Institute Petroleum Guidelines

INSTITUTE OF PETROLEUM
GUIDELINES FOR SOIL, GROUNDWATER AND

SURFACE WATER PROTECTION AND
VAPOUR EMISSION CONTROL
AT PETROL FILLING STATIONS
INSTITUTE OF PETROLEUM
GUIDELINES FOR SOIL, GROUNDWATER AND

SURFACE WATER PROTECTION AND
VAPOUR EMISSION CONTROL
AT PETROL FILLING STATIONS
June 2002
Published by
The Institute of Petroleum, London
A Charitable Company Limited by Guarantee
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ISBN 0 85293 358 4
Institute of Petroleum, 2002
Institute of Petroleum
61 New Cavendish Street
London W1G 7AR, United Kingdom
Tel: +44 (0)207 467 7100
Fax: +44 (0)207 255 1472
Email: ip@petroleum.co.uk
Web: www.petroleum.co.uk
Published in the UK
CONTENTS
Page
Contents guide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi
Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xii
1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2 Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
3 Philosophy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
4 Environmental policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
5 Environmental management systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

5.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
5.2 Licences and consents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
5.3 Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
5.4 Organisation and communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
5.5 Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
5.6 Control and verification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
5.7 Revision of plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
6 Environmental risk assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
7 Emissions to soil, groundwater and surface water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

7.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
7.2 Potential sources of emissions during normal site operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
7.3 Sources of discharges - site infrastructure and equipment options . . . . . . . . . . . . . . . . . . . . . . . . . 17
7.4 Potential pathways for pollution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
8 Detecting loss of product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

8.1 Wetstock monitoring/leak detection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
8.2 Tank/pipework testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
8.3 Apparent losses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
8.4 Testing effluent quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
v
Contents Cont... Page
9 Emissions to air . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
9.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
9.2 Vapour recovery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
10 Management of contaminated sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

10.1 Soil and groundwater contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
10.2 Legal requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
10.3 Process of managing contaminated land . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
10.4 Site investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
10.5 Site remediation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
11 Contractor accreditation and assessment of capabilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
12 Emergency spill procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

12.1 Large scale incident response plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
12.2 Factors to be considered in the response plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
12.3 Small incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
Annex A - Model schedule of inspections and tests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Annex B - Model safety, health and environmental policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
Annex C - Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55
Annex D - References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59
vi
CONTENTS GUIDE
Are you familiar with the purpose of this No

See Sections 1 and 2
document?
Yes
Do you have a good understanding of your

No
legal obligations for environmental See Section 1 and 7.1
protection?
Yes
Are you familiar with the concept of an No

See Section 4
Environmental Policy?
Yes
Are you familiar with the concept of an No

See Section 5
Environmental Management System?
Yes
Is there an Environmental Management No

See Section 5
System for your site?
Yes
Are you familiar with Environmental Risk No

See Section 6
Assessment?
Yes
Is there an Environmental Risk Assessment No

See Section 6
for your site?
Yes
vii
CONTENTS GUIDE continued...
Does the ERA for your site indicate that the

risk of emissions from the following sources
is unacceptable?
See Section 7.3.1

Yes Define process for
Dispensers
implementing change
No
See Section 7.3.2
Pipework
implementing change
No
See Section 7.3.3
Storage Tanks
implementing change
No
See Section 7.3.4
Offset/Direct Fill Pipes
implementing change
No
See Section 7.3.5
Delivery Procedures
implementing change
No
Does the ERA for your site indicate the risk of

the following acting as a pathway is
unacceptable?
See Section 7.4.1

Forecourt Surface Quality
implementing change
No
See Section 7.4.2
Drainage
implementing change
No
See Section 7.4.3
Oil/Water Separators
implementing change
No
See Section 6 for ERA review period

recommendations
viii
CONTENTS GUIDE continued...
Are you familiar with the methods to detect No See Section 8.1
leaks?
Yes
Are you familiar with storage tank/pipework No See Section 8.2

testing?
Yes
Are you familiar with vapour emission No

See Section 9
control?
Yes
Are you familiar with the management of No See Section 10

contaminated land/site remediation?
Yes
Are you familiar with emergency spill No

See Section 12
procedures?
Yes
Is there an Emergency Spill Response Plan for No

See Section 12
your site?
ix
x
FOREWORD
This publication has been produced by the Institute of Petroleums Service Station Panel to provide guidance to
petrol filling station operators for the protection of soil, groundwater, surface water discharges and air quality at
petrol filling stations. The guidance in this publication is intended to complement that contained in the Department
for Environment, Food & Rural Affairs Code of Practice Groundwater protection at petrol stations and other fuel
dispensing facilities involving underground storage tanks approved by the Minister of State under the Groundwater
Regulations, 1998, which applies in England and Wales.
Those wishing to follow any of the engineering options detailed in this publication should satisfy themselves
that due consideration is given to the potential impact on safety that any changes may have. For guidance on safety
issues readers are referred to IP/APEA Guidance for the design, construction, modification and maintenance of
petrol filling stations.
Although it is hoped and anticipated that this publication will assist those involved in the operation of petrol
filling stations, the Institute of Petroleum cannot accept any responsibility, of whatever kind, for damage or loss,
or alleged damage or loss, arising or otherwise occurring as a result of the application of the guidance contained
herein.
Suggested revisions are invited and should be submitted to the Technical Department, Institute of Petroleum,
61 New Cavendish Street, London W1G 7AR, UK.
xi
ACKNOWLEDGEMENTS
This publication was prepared at the request of The Institute of Petroleums Service Station Panel, by Paul Shone
(ChevronTexaco Ltd.). The draft was subsequently reviewed and developed by representatives from the following
companies/organisations:
Association of UK Oil Independents (AUKOI)

Association of Forecourt Systems Contractors (AFSC)
Berry & Co
BP
ChevronTexaco Ltd.
Conoco Ltd.
Environment Agency
Esso Petroleum Company Ltd.
Health and Safety Executive
Kuwait Petroleum (GB) Ltd.
Petrol Retailers Association (PRA)
Petroleum Equipment Installers and Maintenance Federation (PEIMF)
Petroleum Enforcement Liaison Group (PELG)
Shell UK Ltd.
Tesco Stores plc
TotalFinaElf UK Ltd.
United Kingdom Petroleum Industry Association (UKPIA)
Veeder-Root
The Association for Petroleum and Explosives Administration (APEA) is thanked for agreeing to the reproduction
of several sections of text taken directly from APEA/IP Guidance for the design, construction, modification and
maintenance of petrol filling stations.
xii
1
INTRODUCTION
The need for good environmental performance has structured means of deciding what has to be done to
always been a requirement, but increased public satisfy policy requirements and should be an integral
awareness and new regulations over the last few years part of the normal management process. It will include
have brought it into sharp focus. Many companies organising implementation, checking results against
already have good practices and procedures to protect targets and making adjustments as necessary to ensure
groundwater, soil, surface waters and prevent vapour the original objectives are met. If the policy calls for
emissions to air, but up to now there has not been continuous improvement then the process of planning,
agreed petroleum industry guidance for service stations. action and review needs to be ongoing.
This publication is intended to be a reference guide A number of recognised management systems are
for any individual charged with environmental available, e.g. ISO 14000, ISO 9000 and Eco
protection of petrol filling stations. It outlines the Management and Audit (EMAS). However it is neither
minimum standards expected of a well operated facility a legal requirement nor a recommendation of the
whose owner/operator seeks to meet the requirements Institute of Petroleum to have the management system
of the European Directive 80/68/EEC and UK externally verified and accredited. The duties and
Groundwater Regulations 1998, provides details of best responsibilities described in the following guidelines
practice and is intended to act as a bibliography and may be carried out by site personnel, or other people
guide to other more detailed legislation, codes of within the organisation. Records may also be kept
practice and relevant publications. locally in whatever form is easily accessible and
These guidelines concentrate on the practical maintainable.
means of minimising the potential impact of motor fuels Within the UK, health and safety issues associated
where they are stored and dispensed to the public at with the design, construction, modification,
petrol filling stations to soil, groundwater, surface maintenance and operation of petrol filling stations are
waters and local air quality. It is recommended that subjected to a regulatory regime, guidance for which is
these guidelines should form part of the Environmental contained elsewhere. In addition, other authorisations
Policy of the company that owns the installation. Such may be required from one of the Environment
a policy will set the broad long-term objectives without Agencies1, a water company, and the Local Authority
giving details of how they are to be achieved. An Environmental Health Department, whose aim is to
Environmental Management System then provides a ensure adequate environmental protection.
1
Depending on location in the UK authorisations may be required from either the Environment Agency (in England and Wales),
the Scottish Environment Protection Agency or the Environment and Heritage Service (in Northern Ireland). These are referred
to as the 'UK Environment Agencies' throughout this publication.
1
GUIDELINES FOR SOIL, GROUNDWATER & SURFACE WATER PROTECTION & VAPOUR EMISSION CONTROL AT PETROL FILLING STATIONS
In countries outside of the UK, sites also operate under practices.

a variety of authorisations, licences and consents that A number of guidelines and codes of practice
stipulate minimum operating standards. These provide details of specialist aspects of the
conditions may be enforced at Local, State or environmental impact of fuel storage and dispensing.
Federal/National level. It is anticipated that these The following subjects are covered briefly in this
guidelines may prove to be a useful reference for those publication, with more detail to be found in the
responsible for ensuring adequate environmental publications listed in the bibliography:
protection measures are in place.
In reading the guidelines it should be noted that vapour recovery;
actions to minimise release of hydrocarbons to the general construction issues;
environment may also lead to improvements in safety groundwater risk assessment of existing
performance, healthier working conditions for operations;
employees and more cost-effective operations. fire and explosion risk assessment (see HS(G) 146);
The guidance offered is intended for international CNG or LPG;
use but, where appropriate, reference is made to EC and local ambient air quality impacts of station
UK legislation. In other countries reference should be operation.
made to national legislation and recognised operating
2
2
SCOPE
This publication aims to provide: A reference document for minimum standards of

operation and guidance on cost-effective practices
An explanation of the soil, groundwater, surface to minimise impact to soil, groundwater, surface
water and air quality issues involved in the water and air.
operational aspects of petrol filling stations. Details of 'best practices' to enhance protection of
soil, groundwater, surface water and air.
3
4
3
PHILOSOPHY
The philosophy presented in these guidelines is that To implement this simple philosophy it is
"prevention is better than cure" and that there should necessary to raise the level of understanding of all
not be a reliance, solely, on the so-called "end of pipe" personnel on how to operate existing equipment and
solution to clean up emissions2 arising out of facilities to ensure, as a minimum, that environmental
operations. Therefore the overall aim should be fuel performance meets legal requirements.
containment integrity, from the tanker off-loading point It is therefore necessary to understand and analyse
to the dispenser nozzle, through correct operational the operations to identify all the potential sources of
procedure, site design, construction and maintenance. emission and then tackle the largest potential sources
If an emission stream is not generated, it does not have first. The cost effectiveness of this approach is
to be cleaned up or controlled. illustrated by Figure 1.
"END OF PIPE"
SOLUTIONS
Costs
for High Capital
Environmental investment
Control
PREVENTION
AT SOURCE
Low investment
IMPROVED PRACTICES (e.g. segregation,

AND PROCEDURES sample collection,
Usually very low cost etc)
Figure 1 - Cost effectiveness
2
Emission is defined as a 'release of product to the environment' and is not therefore limited to petroleum vapour.
5
It should be recognised that the requirement for

enhanced environmental protection is likely to increase
and it will be important to demonstrate that the
knowledge, training and the management capability and
commitment to handle the problems exist.
6
4
ENVIRONMENTAL POLICY
An environmental policy should be developed which environmental performance.

outlines the way a company or site operator is to Communication with the public on environmental
exercise control over potentially polluting operations. matters and sharing information and experience
The environmental policy can be an extension of an with others to bring about improvements in
existing safety policy or a separate document. It should performance.
make commitments to the following:
See Annex B for a model safety, health and
Compliance with all local environmental laws, environmental policy.
regulations and site specific conditions of
authorisation, as a minimum, together with the These are broad directional commitments which
setting of self-imposed responsible standards recognise that a company will have to operate within a
where laws and regulations do not exist, or the changing climate as the expectations of the public, their
operator wishes to achieve higher standards. representatives and regulatory authorities, grow more
Conducting business in a manner which balances demanding. At the operational level, an effective
environmental and economic needs of the management system is essential to ensure performance
community. continues to improve, to match the increasing demands
Continuous assessment and review to improve required by the policy.
7
8
5
ENVIRONMENTAL
MANAGEMENT SYSTEMS
5.1 GENERAL 5.3 PLANNING
An Environmental Management System (EMS) should The systematic achievement of environmental policy
be developed, which considers organisational objectives requires an assessment of the risk of
structures, responsibilities, operational measures and detrimental impact to soil, groundwater, surface water
resources required to implement a company's and air quality. The principles of risk assessment are
environmental policy and to monitor and control covered in Section 6. The plan should be reviewed
performance. It should be flexible enough to take regularly, usually annually, as follows:
account of site specific conditions and specific Industry
initiatives and should ensure that environmental Assess the environmental performance of current
considerations are continuously integrated into business operations against statutory consents and company
decisions in a systematic way. standards.
Initially, the EMS may concentrate on providing Identify improvements needed.
information and raising the level of environmental Review regulatory and legislative developments
awareness; subsequently, the emphasis will switch to with assistance of Trade Associations.
specific operational targets for improvement measures. Review complaints.
See Figure 2. Modify the environmental objectives to take
account of these developments.
Establish a dialogue with the regulatory authorities,
5.2 LICENCES AND CONSENTS local authority and public.
A site may have a number of consents, covering Short-term plans within the framework of a long-term
emissions to the environment, issued by appropriate strategy will enable staff to monitor progress, and to
regulatory authorities. These may specify equipment ensure achievement of goals. Where major changes are
and operating standards as well as the maximum planned it is particularly important to carry out an
allowable levels of emissions. Copies of all consents, assessment of their possible effects on soil,
licences and records should be accessible to site staff groundwater, surface water and air quality. This can be
and it is recommended that they be stored on site. done using the risk assessment technique described in
9
Generate Management Commitment
Review the Policy

Agree an Environmental Policy Periodically
Carry out a thorough review of all

current operations and procedures to
assess the potential risk to the
environment.
Assess performance of current

operations vs statutory consent levels
Develop/revise a plan to address ways to reduce or eliminate the highest

priority risks and ensure that consent levels are met, as a minimum
Monitor Legislation and Communicate the plan to all

Regulations involved personnel
Compare actual performance with Provide training and

the targets set in the plan implement the plans
Actions in this loop should be ongoing, reviewed at least annually
Figure 2 Environmental management structure
Section 6. Such an assessment should also include and why. All personnel should be made aware of how
simple cost/benefit analysis to help in planning and to contribute to a two way process of reducing the
prioritising changes. potential impact of site operation on soil, groundwater,
surface water and air quality. It may be necessary to
provide training for employees where existing standards
5.4 ORGANISATION are changed, or new ones established, in order to take
AND COMMUNICATION account of environmental requirements.
External communication is necessary if good
Management should be responsible for environmental working relationships are to be established with
protection and performance, for which staff at all levels regulatory authorities and neighbours. Any
are accountable. Improvements can only be made with environmental complaints should be recorded along
the full support of all employees. It is recommended with the action taken and by whom. Responses should
that the responsibility for development of policy, be professional, courteous and tactful. Local
drawing up of programmes and regular reviewing of relationships can prove to be an invaluable asset in the
progress should be given to one person. event of an environmental incident. It is helpful to
To earn support it is essential to raise maintain a good record of all environmental
environmental awareness amongst personnel, both full improvements and changes made.
time and contract, so that they have a clear In order to meet environmental performance targets
understanding of what the company is trying to achieve the Responsible Person in charge of the station should
10
ENVIRONMENTAL MANAGEMENT SYSTEMS
ensure that: weekly, monthly and annual inspections and tests.

A log book for recording and reporting of failures
all staff and customers comply with site rules and should be introduced in order to extend understanding
procedures; of environmental impact and to avoid further failures.
all maintenance visits are recorded; Incident investigation and corrective action should
equipment is inspected (see below) and all tests be made and recorded.
and maintenance are carried out when required;
adequate information, instruction and training to
staff is provided; 5.6 CONTROL AND VERIFICATION
Material Safety Data Sheets are provided;
any environmental measures that may be needed Control and verification of the measures implemented
are immediately actioned and a record of them can be achieved through monitoring and audits.
kept; Improvement in performance depends very much upon
any accidents, incidents are recorded; raising environmental awareness of employees. Regular
a suitably trained stand-in is available in the event assessments involving both the Responsible
of absence. Person/management and operators to identify
improvements made, and areas for further
Similarly all employees should ensure that: improvement, are strong stimuli.
Complaints and any incident affecting soil,
All unplanned or non-approved discharges to the groundwater, surface water or air quality should be
environment are fully recorded and management reviewed by the site manager.
advised. Reporting and reviewing environmental
All appropriate procedures for controlling performance should be a regular process, with the
emissions to the environment are fully observed. frequency aligned to the risk associated with the
All faults on equipment and fittings are entered in environmental impact. Where performance is falling
the site log to enable remedial action. short of expectations, action can then be taken in time
All complaints from members of the public are to ensure the short term targets are met. Environmental
recorded to enable follow-up action. auditing should be a systematic, objective and fully
documented exercise to demonstrate the way in which
management and facilities are performing in
5.5 IMPLEMENTATION safeguarding the environment.
The results of this review should be communicated
Performance targets, consistent with short and long- to the operational personnel providing the information.
term policy objectives, should be developed. These In the UK, regulations require most inspections to be
must take account of existing regulatory consents and documented, and this should be done using a register,
set a minimum standard to be maintained at all times. logbook or other record that satisfies the minimum
As targets are developed they should anticipate requirements.
changes, financial constraints and technical and
operational developments.
In addition to statutory inspection and test regimes 5.7 REVISION OF PLANS
on vapour recovery equipment, the introduction of
voluntary inspection programmes should be considered. The periodic review and audit of inspection records and
All inspections and tests should be scheduled on a other documentation should include a review of targets
regular basis. and goals. This process forms part of the environmental
See Annex A for a model schedule of daily, risk assessment (ERA) and continual improvement.
11
12
6
ENVIRONMENTAL
RISK ASSESSMENT
The first step in understanding the implications for soil, each area and assess the consequences.
groundwater, surface water and air quality of operating 3. Identify what is in place to prevent such a release.
a petrol filling station is to undertake an environmental 4. Identify what measures are in place to minimise the
risk assessment (ERA). effects of any release that may occur.
The purpose of undertaking an ERA is to identify 5. Decide if these measures are enough, or if
parts of an operation that could cause emission of improvements are required to reduce risk.
hydrocarbons (in either liquid form or as vapour), and
assess the likelihood and consequences of the release. In order for pollution to occur, three components must
The ERA can also be used to contribute to the planning be present, which are collectively termed a 'pollutant
and design process as it should indicate the need or linkage' under the definition given in Part IIA of the
otherwise for improved engineering controls. However Environmental Protection Act 1990:
it should be noted that the conclusions of an ERA may
preclude site development in the most 'environmentally (a) There must be a source of pollution.
sensitive' areas. (b) There must be a pathway to a receptor.
(c) There must be an environmental receptor that can
An ERA consists of five stages: be affected.
1. Identify potential sources of pollution. Examples of pollutant linkages are given in Table 1, see
2. Identify what may go wrong to cause a release in also Figure 3.
Table 1 Pollutant linkages
Source Pathway Receptor

Leaking underground fuel tank Permeable strata above water table Groundwater in aquifer
Poorly maintained oil/water separator Surface water sewer Surface watercourse

Faulty pressure/vacuum vent on tank Prevailing wind direction Air quality in local residential area
vapour manifold
13
Pathway
Source Receptor
Figure 3 Pollutant linkage
If any of the three components in this example is services. All potential pathways;
absent, then there is no pollutant linkage and the site proximity of houses, cellars, rivers, aquifers, water
may not pose a risk to the environment. It is important abstractions. Potential receptors.
to remember, however, that new sources, pathways and
receptors may arise at any time in the future, and these An ERA should be carried out at all sites, regardless of
will need to be considered to ensure that the risk age. It should be reviewed periodically, and always
assessment remains valid. Breaking the linkage, by prior to significant changes to site infrastructure, or
removing any one or more elements, removes the risk surrounding land use caused by external influences.
associated with that linkage. Where a site is determined by assessment to be 'high
The process of ERA is similar to the fire and risk', the suitability of emission control measures should
explosion risk assessment as recommended in HS(G) be reviewed immediately, see section 7.
146. For more detailed information on the methods of In extreme circumstances e.g. a poorly run station
performing an ERA see IP publication Guidance adjacent to a drinking water abstraction well, the
document on risk assessment for the water environment Environment Agency may consider the risk
at operational fuel storage and dispensing facilities, unacceptable and either serve an improvement or
developed in conjunction with the Environment prohibition notice. The Environment Agency may also
Agency. object to planning applications for redevelopment of a
By reviewing the type and condition of equipment site through the planning regime.
on site and putting it in a site specific context (both in In the UK, regulatory bodies often use ERA as a
terms of surrounding neighbours and environment), it way of setting inspection priorities, see 7.1. It may be
is possible to judge relative risks of pollution. possible to obtain copies of regulatory ERA or
An ERA requires the identification of source risks, complete the exercise jointly, as both owner and
pathways and receptors/consequences from inter alia: regulator have access to site specific information.
For a model questionnaire to facilitate the
tank and pipe age, soil chemistry conditions, undertaking of ERA, see IP Guidance document on risk
oil/water separator design, leak and spill history. assessment for the water environment at operational
All potential sources; fuel storage and dispensing facilities.
drainage layout, geology and underground
14
7
EMISSIONS TO SOIL,
GROUNDWATER AND SURFACE
WATER
7.1 GENERAL aquatic habitats, see Figure 4. Groundwater in the
vicinity of the petrol filling station may or may not be
Hydrocarbons which escape from containment at a fed from water falling on the surface at the filling
petrol filling station may enter the soil directly beneath station, depending on whether there is a path for it to
the site, or around its perimeter. Motor fuel entering the follow. Components of motor fuels have significant
soil will, because of its known toxicity, have a solubility in water and once dissolved can give rise to
detrimental or fatal effect on the flora and fauna within contaminant plumes that can pollute significant
the contaminated area. Its subsequent dispersion will volumes of water. As well as being toxic towards
depend on migration of fuel, water movement, aquatic life, motor fuels may cause health problems to
biodegradation and soil absorption. The extent and humans if ingested and because of this, any
duration of the pollution will also depend on the contamination will have to be removed from potable
quantity and duration of the motor fuel release and any water by the relevant water supply companies.
subsequent action. In Europe, EC Directive 80/68/EEC specifies that
Soil, and the substrate beneath it, may contain there should be no entry of List 1 substances, including
water that ultimately feeds a water supply for people or mineral oils and hydrocarbons, e.g. benzene (see Table
animals, or supports river flows, wetlands or other 2), into groundwater.
Table 2 List 1 Substance from EC Directive 80/68/EEC
Organohologen compounds (and substances which may form such compounds in the aquatic environment)
Organophosphorous compounds: any organic compound which contains one or more covalently bonded phosphorous
atoms
Organotin compounds: any organic compound which contains one or more covalently bonded tin atoms
Mercury and its compounds
Cadmium and its compounds
Cyanides
Substances which are carcinogenic eg benzene, mutagenic or teratogenic in or via the aquatic environment
Mineral oils or hydrocarbons
15
Precipitation
Water vapour
movement within
atmosphere
Infiltration Urban area
Evaporation
Abstraction
Run-off
W ate
r tab
le / G Run-off
roun
dwate
r leve
l
Wetland
Groundwater flow
within aquifer River
Figure 4 Schematic of the water cycle
In England and Wales the discharge of motor fuel to supplies resulting from potentially polluting activities
watercourses is controlled principally under the Water and accidental releases of pollutants. Generally the
Resources Act 1991 which states that it is an offence to closer the activity or release is to a groundwater source
discharge poisonous, noxious or polluting material the greater the risk. The Zone classification used is
(which includes petrol) into any 'controlled waters' shown in Table 3. For further information see the
(which includes any watercourse or underground strata) following pages of the Environment Agency website:
either deliberately or accidentally. In England and
Wales guidance has been issued by the Department for http://www.environment-agency.gov.uk/subjects/
Environment, Food and Rural Affairs in Code of waterres/groundwater
Practice Groundwater protection at petrol stations and http://www2.environment-agency.tv/gwcl/
other fuel dispensing facilities involving underground gwvmpicker_1.htm.
storage tanks. In the UK the Environment Agencies are
responsible for the protection of controlled waters from For Scotland, groundwater vulnerability maps may be
pollution and several relevant guidance notes have been obtained from British Geological Survey3 and advice
issued, for example PPG3 Use and design of oil should be sought from SEPA.
separators in surface water drainage systems. When undertaking a site ERA it is important to
In England and Wales the EA has developed have a clear understanding of the sensitivity of
Source Protection Zones to support their groundwater groundwater to hydrocarbon emissions. Whilst the
protection policy. The Agency's policy approach Groundwater Directive requires all groundwater to be
affords the greatest protection to groundwater resources protected, not just that in Source Protection Zones, the
most at risk and enables pollution prevention measures Zone classification should form an essential part of any
to be targeted more effectively. Source Protection ERA and prioritisation process.
Zones provide an indication of the risk to public water
Table 3 - Environment Agency For England and Wales Groundwater Source Protection Zones
Zone Criteria
Inner Zone I 50 day travel time from any point below the water table to the source. Minimum size 50 m.
Outer Zone II 400 day travel time or 25% of the catchment area, whichever is the larger.
Source catchment Area needed to support the protected yield from long term groundwater recharge.
Zone III
3
British Geological Survey can be contacted via their website www.bgs.ac.uk
16
EMISSIONS TO SOIL, GROUNDWATER AND SURFACE WATER
7.2 POTENTIAL SOURCES OF EMISSIONS ground. It is therefore recommended that all dispensers
DURING NORMAL SITE OPERATIONS should be fitted with a leak proof drip tray or membrane
arrangement beneath the dispenser (as required by BS
The ERA needs to take account of the fact that despite 7117 Part 2: 1991 for new dispensers) to ensure that
rigorous operating procedures and mechanical integrity product from small internal leaks flows onto the
of equipment some product may escape from forecourt surface where it will be noticed, and diverted
containment to groundwater during normal site to the site drainage system. Drip trays can also be fitted
operations. Effective control and limitation of these with monitoring devices. With pressure systems, leak
releases is a second line of defence after containment. proof sumps may be used instead of, or in addition to,
The principal sources of loss of product a drip tray. These provide convenient access below the
containment, in approximate descending order of dispenser to any isolating and impact check valves and
frequency of incidents (not volume of product), are for the connection of pipework. Under pump sumps are
shown in Table 4. For further details of the sources see likely to contain vapour. To avoid ground
7.3. contamination, and the likelihood of a potential
explosion hazard, special precautions will be necessary.
Table 4 Sources of discharges Consequently under pump sumps should be:
Possible discharges in runoff to surface watercourses. impervious to the fuel;

Leaks from: under dispenser valves and flexible adequately protected against corrosion;
couplings sealed at all pipe entries to prevent fuel leakage
pipework into the ground and ingress of groundwater;
tanks and offset fill pipes fitted with an appropriate leak detector device
faulty oil/water separator operation certified for use in a Zone I hazardous area;
Possible discharges to soakaways. designed to allow easy removal of any fuel or
Spills during: customer refuelling, including water that may accumulate.
leaking car fuel tanks
filling of petrol filling station All installations should be inspected for integrity
underground storage tanks directly periodically and as a minimum every six months.
or by below ground level offset fill
Dependent on the outcome of the ERA an option
points
filling of petrol filling station that may be considered is the replacement of
underground storage tanks via above problematic dispensers with new ones which meet the
ground level offset fill points requirements of current design standards.
overfilling of portable containers
7.3.2 Pipework
7.3 SOURCES OF DISCHARGES - Experience has shown that leaks in underground

SITE INFRASTRUCTURE pipework outnumber leaks from storage tanks 10:1 and
AND EQUIPMENT OPTIONS in terms of leak size are the principal source of soil
and groundwater contamination beneath petrol
Where an ERA identifies unacceptable risks (either as stations. This has in a large measure been a direct
a result of environmental sensitivity or current consequence of the vulnerability of buried steel
infrastructure/equipment performance), or opportunities pipework to corrosion which, coupled with inadequate
for improvement and cost reduction, the operator attention to corrosion protection during installation,
should review the site infrastructure and equipment particularly of the vulnerable cut threads of screwed
options detailed in 7.3.1 7.4.3 joints, has lead to serious point corrosion and early
failure of pipework. Steel pipework was usually
7.3.1 Dispensers and under dispenser trays installed, but since 1989 has usually not been approved
for new installations without effective anti-corrosion
Experience has shown that dispenser (pump) leaks are protection.
the most common form of containment failure at petrol The development of non-metallic pipework and
filling stations and may range from air separators, latterly the better protection available for steel
dispenser valves or flexible couplings. As dispensers pipework, together with the technique of secondary
can be set over open soil, any leak may go straight to containment, has been a direct result of increased
17
awareness of the consequences of unabated pollution. new non-metallic pipework meets the requirements of
A test of existing pipework may be required if a IP Performance specification for underground
leak is suspected, (see also Section 8). The methods pipework systems at petrol filling stations, 2nd edition.
used will be determined by the type of pipework, its That document provides performance testing
installation and an assessment of the risks involved in procedures to demonstrate that a product has overall
using each method. For details of suitable test methods fitness-for-purpose for use in underground piping
see 8.2, APEA/IP Guidance for the design, systems, and encompasses all issues relating to
construction, modification and maintenance of petrol operational life expectancies of at least 30 years. The
filling stations and HELA PETEL circular 65/34 Leak document also includes a requirement for new samples
detection in tanks and pipework, October 2000. of a manufacturers product to be tested annually, to
If pipework is subject to corrosive failure, it should ensure that it continues to meet fully all performance
be replaced, see Section 12. In such circumstances requirements.
consideration should be given to fitting an under Depending on the outcome of the ERA for the site,
dispenser check valve and removing the angled check consideration should be given to the need to install
valve on the tank lid to provide immediate drain back. pipework with either Type 1 or Type 2 secondary
The removal of any pipework should not containment. The main function of secondary
commence until a risk assessment has been carried out containment is to retain any leaks from fuel carrying
and the pipe has been drained and isolated from sources pipes and to provide a conduit for leak detection. For
of fuel. A flammable atmosphere or residue of motor further details see IP Performance specification for
fuel may be present in the pipework and a precautionary underground pipework systems at petrol filling stations.
measure of flushing with water should precede the Experience has shown that a high proportion of
removal and dismantling work. Due to the risk of pipework leaks result from poor installation. The IP
petroleum vapours being present when pipelines are specification places a requirement on pipework
disconnected, continual atmosphere monitoring is manufacturers to make available a written manual on
recommended. Excavated pipeline should be removed the correct methods of laying out underground systems,
from site as soon as possible and disposed of safely. and details of how to make sound pipe connections and
Water used to flush out the pipework should be any proprietary techniques and tools to achieve
collected for safe disposal. It may be possible, subject reproducible leak-proof joints. The manufacturers
to approval, to discharge this water through the on-site manual is also required to provide a checklist of
oil/water separator. sequential actions necessary to achieve a correct
For guidance on the design considerations for the installation, and instructions for safety and repair.
selection of new pipework see Chapter 8 of APEA/IP It is recommended that every person undertaking
Guidance for the design, construction, modification and an on-site installation shall have received training on
maintenance of petrol filling stations. Key points to best practice for the specific commercial pipe system
note are: being installed. It is the responsibility of pipe
manufacturers, or their designated distributors, to
It is essential that steel pipework has adequate provide training to installers either on-site or through
protection against corrosion, particularly of the specific courses with representative installation layouts.
joints, or is secondarily contained and provided Site operators should determine that installers have
with a system which continuously monitors the undergone a refresher course within the previous five
interstitial space for the integrity of both skins. years.
Joints for steel pipework may be mechanical or
welded. In either case special precautions will be 7.3.3 Storage tanks
necessary to ensure that the integrity of the
corrosion protection is fully maintained and can be The following provides a summary of current and
sustained for the lifetime of the installation. historic tank types and configurations to assist in the
Steel and GRP pipework should always be ERA. For further details on tankage design
connected to tanks or dispensers using flexible considerations, see Chapter 7 of APEA/IP Guidance for
connections to allow for relative movement and the design, construction, modification and maintenance
ensure no resulting load is transmitted to the of petrol filling stations and EA PPG27 Installation,
pipework. decommissioning and removal of underground storage
tanks.
It is recommended that operators should ensure that
18
7.3.3.1 Types of tank minor aquifer, or on a non-aquifer used locally for

Several types of storage tank are available for use both potable supply. The tank should be constructed of a
above and below ground. Tanks are generally material that is resistant to the local ground conditions,
cylindrical and installed horizontally. Tanks are or provided with appropriate corrosion protection. New
commonly manufactured from steel, glass reinforced metal tanks are generally protected against corrosion by
plastic (GRP) or using a combination of steel and the application of an external protective coating. Such
plastic or GRP. They may be single skin or double skin coatings are specified for tanks complying with BS EN
depending on the type and construction and the 12285. Coatings should be inspected for damage and
intended use. The risks arising from a loss of integrity may be tested for thickness and continuity prior to
will vary with the circumstances at each site and the installing the tank. Any damage should be made good
selection of the appropriate type of tank should be in accordance with the manufacturers instructions.
determined from an ERA. LPG systems are pressure
systems and in the UK need to conform with the 7.3.3.3. Corrosion protection
requirements of the Pressure Systems Safety Corrosion control for either new or existing tanks can
Regulations 2000: be provided by cathodic protection in which sacrificial
anodes are used. The anodes are normally magnesium
Prior to ca. 1960 underground storage tanks were or zinc and details of the necessary type and size should
generally located beneath dispensers and often be sought from the tank manufacturer. Tanks protected
placed adjacent to the front site boundary. in this way should be electrically isolated from
Typically 500 gallon capacity. pipework and conduit through use of isolation bushings
Prior to 1990 underground storage tanks were and flanges. It must be recognised, however, that
generally constructed of single skin steel. metalwork on either side of such isolation bushings
Older tanks may be set in a brick/concrete vault, may be at different electrical potentials and such actions
set in mass concrete, sand, or earth backfill. should be discussed and agreed with the electrical
Since 1990 new underground storage tanks are designer to ensure that an unsafe condition cannot arise.
increasingly double skin steel, with interstitial A method of testing to confirm the continued
monitoring and set in pea shingle or foam. effectiveness of the system should be provided.
Since around the mid-1980s single skin steel tanks For existing tanks corrosion control can be
may have been lined with new single or double provided using an impressed current system. Electrical
liners, often with interstitial monitoring. currents from such systems can influence other nearby
LPG storage vessels, as pressure vessels metallic structures which are not part of the protected
constructed to BSI Published Document 5500, can system. Proper design by a competent corrosion
either be installed above ground or covered with engineer is required to prevent adverse effects on
gravel, sand or foam backfill. The vessel can either adjacent above ground tanks, utilities and other metallic
be buried (completely underground) or mounded structures. This should be carried out by a competent
(partially underground). corrosion engineer working in close liaison with the
electrical designer and the manufacturers of any
7.3.3.2 Replacement with a new tank equipment installed within or on the tanks, e.g. leak
If a breach in tank integrity is identified, several options detection or tank gauging systems.
could be followed. A breach of underground storage
tank integrity on the lid or high in the ullage space may The most effective corrosion protection is provided
not necessarily result in a leak. However, the lower when high quality coatings and an appropriate
down the body of the tank the greater the potential for cathodic protection system are used in combination.
loss of product. It should also be recognised that tank
leaks may also be a cause of water ingress, where the One risk reduction method is to install cathodic
groundwater table is above the hole. Any corroded or protection to existing tanks, which have not
defective tank which has been identified underground corroded significantly. Virtually all the corrosion
should be taken out of use, see also Sections 12 and 10. of buried steel occurs by an electrochemical
If the reduced tankage is insufficient for the site, and a mechanism. To assess the risk of external corrosion
replacement is required, consideration may be given to failure requires measurement of soil conditions
installing new double skin tanks by carrying out an such as moisture, conductivity, pH, sulphides,
ERA, especially where the site is located on a major or chlorides, electrical activity etc.
19
Further guidance on the use of cathodic protection for containing product. Where a site has changed
underground storage tanks and associated steel ownership many times, the most complete set of site
pipework will be provided in a forthcoming IP drawings may be found with the Local Authority. If
publication. tanks are encountered during redevelopment works they
should be probed by a suitably experienced contractor
7.3.3.4 Tank repair to ensure that they are stable and not an ongoing source
Dependent on the outcome of the ERA, consideration or potential source of pollution.
may be given to obtaining a detailed inspection and
assessment by a competent person to determine whether 7.3.4 Offset/direct fill pipes
repair of a tank, rather than replacement, may be
feasible. For existing single skin tanks the repair is Below ground offset or direct fill tank manchambers are
normally carried out using a specialist lining technique prone to the accumulation of small amounts of product
and may provide a double or a single skin within the during delivery. If such manchambers appear oily on
existing tank shell. It is recommended that such relining the surface of the walls, but do not accumulate
is only undertaken by suitably trained and competent significant product, then the walls may be leaking and
personnel. Site operators should satisfy themselves that require remedial work. Equally in areas with a high
the relining activity conforms to basic requirements for water table, if the chamber cannot be kept dry, then
tank preparation. For double skin tanks it will be treatment to prevent egress of fuel may be required. The
necessary to determine whether the leak is in the outer options for such works are described in section 7.4.3 for
or inner skin and what caused the fault before deciding oil/water separators. Dependent on the outcome of the
on an appropriate course of action. A leak in the inner ERA an option may be to replace below ground offset
skin, providing its position can be determined, can be fills with above ground offset fills, or to replace the
repaired by patching or alternatively by relining the manchamber with one which is water tight.
tank as above. A leak in the outer skin will necessitate
replacing the tank or relining it with a double skin 7.3.5 Delivery procedures
system where the interstitial space can be monitored.
Where interstitial monitoring of double skin tanks has One risk reduction option is to ensure that delivery
been installed, periodic checks of the alarm system procedures include underground storage tank ullage
should be carried out to ensure that it is working checks to avoid the possibility of tank overfills. Overfill
correctly. All repaired tanks should be leak tested contingency plans should be based upon product
following the repair and before being brought back into dispensing, to avoid the high risk of spill from manually
service. decanting delivery hoses after an overfill.
7.3.3.5 Tank decommissioning

If decommissioning a tank it is important that it does 7.4 POTENTIAL PATHWAYS FOR
not then become a potential source of pollution. The POLLUTION
Environment Agency recommends that tanks which are
not going to be used again are removed wherever It is not possible to prevent certain types of spillage
possible. Where tanks are abandoned in situ they should occurring during routine petrol filling station
be purged and filled with hydrophobic foam or operations. The most frequent spills are customer
concrete. For further information see Chapter 17 of refuelling incidents, spills caused by leaking car fuel
APEA/IP Guidance for the design, construction, tanks, spills caused during the filling of portable
modification and maintenance of petrol filling stations. containers and spills during the filling of petrol filling
Where tanks are water filled to make them safe on station underground storage tanks, either directly, or by
a temporary basis, the water level should be checked below or above ground offset fill points.
regularly to ensure corrosion induced leaks do not result The concept of a 'pathway' from a source of
in new releases of oily water to ground. Tanks should pollution to an environmental receptor was introduced
not be permanently filled with water. in Section 6. As stated in that Section, if there is not a
As a site may have developed over 75 years, old source-pathway-receptor linkage then pollution will not
tanks may have been decommissioned in the ground. In occur. This Section gives details of pathways that can
general decommissioned tanks should have been filled be identified and controlled at a petrol filling station.
with solid material, but it is recognised that there may Where a pathway cannot be controlled, i.e. a permeable
be some tanks buried either empty or even still strata surrounding an underground storage tank, more
20
emphasis will be placed on the equipment options channel drains should be designed to ensure that no
previously described. leakage occurs and laid to gradients that will achieve
self-cleansing flow velocities at design conditions.
7.4.1 Forecourt surface quality
Gratings should be installed which allow the run off to
Areas susceptible to contamination, e.g. near pump be intercepted and freely to enter the channel. Channel
islands or tanker off-loading points, should be gratings should be continuous and uninterrupted.
impermeable to hydrocarbons and other liquids and Channels and gratings should be installed and tested to
should not allow seepage through or below the surface. manufacturers instructions. All outlets should be
Typically, concrete (recommended minimum 180 mm trapped, accessible and easily maintained.
thick, laid in accordance with a recognised standard, When considering the design of drainage pipework,
e.g. BS 5328, and in the UK to The Specification for the rainfall, proximity of high buildings and levels of
Highway Works), or similar highly impermeable surrounding land should be considered. The drainage
materials such as sealed block paving will fulfil this pipework should be:
requirement provided any associated jointing material
is also impermeable and resistant to attack by motor Sized to suit the storm return periods appropriate to
fuel. Other areas may be surfaced with materials such the location and in accordance with the
as hot rolled asphalt, macadam, unsealed block paving, requirements of BS 6367 and capable of
gravel, etc. transporting a spillage from the tanker standing
It should be recognised that hard-standing areas area at a rate of at least 15 litres/second.
do not remain impermeable over a long period of Resistant to the effects of light hydrocarbon liquids
time. They can be compromised by pipework repair, when tested as specified in prEN 858-1.
subsidence or wear and tear along pavement expansion
joints. In general the extent of cracking, multiple joints The access and egress cross over points are normally
and pavement subsidence are a good indication that protected by a channel line drainage system set at least
potential contaminant pathways exist. 300 mm into the site, and 50 mm below cross over
level. This will prevent the flow from any spillage on
7.4.2 Controlling surface run-off by appropriate the forecourt, not otherwise routed to drainage,
drainage going beyond the curtilage of the petrol filling
station. Additional drainage is not required where
All forecourt surface areas where contamination is cross-over points are at a higher level than the
possible, e.g. pump islands and tank off-loading points, operational areas of the forecourt.
and any drainage apparatus which could receive A penstock or other suitable valve should be
contaminated water, should be contained by peripheral installed in the first manchamber downstream of the
surface drainage channels or kerbs to divert all spills oil/water separator capable of shutting off all flow and
and runoff to an oil/water separator or constructed assisting the prevention of contaminated effluent
wetland. It is advantageous to use absorbent material to leaving the site during maintenance or emergencies.
contain all surface spills. The drainage containment Where a constructed wetland is used instead of an
should be designed to provide an adequate number of oil/water separator it should be fitted with an automatic
channels and gullies so as to limit the surface travel of shutoff valve which will close in the event of a spill, see
spilt hazardous products and prevent them reaching 7.4.3.1.
areas where surfaces are unprotected. Adequate All drainage channels and systems should be
containment of any contamination is required during installed and maintained in accordance with
routing to the oil/water separator or constructed manufacturers instructions.
wetland. Foul sewer water disposal is the most common
Where rodding eyes and manhole chambers for discharge route for effluent disposal, as highway
surface water are located in areas likely to be drainage usually discharges directly to water courses
contaminated they should be double sealed to prevent without treatment. In the UK it is a legal requirement
ingress of fuel. for all discharges of trade effluent to be authorised by
The catchment areas defined in Figure 5 should be the local sewerage undertaker.
designed to direct all run-off towards the drainage Disposal of effluent to controlled waters in the UK
system in an efficient manner. Material and joints of is authorised by the Environment Agencies.
21
Figure 5 Typical discharge arrangements for petrol filling stations
In the UK soakaway discharges must also be 7.4.3 Oil/water separators

authorised under the Water Resources Act 1991 and the
Groundwater Regulations 1998. Prior to 1999 the EA in 7.4.3.1 General
England and Wales did not generally seek Oil/water separators act as a potential pathway from a
authorisations for the discharge of effluent from surface source of pollution to a receptor. Where separator
water drainage systems (including soil/water separator chambers are unable to hold water due to porous
discharge) to controlled waters on petrol filling stations. brickwork or damaged pointing, the oily effluent will
However this legal requirement is now being actively soak into the surrounding ground. Options for such
enforced. Authorisation for a petrol filling station chambers include upgrading to a new model, relining
soakaway in Source Protection Zone 1 (50 day water with GRP, re-pointing or injection grouting. Dependent
travel time) or Source Protection Zone II (400 days) of on the outcome of the ERA an option to assist
a drinking water abstraction will be resisted by the increasing capacity and effectiveness is to add an
Agency, and only allowed under strict control in Source additional chamber. For further information on use and
Protection Zone III which represents the wider design of oil/water separators see EA PPG3 Use and
catchment area. design of oil separators in surface water drainage
systems.
22
The limitations of oil/water separators should be to install hydrocarbon sensors in oil/water separators
recognised when designing a drainage system. They do that are linked to the site petroleum gauging system.
not treat dissolved phase hydrocarbons and their This allows the continuous monitoring of the unit for
performance in the field is likely to be inferior to that the presence of fuel. Where units discharge to highly
stated by the manufacturer (which relates to test sensitive watercourses the alarm may also be connected
conditions). If the receiving surface water is to remotely actuated shutoff valves.
environmentally sensitive then some form of The waste water from automatic vehicle washes,
additional/alternative treatment may need to be high pressure hand washes and steam cleaners produces
considered such as a constructed wetland. A wetland large volumes of water, possibly at high temperatures,
with reeds Phragmites spp. enables bacteria around the which are contaminated with detergents, oil and road
roots of the plants to biodegrade any hydrocarbons, so dirt. The wide range of cleaning detergents used in the
that there is no long-term accumulation of product. This washing process can form stable emulsions. These
results in an improved quality of water leaving the site, emulsions take time to 'break' and separate into the
with potentially less on-going maintenance compared oil/water phases, therefore this type of effluent should
with an oil/water separator. For details of the safety not be regarded as a trade effluent and managed in a
considerations required if installing a constructed totally separate drainage system to the one used to
wetland see HELA PETEL circular 65/45 Petrol filling drain the forecourt to an oil/water separator.
stations Surface water drainage Constructed Wherever possible the car wash water should be re-
wetlands. circulated.
7.4.3.2 Design Note: Under no circumstances should waste water

Oil/water separators are designed, under ideal from vehicle wash facilities be discharged through
conditions to prevent hydrocarbons from leaving the the forecourt oil/water separator. Such action will
site and to also reduce the quantity of grit and silt in the reduce the separators effectiveness.
effluent. Separator capacity should be determined by:
All roof drains which collect clean, uncontaminated
the drainage capacity feeding the unit; water may be routed to bypass the oil/water separator to
separator performance required; avoid otherwise reducing the capacity of the unit to
the likely size of a spill. contain a spill. In order to mitigate urban runoff it may
be preferable to reclaim this clean water for use in the
In general 3000 litre units are adequate for petrol filling sales building or for valeting operations, or use to
stations. recharge groundwater through soakaways if this is
Older oil/water separators are generally two or acceptable to the Environment Agency.
three-chambered brick structures that should contain the
hydrocarbons in the first chamber. If hydrocarbon is 7.4.3.3 Cleaning
visible in the third downstream chamber the unit should The cleaning operation should include pressure washing
be cleaned by a waste contractor. In heavy rain (high of the surface gullies on site to ensure they are free of
flow) the effectiveness of an oil/water separator is debris.
considerably reduced. There is also a tendency for the The frequency of cleaning may be reduced where
first chamber to act as a grit arrestor and unless it is the oil/water separator only receives rainwater runoff
cleaned regularly, the outlet to the second chamber will from the peripheral pavement areas or the canopy, and
become obstructed thereby reducing the efficiency of is therefore unlikely to contain hydrocarbons.
the unit. The most effective, and preferred, method of
Modern oil/water separators are generally single cleaning an oil/water separator is by purging. This
chamber GRP units, making visual assessment more requires the uplift and disposal of all liquid and sludge
difficult as the unit will still function when there is in the unit and then re-filling with clean water.
visible product in the main chamber. As a rule all units Previously a decanting method was also accepted as an
should be visually inspected every 6-12 months and adequate cleaning process. This involved the uplift of
cleaned where necessary. Records of inspection and the separator contents to a vacuum tanker, where it was
maintenance should be kept. The cleaning frequency allowed to stand for at least one hour. After allowing
may be reduced where biological treatment is added the sludge to settle in the base of the tanker and the free
regularly. Modern units may be fitted with coalescing oil to rise to the surface the effluent water could then be
filters and automatic shut-off valves. It is also possible decanted from the middle of the tanker, back to the
23
separator. In practice this separation is difficult to Oil/water separators should always be inspected
achieve and fine particles of silt and dissolved oil will after a spill, see Section 12.
be returned to the separator. The decanting method is
not recommended, but if used, site operators should be 7.4.3.5 Disposal of oily waste and sludge
aware that 10 ppm oil can easily be returned to the In the UK, producers of waste have Statutory Duty of
separator, necessitating further cleaning within a Care to ensure wastes are properly disposed of. Waste
relatively short period of time. If decanting is used the from oil/water separators and oily waste liquid from
separator must be isolated from the downstream drains tank man-chambers is generally classified as Special
during the operation to prevent overfilling and Waste requiring advance notification of transport and
discharge of grossly polluted effluent. disposal. This should be arranged with the Environment
All peripheral drains on the forecourt should be Agencies4, by the waste contractor three days before
pressure washed clean as part of the same operation. collection, along with the provision of a consignment
Oil/water separators should be re-filled with clean note. The producers should ensure that the waste
water as soon as the cleaning operation is complete. contractor is registered with the Environment Agency
Under no circumstances should rainfall runoff be relied and should satisfy themselves that the waste is properly
upon to refill a separator. dealt with.
Coalescing oil filters should only be removed for Where effluent testing in advance of collection can
cleaning when the unit is empty to avoid damaging the be carried out, and the flash-point of the material is
filter. The effectiveness of sensor probes, valves and >21EC and the benzene content <1000 ppm, then the
alarms should also be checked periodically as the unit effluent can be demonstrated not to be Special Waste.
will be ineffective without a water seal. However the cost and delay caused by such testing
should be compared to the costs of disposal. In practice
7.4.3.4 Inspection/maintenance only sludges from oil/water separators dedicated to car
It is of utmost importance that oil/water separators are wash effluent are likely to be non-Special wastes.
regularly inspected and routinely maintained according In the UK a waste transfer note must be supplied to
to the manufacturers recommendations. The frequency comply with the Duty of Care regulations under Section
should be determined by site conditions but as a 34 of the Environmental Protection Act 1990. Special
minimum inspection is recommended every six months. Waste transfer documents should be kept indefinitely
Forecourt maintenance which involves degreasing and all other transfer notes for two years.
either by steam cleaning or using a solvent or a Except in an emergency following a spill, all
combination of both must be carried out with the cleaning should be notified to the Environment Agency
shutoff valve downstream of the oil/water separator, if in advance of the work. Where the contractor carries
one is installed, in the closed position to prevent escape out the work without advance notification both the
of contaminants. It is essential that the oil/water contractor and site operator are contravening UK
separator is cleaned out before the valve is reopened. legislation.
Modern oil/water separators can be fitted with The Duty of Care transfer note supplied by the
hydrocarbon sensors and alarms to indicate the presence contractor should include an Enviroment Agency
of fuel, and the need for non-routine maintenance. manifest number.
4
Environment Agency, http://www.environment-agency.gov.uk/?lang=_e (0345 001166)
SEPA, http://www.sepa.org.uk/
24
8
DETECTING LOSS OF PRODUCT
8.1 WETSTOCK MONITORING/LEAK equivalent to 5 20 lpd depending on the

DETECTION throughput of the site.
The source of a leak or spill is not necessarily a good The following sections from IP/APEA Guidance for the
indicator of the potential spill size. The accuracy of design, construction, modification and maintenance of
stock monitoring and other leak detection techniques is petrol filling stations are included to provide guidance
critical to detecting leaks at an early stage. It follows on the main types of leak detection systems available
that a larger quantity of product may leak to soil and and some of the factors that should be considered when
groundwater from a long running undetected pipework deciding on the type of system to give the appropriate
leak than from a catastrophic failure of an underground level of environmental protection for the identified
tank. risks. An effective leak detection system should provide
It should also be recognised that any leak detection early warning of a potential problem so as to enable
system is only as good as its detection limit and the prompt corrective action to be taken. Careful
standard to which it is maintained and operated. Poorly consideration should be given to the fail-safe qualities
maintained leak detection systems may have severely of any leak detection system, to ensure that the
impaired performance, or in some cases may not be surrounding environment remains properly safeguarded
detecting leaks at all. Leak detection standards vary in the event of component failure or inadvertent
according to the variety of method used, as shown in disabling of the system. Leak detection systems are split
Table 5: into classes as shown in Table 5.
The classes described in Table 5 are mainly derived
Current standards for mechanical and electrical from the draft European Standard for Leak detection
leak detection systems accredited by the US systems prEN 13160 (Parts 1-7). Some changes and
Environment Protection Agency (EPA) set tank additions have been made which are of particular
leak detection limits ranging from 9 50 litres per relevance in the UK.
day (lpd). Table 6 provides a brief summary of the various
US EPA Statistical inventory reconciliation (SIR) classes of system currently available, their method of
standards are 7-9 lpd for pipework and storage operation, detection capability and effectiveness. The
tanks. performance standards referred to as classes 1 to 5 are
EN Class 4A & 4B1 automated reconciliation specified in prEN 13160-1. One means of
standards 50 lpd. demonstrating the performance capabilities of any of
Proprietary reconciliation services are available these classes of leak detection systems is certification
with detection limits of 0,1 % throughput, by an independent test house.
25
Table 5 Classes of leak detection systems
Class Method of operation Detection capability Effectiveness

Monitors air pressure or vacuum Detects leaks anywhere in Very secure system. Alarms
1 between the skins. Alarms if double skin equipment, before product can reach the
pressure changes irrespective of product level environment
Monitors pressure of a liquid Detects leaks anywhere in Very secure system, alarms on
2 filling the gap between the skins double skin equipment, any leak. External leak loses
irrespective of product level fluid into ground
Detects the presence of liquid or Detects leaks in double skin Liquid sensors at low points.
3 hydrocarbon vapour within the equipment with large interstitial Vapour sensors unable to detect
interstitial space space failure of outer skin
Analyses rates of change in tank Detects leaks below liquid level Product released to the
4 contents. in tanks and pipework environment before a leak is
Three sub-classes possible detected
4a Automatically compares change in Detects leak anywhere in tank As for Class 4. Does not detect
Dynamic tank contents with volume of or pipework below liquid level leaks above liquid level
product dispensed
4 b (1) Monitors tank contents over the Detects leak in tank below As for Class 4a but does not
Statistical periods when no product is being liquid level detect leaks in product line.
quiet dispensed Only operates whilst no product
period is being dispensed
4 b (2) Monitors as for 4 b (1) but for As for 4b(1) As for Class 4b(1) but requires
Static longer periods of time long quiet period
Uses monitoring wells round the Detects leaks below the liquid
5 site to detect released product surface level in tanks or As for Class 4
pipework
Change in tank contents and Detects leaks below the liquid
6 metered sales taken manually are surface level in tanks or As for Class 4
reconciled pipework
7 Applicable only to pipework
The choice of system for any particular application will Conversely, some systems are not suitable in all
depend upon the circumstances at a site and its circumstances, for example monitoring wells are
surrounding environment. The risks of damage to the ineffective in heavy clay soils. Ultimately, it is for the
environment should be assessed, and the higher risk operator to determine, and where necessary justify, the
taken as the design criterion. This, together with a most suitable system in the particular circumstances of
consideration of the type, condition, and inherent each case. The column headed 'Severity of impact of a
security of the installation to be protected, and applying leak' is intended to allow for variations in the effect of
the test of reasonable practicality, will enable an a leak on the surrounding area from an environmental
appropriate system to be selected for the assessed risks. (and safety) standpoint. The severity of impact is
The guidelines in Table 6 provide information on divided into high, medium or low but there may be
the classes and methods of leak detection suitable for gradations between these, and each case should be
various elements of an installation which may require considered in the light of its particular circumstances. In
such protection. They are intended to assist the operator some instances, no adequate leak detection system is
in making informed decisions as to the most appropriate available and this is indicated by the words 'none
system for the circumstances and risks associated with available' appearing in the table. On the other hand, it
each site, which will vary depending upon the effect a may not be necessary, in some instances, to consider
leak would have on the surrounding area. any form of leak detection at all. In such cases the
The inclusion of particular systems or methods in words 'not necessary' appear in the table.
the table does not imply that these should always be For further information on the classes and methods
used; they are intended as illustrative guidance only and of leak detection for new installations (including
there may be other equally suitable systems available. complete redevelopment), and for a description of each
26
of the system classes, see IP/APEA Guidance for the in HS(G)146 and IP Guidance on risk assessment for
design, construction, modification and maintenance of the water environment at operational fuel storage and
petrol filling stations. The guidance for new dispensing facilities. Additional information can be
installations recognises that they will generally be found in HELA LACOTS PETEL 65/34, October 2000.
provided with a high standard of protection. Such To minimise the environmental impact from leaks
systems may not always be reasonably practicable for and spills, good stock reconciliation and operation are
existing installations. Further information on assessing critical. Wetstock should be reconciled daily and
the risks and deciding on appropriate standards is given reviewed weekly.
Table 6 - Typical systems for existing installations

(Note: For older elements the more secure class should be selected)
Severity of impact of a leak

Element to be monitored
High Medium Low Notes
A. Tanks
Steel - single skin class 4a class 4b(1) or class 6
4b(2)
GRP - single skin class 4 or 5 class 4 or 5 class 4 or 5
Steel, GRP, composite - double skin or class 1 and 5 class 1 or 2 class 2 1
old tank or 2 and 5
refurbished as
double skin
B. Product pipework
Pressure system - single skin None available class 4a and 7 class 7 2
- double skin class 3 and 7 class 7 class 7
Suction system - single skin, check class 5 class 5 class 6
valve at tank
- single skin, check class 6 class 6 class 6
valve at dispenser
- double skin class 3 class 4a class 6
Siphon system - single skin class 5 class 6 or none not necessary
Off-set fill - single skin class 5 not necessary
- double skin class 3 not necessary
C. Vapour pipework
Vent - single skin overfill prevention devices not necessary
Stage 1b or 2 - single skin class 5 not necessary 3
- double skin class 3 not necessary 3
D. Sumps and chambers
Dip, fill, changeover valve chambers, sumps class 3 not necessary
beneath dispensers, etc
Notes:
1. Where it is assessed that the impact of a leak on the surrounding environment would be high, a class 1 system will be most
appropriate; elsewhere, class 2 may be adequate.
2. Single skin pipework is not recommended for use with pressure systems in locations where there would be a high environmental or
safety impact resulting from a leak.
3. Stage 1b and 2 Vapour Recovery installation should be designed to preclude the possibility of liquid hydrocarbons entering the
vapour lines. Where this is achieved, leak detection is not necessary and single skin pipework will be adequate even in situations
where the impact of a leak will be high. However, where this cannot be avoided, the stated leak detection systems are
recommended.
27
8.2 TANK/PIPEWORK TESTING considerations and qualifications pertinent to such tests

are fully addressed at the time of testing. The method
It should be noted that the operation of an appropriate statements should clearly identify particular factors that
leak detection system can obviate the need for regular have to be considered and which may affect the
tank/pipework integrity testing. Where a leak is accuracy of the test including:
suspected the tank and/or pipework should be tested
using a method appropriate to the installation. water table measurement and compensation;
In the absence of UK, European or petroleum positions of sensory probes within or outside the
industry standards, the tank testing methods are tank in order to detect leakage;
generally certified as meeting the requirements of the procedures for testing multi-compartment tanks;
United States Environmental Protection Agency (EPA) minimum certified product levels for testing;
Standard test procedure for evaluating leak detection compensation for climatic conditions at the time of
methods. Certification will be from an accredited EC or test;
US test house that will issue a Certificate of Conformity stabilisation periods for equipment or product to
for the system. eliminate temperature effects;
The requirement of the EPA protocol is for a tank process to compensate for fuel vaporisation in the
testing system to detect a leak rate of 380 ml/hr or more ullage space;
within a 95 % probability of detection accuracy whilst means of detecting both leaks of product out of,
operating a false alarm rate of 5 % or less. and entry of water into, the tank.
It should be recognised that it is therefore possible
for tank/pipework to 'pass' an integrity test in Operators of tank/pipework testing systems should
accordance with the EPA protocol, but still be releasing demonstrate that the operating criteria specified by any
up to nine litres per day of product into soil and certification, including any limitations, are strictly
groundwater. Given the legal obligations and depending adhered to. If for any reason a test is conducted under
on the outcome of the ERA for the site, the site operator conditions outside the limitations of the evaluation
may wish to seek guidance from operators of the testing certificate, the test report will need to state the
system as to the actual leak detection threshold limitation(s) that have been exceeded together with
achievable by the method. details of any supporting calculations or increase in the
It is recommended that test methods based on data collection period etc. to confirm that the test
precision testing techniques should be used wherever complies with the EPA protocol.
possible. Such forms of testing take account of the Additional information can be found in HELA
many uncontrolled variables which a simple hydrostatic LACOTS PETEL 65/34 Leak detection in tanks and
test cannot. They are therefore more reliable and have pipework, October 2000.
a greater probability of identifying a leak than the latter.
Precision tests generally fall into one of two broad
categories: 8.3 APPARENT LOSSES
(a) Volumetric Methods use techniques which detect Losses of product are often indicated by stock
any change in height of liquid in the tank to define reconciliation systems. Upon investigation it may be
a leaking or tight tank. Typically such tests provide determined that losses are not caused by leaks.
a measurement of the actual leak rate if any. Dispenser meters should be checked periodically and
other sources of loss e.g. theft, faulty gauge probes etc.
(b) Non Volumetric Methods do not rely on detecting should be considered. The elimination of apparent
a change in height measurement to determine a losses should improve business performance and
leaking or tight tank, and typically provide a pass improve the leak detection capability of the systems in
or fail result. Examples of this type of test are those use.
applying a vacuum and/or pressure to the tank,
those using chemical trace elements or mass Recommended Interval for Meter Audit:
measurement. All dispenser meters at least once every three
years. Sites with high throughput (>5 m lpa) - one
Method statements and operating protocols should to three times per year or as suggested by wetstock
always be available with precision test methods. These analysis.
are necessary to ensure that the appropriate test
28
8.4 TESTING EFFLUENT QUALITY
Testing of effluent quality is not currently routinely

carried out at petrol filling stations in the UK. On
'sensitive sites' or following a reported incident, the
Environment Agency may require monthly or annual
samples. Where oil reducing bacteria are dosed to the
oil/water separator to reduce the cleaning frequency
then quarterly samples should be taken to ensure the
dose rate is adequate.
The testing suite should include the following as a

minimum requirement:
total petroleum hydrocarbons;

benzene, toluene, ethyl-benzene, xylene (BTEX).
29
30
9
EMISSIONS TO AIR
9.1 GENERAL Without vapour collection

Without vapour control equipment the vapour displaced
Petrol is a volatile liquid and gives off vapour even at from the underground storage tank is vented to
very low temperatures. More vapour is given off as the atmosphere, and the space created in the tanker
temperature increases. Vapours released from petrol compartment is filled with fresh air drawn in via the
lead to the formation of damaging ozone in the lower P/V valve on the tanker.
atmosphere. A build up of ozone in the lower
atmosphere adversely affects human and animal health, With vapour collection
interferes with plant growth and damages building With vapour control equipment, the vapour vents from
materials. It can also cause photochemical smog which the underground tanks are connected back to the
is detrimental to the respiratory system. delivery tanker. In this way, as petrol flows out of the
Releases of product from site to air, will be either vehicle, the vapour present in the underground tanks is
through vents, dip tubes or pipework maintenance. routed back to the vehicle compartment. To stop the
These releases may be planned, such as during vapour going out to atmosphere, the tank vents are
maintenance and dispenser calibration, and unplanned fitted with pressure/vacuum valves (P/V valves) which
releases from leaks and spills. maintain a small back pressure in the system. This,
together with the negative pressure in the road tanker,
encourages vapour to flow back to the vehicle
9.2 VAPOUR RECOVERY compartment. This process is shown in Figure 6.
As the volume of vapours displaced is roughly
9.2.1 Stage 1b balanced by the volume of product discharged, the
concept is known as 'vapour balancing'. However, it
When a road tanker off-loads petrol into the should be noted that vapour can be generated during the
underground storage tanks at a petrol filling station, the off-loading process which can affect the overall system
vapour in the tanks is displaced by the incoming petrol efficiency. Vapour generation can arise from the
and a vapour space is created in the tanker turbulence caused by fuel and air entering the tank, and
compartment. The following diagrams illustrate what by relatively warmer fuel from the road tanker mixing
happens before and after the installation of a Stage 1b with cooler fuel in the underground storage tanks.
system:
31
P/V valve
Vapour return line
Liquid fill line
Figure 6 With vapour collection
The achievement of a satisfactory return vapour flow 2) Provision of a vapour connection at the filling
from underground storage tanks to the road tanker point for returning vapours to the road tanker.
compartments is dependent on minimising the
resistance to flow at all stages of vapour transmission, 3) Provision of vapour transfer hoses. Generally these
and minimising the generation of additional vapour. will be carried on the tanker but in some cases may
This must be a primary consideration when designing need to be stored securely at the petrol filling
or retrospectively introducing a vapour balancing station.
system. The aim is to induce the vapour to flow
preferentially from the underground storage tank to the Note: The condition of the existing fill and vent
road tanker rather than through the filling station vents pipework installation should be checked in order to
to atmosphere. determine which design options are most suitable for a
High emission control efficiencies can only be particular filling station. It is important that a check is
achieved with this system if it is correctly designed with made to determine if there are any leaks or restrictions
particular attention being paid to component selection in either the liquid fill system or the vapour vents.
and installation.
The requirement for petrol vapour recovery at stations
9.2.1.1 Changes required to an existing installation is derived from Section 7(2) of the Environmental
Any modification to existing pipework must be Protection Act 1990 in the UK and the VOC Directive
approved in advance by Petroleum and Environmental 94/63. The detailed requirements of the UK legislation
Health Officers. All changes should be noted on site are given in the Secretary of States Guidance PG1/14
drawings, on new pipework and in chambers. If diesel (96). This requires vapour recovery to be installed to a
tanks remain manifolded to tanks with vapour recovery, timetable based upon the throughput if the station, with
they should be treated as petrol tanks for road tanker all sites to be licensed have equipment installed by
deliveries and maintenance purposes. 31/12/2004.
Installation of a vapour balancing system to an By each relevant deadline the site must hold an
existing filling station is likely to require the following authorisation for vapour recovery issued by the Local
major changes (note, for a new station these facilities Authority environmental health department in England
would be designed in from the beginning): & Wales and by SEPA in Scotland. In some areas the
duty for periodic regulatory inspection may be carried
1) The addition of a vapour return pipework system to out by local petroleum officers on behalf of the EHO.
route the vapour back to the road tanker and Authorisations are renewable annually for a fee.
modifications to the storage tank vent system, The regulations require the installation of vapour
including the addition of a vent emission control recovery pipework and manifolds, pressure/vacuum
device. valves on petrol tank vents, delivery procedures and a
32
EMISSIONS TO AIR
regime of regular inspection and maintenance. It should from the cars petrol tank are vented direct to
be noted that all substantial alterations to fuel storage atmosphere and fresh air is drawn into the underground
infrastructure require notification to the EHO, as well tank via the vent pipe.
as the PO. Alteration of tank grades between diesel and
petrol or new tanks should be pre-notified. The With a Stage 2 system
requirement for record keeping can usually be met With Stage 2 systems a special nozzle collects vapour
through modification of the site petroleum register to from the car fill pipe instead of allowing it to vent to
include forecourt inspection and maintenance. Model atmosphere. The vapour may be returned to storage,
procedures and records can be found in PG1/14 (96). vented via a filter or burned off in an incinerator unit. A
vacuum pump may be situated in each dispenser
9.2.2 Stage 2 housing or there may be a single central pump at a
remote location. This arrangement is shown in Figure
The emission of VOC is regulated at European level by 7.
EC Directive 94/63 and enacted in the UK by Part 1
Environmental Protection Act. There is currently no 9.2.2.2 Changes required to existing installations
legal requirement for nationwide Stage 2 vapour The introduction of a Stage 2 system requires some or
recovery. However, Local Authorities are obliged to all of the following modifications to be made to an
carry out air quality assessments and these may require existing installation:
the installation of Stage 2 equipment as a local air
quality improvement measure. use of a special refuelling nozzle and ancillary
fittings;
9.2.2.1 Basic principles introduction of a vapour return hose on the
As vehicles are being filled on the forecourt, vapours dispenser connecting the nozzle to the vapour
are displaced by the fuel entering the vehicle tank and piping;
at the same time a similar vapour space is created in the additional pipework to return vapour from
underground storage tank. The following diagrams dispenser to storage tank;
illustrate the situation before and after the installation of additional equipment installed within the dispenser
a Stage 2 system. or at a remote central location. This will be
influenced by the method adopted for achieving
Without Stage 2 vapour flow back to the storage tank;
Where there is no Stage 2 system, vapours displaced a Stage 1b system unless already fitted.
P/V valve
Vapour returned to
underground tank
Car tank
Petrol in
Figure 7 With Stage 2
33
9.2.2.3 Types of vapour return system force the displaced vapours back to the filling station
Two established methods of collecting and returning storage tank. It requires a good seal on the nozzle to
vapours for Stage 2 operation currently exist. These are prevent vapour from escaping to atmosphere. In some
known as active (open) and passive (closed or balance) cases the provision and action of this seal can make the
systems. Other systems, such as those using nozzle clumsy and difficult to use. In consequence
refrigeration techniques to produce liquid condensate at passive systems have not been installed as extensively
the petrol filling station, may be available but are not in Europe as the active systems.
covered here. Any equipment used should hold an appropriate
The active system employs a vapour pump to assist safety and performance approval, either as components
return vapour flow from the vehicle fuel tank to the or as a complete system, by the appropriate authorities
supply storage tank. The vapour pump may either be in an EU member state which has enacted national
installed and driven from within the dispenser or be Stage 2 vapour control legislation.
located remotely from it, in which case it is generally It is important to ensure that retrofitting of a vapour
referred to as a centralised system. collection system into an existing dispenser does not
The passive system relies on the pressure generated compromise the relevant certification of that dispenser.
when dispensing petrol into the vehicle fuel tank to
34
10
MANAGEMENT OF
CONTAMINATED SITES
10.1 SOIL AND GROUNDWATER redevelopment programme;
CONTAMINATION in response to complaints from neighbours of
smells of petrol and/or about the presence of
Operation of petrol filling stations over a long period petroleum products thought to have migrated onto
causes a build-up of vapour at a shallow depth below their land;
the forecourt pavement area, mainly from customer in response to a companys contaminated land risk
spillage. This is generally of little environmental management policy;
significance and is characterised by vapour in the upper in response to the requirements of regulatory
1 m of the ground at levels of up to 50 ppm. The authorities.
amount of contamination may increase due to:
In any of these circumstances, a retail site operator may
cracks in surface pavement; need to investigate and assess his land for the presence
leaks from oil/water separator chambers; of any contamination which could cause unacceptable
spillage to direct fill tank manchambers; risks, and to take remedial (or corrective) action to
spillage to above or below ground offset fill reduce or control these risks.
chambers;
dispenser leaks;
pipework leaks; 10.2 LEGAL REQUIREMENTS
offset fill line leaks.
In the UK, there are several pieces of legislation which
Deeper contamination may be caused by migration of can be relevant to land contamination. The term
contaminants through shallow ground or by tank leaks. contaminated land is in this case used in its general
Where the water table is found less than three metres sense, and hence is intended to include contamination
below the surface then downward migration of of ground and surface waters.
contaminants is more likely. Typically (but not always, or exclusively)
petroleum retail sites may be affected by:
In addition site operators may need to consider
contamination issues for a number of other reasons, e.g: planning and development control legislation;
water legislation, such as the Water Resources Act
during the commercial acquisition or disposal of 1991; Groundwater Regulations 1998;
land used for petroleum retail purposes; waste legislation, including the Duty of Care
short-term incidents; provisions of the Environmental Protection Act
as part of a normal tank refurbishment/site 1990 [EPA];
35
Part IIA of EPA 1990 (introduced by section 57 of where agreement is not possible, the Regulator will
the Environment Act 1995). serve a remediation notice requiring specified action to
be carried out.
UK policy on contaminated land requires the adoption Sites subject to a remediation notice will be listed
of a balanced and risk-based approach to dealing with on a public register. Appropriate persons are defined as
contamination, which is compatible with the general those who are responsible for causing the
principles set out in the DETRs Guide to risk contamination, or for allowing it to remain in place
assessment and risk management for environmental (which could include the site owner or occupier if they
protection, and consistent with the principle of were aware of the presence of contamination e.g.
sustainable development. Current policy is committed through a spill, but did nothing about it), or in the event
to the 'suitable for use' approach, taking into account the that these persons can not be found, the site owner or
costs and benefits associated with any action. This occupier. [Note that the site owner or occupier is not
means that the significance of any contamination found, held responsible for water pollution unless he caused
and the need for any remedial action, should be the pollution or knowingly allowed it to remain, or
assessed in the light of the current use and/or proposed unless he acquires 'class A status' by acquiring the
use, where applicable, of the land. property with knowledge of its (contaminated)
In the UK Part IIA of the EPA sets out a statutory condition.]
regime for contaminated land management, It may be the case that the site operator has
implemented through Regulations and Statutory insufficient resources or the specialist knowledge to
Guidance. This covers the identification and control of carry out this work, and hence needs to employ suitable
land which, under its existing use, poses a threat of advisors/consultants and/or contractors to undertake it.
significant harm or pollution of controlled waters Whether an operator does the work himself or appoints
because of the contamination present. Part IIA is not experts, the investigation, assessment and remedial
relevant where a change in land use or development is treatment should be carried out in accordance with good
planned which requires planning permission - in these technical practice.
cases, existing planning and development control
legislation will apply. Under Part IIA, local authorities
are required to inspect their areas and identify land 10.3 PROCESS OF MANAGING
which falls within a new statutory definition of CONTAMINATED LAND
contaminated land:
A risk based approach, as described in section 6, should
"Contaminated land is any land which appears to the be adopted to identify risks from contamination, assess
local authority in whose area it is situated to be in such the significance of them and take action to deal with
condition, by reason of substances in, on or under the any which are unacceptable. For further information see
land, that: IP Guidance document on risk assessment for the water
environment at operational fuel storage and dispensing
significant harm is being caused or there is facilities.
significant possibility of such harm being caused; In the UK, the Department for Environment, Food
or and Rural Affairs (DEFRA) has published a series of
pollution of controlled waters is being or is likely model procedures for managing contaminated land, see
to be caused." Annex D. This procedural guidance relies on the risk
based approach to assessing and managing land
Where land is identified as contaminated in this way in contamination, and is intended to be applicable to a
the UK, the regulatory authority (either the local wide variety of types of contaminated site. The
authority or the Environment Agency or Scottish approach adopted by the petroleum industry to dealing
Environment Protection Agency [SEPA]) is required to with contamination is generally consistent with the
identify appropriate persons, and to reach agreement Departments model procedures.
with them that appropriate remediation is to be carried The process of managing contaminated, or
out. This can be carried out on a voluntary basis which potentially contaminated, land involves following a
is by far the preferred option, as under such logical sequence of steps or activities. These are
circumstances the site owner has greater freedom over summarised following and in Figure 8.
the choice of remedial action employed. In some cases,
36
MANAGEMENT OF CONTAMINATED SITES
1. Establish why the work has to be carried out, and cases there may be iteration, both within individual
set objectives steps and between them. Iteration is commonly
provides the focus and context for the activities to practised between step three, site investigation, and step
be carried out; four, estimating and evaluating risks, with more data
context and objectives will always be site specific; being collected to enable risk estimates to be refined.
objectives will influence the amount and type of For greater detail on the above steps see IP
data to be collected; Guidelines for investigation and remediation of
influences decision of whether to carry on with petroleum retail sites.
further work at the site or whether it is acceptable Whilst site operators will normally be able to
to stop. collect much of the information needed for a
preliminary site assessment, the interpretation of this
2. Carry out a preliminary assessment of the site and any further investigative work may not be
both qualitative and quantitative risk reviews are straightforward, and will require additional expertise.
possible to develop a conceptual model of sources, Subsequent stages of site investigation, risk estimation
pathways and linkages at the site; and evaluation, and risk management will normally be
a qualitative approach to identifying pollutant carried out by, or in conjunction with, specialists. Site
linkages may not satisfy all parties involved. operators/owners may wish to refer to the following
background publications to assist them in understanding
3. Carry out site investigation(s) further the technical process of dealing with
contaminated land:
4. Estimate and evaluate the risks from
contamination at the site Institute of Petroleums Code of Practice for the
Investigation and mitigation of possible petroleum-
5. Decide on appropriate risk management options based land contamination
Institution of Civil Engineers Design and Practice
6. Where appropriate, implement remedial measures Guide: Contaminated land: Investigation,
and carry out testing/monitoring to validate their assessment and remediation
effectiveness Environment Agency 1999: Methodology for the
derivation of remedial targets for soil and
7. Implement long-term monitoring and groundwater to protect water resources. R&D
maintenance measures, if necessary publication 20
DETR, EA and Institute for Environment and
It will not be necessary to carry out all steps of the Health 2000: Guidelines for environmental risk
process at all sites. Depending on the site conditions, it assessment and management. TSO
may be possible to stop at the end of step 2, or at the CIRIA SP101-112: Remedial treatment for
end of step 4. However, the amount of information contaminated land
available about a site at the end of step 4, is much CIRIA SP111: Volume XI: Planning and
greater than that obtained by step 2. It should be noted management in remedial treatment for
that both qualitative and quantitative risk reviews are contaminated land
possible, and a thorough and considered use of the DETR CLR reports (see Annex D)
former will often reduce the need for the more detailed DETR CLR 11: Model procedures for the
quantitative approach. However, in some management of contaminated land introduction
circumstances, it may be difficult to persuade other and overview
parties, such as regulatory authorities for example, that
stopping the process at the end of step 2 is sufficiently Site operators/owners may also wish to use other
safe and protective of health, safety and the guidance material e.g. Confederation of British Industry
environment. Tackling contamination, and also DETRs CLR 12:
It is necessary to follow the steps sequentially. For Quality assurance in contaminated land consultancy, to
example, it is not normally possible to decide on assist with the process of appointing appropriate
appropriate risk management options (step 5), without specialists to assist them.
having first completed steps 1 to 4. However, in many
37
Risk Assessment Risk Management
Start
ch3 ch4 ch5 ch6

Preliminary Site Risk Risk
Why am I Site Investigation Estimation & Management
doing this? Assessment Evaluation Options ch7
Select &
implement
remedial
measures
Risk estimates
Objectives Objectives Factual for relevant
of work of work report pollutant Set risk
linkages management
objectives ch7
Implement
validation
38
testing
Evaluation of
Likely pollutant Yes risk
linkages? estimates
Implement
operational No
Are objectives
controls
met?
Are other No Are any risks No

parties satisfied? acceptable to all Yes
parties?
Long term
Monitor and
Yes Yes monitoring &
review
maintenance
regularly
STOP STOP if necessary
Figure 8 Main steps involved in managing contaminated land

10.4 SITE INVESTIGATION Soil Vapour Survey (SVS) advantages:
Where an operator is responsible for more than one site cheapest form of intrusive survey (~500);
it is recommended that sites be ranked according to quick, can be completed within eight hours;
their pollution potential. The following factors may be wide site coverage;
considered to assist in this process: good for locating plumes from line leaks;
minimal disruption to the site.
any leaks and spills recorded by the Local
Authority or the owner; Soil Vapour Survey (SVS) disadvantages:
presence of single-skin abandoned tanks, which
may be indicative of leaks; visual impact on tarmac or block pavement through
multiple abandoned tank farms indicating the drilling of 40 small 10 mm diameter holes;
redevelopment; little information below 1 m depth;
age of site as a fuel storage location. no information obtained on groundwater depth or
quality.
None of the above factors should be used in isolation
and it should be recognised that some sites over 50 To obtain more detailed information groundwater wells
years old may have no significant contamination upon are required. Generally 50-100 mm diameter they
investigation. should be installed after a SVS to ensure optimum
It should not be necessary to investigate petrol positioning in terms of contamination location. Wells
filling stations using intrusive techniques, such as should be completed with a lockable cover that clearly
drilling boreholes, in normal operational circumstances. identifies it as a well and marked NOT FOR FUEL.
Intrusive surveys will only usually be required: In traffic areas the well cap should be sufficient to
withstand a 44 t tanker.
where a station is suspected of causing pollution For routine investigations a well will rarely need to
e.g. oil in a stream, fuel smells in adjacent be greater than 6 m deep and a minimum of three wells
building, groundwater pollution; is usually sufficient to provide an appropriate level of
by planning authorities as part of redevelopment information for any given petrol filling station. It should
proposals; be noted that drilling companies typically charge by the
when buying or leasing an existing station. day hence the cost of three wells is unlikely to be
significantly greater than only one or two. Where
No work should take place until the Local Authority significant contamination is found, a more extensive
and the Environment Agency have been informed (in investigation will be required (see Section 12 on
the UK) and the location of buried services established. Emergency Spill Response).
An initial ERA should be carried out before any non

emergency intrusive survey and should include: 10.5 SITE REMEDIATION
site history; Remediation works may be carried out following

construction and equipment type; substantial leaks or as required by a Planning Consent,
hydrogeology; Local Authorities, or prior to sale of the site for
surrounding environmental receptors. redevelopment. The scope of the works should be
discussed with the appropriate enforcing agency and in
Investigation encompasses: many circumstances will require separate licensing or
agreement:
all of the above, plus;
shallow soil vapour survey at ~40 points Local Authority approval for works on operational
across a service station; sites.
wells constructed to sample deeper soil and Local Authority approval for works associated
groundwater; with redevelopment.
analysis of samples for a wide variety of Environment Agency approval for remediation
hydrocarbons and fuel additives. activity that may fall within the waste management
licensing or pollution prevention and control
39
regimes, which require permits under the Water making excavation and disposal of contaminated spoil
Resources Act 1991. often impractical, except during site redevelopment or
Emergency works to protect life or property do not closure. Where the opportunity to excavate spoil does
require formal licensing. exist, care should be taken to ensure adequate support
to site boundaries and excavation sides. Excavation to
Where remediation systems require discharges of solely remove contamination is not recommended in
treated effluent, a separate discharge consent may be loose sand or gravel strata due to the risk of collapse.
required. Should the works require temporary storage of Alternative in situ technology is usually more suitable
recovered free product, Local Authority consent will be in such ground conditions.
required, even if the site has ceased to store petroleum It should be noted that disposal of arisings may be
spirit on a commercial basis. subject to Landfill Tax, although exemptions may be
A wide variety of remediation techniques exist and available where the site has been decommissioned and
new technologies are in continual development. The a redevelopment is proposed.
principal methods used on petrol filling stations are
briefly summarised in this section with their typical 10.5.3 Vacuum extraction
operating criteria. Remedial techniques fall into two
categories: engineering and process based. A more In situ soil vapour extraction (SVE which may also be
comprehensive review of remedial techniques can be referred to as vacuum extraction, in situ volatilisation or
found in CIRIA Report 186, 1998. soil venting) is effective in the removal of volatile
All types of remediation should be carried out by compounds such as petrol from the unsaturated (above
experienced personnel and subject to detailed risk the water table) zone (CIRIA, 1998). The technique has
assessment and method statements. In the UK, works the advantage of easy installation on an operational
may also be subject to the Construction Design and filling station and relatively low cost when compared to
Management Regulations where demolition is included excavation. The technique uses a central vacuum pump
in the scope of works. to draw contaminants out of the ground, either for
storage, destruction or other surface treatment. The
10.5.1 Monitored natural attenuation (MNA) vacuum pump may be configured to draw contaminated
vapour (soil vapour extraction), free phase oils,
It is now widely recognised that hydrocarbon groundwater, or a mixture of air and liquids (dual phase
contamination of soil and especially groundwater can extraction).
attenuate naturally at a site under the right conditions. Vacuum extraction techniques work best in loose
The principal mechanism is biodegradation. Naturally sand and gravel although effective recovery can be
occurring microorganisms which use the hydrocarbon gained in less permeable soils provided the extraction
contamination as a food source break it down to the points are placed closer together and the treatment time
harmless products carbon dioxide and water. Natural extended. An impermeable surface such as clay or
attenuation is not a rapid process and can take several pavement is also usually required to maximise the zone
years, but monitoring the process to demonstrate that it of influence of an extraction well and avoid short-
is taking place at a sufficient rate to mitigate any risks circuiting of the airflow. Due to the inherent variability
can be a very cost effective alternative to expensive of ground conditions a detailed site investigation,
engineered solutions. usually including pilot testing, is recommended before
Further information and guidance on MNA can be such techniques are used.
obtained in Environment Agency publications Natural Vacuum extraction systems typically run for six to
attenuation of petroleum hydrocarbons and chlorinated twelve months depending upon the level of existing
solvents in groundwater R&D Technical Report P305, contamination and the cleanup required. Where used as
prepared by Golder Associates (1999) and Guidance on a means of boundary containment, a vacuum extraction
the assessment and monitoring of natural attenuation of trench may be operational for two to three years. This
contaminants in groundwater R&D publication 95, is because the trench is used to intercept migrating
prepared by Enviros Aspinwall and LGC (2000), and at contaminants as opposed to reduction of the
the website howtomna.com. contamination in the source area.
10.5.2 Excavation and disposal 10.5.4 Sparging
Petrol filling stations rarely cover more than 0,25 ha, This technique involves the injection of compressed air
40
below the water table. It is often used in combination used, care should be taken to ensure that product is not
with SVE. The compressed air drives volatile petroleum forced offsite by the air injection. Where this risk
based contaminants from the soil and groundwater. The exists, either the free phase should be removed first or
addition of oxygen at depth also assists in the a boundary collection system should be installed. This
acceleration of natural biodegradation. The air-vapour may be a line of closely spaced extraction boreholes or
mixture is intercepted by SVE wells or collection a recovery trench.
trenches.
Sparging is a suitable technique for sand and gravel 10.5.5 Free product recovery
material, particularly those contaminated with
petroleum rather than diesel. The technique is capable Where large quantities of fuel are present, direct
of achieving a high degree of contaminant removal pumped recovery using well pumps may be suitable.
from groundwater and can be used as combined soil The pumps can be configured to selectively pump free
and groundwater clean-up approach. However, sparging oil from above the water table and into storage. The
should not be used where a substantial quantity of free technique generates little additional water but the zone
phase fuel is present, as more efficient techniques are of influence for each pump may not be great.
available e.g. vacuum extraction. Where sparging is
Table 7 Typical engineering methods (see CIRIA SP104)
Method Examples Application Limitations

Excavation followed by: - widespread - does not treat the
- off-site disposal - not contaminant or contaminants
- on-site disposal media dependent, - can be costly and have
- clean-up treatment although certain types practical difficulties
of fill may be very - lack of, or limitations
difficult to excavate of, local licensed
without major support disposal sites
measures - environmental
concerns
Containment - surface covering - wide range of - requires careful design
systems contaminants, and implementation
- vertical barriers especially complex - susceptible to failure
- horizontal barriers mixtures or damage
- macro-encapsulation - all media types - long-term durability
- large or small sites unproven
Hydraulic - isolation/containment - all aspects of control - highly site-specific
control of contaminant plume and management of the specialist design
measures - pumping for treatment hydrological regime - long-term input
purposes - usually a temporary or needed
- in conjunction with short-term measure - long-term monitoring
containment measures - most contaminants in - limited applicability to
water soluble form certain hydro-
- especially useful for geological conditions
operational sites
41
Table 8 Typical process-based methods (see CIRIA SP104)
Process Method Examples Application Limitations

Thermal - use of heat to - thermal - most soils* - toxic emissions or
remove or desorption - mainly organic residues possible
destroy - incineration contaminants - approvals needed
contaminants - vitrification for mobile plant
- energy intensive
Physical - separation - soil washing - usually at early - do not destroy
- isolation or - solvent stage in the clean- contaminants
concentration extraction up process - difficult in clays
of - soil vapour - most contaminants - not a complete
contaminants extraction solution
Chemical - use of - oxidation/ - reasonably well - uncertainties over
chemical reduction established for chemical reactions
reactions to - dechlorination liquids and - limited experience
destroy or - pH adjustment slurries, some in practice
modify - hydrolysis experience for
contaminants extraction soils, can be
designed for the
specific chemical
conditions
Biological - use of natural - engineered - organic - very site- specific
activities of treatment beds contaminants - difficult to predict
micro- - reactor systems - most soil types precise timescale
organisms to - land-farming and water needed for
transform or - composting - operational sites effectiveness
destroy - ioventing - not applicable to
contaminants all contaminants
Solidification - immobilisation - inorganic - proven for some - needs long-term
or of binders e.g. inorganic monitoring
Stabilisation contaminants cement, lime, contaminants, - containment rather
organic binders tests underway for than destruction
organics
- potentially
suitable for wide
range of media
types
* Soil type may affect performance
42
11
CONTRACTOR ACCREDITATION
AND ASSESSMENT OF CAPABILITIES
Operators should satisfy themselves that any forecourt reasonably practical, that chosen contractors are
contractors that are employed to undertake work on the competent. Where accreditation is not available then
forecourt are aware of the guidance contained in this references should be sought from other companies or
publication and are familiar with the safety guidance trade associations. For major development falling under
contained in IP Code of safe practice for contractors the Construction, Design & Management Regulations,
working on petrol filing stations. Useful background the selection and appointment of competent contractors
information on the selection and management of is a legal requirement of the Designer.
contractors can be found in IP Code of safe practice for Where a variety of contractors are present on site
retailers managing contractors working on petrol at any one time, the client should appoint a Principal
filling stations. Contractor (PC) in writing. The PC should be liable in
A variety of accreditation schemes are available for contract for the safety performance of all other
contractors. Operators should ensure, as far as contractors and sub-contractors.
43
44
12
EMERGENCY SPILL PROCEDURES
12.1 LARGE SCALE INCIDENT filling station to develop an appropriate environmental

RESPONSE PLAN response plan for a large leak or spill.
All sites storing fuel of any type should have an Site operators should be aware that in the event of a
incident response plan. Site operators should consider large leak or spill, the primary consideration is the
the risks, consequences and emergency actions that may health and safety of personnel, both on site and in
occur or be required following: the vicinity of the petrol filling station.
spills during delivery of fuel; However, action to reduce the risk to health and safety
spills during dispensing; is also likely to assist in the protection of soil,
underground leaks. groundwater and surface waters, and air quality to a
lesser extent. For guidance on non-emergency
The spill response plan should consider the immediate remediation see Section 10.
safety and environmental risks and consequences of a
spill including the risk to off-site building and The aims of the emergency response are to:
environmental targets such as watercourses and protect the public and employees;
farmland. The plan should include details of: prevent migration off site and commence
recovery/cleanup;
emergency procedures; establish the rate and direction of product
contact numbers for notification and additional movement.
help;
clean-up equipment; A checklist at the end of this section summarises the
the layout of the site with services adjacent to the key actions to be taken in an emergency.
site clearly marked.
The plan should be reviewed annually to ensure it is up 12.2 FACTORS TO BE CONSIDERED IN

to date and should be communicated to all staff. THE RESPONSE PLAN
Operators should ensure that all staff are appropriately
trained. 12.2.1 Identification of a large spill
Guidance can be found in UK Environment
Agencies Pollution Prevention Guideline 21 Pollution If the final chamber of the oil/water separator, or the
incident response planning. This section is intended to constructed wetland, shows any evidence of product
give guidance to the owner or operator of a petrol following a known spill of any size:
45
1. Close the outlet valve, if there is one. down-slope direction, check all of the above in
2. Close the site and shut down the forecourt surrounding streets, plus any external gas or
electrics. electric meter cupboards on houses, any cellars or
3. Call the fire brigade. under-floor voids.
4. Contact the site owner, Local Authority, 3. If it is necessary to enter occupied premises, this is
Environment Agency and an oil spill contractor. best done while accompanied by a police officer, at
least for the first visit.
12.2.2 Surface spills 4. If there is good reason to enter an unoccupied
building, especially commercial buildings at night,
Uplift product from leaking tanks remembering the fire brigade/police should contact the key
that a spirit uplift will require a separate pump unit. holder.
Once emptied, tanks should be water filled by the 5. Where product is found near an unoccupied
fire brigade. During the uplift operation the whole building it will be necessary to enter, by force if
forecourt should be a restricted area. necessary. In the UK this should be undertaken by
Holed lines and all site electrics should be isolated. the fire brigade/police who have statutory powers
Any surface spill contained in an oil/water to enter.
separator can be collected for disposal by vacuum 6. Remember that in an incident the public cannot be
tanker. Ensure vacuum trucks are always earthed. relied upon to report smells accurately. They may
not have a sense of smell or may mistake natural
It is possible for spills to migrate into the ground gas or damp for fuel. A decision to reoccupy
through cracks in the pavement and drains, expansion should be made in conjunction with the fire
joints in the slab or via the drainage system. In such brigade and Environmental Health Officer.
cases the considerations outlined for underground leaks 7. Repeat the checks at least every four hours until
in 12.2.3 will also apply. the flow direction is known. If heavy rain is
forecast then the product could appear in drains or
12.2.3 Underground leaks premises at short notice.
All spills will migrate off site down slope. If the 12.2.4 Product found off-site
product enters a duct or sewer the rate of movement
may be greater than 500 metres per day. If the product 1. Notify sewerage undertaker. Ventilate drains or
is dissolved in groundwater the rate of movement can ducts either by simply opening the covers or via
vary between millimetres and tens of metres per day. mechanical means. Do not use compressed air
The level of risk and the extent of remedial action blowers on ducts as the product can be forced into
required will be determined by the rate of product buildings. Extraction fans should be used and can
movement. often be hired locally.
In many cases the gradient of the site and the 2. Blowers may be used directly into affected
surrounding streets will give an indication of the route buildings and cellars.
off site but note groundwater movement may not 3. Notify sewerage undertaker. Sewers may be
necessarily follow surface gradient. flushed with water by the fire brigade or Local
Note: Petrol may seep through polythene water Authority. However where sewer flushing is used
supply pipes and taint drinking water. it must be recognised that it may displace vapours.
If there is any doubt as to the route of the drainage, Downstream premises should be monitored
plans of the sewers, telecommunications ducts etc. closely.
should be sought from the Local Authority, 4. Any building that has reported vapours should be
Environment Agency or water company. In an evacuated, ventilated, and inspected for the route
emergency situation the fire brigade or police should of entry. This is typically through wooden floors,
obtain such plans. The emergency services can obtain drains or cable/gas ducts. Forced ventilation
plans much faster than the other parties involved. equipment can be sited outside an affected building
and therefore need not be intrinsically safe.
1. Check all drains, manholes, stopcock covers, cable Extraction equipment used in drains or areas
ducts and floor voids on the site with a gas affected by high levels of vapour (>1%LEL)
detector. should be intrinsically safe.
2. Working away from the site, concentrating on the
46
The following tasks should be carried out on the required quickly, to prevent off-site migration,
station: work should not be delayed by waiting for plant
equipped with arrestors and valves. In such cases
1. Carry out a line trace. continuous gas monitoring should be carried out in
2. Carry out a soil vapour survey (SVS) as soon as and around mechanical plant. More harm and
possible. greater risk may be caused by delay.
3. Order appropriate boundary fencing and If product is found in watercourses or ditches they
appropriate plant equipment such as concrete should be dammed with absorbent booms.
coring machine, drill rig, mechanical excavator, 8 Consider over-pumping contaminated water to a
yard skip (with lid to prevent rainwater entry), an holding tank. The same approach can be applied to
earthworks lorry, six empty 200 litre lidded drums affected sewers. Wherever pumps and fans are
to site. used overnight it is important to consider their
4. A 40 KVA generator should be put on standby. security from theft and malicious damage,
including them being turning off, and their need for
Mobilise plant as soon as possible. The plant moves fuel.
slowly and delays may be exacerbated by roadblocks Waste excavation material, absorbents and liquid
associated with a major incident. If delays are products may need temporary storage on site. This
anticipated the police will usually arrange, on request, should be secure, covered storage that is held on
an escort for plant. site for no longer than absolutely necessary. Waste
Once the line trace is complete, the source of the storage normally requires licensing or exemptions,
leak is known, and the Environment Agency has been however in an emergency the pollution control
consulted, a borehole should be drilled as close to the regulations provide a defence for emergency
leak site as possible. If the borehole encounters any storage.
contaminated ground, complete the hole as a Drill further holes on the site, down-slope of the
groundwater well. If the well subsequently accumulates leak and along the boundary where the plume is
product it can be pumped or bailed out and disposed of thought to leave site. It may be necessary to drill
appropriately. off site depending on where the plume is found.
Once found, extraction can commence at the
Consider the need for pumps, separators, air source, at the boundary, and even close to affected
treatment units and storage tanks. premises.
Consider appropriate power supplies.
If the plume is localised in a part of the site with no If the rate of recharge of product into the wells is low it
pipes, ducts or canopy it may be possible to dig out may only be practicable to bail the wells by hand and
the source area of the plume. The excavation will store the product in drums for immediate disposal, or
emit high levels of vapours, requiring continuous install a cut-off trench to capture migrating product. In
gas detection. Work should be suspended if >10 % general slow and steady pumped recovery from cut-off
LEL is detected at the edge of the excavation, or trenches or wells is preferable to excavation (where
20 % LEL at the base of the cut. Spark arrestors there is a high water table), unless the leak is confined
and Chalwyn-type valves are normally required for to a small area and swift excavation can eliminate the
this type of excavation, however in an emergency source of the plume (more effective where there is a
they may not be available. If excavations are lower water table).
47
Large Spill Response Guidelines Checklist
1 If spill on site, shut off dispensers, turn off forecourt electrics, evacuate site, call fire brigade.
2 If spill is visible it should be contained with sand, and the oil/water separator closed.
Call site owner, Petroleum Officer, Environment Agency5 and Environmental Health Officer
3 Arrange fuel uplift if required.
4 Any spill contained by oil/water separator, or constructed wetland, should be collected for disposal by
vacuum tanker.
Ensure vacuum trucks are always earthed
5 Establish where oil/water separators are draining to (e.g. soakaway, sewer).
6 If any doubt about drainage route, get plans from LA, EA or Water Utility via Emergency Services.
7 If high vapour readings, then ventilate manually, by opening, or mechanically.
8 Contractor to carry out line trace, SVS, order skips, drums, generators, excavators and earthwork lorries
as required.
9 Checks to detect gas on site and surrounding streets and houses should be carried out regularly.
10 If product found in unoccupied building it may be necessary for police/fire brigade to enter by force.
11 Any building with vapours should be evacuated, inspected and ventilated as required. Decisions to re-
enter should be agreed with fire brigade and EHO.
12 Keep repeating checks every four hours until plume is found.
13 When source of leak is known, consult Environment Agency and drill borehole as close to leak site as
possible. If the borehole encounters any contaminated ground, complete the hole as a groundwater well.
14 As the well accumulates product, bale or pump out product.
15 If product in ditches or watercourses, dam them with booms in consultation with the EA.
16 Make sure that there is secure storage for all plant to prevent it being stolen or tampered with.
17 Waste excavation material, absorbents and liquid products may need temporary storage on site. This
should be secure, covered storage that is held on site for no longer than absolutely necessary.
Consultation with the EA should be made.
18 In consultation with the EA drill further holes on the site, down slope of the leak and along the boundary
where the plume is thought to leave site.
19 Once the plume is found, extraction can commence at the source, at the boundary and even close to
affected premises. If rate of recharge of product into wells is low it may only be practicable to bail the
wells by hand, alternatively extract by pump from wells or trenches. If leak is confined to a small area
with no pipes, ducts or canopy, swift excavation can eliminate the source of the plume.
5
UK Environment Agencies: Pollution Incident Notification (0800 807060), Control Office for movement of
Special Wastes (08457 00 11 66).
48
12.3 SMALL INCIDENTS 12.3.2 Customer spills small amount of product at

the dispenser
This section provides recommended procedures that
should be followed by the Responsible Person at the 1. Clear the spillage.
petrol filling station when: Petrol: Small amounts are best swept over as
large an area as possible, they will rapidly
a) a customer spills a large amount of product at the evaporate. Larger amounts should be washed into
dispenser on the forecourt; the oil/water separator.
b) a customer spills a small amount of product at the Diesel: Small amounts should be absorbed with
dispenser on the forecourt; sand and then shovelled away for safe disposal.
c) a customers vehicle develops a fuel tank leak. Larger amounts should be washed into the
oil/water separator. Detergents should not be used
Appropriate action to reduce the risks to health and to clean spillages.
safety will, in many cases, also ensure that 2. Push the vehicle off the forecourt (do not start the
environmental receptors are also protected. engine) and ventilate.
3. Inform line manager, and ensure the Petroleum
12.3.1 Customer spills large amount of product at Officer is informed.
the dispenser
12.3.3 Vehicle develops a fuel tank leak
1. Ensure the vehicle is evacuated.
2. Position fire extinguisher upwind of the hazard. 1. Push the vehicle off the forecourt (do not start the
3. Clear the spillage. engine).
4. Push the vehicle off the forecourt (do not start the 2. Deal with the spillage as above and ventilate the
engine) and ventilate. vehicle, including the boot.
5. Inform line manager, and ensure the Petroleum 3. Allow the customer to telephone for assistance in
Officer is informed. removing the vehicle.
49
50
ANNEX A
MODEL SCHEDULE OF
INSPECTIONS AND TESTS
FORECOURT
Tank tops empty of water
Tanks with caps, locks and grade labels
Offset fills with caps, locks and grade labels
Vapour recovery with caps, locks and warning signs
Oil/water separators clean and free from debris
DISPENSERS
Panels free of leaks and W&M seals in good condition
Waste disposal area is clean and regularly cleared
Fire extinguishers and sand buckets present at each dispenser island
All public warning and information labels are posted
Car wash area is clean and free of hazards
Tank vents free of debris
No audible noise from vent valves during delivery
GENERAL AREAS
Emergency doors free from obstruction and open outwards
Emergency stop button working
PA in working condition
Electrical cupboard free of combustibles and locked
Fire action notice displayed and complete
Assembly point sign displayed
OFFICE AREA
Petroleum licence available with plans (expiry date )
DCD licence available
Vapour recovery authorisation (expiry date )
Electrical test available and current
Air regulations folder F59 available and complete
Petroleum filling station register up-to-date and complete
Risk assessments complete and up-to-date
EHS Policy Statement is prominently displayed
Emergency telephone numbers are up-to-date and displayed
Accident book available and used (review trends)
RIDDOR forms and guidance book available
First aid box complete and clean
Good housekeeping standards are maintained
All weekly checklist actions are completed as planned
Vapour recovery maintenance log available
Vapour recovery instructions available
COMPLETED BY:
(Signature)
51
MODEL SCHEDULE OF INSPECTIONS AND TESTS (Continued)
Dispenser Islands
Visually check dispenser housings internally for fuel
Check hoses for kinks and damage
Check nozzle cut-off device is working
Individual dispenser isolation switches are working
Pipework & Vent Pipes

Remove any shrubs around vent pipes etc. within a 3 metre radius
Check all pipes are adequately labelled
Check the condition of pipes and valves for signs of leaks, corrosion or damage
Storage Tanks & Fill Points

Check tanks for water build up
Check tank top manholes free from water, product and are adequately labelled
Check tank fill pipes are locked
Check below ground offset fill point chambers are free from product, debris and
labelled adequately
Check manhole covers are seated correctly and can easily be lifted using
appropriate lifting device
Lighting Levels
Check lighting levels are adequate in all areas, tankfarm, forecourt, office and
shop
Fire Fighting Equipment & Emergency Equipment

Check that all fire extinguishers are present, fully charged and the correct
number are present with no signs of damage
Check sand buckets are full of dry sand and test fire alarms are working
Check emergency switches (panic button) and loudspeaker system are
functioning properly
Check contents of first aid box are all present and correct
Warning / Advice Notices

Check all notices are posted as required, are undamaged, clean and legible
Oil/Water Separator
Check all chambers for the presence of petrol / oil and build up of grit and
debris.
Check drains are not blocked or full
COMPLETED BY:
(Signature) Date
52
ANNEX B
MODEL SAFETY, HEALTH
AND ENVIRONMENTAL POLICY
XXXX Petroleum Retail Company and its employees are fully committed to health, safety and
environmental protection and will:
COMPLY with all relevant laws and regulations.
DESIGN, CONSTRUCT, OPERATE, MAINTAIN and DISPOSE of our assets in a healthy, safe and
environmentally sound manner.
STRIVE for high standards of personnel health, safety and protection.
REQUIRE contractors to operate to the same high standard.
RESPOND quickly and effectively should any incidents occur.
TRAIN and encourage all employees to perform their jobs consistent with this policy.
MAINTAIN an excellent reputation in these fields.
Signed:
Owner / Managing Director
53
54
ANNEX C
GLOSSARY
For the purpose of these guidelines, the following catalytic incinerator: an incinerator incorporating a
interpretations apply irrespective of any other meaning catalyst designed to promote the oxidation of pollutants.
the words may have in other connections.
closed system: a product handling and transfer system
absorb/absorption (of gases): the taking up of gases designed to prevent vapours venting to atmosphere.
into the inner structure of liquid.
coaming: a structural device (often hollow) on the top
adsorb/adsorption (of gases): the taking up of gases of a road tanker to prevent damage to the tanker fittings
onto the surface of a material. in the event of a roll-over, sometimes utilised as a
means of passing vapour from compartments to a
ACV (angle check valve): an underpump in-line valve common vapour collection point.
to ensure product drains back to the tank in the event of
a leak. condensate: liquid formed due to the change of state
from vapour to liquid.
additive: detergent performance enhancing additive
that inter alia prevents coking of engines, improves containment: a means to prevent loss of liquid product
combustion. in the event of a leak/spillage.
anti-static: conductivity improver. direct fill point: a product entry point, e.g. on an
underground tank at a gasoline retail site, positioned
arc: flow of electrical current at the instant of directly on top of the tank.
separation of two points e.g. break of an electrical
contact. distillate: generic term from middle boiling point
distillate for a class of hydrocarbon products that
auxiliary fuel: additional gas added to a vapour line include diesel and kerosene.
feeding an incinerator to ensure that the hydrocarbon
concentration of the vapour in the line is well in excess drop pipe: a fill pipe fitted vertically inside a tank and
of the upper flammable limit (UFL). reaching the bottom of the tank, designed to reduce
splashing during tank filling.
bottom loading: the filling of a mobile container by Typically 3 / 0.076 m diameter.
means of a connection at ground level.
Typically 4/ 0.101 m diameter. dry break coupling: a coupling designed to minimise
the leakage of product when disconnected.
breather valve: a valve designed to relieve the pressure
or vacuum in a tank due to ambient eductor: a device for increasing the flow rate of a
temperature/pressure effects or vaporisation/ vapour by decreasing downstream pressure.
condensation of product.
emission: a release of product to the environment.
breathing: emissions from, or intake of air into, a tank
due to ambient temperature/pressure effects, or due to enrichment: the addition of a flammable gas, typically
vaporisation/condensation of product. LPG, to a vapour line to ensure that the vapour
concentration in the line is significantly greater than the
bund: an enclosure bounded by a wall or by natural or upper flammable limit (UFL).
constructed ground contours and designed to confine a
spillage of product. evaporation: conversion of a liquid to a vapour,
without necessarily reaching the boiling point.
55
external floating roof: a device that floats on the hazardous area: an area in which there exists or may
surface of the product in an open top vertical tank. exist an atmosphere containing flammable gas or
vapour in a concentration capable of ignition.
fail-safe (valve): a valve that upon the removal of its
activating force assumes a safe position. hazard and operability study (HazOp study): a study
taking account of all foreseeable normal and abnormal
fail-shut (valve): a valve that upon the removal of its circumstances that could lead to hazardous situations in
activating force assumes a shut position. and around a piece of equipment.
faucet: a valve, in the context of mobile containers the high level cut-off (HLCO) system: a safety system
valve at the end of the discharge/loading pipe. that stops the flow of liquid into a tank to ensure that it
is not overfilled.
fire engulfment valve: a valve designed to relieve at a
sufficient rate to prevent the pressure in a vessel hydrocarbon: a compound made up entirely of
exceeding the design value when the vessel is subject to hydrogen and carbon atoms.
the temperatures expected during engulfment in a
petroleum product fire. ignition source: accessible source of heat or energy,
electrical or non-electrical, capable of igniting
fill pipe: a pipe either fitted to a tank or inserted into a flammable atmospheres.
tank to permit filling.
inert gas: a gas or mixture of gases which will not
flash point: temperature at which a liquid gives off support combustion.
sufficient vapour to form an ignitable mixture with air
near the surface of the liquid under standard test inerting: the addition of inert gas to a vapour line or
conditions. vessel to ensure that the oxygen concentration of the
vapour in the line or vessel is significantly less than that
flammable: (synonymous with INFLAMMABLE) required to sustain combustion of the vapour.
refers to any substance, solid, liquid, gas or vapour, that
is easily ignited. interlock: a safety system that ensures that two or more
actions can only take place in a pre-determined
flammable limits (or range): the limits of sequence.
combustibility of flammable gases or vapours when
mixed with air (see upper flammable limit and lower incendive spark: of sufficient temperature and energy
flammable limit) (Note: synonymous with EXPLOSIVE to ignite a flammable substance.
LIMITS or RANGE).
lance loading device: a fixed location fill pipe which
flow rate: litres per minute or gallons per minute can be mechanically inserted into a mobile container.
(lpm/gpm) 1000 lpm = 220gpm.
lower flammable limit (LFL): the lowest
foot valve: a valve at the base of a mobile container. concentration of flammable gas in air at atmospheric
pressure capable of being ignited, expressed as
fuel grades: percentage by volume.
Four Star Leaded fuel
Kerosene / Paraffin liquid: flammable (flash point <55EC).
PUL/EM13 Premium
Unleaded 95-97 RON SUL/EM38 Super LEL/UEL: lower and upper explosive limits. The
Unleaded Oxygen : Fuel concentration in % range necessary to
ULSD/EG15 Ultra Low sulphur diesel support combustion.
Gas Oil EG9
Burning Oil EK3 mobile container: a tank in which liquid product can
be transported, e.g. a road tanker, rail tank car, barge or
gauging device (level): a device for the measurement sea-going tanker.
of the level of liquid in a tank.
56
ANNEX C
off-set fill point: a filling point, e.g. on a service station gasoline storage and loading at a refinery or terminal.
tank, on which connection for the hose of the delivery
vehicle is at some distance from the tank. Stage 1b: the control of vapour emissions during the
filling of a storage tank at a service station.
orifice plate: a device to restrict the flow through a
pipe to a pre-determined extent. Stage 2: the control of vapour emissions during the
filling of a fuel tank of a vehicle.
overfill prevention device (OPD): see high level cut-
off system. sump tank: tank installed in a vapour line at its lowest
point to collect condensate or product accidentally
permeate (of a membrane): in a membrane gas introduced into the line.
separation system, that part of the vapour which passes
through the membrane. switch loading: the practice of loading a less volatile
product into a mobile container that has previously
poppet valve: a valve mounted in half a coupling that contained a more volatile product.
is opened by a protruding member on the other mating
half of the coupling. ullage: the free space above the liquid product in a
tank.
pressure relief valve: a valve which automatically
prevents excessive pressure in the tank or pipe to which upper flammable limit (UFL): the concentration of
it is connected. flammable gas in air at atmospheric pressure above
which combustion will not occur, expressed as
pressure/vacuum valve (P/V valve): a dual purpose percentage by volume.
valve which automatically prevents excessive positive
or negative pressure in the tank or pipe to which it is vapour balancing: a practice by which vapour
connected. displaced during the filling of a container by product is
fed back to the ullage of the container from which the
RTW: road tank wagon. A tanker usually rated product was discharged.
between 18 44 tonnes.
vapour collection system: the pipework and associated
saturated vapour: a hydrocarbon vapour/air mixture equipment which are used to connect vapour emission
which can not contain any further hydrocarbons at sources to a vapour control unit.
specified pressure and temperature.
vapour concentration: the percentage of hydrocarbons
secondary seal: a seal mounted above a primary seal to in a hydrocarbon/air mixture.
increase the vapour retention efficiency.
vapour control system: the combination of a vapour
self-checking (device): a device that automatically collection system and a vapour control unit.
checks whether a fault exists within it.
vapour control unit: a device for the reduction in the
self-sealing (device): a device that automatically shuts hydrocarbon concentration in a hydrocarbon/air
when the force keeping the device open is removed. mixture. This can be achieved either by recovering the
hydrocarbons in a vapour recovery unit or by
shell (of tank): the walls of a tank. destroying them, e.g. in an incinerator.
single stage (vapour recovery unit): a vapour recovery vapour generation: the production of hydrocarbon
unit in which the reduction in vapour concentration from vapour by evaporation of a volatile product. Where this
inlet to vent is undertaken in one process step. occurs during filling of a tank a greater volume of
hydrocarbon/air mixture will be emitted than the
splash loading: filling of a tank resulting in excessive volume of product pumped into the tank due to the
splashing and vapour generation. vaporised hydrocarbons being added to the air existing
in the tank before filling.
Stage 1a: the control of vapour emissions during
57
vapour header: the main vapour pipe feeding vapours form readily evaporates at ambient temperature. Not all
to a vapour control unit. Pipes connected to individual VOCs are hydrocarbons: e.g. ethers are not
emission sources are manifolded into this main pipe. hydrocarbons as they also contain oxygen atoms.
vapour holder: a variable volume tank designed to vapour pressure: the pressure exerted by a volatile
store vapour prior to processing in a vapour control liquid.
unit.
water bottom: water accumulated in the base of a
vapour recovery unit (VRU): a device that separates storage tank.
hydrocarbons from air and converts them back to liquid.
weather shield: a device fitted above seals on external
volatile organic compound (VOC): compound floating roofs to cover and hence protect the seals.
containing at least one carbon atom and which in liquid
58
ANNEX D
REFERENCES
British Standards Institution (BSI)6 Natural attenuation of petroleum hydrocarbons and

BS 5328 Part 1: Guide to specifying concrete, 1997. chlorinated solvents in groundwater. R&D Technical
BS 6367: Code of practice for drainage of roofs and Report P305, 1999.
paved areas, 1983.
BS 7117-2: Metering pumps and dispensers to be UK Department for Environment, Food and Rural
installed at filling stations and used to dispense liquid Affairs (DEFRA)10
fuel, Part 2: Installation, 1991. CLR9: Contaminants in soils. Collation of toxicological
PD 5500: Specification for unfired fusion welded data and intake values for humans.
pressure vessels, 2000. CLR 11: Model procedures for the management of
Pr EN 858-1: Installation of separation of light liquids, contaminated land: Introduction and overview.
Part 1: Principles of design Performance testing CLR11 MP1: Model procedure for risk assessment.
Marking and quality control. CLR11 MP2: Model procedure for evaluation and
Pr EN 12285: Steel tanks. selection of remedial measures.
CLR11 MP3: Model procedure for implementation of
Confederation of British Industry (CBI)7 risk management action.
Tackling contamination. CLR11 MP4: Model procedure for verification of risk
assessment and risk management.
Construction Industry Research and Information CLR 12: Quality assurance in contaminated land
Association (CIRIA)8 consultancy.
Hydraulic measures for the control and treatment of PG1/14(96): Secretary of States Guidance Unloading
groundwater pollution. Report No. 186, 1999. of petrol into storage at service stations.
SP101 Remedial treatment for contaminated land, Guidelines for environmental risk assessment and
Volume I: Introduction and guide, 1998. management. TSO, 2000.
SP111 Remedial treatment for contaminated land,
Volume XI: Planning and management, 1995. UK Environment Agencies11
Pollution Prevention Guideline 3: Use and design of oil
Environment Agency for England and Wales9 separators in surface water drainage systems.
Guidance on the assessment and monitoring of natural Pollution Prevention Guideline 21: Pollution incident
attenuation of contaminants in groundwater. R&D response planning.
Publication 95, 2000. Pollution Prevention Guideline 27: Installation, decom-
Methodology for the derivation of remedial targets for missioning and removal of underground storage tanks.
soil and groundwater to protect water resources. R&D
Publication 20, 1999.
6
Available from BSI, 389 Chiswick High Road, London, W4 4AL, Tel: +44 (0)20 8996 9001, Fax: +44(0)20 8996 7001,
www.bsi-global.com
7
Available from CBI, Centre Point, 103 New Oxford Street, London, WC1A 1DU, Tel +44(0)20 7395 8247, Fax: +44(0)20 7240
1578, www.cbi.org.uk
8
Available from CIRIA, 6 Storeys Gate, Westminster, London, SW1P 3AU, Tel +44 (0)20 7222 8891, Fax: +44 (0)20 7222
1708, www.ciria.org.uk
9
Available from Environment Agency Dissemination Centre, c/o WRc plc, Tel +44(0)1793 865138, Fax +44(0)1793 514562,
www.wrcplc.com/ea/rdreport.nsf
10
Available from The Stationery Office Publications Centre, PO Box 276, London, SW8 5DT. Tel: +44 (0)20 7873 9090, Fax:
+44 (0)20 7873 8200, www.clicktso.com
11
Available from Environment Agencies order line, Tel: +44(0)151 604 1222, Fax: +44(0)8457 337700, email environment
.agency@dmsltd.co.uk
59
UK Health & Safety Executive (HSE)12 installations, May 1996.

HELA PETEL circular 65/34: Leak detection in tanks Guidance for the design, construction, modification and
and pipework, October 200011. maintenance of petrol filling stations, November 1999.
HELA PETEL circular 65/45: Petrol filling stations Guidance document on risk assessment for the water
surface water drainage Constructed wetlands. environment at operational fuel storage and dispensing
HS(G) 146: Dispensing petrol: Assessing and facilities, December 1999.
controlling the risks of fire and explosion at sites where Guidelines for the design and operation of gasoline
petrol is stored and dispensed as a fuel. vapour emission controls, October 2000.
Guidelines for investigation and remediation of
Institute of Petroleum (IP)13 petroleum retail sites, November 1998.
Code of practice for the investigation and mitigation of Storage and dispensing of LPG as an automotive fuel at
possible petroleum-based land contamination, February petrol filling stations, IP/LPGA Technical
1993. Memorandum No. 70. (Available at www.lpga.co.uk).
Code of safe practice for contractors working on petrol
filling stations, September 1997. Institution of Civil Engineers (ICE)14
Code of safe practice for retailers managing Design and Practice Guide: Contaminated land:
contractors working on petrol filling stations, March Investigation, assessment and remediation.
1999.
Environmental guidelines for petroleum distribution
12
Available from www.hse.gov.uk/spd/content/petel.htm
13
Available from Portland Press Ltd, Commerce Way, Whitehall Industrial Estate, Colchester, CO2 8HP. Tel: +44 (0)1206 796
352, Fax: +44 (0)1206 799 331, email: sales@portlandpress.com
14
Available from The Institution of Civil Engineers, One Great George Street, Westminster, London, SW1P 3AA, Tel +44(0)20
7222 7722, Fax +44 (0)20 7222 7500, www.ice.org.uk
60

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INSTITUTE OF PETROLEUM

GUIDELINES FOR SOIL, GROUNDWATER AND

GUIDELINES FOR SOIL, GROUNDWATER AND

Adobe is a trademark of Adobe Systems Incorporated.

ISBN 0 85293 358 4

Institute of Petroleum, 2002

Contents guide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii

5 Environmental management systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

6 Environmental risk assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

7 Emissions to soil, groundwater and surface water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

8 Detecting loss of product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

10 Management of contaminated sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

11 Contractor accreditation and assessment of capabilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

12 Emergency spill procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Annex A - Model schedule of inspections and tests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Are you familiar with the purpose of this No

Do you have a good understanding of your

Are you familiar with the concept of an No

Are you familiar with the concept of an No

Is there an Environmental Management No

Are you familiar with Environmental Risk No

Is there an Environmental Risk Assessment No

Does the ERA for your site indicate that the

See Section 7.3.1

Does the ERA for your site indicate the risk of

See Section 7.4.1

See Section 6 for ERA review period

Are you familiar with storage tank/pipework No See Section 8.2

Are you familiar with vapour emission No

Are you familiar with the management of No See Section 10

Are you familiar with emergency spill No

Is there an Emergency Spill Response Plan for No

Association of UK Oil Independents (AUKOI)

In countries outside of the UK, sites also operate under practices.

This publication aims to provide: A reference document for minimum standards of

IMPROVED PRACTICES (e.g. segregation,

Figure 1 - Cost effectiveness

It should be recognised that the requirement for

An environmental policy should be developed which environmental performance.

5.1 GENERAL 5.3 PLANNING

Generate Management Commitment

Review the Policy

Carry out a thorough review of all

Assess performance of current

Develop/revise a plan to address ways to reduce or eliminate the highest

Monitor Legislation and Communicate the plan to all

Compare actual performance with Provide training and

Actions in this loop should be ongoing, reviewed at least annually

Figure 2 Environmental management structure

ensure that: weekly, monthly and annual inspections and tests.

Table 1 Pollutant linkages

Source Pathway Receptor

Poorly maintained oil/water separator Surface water sewer Surface watercourse

Figure 3 Pollutant linkage

Table 2 List 1 Substance from EC Directive 80/68/EEC

Infiltration Urban area

Figure 4 Schematic of the water cycle

Possible discharges in runoff to surface watercourses. impervious to the fuel;

7.3 SOURCES OF DISCHARGES - Experience has shown that leaks in underground