Re-classification of Diesel, Gas Oil and Light Heating Oils by CPL

As flammable liquids the storage and handling fell under Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEAR) and HSG 176 “Storage of flammable liquids in tanks”

Oil Tank Supplies (OTS) as founding member of the Fuel Experts Association (FEA) were instrumental in forming a working group (FIWG) made up of other associations and industry experts with the aim and objective to lobbying the Health & Safety Executive (HSE) to present measured counter arguments as to why the above changes would be a cost burden to the fuelling industry and did not comply with the Government’s policy that no new Regulation should be allowed unless there was a clear Cost/Risk benefit.

The Health and Safety Executive, the FEA and the FIWG worked together to clarify the application of HSG176 and the Chairman of the FEA is pleased to confirm that following constructive discussions the HSE has issued a formal statement dated 9th November 2016:

“Under the EU CLP Regulation which came in June 2015, there are a number of substances that now meet the criteria for classification as flammable which did not do so in the past. This is partly because the upper flashpoint for classification as a flammable liquid has been increased from 55 °C to 60 °C. The changes mean that for example, diesel, gas oil and light heating oils are now classified as flammable liquids”

Re-classification of Diesel, Gas Oil and Light Heating Oils by CPL

“For the avoidance of any doubt, where diesel fuel is stored in storage tanks with a capacity not exceeding 150,000 litres, designed to recognised and appropriate industry standards such as BS 799 Part 5, OFS T/200, EN 13341 or OFS T/100 and where the vessels were manufactured in a workshop environment to controlled standards and where there is no risk associated with the formation of a flammable oil mist, the requirements of HSG 176 do not need to be applied. Information that could be used to inform this decision would include any historical evidence of an incident due to misting as well as any other relevant guidance”

Storage of kerosene at commercial, industrial and Domestic premises

 “I am also taking this opportunity to reconfirm the position set out in HSE’s letter dated 12 February 2012 to the Chairman of BSI Committee RHE/13 on the interface of the standards detailed in both HSG 176 and BS 5410 Part 1 and BS5410 Part 2 regarding the storage of Kerosene. For installations up to 10 000 litres the provisions of BS 5410 Part 1 and BS 5410 Part 2 should be applied and for installations of a greater capacity than 10 000 litres the provisions of HSG 176 should be applied.”

Oil Tank Supplies manufactures storage tanks to the highest UK Standards including being certified to OFS T/200 and are proud to be part of an industry where there is no evidence of a fatality caused by a Diesel/Gas Oil or Kerosene static storage tank exploding in over 40 years.

For Purchase or Hire of Quality Tanks, Smart Gauges or Pop Up Filling Stations (MultiServ) contact the experts on 01386 853409

To download the statement click here.

BS5410 Oil Tank

Risk Management for Critical Standby Generators – Fuel and Equipment

BS 5410

The British Standards Institution has recognised the importance of fuel quality and cleanliness in their 2016 update of BS5410-3: 1976, now withdrawn and superseded with the May 31st, 2016 release.

Concerns surround critical application standby generators whereby failure of a critical application generator could result in loss of life, a high cost of failure of applications such as emergency lighting or other “non-critical” applications. Such standby generators are typically used in hospitals, banks and other communication centres.

Filters are addressed in the update with guidance notes:

Note 1 since the introduction of Biofuel (FAME) into the fuels the quality and life expectancy of fuels has been adversely affected as FAME is hygroscopic so any water in the fuel goes into suspension. This water can lead to injector pump damage and facilitate the growth of bacteria which blocks conventional filters.

Note 2 removing as much water as possible preserves the quality of fuel and for critical standby generators only filters conforming to SAE J1488 2010_10 are to be used.

Filters should be duplicated or be of a type that permits maintenance with-out shut-down

Fuels for emergency generators should be tested every six months for quality and suitability if fitted with a fuel polishing system, if there is no polishing system the fuel should be tested every three months

Filters for “non-critical” generators should conform to OFS E104

OTS and solutions for UK/Europe

  1. Widespread deployment of DieselPure systems
  2. Advocating 3 monthly fuel sampling and testing
  3. Upgrading 80mesh duplex basket filters for SAE J1488 2010_10 compliant elements
  4. Mobile fuel filtration rigs used to clean fuel to meet SAE J1488 2010_10

What does this mean, what should I do

  1. Establish if standby generator is “critical or non-critical”
  2. If “critical” establish fuel testing regime – six or three months (verifiable by UKAS Accredited Laboratory)
  3. Has a fuel polishing system been installed, has it been tested and certified to meet SAE: J1488 2010_10 for removal of suspended water?
  4. Review fuel system maintenance schedule for standby generators with particular reference to fuel filters and SAE J1488 2010_10
  5. Identify fitment of inline “basket” filters, typically these are fitted with 80mesh filters, these will be ineffective if used with FAME based fuels, should be upgraded/replaced with SAE J1488 2010_10 certified filters.
  6. Mobile fuel polishing systems used for ad-hoc maintenance, verify system deployed meets SAE J1488_10 criteria

Possible Locations

  1. NHS – hospitals
  2. Emergency Services
  3. Facility Management Businesses – Highways, Shopping Centres
  4. Banks
  5. Data Centres
  6. Petrol Forecourts – standby generators for firefighting equipment

What is the solution?

A Canadian-designed and built filtration system that has been tested and certified to meet and exceed SAE J1488 2010_10 test criteria – DIESELPURE

Still unsure, then please contact one of our fuel experts at OTS on 01386 853409 or sales@oiltanksupplies.com

Click here to read how FAME based fuel is advancing internal corrosion of fuel storage tanks and associated downstream equipment.

Key recommendations and guidance introduce principle changes to:

  • Bio-fuels
  • Coal tar fuels have been deleted
  • Standby generators included

Corrosion images

SAE J1488_201010 Compliance and the Prevention of Infrastructure Corrosion in ULSD and Biodiesel Storage

When a problem affects a whole industry, industry wide standards are implemented to address that issue. When a new problem impacts an existing standard, that standard is updated to present a solution to the new problem. We are familiar with these standards bodies, ISO, ASTM, SAE, ASE, NFPA, STI, PEI, etc.

SAE J1488 is the industry standard “To determine the ability of a fuel/water separator to separate emulsified or finely dispersed water from fuels.” This standard is revised as required; the latest revision of this standard is SAE J1488_201010.

Why the Revision?

Water is a fact of life in diesel and diesel storage. Water in the fuel can cause a host of problems, from damage to the diesel engines to enhancing microbial growth which can clog filters and shut down gensets. In pre ULSD diesel, practically 100% of water was efficiently removed by filters, either absorbent or coalescing, and by implementing good tank housekeeping procedures, such as draining the water from the bottom of the tanks as required.

ULSD (Ultra Low Sulfur Diesel) was introduced to combat the huge environmental impact of adding sulfur to the atmosphere, notably the severe impact of acid rain on rivers and lakes and forests, not to mention the health issues affecting humans over time. The process of removing the sulfur from diesel changed the chemistry of the fuel. First to be noticed was the reduction of the natural lubricity normally found in pre ULSD diesel; there was much more wear and tear on diesel engines. This problem was addressed by adding lubricity back into the fuel with additives. What was not noticed initially was that the water in the fuel was much more tightly held to the ULSD than before. Traditional filters lost a great deal of efficiency in removing water from diesel. (Uptime Report, Biodiesel). In addition, the additives added to bring lubricity back to the fuel reduced the interfacial tension between diesel and water. This meant that the water could more easily mix with the diesel. Less of the water in storage tanks was free standing on the bottom, and more was absorbed into the fuel itself. With biodiesel fuels the interfacial tension is much lower, and volumes of emulsified water absorbed are dramatically higher.

Microbial growth in pre ULSD diesel was limited along the water/diesel interface, where there is diesel for food and water for life. Most of the emulsified water in the volume of the pre ULSD fuel precipitated out to become free standing water on the bottom. Biodiesel blends absorb much more water, and the emulsified water is so tightly held that it remains emulsified throughout the volume of the diesel. Microbes now have a much greater volume to grow in, such that there is an explosion of microbial growth in biodiesel blends. A small percentage of the microbes produce acid; in pre ULSD fuel it was such a small amount the acidic levels were rarely noticed. Todays biodiesel fuels have so much more microbial growth the acid levels are reaching a state that within a year or so that corrosion is now seen in the diesel infrastructure, affecting storage tanks, piping, and diesel engines such as emergency generators.

SAE updated their standard to SAE J1488_201010 to address the great increase in the amount of emulsified water absorbed in ULSD and biodiesel blends. SAE tested the efficiency of filters to remove the tightly bound emulsified water from these fuels. The removal/control of the emulsified water also controls the microbial growth, such that acidification is no longer an issue in these treated fuels.

The test procedure entails injecting up to 2500 ppm emulsified water into diesel with an interfacial tension of 15 mN/m, similar to biodiesel blends available today, and then filtering the fuel to provide an efficiency rating of the filters capability of removing the emulsified water. Since OEM manufacturers of gensets have warranty based on 200 ppm water or less, filters need at least an efficiency rating of 92% or better to protect the infrastructure.

SAE J1488_201010 is the industry standard to protect biodiesel infrastructures; it should be a mandatory requirement for installation of all fuel/water separators and diesel filters.

Industry Reference Documents

For further reading on biodiesel, water and corrosion, read the following. All the references below have the same common recommendation - dry the fuel.

"Corrosion in Systems for Storage and Transportation of Petroleum Products and Biofuels: Identification, Monitoring and Solutions”, Publisher: Springer Science & Business Media, Feb 17, 2014, ISBN: 9789400778849

Degradation of Fiberglass Underground Storage Tanks May 04, 2015

Battelle Report - “Corrosion in Systems Storing and Dispensing Ultra Low Sulfur Diesel (ULSD), Hypotheses Investigation”

UPTIME INSTITUTE, LLC Technical Paper: Biodiesel

NFPA 110

STI Steel Tank Institute “Keeping Water Out of Your Storage System”

PEI Petroleum Equipment Institute (PEI) Recommended Practice (RP) 2014 Final Draft RP 1400 “Recommended Practices for the Design and Installation of Fuelling Systems for Emergency Generators, Stationary Diesel Engines and Oil Burner Systems”

SAE Emulsified Water/Fuel Separation Test Procedure