You walk into the shop early in the morning and see a mega oil spill. Material loss and cleanup can cost a big bundle, not to mention the shop shut down time while the cleanup crew vacuums the shop floor, slurries the lot and undertakes 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 the 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. This resulted in the oil tank emptying out, 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 case where oil was spilled to the storm sewer, extensive regulatory enforcement activity followed. Clean up of the entire lot and service department had to be undertaken as well, along with the clean-up performed on the entire storm sewer system impacted by the oil spill. The price tag in each of the cases was tens of thousands of dollars! The SPCC Plan prepared by the dealership was also summoned by the federal EPA and the dealership underwent rigorous questioning.

CIVIL: Preventive Measures Involve Building Physical Barriers to Prevent & Catch Oil Spills

1. Build a concrete wall: The wall around the tank will contain an accidental leak from failure of fittings or a leak from the tanks. Many times, tanks are double walled: the interstitial space must be monitored for leaks and an inspection log kept. When tanks are in a tank room, a berm at the entrance can be built to contain a spill from a leaking fitting or a burst hose. A dealer in the Bay area insists on the berm at each of his 16 stores!
2. Bollards: Tanks are generally kept in tank rooms specifically built for the purpose. Auto manufacturers have come up with specialized lube oil, the storage of which is now in tanks in the shop area and exposed to traffic. Install steel bollards to protect the tanks from accidental impact.
3. Secondary Containment: Generally secondary containment for all containers greater than 55 gallons is necessary. Appropriate containment can be purchased and placed for effective containment.

MECHANICAL: Float Devices & Overflow Alarms

1. Mechanical Gauge: Each of the tanks should be provided with a gauge indicating the level of fluid in the tanks. A matrix provided by the tank and gauge manufacturer and placed on the tank can translate the level of oil in the tank to actual gallons in the tank. Once tank storage is determined and tank capacity is known, the delivery company can determine the gallons to be delivered. Dip sticks may not be always provided and may be difficult to reach for large storage tanks, so this is an effective way to prevent spills. 
2. Tank Level Monitors: Electronic tank level monitors track new product supply or used oil levels, and wirelessly transmit tank level information to the Managers desktop. The desktop allows for easy viewing and management of tank levels without labor costs. Data related to tank levels may be automatically emailed to oil distributors and used oil recyclers for action. Greater inventory management allows for efficient expensing and accounting as well.
3. Overflow Alarms: The used oil and used coolant tanks may have remote filling and as such are not visible to the technician unloading used oil through a diaphragm pump. Without an overflow alarm, tanks at remote locations can continue to overflow and create spills. Overflow alarm panels at the fill station should be equipped with a visual and audible alarm. The alarm should also shut off the compressed air to the pump and hence prevent any transfer to the tank once the tank reaches capacity. Alarms should be checked for proper operability on an annual basis.

ELECTRICAL DEVICES: A $500 VALVE/TIMER DEVICE ON YOUR NEW OIL/AUTOMATIC TRANSMISSION FLUID (ATF) TANKS

The remedial measures to avoid such disasters are straightforward, and easy and inexpensive to install compared to the potential for an expensive and troublesome spill.

1. A $500 Solenoid Valve with Timer Will Shut Off Air to Dispensers during Non-Shop Hours: 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 the 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 Down 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. However, it is prone to human error. 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 valves 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 must 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 down at the end of the work shift. However, there is enough air in the air-storage tank to empty the oil tank of hundreds of gallons when a leak occurs downstream in the hoses, dispenser, or the metering pump, even after the electrical supply to the compressor motor has been shut off. 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 daily. This procedure faces the same limitations discussed in item # 2 above.

NOTE: The devices and procedures discussed above may not be required by law or local regulators. However, they are good engineering practices that, when implemented, minimize the possibility of a leak or a spill from hazmat located at your facility, thereby minimizing disruption to operations. Clean up expenses & regulatory burden is also reduced.

Recent EPA Enforcement: https://www.epa.gov/newsreleases/epa-settles-two-watsonville-calif-companies-claims-chemical-safety-violations

DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered 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 in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 36 years. Sam is a Certified Safety Professional (No. 16515) certified by the National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. We welcome your comments/questions. Please send them to sam@cellyservices.com.