Considering the problems that can arise from a poorly labeled fuel tank? At first glance, it might seem like labeling a fuel tank is a simple task, but Shannon joins us to discuss why it's anything but. In a deep-dive discussion, we explore the complexities around regulations and engineering standards that may provide challenges.
Shannon sheds light on the importance of accurate tank identification for operators and emergency responders, unraveling tales of label replacement in the world of bulk fuel storage and revealing the consequences of label violations. We also touch on the frequency of regulatory changes and the vital need for label updates when tank contents change. Get the lowdown on the differences in labeling vertical and horizontal tanks based on varying construction standards. Listen for a unique perspective on the intricacies and critical role of tank labeling in the bulk fuel storage industry.
Additional Resources:
Tank Label Handout
intro/outro created with GarageBand
Considering the problems that can arise from a poorly labeled fuel tank? At first glance, it might seem like labeling a fuel tank is a simple task, but Shannon joins us to discuss why it's anything but. In a deep-dive discussion, we explore the complexities around regulations and engineering standards that may provide challenges.
Shannon sheds light on the importance of accurate tank identification for operators and emergency responders, unraveling tales of label replacement in the world of bulk fuel storage and revealing the consequences of label violations. We also touch on the frequency of regulatory changes and the vital need for label updates when tank contents change. Get the lowdown on the differences in labeling vertical and horizontal tanks based on varying construction standards. Listen for a unique perspective on the intricacies and critical role of tank labeling in the bulk fuel storage industry.
Additional Resources:
Tank Label Handout
intro/outro created with GarageBand
Amanda: 0:53
We're here to talk with Shannon today about the importance and challenges of working with tank labels. Alright well, thank you for joining us today to discuss tank labels. Let's get started with why is tank labeling difficult?
Shannon: 1:37
Well, tank labeling is difficult, because tank labels are required by a number of different engineering standards, and then regulations require adherence to those standards, and so you've got a lot of different documents dictating what goes on to a tank, and there doesn't appear to be any one local resource that says these are the labels required for this tank. Each standard sort of says this is what's required for this standard, and then it's up to you to know which standards apply to the tank.
Amanda: 2:07
So does each tank need its own labels?
Shannon: 2:10
It does, both of the engineering standards international fire code and API 650 or UL 142 for the horizontal tanks. they require each tank to have a unique identifier, and then each tank, of course, could have a different product type in it, and so it's important that each tank have its own set of labels so that people who are operating it know the specific information for that tank. But it's also important for emergency responders to know what they're going to be dealing with if there is an emergency, like a fire or flood from the contents of that tank.
Amanda: 2:45
So if emergency responders are looking for these labels, where on the tank do these labels need to be placed?
Shannon: 2:51
Well, that's a good question For, like the NIOSH and the NFPA labeling, those need to go in a location on the tank that's visible to somebody pulling up to respond to the emergency. Put yourself in the driver's seat of a fire truck or maybe somebody responding to an emergency like a flood and they're not from in town. They need to be able to see what the tank contents are and what they need to consider before responding. But other labels are more for operations and so things like, say, fill hides and product type and tank identifier number. those typically are closer to where you'll be doing tank gauging, because you need that information to do your tank gauging and transfer operations safely.
Amanda: 3:32
In places like Alaska, where we do most of our work, i know that we have a lot of wind, and heavy rain and snow weather can take its toll on these labels. How long do labels typically last?
Shannon: 3:45
That depends on the location of the tank, and you're absolutely right, Alaska's hard on labels. I've seen labels degrade pretty badly in maybe two or three years in western Alaska, especially if they're directly adjacent to the ocean. Saltwater spray tends to really do a number on adhesives, and then excessive UV exposure at some of the higher latitudes will fade labels pretty well. Labels can be made from different materials. They can be made from like a sticky vinyl or sticky epoxy type material that can be put onto the tank, but they can also be laser printed or laser etched onto a metal or aluminum plate. Anything that doesn't stick to the tank, though, can be blown away. We typically see some labels fade faster than others, and what we recommend to our clients is, when you're doing your annual inspections of things, note labels that are beginning to go and just buy a new one and have it ready for when it's no longer legible. It's a lot harder to try to replace all your labels at once. It's better to sort of just keep replacing them as they get damaged.
Amanda: 4:48
Who checks for these labels and how often are they checking?
Shannon: 4:52
Well, typically a compliance for labels is performed at two different times in a tank farm's life. Typically, when a tank's farm is constructed, the label requirements are part of the engineering package and it's part of what goes through the fire marshal's office. And so when a tank farm is completed, there's typically a checklist that says all these labels are in place and in accordance with all the standards and that's part of the package. After the tank farm is created which for many of our clients was a long time ago the tank labeling is only checked when regulators perform inspections And you can get a potential violation for not having correct tank labeling because it's missing information from the tank. In 18AAC 75 and 40 CFR 112, both reference the construction standards and the inspection standards appropriate to vertical tanks and horizontal tanks, and in those standards we see that the labels have to be correct and they have to be placed in certain ways and have to be in accordance with the international fire code and in accordance with the construction standard of the tank. So they get checked every three to five years by the state of Alaska and for the EPA it's variable. Sometimes it could be a very long time if you're a remote facility and sometimes if you're a facility in a good fishing spot it might be more often more frequent.
Amanda: 6:15
Speaking of violations, what do those violations typically entail?
Shannon: 6:22
Usually for the state of Alaska it's typically you need to replace it within a certain time frame. I don't think I've ever seen it become a major violation. I think one of the things that I have seen trip clients up is if they have a spill or some other event and the reason that they had a spill event was because labeling wasn't correct. They didn't have a safe fill height on a tank or they didn't have the right product or service label on a tank and they moved product A to a product B tank. That can trip up some regulatory problems and then the tank labeling is part of the resolution of that. So sometimes we see air violations because they changed diesel tank to a gasoline tank and didn't check in and the labeling was incorrect and that kind of mucks things up on that side. Then we also see where there's no safe fill height on the tank and it gets overfilled because whoever was filling it didn't have a reference and was maybe new to the job. That's what I see from a regulatory standpoint of the impacts of not having good labeling.
Amanda: 7:27
Do tank label requirements change and how frequently would they change?
Shannon: 7:33
Tank labeling requirements don't change very frequently. They're part of the international fire code, which it gets updated annually. but parts of the standards don't get updated frequently. And the same goes for regulations. Regulations don't necessarily get updated all that frequently, maybe every five, ten years. But for most people who work with bulk fuel tanks, tank labeling changes when the product inside the tank changes and it's very important that if you're changing the tank service, that you update the labels at that time, because then somebody has to remember that it's not really diesel anymore When you put something new into it. And we do see that pretty frequently where we've recycled a tank or changed the service of the tank and then you know I'm coming in doing an audit and I'm like, oh, this is your gasoline tank and they're like oh yeah, no, it was a gasoline tank in 2015, but now it's it's a diesel tank. I'm like, hmm, all your signage says gasoline. They're like, yep, it's very important one for just accuracy and and inventory numbers and Communicating with people who are using that tank, but it's also important for emergency response. If you have a spill out of a tank That's labeled gasoline and it's not. That fundamentally changes how we respond to things.
Amanda: 8:44
That makes sense integrity and Inspects tanks that are both vertical and horizontal. Is labeling different for those different style of tanks?
Shannon: 8:53
They are because the construction standards have different requirements. So vertical tanks are generally driven by the API 650 standard, which is a construction standard, and then the API 653 inspection standard. They also have international fire code requirements and NFPA requirements. But the horizontal tanks because they can be many different styles single wall, double wall, self-dike They are guided by the UL 142 construction standard and they have different kinds and types and number of appurtenances Than a vertical tank does, and so they have just a few more requirements. For example, on a horizontal tank you could have a Regular double wall tank and you could also have a fire guard tank, which is a tank specifically for gasoline or av-gas flammable product service, and That tank has a different kind of interstitial space and it has labeling to show that it's a fire guard tank and appropriate for those flammable liquids. That's not something that you would ever see on a vertical tank because they don't make them that size.
Amanda: 10:01
So how do we know we've got it right?
Shannon: 10:03
Well, It is difficult to understand all the pieces and this is a question that integrity gets asked a lot and our clients get it with our Reporting. When we inspect a tank, we include a label audit and we Show them what labels are missing and what need to be put back on or repaired or replaced. But what we have done because I think it's important for everybody to have access to this information is we've collected all of these engineering standards into one PDF that you can print out one for verticals, one for Horizontals and we also have one for closed or out-of-service tanks, and it goes over all the labeling required for each one and a clean, clear, easy Table format, and you can go to our website and download it, and then you'll know that you've got it right. It's printable and this is important information and it's something that I think is it's very important for emergency response, and so we really wanted to make sure it was available to everybody, and I think it would be better for Alaska if all of our tanks had good labels on them. So go go to our website, download it. It's free, it's helpful, and if you want to give us feedback or if we missed anything, I'd be happy to hear it. You can email us at info@integrity-env.com, and we'll be happy to take a look at your feedback.
Amanda: 11:18
Great Well, thank you for joining us today, Shannon. I really appreciate this information and I'm sure that it will help everybody on these tank farms. Just come to compliance and make sure that everything is working out. Once again, we appreciate you joining us here. On tank talk with integrity environmental, please head over to our website, integrity-env.com For a free downloadable version of a tank label instruction to share with your team or view for reference. Until next time.