Celly Services Inc.

PREVENT A $100,000 CATASTROPHE BY INSTALLING A $500 VALVE/TIMER DEVICE ON YOUR NEW OIL/ATF TANKS

You walk into the shop early in the morning and see a mega oil spill. Material loss and cleanup can cost a bundle not to mention the shop shut down time while the cleanup crew vacuums the shop floor, slurry the lot and undertake the cleanup of the storm sewer. Regulators are breathing down your neck threatening civil and criminal penalties.  
WHAT HAPPENED: The leak source may be attributed to equipment failure as follows:
  • Metering Pump Failed: In one case the metering pump controlled by parts department to regulate the dispensing of oil failed, creating a backpressure that emptied out the entire oil tank on the shop floor and then into the storm sewer.
  • Dispenser Came Off The Hose: The new dispenser and hoses installed did not have a tight fit and on a weekend the dispenser unit came off, resulting in emptying out the oil tank, even though the compressor had been shut off. The oil spill damaged the lot and entered the storm sewer resulting in extensive cleanup and regulatory activity.
  • Pipe Leak: The pipes carrying the oil from the oil tanks to the shop burst resulting in an oil spill. Even though no oil was discharged to the storm sewer, there was significant product loss and cleanup activity not to mention productivity loss as the shop had to be shut down for a few days. 
In each of the cases where oil had spilled to the storm sewer, extensive regulatory enforcement activity followed. Cleanup of the entire lot and service department had to be undertaken as well, along with the cleanup performed on the complete storm sewer system impacted by the oil spill. The price tag, in each of the cases was tens of thousand of dollars! The SPCC Plan prepared by the dealership was also summoned by the federal-EPA and the dealership underwent rigorous questioning.  
WHAT TO DO: The remedial measures to avoid such disasters are straightforward, easy and inexpensive to install compared to the potential for an expensive and troublesome spill.
  1.  A $500 Solenoid Valve With Timer Will Shutoff Air To Dispensers During Non-Shop Hours: (We recommend this option) Place a solenoid valve with a timer in the air-line to the oil tank dispensers. With the help of a preset timer, the valve will automatically shut-off air to dispenser pump during non-shop hours thereby preventing any spills. Leaks or spills in the shop area during shop hours are not an issue as they are detected immediately and addressed by the shop staff in a timely manner. Compressed air required by the detail staff or others will still be available even though air is not available to the dispenser pumps.
  2. Training Employees To Shut Air To Dispensers By Hand Valve Is Not Effective: A hand-operated valve would do the same job as shutting the air with a solenoid valve as discussed above but is prone to human errors. Shop porters or other shop staff will have to be trained and routinely reminded to ensure that they are carrying out the job of shutting air during non-shop hours. A shop porter trained to shut-off valve can be on vacation, call in sick, or simply be terminated resulting in the discontinuation of the air shut off procedure. An automatic valve with in-line timer as discussed above does not have the human limitation. The mechanical device has to be tested for proper operation and serviced on a periodic basis.
  3. Compressors On The Timer: Some dealerships have compressors with a timer to shut them at the end of the work shift. However, there is enough air in the air-storage tank, even after compressor has been shut off, to empty the oil tank of hundreds of gallons when a leak occurs down stream in the hoses, dispenser, or the metering pump. So this procedure is of limited use in preventing spills. To prevent corrosion of the air tank, many companies have an employee drain the air-tank on a daily basis. This procedure faces the same limitations discussed in item # 2 above.
DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.  Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.
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