Is your Overfill Prevention INSTALLED properly?
Three Year Inspections – a waste of time and money,
or a best practice?
If everyone just did their job, we wouldn’t need all these regulations! A true statement, unfortunately we human beings are far from perfect and we do make mistakes . . .
There is a shortage of skilled tank service technicians across the country. Other than on the job training there is insufficient training available for tank service technicians. Even a well trained, experienced service technician will occasionally make a mistake on the job like in the photos below.
This is no different than drivers – crawling through a stop sign instead of making a full stop, or going a little too much over the posted speed limit, or being distracted on a phone while driving. Every year 30,000 people are killed in auto accidents - if we all just did our job!
Spills and overfills remain one of the most common petroleum releases. The three year inspection of overfill devices assists the industry in preventing this common problem.
A service tech conducting a three year overfill prevention inspection found the problem in these two photos below. The photos show the drop tubes and flapper valves (Automatic Shut off Devices). The top of the drop tube is round and the bottom is cut off slanted. Note the direction of the flapper valve. These flapper valves were installed upside down.
§ 40 CFR 280.35 (2) Overfill prevention equipment must be inspected at least once every three years. At a minimum, the inspection must ensure that overfill prevention equipment is set to activate at the correct level specified in § 280.20(c) and will activate when regulated substance reaches that level. Inspections must be conducted in accordance with one of the criteria in paragraph (a)(1)(ii)(A)-(C) of this section.
Inspect your Overfill Prevention devices to ensure they are installed and working properly!
This location had ball floats replaced with an automatic shutoff. The new overfill device was inspected 6 months prior to this overfill. Unfortunately, the former opening for the ball float was not sealed and the automatic shutoff did not stop the delivery at 95% of the capacity of the tank.