March 12, 2024 • 13 mins
Tank Talk dives deep into the world of bulk fuel systems by reviving a listener favorite: Oil-Water Separators(OWS). This episode provides an informative exploration of the mechanics and importance of OWS Systems in fuel storage. Shannon discusses how these systems are essential for separating oil from water to prevent contamination, detailing the operational principles, maintenance best practices, and environmental significance. She also tackles common challenges and the latest regulations impacting the use of OWS systems in Alaska. Whether an industry professional or an enthusiast eager to learn more about bulk fuel infrastructure, this episode offers valuable insights into keeping our waterways clean and fuel systems efficient.
Episode Transcription
Additional Resources:
SPCC Guidance for Regional Inspectors
This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may occur from using this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host, which would be me or Integrity Environmental. Thank you very much for listening. We would be happy to provide professional regulatory advice as part of our consulting services if you need professional regulatory advice.
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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Amanda (00:00):
Welcome back Shannon.
How are you doing this morning?
Shannon (00:03):
I'm doing really, really well.
I am enjoying all of thesunshine that we're getting
lately.
It's a good day to talk abouttanks.
Amanda (00:11):
Always.
So we've been getting somequestions about oil water
separators and it sounds prettyobvious, but I've learned that
nothing is as easy as it sounds.
So tell me a little bit aboutoil water separators.
What makes them complicated andhow do they interact with
regulations?
Shannon (00:33):
Well, let's start with the definition of an oil water
separator.
An oil water separator is asimple machine.
A lot of people think of themas a tank, but they are not a
tank, they are a machine.
Well, tanks are machines too,but an oil water separator is a
different kind of machine, so itis a container of some kind,
rather.
(00:53):
Sometimes they're rectangular,sometimes they're cylindrical,
sometimes they're oddly shapedto fit into weird places, but
they are a container that hasbaffles inside and it uses the
physics of fuel floating on thetop of water, because fuel has a
lighter specific gravity thanwater.
So it floats on top and itutilizes baffles and piping to
(01:17):
allow fuel to be trapped on topand water to flow through the
oil water separator and out theother side.
Oil water separators are apassive system, and so they
typically are something thatworks, no matter what it doesn't
.
You know, if they stop working,it will not stop you from
working.
For oil water separators,there's a couple of things that
(01:38):
we always run into with recordkeeping, maintenance and
operations, and then they alsoare a little tricky with how
they're regulated.
Oh, what makes them so tricky?
Well, so some regulations arevery specifically clear about
oil water separators, but awhole lot of them ignore them
completely in the regulation andthen they have more like
(02:01):
guidance documents about how totreat oil water separators,
because an oil water separatorlooks a whole lot like a tank
and it could theoretically holda lot of fuel if it was full of
fuel instead of water, and so wesee them treated a little
differently under differentregulations.
For example, the spillprevention, control and
(02:21):
countermeasures plan, the SPCCthat the EPA requires under 40
CFR 112, they have a wholechapter in a publication that
they have.
It is the SPCC guidance forregional inspectors that was
published last in 2013, althoughthere have been updates along
the way.
They have a whole chapter fiveon oil water separators and how
(02:45):
to treat them.
Within your SPCC and a lot ofour clients have you know they
have to be very specific aboutwhat they use these oil water
separators for and how theyoperate and maintain them to
meet the requirements of theSPCC.
Amanda (03:00):
So what happens if they're not maintained or if
water gets through?
Shannon (03:06):
Well, one of the complications we see for oil
water separators is if you livein a place that freezes and
there's a lot of water in youroil water separator because
there's always what's called thecharge to an oil water
separator it has at least athird of its of the oil water
separator is filled with waterso that the fuel has something
to float on, and so if you livein a place that's cold, that
(03:29):
water can freeze and damage someof the internal mechanisms like
the baffles or the piping, andso the oil water separator you
think is working, but it's not,because some of the baffling has
been damaged or perforated oryour piping has become damaged
and it's no longer at the rightlevel to allow water through but
not fuel.
The other thing we see with oilwater separator maintenance is
(03:51):
that people never check them,they forget about them, and so
years and years and years willgo by, because it's, like I said
, a passive system, so peopledon't need them to operate, and
then when you do crack them open, you see several years of weeps
, drips and leaks all gatheredin there, and if there's enough
fuel in an oil water separator,it will push out that bottom
third of water and it will begindischarging fuel.
(04:14):
If it's completely full of fuel, fuel will flow out of the oil
water separator.
So that is something that tripspeople up a little.
I think they either forget thatit's there or they believe that
it's going to magically containall the fuel no matter what,
and then maybe it'll stopdischarging if it's full of fuel
.
And some oil water separatorshave valves that you can close.
(04:37):
Some of them do have sensorsthat tell you when they sense
hydrocarbons.
But again, if you don'tmaintain those sensors, if those
sensors are 10, 15, 30 yearsold, they may not alarm when
they interact with hydrocarbonsor the power to that sensor may
be gone because the wirecorroded.
I've seen that a lot.
Where there's power to a sensorand the sensor actually looks
(04:59):
pretty good, the actual likewiring itself has corroded or
become disconnected.
Or my other favorite is that itwas beeping all the time or
alarming all the time, sosomebody just disconnected it or
pulled the plug.
Have enough.
Amanda (05:13):
Right.
Shannon (05:13):
Yeah.
Amanda (05:15):
So what complications do you come across with oil water
separators from a regulatorystandpoint?
Shannon (05:21):
Yeah.
So back to that chapter five ofthe EPA guidance for SPCC's.
You need to meet a couple ofconditions for the EPA to exempt
your oil water separator fromthe same requirements as a tank.
And so if it's truly an oilwater separator and you're not
using it as part of a treatmentprocess or you're not using it
(05:41):
as part, like to actually storefuel in some manner, I have seen
some people modify oil waterseparators to where they're
basically storing used or wasteoil in them.
If those are not what you'reworking with and instead it's
just a, it's part of yourfacility drainage, right, like
you drain everything from yoursecondary containment area
through this oil water separatorprior to it going to the
(06:02):
shoreline or to ground, the EPAallows it to be exempted and it
does not count towards yourfacility overall storage volume
and it does not have the samesecondary containment
requirements that, like yourtanks would Right.
So if you have a 1500 gallontank, it has to have 1500
gallons of secondary containment.
If you have a 1500 gallon oilwater separator, it's considered
(06:22):
part of your drainage equipmentand so it does not have to have
secondary containment.
And we see a lot of confusionwith that.
I have absolutely seen SPCC'swritten where they've included
the oil water separator likeit's a tank.
But if you read the guidanceand you go by chapter five, it's
clearly exempt.
You just have to have gotteninto that guidance and we can.
(06:43):
Actually that's a publiclyavailable guidance.
I think everybody who operatesan SPCC or within one, should
read it at least once.
I mean it's not a thriller byany means, but there's a lot of
clarification in that guidancefor some of these areas that 40
CFR 112 is just silent on.
They don't say anything aboutoil water separators and that
regulation.
Amanda (07:05):
How frequently does the EPA check on oil water
separators?
Shannon (07:09):
The EPA does perform inspections and virtual audits,
they are very inconsistent withthe timing of these audits.
So many facilities will goentire lifetimes or careers
without any EPA scrutiny orinvolvement and other facilities
have had multiple interactionswith the EPA.
(07:33):
So it's sort of random andinconsistent which can feel a
lot like never to some people.
But what we see on our end is ifyou have events such as a spill
or something failing or youknow something where you have to
call in and report things,those kind of events increase
(07:53):
your scrutiny and you almostcertainly will get a virtual
audit from the EPA on top of allthe other stuff you have to
deal with from having the event.
And so that's when we getbrought in a lot to clean things
up because they have not paidattention to it and then an
event occurred and now it'simportant all of a sudden.
So we recommend to everybodyhave somebody knowledgeable
(08:14):
review your SPCC it's supposedto be renewed every five years
anyways, but make sure thatsomebody who really understands
what they're doing is goingthrough there and eliminating
all your risk.
And this oil the specific tiny,microscopic look at the oil
water separators is just.
You know, it's one of the manythings that people who write
SPCCs have to look at, but it'snot necessarily as clear-cut as
(08:35):
people think, right?
Amanda (08:38):
What are the record-keeping requirements for
oil water separators?
Shannon (08:42):
That's a really great question.
If you're operating under anSPCC plan, you need to have
documentation of periodic andregular inspections, and that
can be pretty variable.
We typically recommend at leastan annual inspection.
That includes opening it up,inspecting all three chambers
and the outfall and making surethat everything's working
(09:04):
correctly, so that thatsecondary system is working and
you can clean out.
If there's any fuel floating onthe top, you can clean it out.
For another podcast episode wecan talk about water quality
standards and oil waterseparators, but for today let's
just talk about routineoperations and maintenance.
And then we also encouragepeople that have extreme
(09:26):
seasonal fluctuations to maybedo a twice a year inspection,
sort of like once in the springto make sure no damage occurred
during the winter and then onceagain in the fall, before you
put things to bed for winter, tomake sure you're not going to
be causing any damage.
And then it also depends on thefrequency of use for oil water
separators.
Some oil water separators, likethe ones we see that are
(09:48):
attached to large bulk tankfarms.
They process a lot of water andvery, very little contamination
right, like maybe some leaps orleaks or drips from something
that's dripping.
But some oil water separatorsare not part of a facility
containment discharge.
They're actually inside awarehouse or shop and they're
meant to treat stuff that'scoming through a shop drain.
(10:11):
And so if your oil waterseparator is undergoing way more
frequent use or is going tohave heavy use, you may want to
be inspecting that on a monthlybasis just to make sure that
you're not overwhelming it orputting too much stuff in there.
And yeah, it just sort ofdepends.
But if you decide on a routinewhether that's once a year,
(10:34):
twice a year, whatever you needto stick to it and you need to
make sure it's actuallydocumented, like it can't be a
visual and the guy says, yeah,it's good, you need to actually
have a piece of paper that saysI inspected the following
components of my oil waterseparator and the bare minimums
are an inspection for eachchamber chamber one, two and
three, an outfall and then alsoinspecting if there's any drains
(10:59):
that go to it, making sureyou're inspecting, like all the
inlets, basically.
And then if that oil waterseparator has a sensor for
hydrocarbon sensing or if it hasany other equipment that helps
you know when it's full or whenhydrocarbons are in it.
All of that has to be workingand tested and verified as
(11:20):
working and tested annually aswell, and that needs to be
written down somewhere, not justvisually confirmed.
Amanda (11:28):
And that's all included in the SPCCs with integrity.
Yes, yes, we absolutely provideguidance.
Shannon (11:36):
And we can even provide example forms for your oil
water separator inspections, noproblem.
And when we perform our SPCCsite visits like when we're
creating an SPCC or updating weoften because we pay attention
to oil water separators probablya little more closely than many
groups do we often correct orwe not correct?
(12:01):
I don't want to say correct,but we get better descriptions
of the oil water separator andthe volumes of them and how they
work and where they dischargeto, and those can all be really
valuable if you have a spillevent to your drainage system
and nobody's really sure wherethe oil water separator goes to.
Like we can help you understandthat before you have an issue
and so all of that's ready forspill response when you need it.
(12:22):
Beforehand, instead of afterthe effect, try to figure out
where it's gonna come out.
Amanda (12:27):
So it sounds like a lot of potential for preventative
measure there with the oil waterseparators.
Shannon (12:33):
Yes, all passive systems do better with
preventative maintenance andproactive monitoring and
inspections.
Amanda (12:43):
All right.
Well, thank you so much forjoining us again today and
sharing some information on oilwater separators with us.
Are there any additionalresources that we can find
online?
Yeah, absolutely.
Shannon (12:55):
We will post the EPA's SPC sequence original inspectors
on the show notes and for youroil water separators.
Some of the best sources ofinformation are construction
schematics and drawings for yourfacility.
A lot of them have all of thedetails in there and you can
(13:16):
look up the volume and how it'splumbed and where it drains.
It's all part of thatconstruction documentation.
So if you have those, they'rereally important to retain
because that kind of informationgets lost over time.
Amanda (13:29):
All right, well, thank you so much for joining us today
, shannon, and we look forwardto our next chat, yeah glad to
have happy to do it.
Shannon (13:40):
Oil water separators are funky little machine and we
deal with them quite a bit, soI'm glad to put more education
out there.
Welcome back Shannon.
How are you doing this morning?
Shannon (00:03):
I'm doing really, really well.
I am enjoying all of thesunshine that we're getting
lately.
It's a good day to talk abouttanks.
Amanda (00:11):
Always.
So we've been getting somequestions about oil water
separators and it sounds prettyobvious, but I've learned that
nothing is as easy as it sounds.
So tell me a little bit aboutoil water separators.
What makes them complicated andhow do they interact with
regulations?
Shannon (00:33):
Well, let's start with the definition of an oil water
separator.
An oil water separator is asimple machine.
A lot of people think of themas a tank, but they are not a
tank, they are a machine.
Well, tanks are machines too,but an oil water separator is a
different kind of machine, so itis a container of some kind,
rather.
(00:53):
Sometimes they're rectangular,sometimes they're cylindrical,
sometimes they're oddly shapedto fit into weird places, but
they are a container that hasbaffles inside and it uses the
physics of fuel floating on thetop of water, because fuel has a
lighter specific gravity thanwater.
So it floats on top and itutilizes baffles and piping to
(01:17):
allow fuel to be trapped on topand water to flow through the
oil water separator and out theother side.
Oil water separators are apassive system, and so they
typically are something thatworks, no matter what it doesn't
.
You know, if they stop working,it will not stop you from
working.
For oil water separators,there's a couple of things that
(01:38):
we always run into with recordkeeping, maintenance and
operations, and then they alsoare a little tricky with how
they're regulated.
Oh, what makes them so tricky?
Well, so some regulations arevery specifically clear about
oil water separators, but awhole lot of them ignore them
completely in the regulation andthen they have more like
(02:01):
guidance documents about how totreat oil water separators,
because an oil water separatorlooks a whole lot like a tank
and it could theoretically holda lot of fuel if it was full of
fuel instead of water, and so wesee them treated a little
differently under differentregulations.
For example, the spillprevention, control and
(02:21):
countermeasures plan, the SPCCthat the EPA requires under 40
CFR 112, they have a wholechapter in a publication that
they have.
It is the SPCC guidance forregional inspectors that was
published last in 2013, althoughthere have been updates along
the way.
They have a whole chapter fiveon oil water separators and how
(02:45):
to treat them.
Within your SPCC and a lot ofour clients have you know they
have to be very specific aboutwhat they use these oil water
separators for and how theyoperate and maintain them to
meet the requirements of theSPCC.
Amanda (03:00):
So what happens if they're not maintained or if
water gets through?
Shannon (03:06):
Well, one of the complications we see for oil
water separators is if you livein a place that freezes and
there's a lot of water in youroil water separator because
there's always what's called thecharge to an oil water
separator it has at least athird of its of the oil water
separator is filled with waterso that the fuel has something
to float on, and so if you livein a place that's cold, that
(03:29):
water can freeze and damage someof the internal mechanisms like
the baffles or the piping, andso the oil water separator you
think is working, but it's not,because some of the baffling has
been damaged or perforated oryour piping has become damaged
and it's no longer at the rightlevel to allow water through but
not fuel.
The other thing we see with oilwater separator maintenance is
(03:51):
that people never check them,they forget about them, and so
years and years and years willgo by, because it's, like I said
, a passive system, so peopledon't need them to operate, and
then when you do crack them open, you see several years of weeps
, drips and leaks all gatheredin there, and if there's enough
fuel in an oil water separator,it will push out that bottom
third of water and it will begindischarging fuel.
(04:14):
If it's completely full of fuel, fuel will flow out of the oil
water separator.
So that is something that tripspeople up a little.
I think they either forget thatit's there or they believe that
it's going to magically containall the fuel no matter what,
and then maybe it'll stopdischarging if it's full of fuel
.
And some oil water separatorshave valves that you can close.
(04:37):
Some of them do have sensorsthat tell you when they sense
hydrocarbons.
But again, if you don'tmaintain those sensors, if those
sensors are 10, 15, 30 yearsold, they may not alarm when
they interact with hydrocarbonsor the power to that sensor may
be gone because the wirecorroded.
I've seen that a lot.
Where there's power to a sensorand the sensor actually looks
(04:59):
pretty good, the actual likewiring itself has corroded or
become disconnected.
Or my other favorite is that itwas beeping all the time or
alarming all the time, sosomebody just disconnected it or
pulled the plug.
Have enough.
Amanda (05:13):
Right.
Shannon (05:13):
Yeah.
Amanda (05:15):
So what complications do you come across with oil water
separators from a regulatorystandpoint?
Shannon (05:21):
Yeah.
So back to that chapter five ofthe EPA guidance for SPCC's.
You need to meet a couple ofconditions for the EPA to exempt
your oil water separator fromthe same requirements as a tank.
And so if it's truly an oilwater separator and you're not
using it as part of a treatmentprocess or you're not using it
(05:41):
as part, like to actually storefuel in some manner, I have seen
some people modify oil waterseparators to where they're
basically storing used or wasteoil in them.
If those are not what you'reworking with and instead it's
just a, it's part of yourfacility drainage, right, like
you drain everything from yoursecondary containment area
through this oil water separatorprior to it going to the
(06:02):
shoreline or to ground, the EPAallows it to be exempted and it
does not count towards yourfacility overall storage volume
and it does not have the samesecondary containment
requirements that, like yourtanks would Right.
So if you have a 1500 gallontank, it has to have 1500
gallons of secondary containment.
If you have a 1500 gallon oilwater separator, it's considered
(06:22):
part of your drainage equipmentand so it does not have to have
secondary containment.
And we see a lot of confusionwith that.
I have absolutely seen SPCC'swritten where they've included
the oil water separator likeit's a tank.
But if you read the guidanceand you go by chapter five, it's
clearly exempt.
You just have to have gotteninto that guidance and we can.
(06:43):
Actually that's a publiclyavailable guidance.
I think everybody who operatesan SPCC or within one, should
read it at least once.
I mean it's not a thriller byany means, but there's a lot of
clarification in that guidancefor some of these areas that 40
CFR 112 is just silent on.
They don't say anything aboutoil water separators and that
regulation.
Amanda (07:05):
How frequently does the EPA check on oil water
separators?
Shannon (07:09):
The EPA does perform inspections and virtual audits,
they are very inconsistent withthe timing of these audits.
So many facilities will goentire lifetimes or careers
without any EPA scrutiny orinvolvement and other facilities
have had multiple interactionswith the EPA.
(07:33):
So it's sort of random andinconsistent which can feel a
lot like never to some people.
But what we see on our end is ifyou have events such as a spill
or something failing or youknow something where you have to
call in and report things,those kind of events increase
(07:53):
your scrutiny and you almostcertainly will get a virtual
audit from the EPA on top of allthe other stuff you have to
deal with from having the event.
And so that's when we getbrought in a lot to clean things
up because they have not paidattention to it and then an
event occurred and now it'simportant all of a sudden.
So we recommend to everybodyhave somebody knowledgeable
(08:14):
review your SPCC it's supposedto be renewed every five years
anyways, but make sure thatsomebody who really understands
what they're doing is goingthrough there and eliminating
all your risk.
And this oil the specific tiny,microscopic look at the oil
water separators is just.
You know, it's one of the manythings that people who write
SPCCs have to look at, but it'snot necessarily as clear-cut as
(08:35):
people think, right?
Amanda (08:38):
What are the record-keeping requirements for
oil water separators?
Shannon (08:42):
That's a really great question.
If you're operating under anSPCC plan, you need to have
documentation of periodic andregular inspections, and that
can be pretty variable.
We typically recommend at leastan annual inspection.
That includes opening it up,inspecting all three chambers
and the outfall and making surethat everything's working
(09:04):
correctly, so that thatsecondary system is working and
you can clean out.
If there's any fuel floating onthe top, you can clean it out.
For another podcast episode wecan talk about water quality
standards and oil waterseparators, but for today let's
just talk about routineoperations and maintenance.
And then we also encouragepeople that have extreme
(09:26):
seasonal fluctuations to maybedo a twice a year inspection,
sort of like once in the springto make sure no damage occurred
during the winter and then onceagain in the fall, before you
put things to bed for winter, tomake sure you're not going to
be causing any damage.
And then it also depends on thefrequency of use for oil water
separators.
Some oil water separators, likethe ones we see that are
(09:48):
attached to large bulk tankfarms.
They process a lot of water andvery, very little contamination
right, like maybe some leaps orleaks or drips from something
that's dripping.
But some oil water separatorsare not part of a facility
containment discharge.
They're actually inside awarehouse or shop and they're
meant to treat stuff that'scoming through a shop drain.
(10:11):
And so if your oil waterseparator is undergoing way more
frequent use or is going tohave heavy use, you may want to
be inspecting that on a monthlybasis just to make sure that
you're not overwhelming it orputting too much stuff in there.
And yeah, it just sort ofdepends.
But if you decide on a routinewhether that's once a year,
(10:34):
twice a year, whatever you needto stick to it and you need to
make sure it's actuallydocumented, like it can't be a
visual and the guy says, yeah,it's good, you need to actually
have a piece of paper that saysI inspected the following
components of my oil waterseparator and the bare minimums
are an inspection for eachchamber chamber one, two and
three, an outfall and then alsoinspecting if there's any drains
(10:59):
that go to it, making sureyou're inspecting, like all the
inlets, basically.
And then if that oil waterseparator has a sensor for
hydrocarbon sensing or if it hasany other equipment that helps
you know when it's full or whenhydrocarbons are in it.
All of that has to be workingand tested and verified as
(11:20):
working and tested annually aswell, and that needs to be
written down somewhere, not justvisually confirmed.
Amanda (11:28):
And that's all included in the SPCCs with integrity.
Yes, yes, we absolutely provideguidance.
Shannon (11:36):
And we can even provide example forms for your oil
water separator inspections, noproblem.
And when we perform our SPCCsite visits like when we're
creating an SPCC or updating weoften because we pay attention
to oil water separators probablya little more closely than many
groups do we often correct orwe not correct?
(12:01):
I don't want to say correct,but we get better descriptions
of the oil water separator andthe volumes of them and how they
work and where they dischargeto, and those can all be really
valuable if you have a spillevent to your drainage system
and nobody's really sure wherethe oil water separator goes to.
Like we can help you understandthat before you have an issue
and so all of that's ready forspill response when you need it.
(12:22):
Beforehand, instead of afterthe effect, try to figure out
where it's gonna come out.
Amanda (12:27):
So it sounds like a lot of potential for preventative
measure there with the oil waterseparators.
Shannon (12:33):
Yes, all passive systems do better with
preventative maintenance andproactive monitoring and
inspections.
Amanda (12:43):
All right.
Well, thank you so much forjoining us again today and
sharing some information on oilwater separators with us.
Are there any additionalresources that we can find
online?
Yeah, absolutely.
Shannon (12:55):
We will post the EPA's SPC sequence original inspectors
on the show notes and for youroil water separators.
Some of the best sources ofinformation are construction
schematics and drawings for yourfacility.
A lot of them have all of thedetails in there and you can
(13:16):
look up the volume and how it'splumbed and where it drains.
It's all part of thatconstruction documentation.
So if you have those, they'rereally important to retain
because that kind of informationgets lost over time.
Amanda (13:29):
All right, well, thank you so much for joining us today
, shannon, and we look forwardto our next chat, yeah glad to
have happy to do it.
Shannon (13:40):
Oil water separators are funky little machine and we
deal with them quite a bit, soI'm glad to put more education
out there.
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