ENVIRONMENTAL CODE OF PRACTICE

Oils & Fuel Handling

Overview

Businesses and individuals are responsible for complying with environmental regulations and for avoiding pollution incidences. Careful management of hazardous materials, fuels and oils can be taken to avoid such incidences, avoid negative publicity and fines. Effective pollution prevention measures can be identified by carrying out an environmental review (site audit), which should cover legal requirements, areas of risk, resource management and waste minimisation and community relations. An environmental review is the first step towards developing an Environmental Management System (EMS), which provides the framework for a company to deal with the immediate and long-term environmental impact of its products, services and processes.

The environmental agencies have produced a publication entitled ‘Getting your site right - Industrial and Commercial Pollution’ to help businesses reduce the risk of causing environmental pollution. The publication offers good practice measures and ideas for improvements, many of which can be implemented at little or no cost. Remember it is your responsibility to ensure that relevant environmental legislation is complied with at all times.

Oil and fuel storage

The protection of groundwater and watercourses from oil and fuel pollution is a key consideration and subject to regulations.

In England, all oil storage containers must comply with the Oil Storage Regulations 2001. The Environment Agency is responsible for enforcing the regulations throughout England and may serve notice requiring inadequate facilities to be brought up to standard. Failure to comply with a notice is a criminal offence and may result in prosecution. Although these regulations only apply in England, at the time of publication similar measures are planned in Wales and Northern Ireland.

In Scotland, The Water Environment (Oil Storage) (Scotland) Regulations 2006 came into force on the 1st April 2006.

The regulations come in three stages:

1. New tanks installed after 1st April 2006 will have to comply by 1st October 2006

2. Existing tanks within 10 metres of surface water or 50 metres of a borehole or well will have to comply by 1st April 2008

3. Remaining existing tanks will have to comply by 1st April 2010

In Northern Ireland and Wales you should still consider meeting the requirements of the Regulations, as they are designed to prevent contamination of the water environment which would be an offence under other legislation.

Fuel storage below ground is primarily covered by the Groundwater Regulations 1998. In cases where the control of Pollution (Oil Storage) Regulations 2001 do not apply (e.g. on farms and for waste oil) following the guidelines below will minimise the risk of your site causing pollution.

In summary, the Regulations state that:


  • Oil storage tanks must be of sufficient strength and structural integrity so as to be unlikely to leak or burst under normal operating circumstances
  • Oil tanks and drums must be stored in some kind of secondary containment, usually a bund
  • Also, all of the valves, filters, sight gauges and pipe work must be contained within the bund when not in use
  • The bund must be big enough to contain 110% of the maximum volume of the container. For bunds serving multiple containers, the bund should be able to hold 110% of the largest tank, or 25% of the total volume, whichever is larger
  • A single drum requires a drip tray able to contain 25% of its capacity, and mobile bowsers should be self-bunded, stored in a bund or have a drip tray
  • The bund should be impermeable to water and oil, and must not contain any drainage valves
  • If there is above ground pipe work, it must be properly supported and maintained
  • Underground pipe work needs to be suitably protected from damage, with detection measures in case of leaks, and mechanical joints need to have accessible inspection points
  • Care should be taken to position storage tanks away from any possible damage from traffic, and secure from vandals
  • Tanks and bunds should be maintained and checked regularly

All types of oil, with the exception of waste oil, are covered by these regulations, including petrol, diesel, vegetable, synthetic and mineral oil. Waste oil storage is covered by the Waste Management Licensing Regulations. It is important to note that in the case of flammable liquids, such as petrol, additional health and safety requirements may also apply
The environment agencies have produced Pollution Prevention Guideline for oil (PPG2), which provides guidance on how to minimise the risks associated with storing oil above ground. It also contains a checklist to help you decide whether improvements are needed to your oil storage to ensure compliance with the Oil Storage Regulations. Advice on storage in drums and intermediate bulk containers is available in PPG26 and details on minimising the risk of your boat or marina causing such pollution can be found in PPG14. PPG 8 covers the storage of all waste oils.

In addition to the requirements of the legislation, the following Best Practise is recommended:

  • Fuel storage and dispensing installations should be well maintained. Maintain all delivery hoses, pipe work and trigger nozzles to a high standard and secure them to prevent unauthorised interference. Clearly display a notice providing advice on how to avoid spillages and what to do if they occur
  • Oil should not be stored on pontoons as the risk of pollution is greatly increased. Where this is unavoidable, please discuss the necessary pollution prevention measures with your local Agency office. Prefabricated proprietary tank systems are likely to be necessary to provide adequate protection from pollution. These have a primary container with integrated secondary containment.
  • Ensure fixed storage tanks cannot move from their base or float away in the event of unusually high tides or floods as this causes pipelines to break and oil to be spilled. Where possible, avoid placing tanks in areas at risk from flooding. Contact your local Agency office to check if your tank is located in a flood plain.
  • It is recommended that fuel tanks and pipe work should be installed above ground whenever possible. This will enable regular maintenance checks to be carried out and leaks to be identified earlier.
  • Underground storage tanks provide one of the greatest risks to groundwater quality. This is why their control comes under the Groundwater Regulations 1998, in England and Wales. The Department for Environment, Food and Rural Affairs (DEFRA) has also produced the Groundwater Protection Code, which gives comprehensive guidance on the installation, operation and decommissioning of underground storage tanks. In Scotland, the Scottish Executive Environment Group Publication “Underground Storage Tanks for Liquid Hydrocarbons”, covers this topic. These documents should be consulted whenever an underground facility is present or planned.

Dispensing oil and fuel

When dispensing fuel, the potential for direct water contamination is more pronounced, especially at landing places and marinas. In order to reduce these risks the following procedures should be undertaken.

Fuel installations should be well maintained and all delivery hoses, pipe work and trigger nozzles kept to a high standard and secured, perhaps in a secure cabinet (with a drip tray) to prevent unauthorised interference. Flexible delivery pipes should be kept within a bund and have a cut-off valve or lockable valve where it leaves the container. “Trigger” delivery nozzles with automatic cut-off on release are considered good practise.

Any pump attached to the tank should have a check valve in the feed line to prevent the tank contents draining down in the event of damage to the pump or feed line. The pump should be positioned or other steps taken to minimise risk of impact damage and unauthorised use. Be aware that the potential for leaks increases with the number of joints in the pipe work. You should ensure that an appropriate form of leak detection is in place, dependent on whether you are using a pressure or suction delivery system.

Wherever possible locate dispensing facilities in an area where spills can be contained easily, for example, away from main river flows or heavy river traffic. When refuelling, vessels should be adjacent to the dispensing point to ensure that none is spilt in to the water or the boat itself. Consider allocating a separate berth, which is used only for refuelling.

Fixed fuel tanks

These should be carefully filled adjacent to the fuel supply facility, ensuring that no fuel is discharged over the side or into any part of the vessel. Some free space should be left in the tank to avoid overflow should the craft tilt. Any spillages must be cleared up with a suitable absorbent. Absorbents and other materials used in a clean up operation will be classified as hazardous waste and should be properly disposed of at approved facilities or local authority waste disposal sites.

Portable fuel tanks

Portable tanks and spare fuel containers should be filled away from the water’s edge and never overfilled, as spillage and bilge contamination will result. They must be clearly marked with the type of fuel and sited and secured safely on the vessel to minimise the risk of collision damage, accidental spillage overboard or unauthorised interference.

Mobile bowsers

In England mobile bowsers must also comply with the Oil Storage Regulations and should be maintained to a high standard. The bowsers should have secondary containment able to contain 110% of the bowser storage capacity. All ancillary equipment including sight gauges, vent pipes, valves and filters should be within the secondary containment. Where fuel is delivered via a flexible pipe it should have a manually operated pump or valve at the delivery end that closes automatically when not in use. The pump or valve must have a lock and be locked shut when not in use. The pipe must have a lock where it leaves the container that is locked shut when not in use. Where fuel is to be delivered by pump, an anti-siphon valve should be incorporated in the delivery line. When not in use, bowsers should be kept securely locked, preferably in a bunded compound well away from the water’s edge or surface water drains.

Where a tank (proprietary or conventional) is used for re-fuelling plant, yachts or vehicles the refuelling area surface water drainage should be isolated from the general site drainage system and passed through an oil separator because it is most likely that oil will be “lost” from refuelling activities rather than from storage tank itself. If you wish to discharge to a controlled water body you should obtain consent from the Environment Agency. The use of overfill prevention devices is recommended as just an overfill alarm may not notify an overfill in time.

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