used for oil storage, on-site oil-containing equipment (such as transformers, generators, and compressors), oil storage associated with or incidental to wastewater treatment units, and oily wastewater.
SPCC plan requirements are very involved. The plan should provide a complete discussion of the facility's conformance with the rule requirements regarding spill prevention and containment procedures. At a minimum, SPCC plans must be reviewed every five years, and each review must be documented. Training must be provided to “oil handling” employees at least once a year. An overview of the training program must be included in the SPCC plan.
Under the SPCC security section, facilities must be outfitted with the following: sufficient lighting to detect oil spills at night, fencing, gates that can be locked when no one is in attendance, and starter controls on pumps locked in the off position when not in use.
Wash racks that are part of a truck fleet may need a much more extensive security plan, because these facilities may fall under Department of Transportation oversight. DOT officials caution that inspectors are paying close attention to security plans that are flawed.
Security plans must be written, and DOT officials suggest that they follow a graduated approach in dealing with security issues. The plan must be site-specific. Employee training must be part of the plan and must be repeated at least every three years.
Yes, safety and security programs add to the workload at wash racks. However, these programs protect wash rack workers, truck drivers waiting for their tank trailers to be cleaned, and the general public. These aren't the corners to cut when things are busy.