Petroleum Measurement Manual
Petroleum Measurement Manual
Petroleum Measurement Manual
This distinction is important, since at times we are not interested just in measuring a quantity or
volume of oil in order to determine an actual amount of duty, but because we want instead to
control the oil as it may later be delivered at a reduced or nil rate of duty, having been either
fully or partially ‘rebated’ or relieved of duty.
Please note, that whilst this section is focused on mineral oils, the principles and guidance on
measurement it contains, may be applied equally to fuel oil substitutes, fuel additives and to
biofuels.
The Energy Institute’s Petroleum Measurement Papers (See HCOTEG171500) apply equally to
these products.
Training
A Guided Learning Unit on ‘Measurements’: Reference 003200 is now available in
Online Learning
A Guided Learning Unit on ‘Health and safety’: Reference 003199 is now available in
Online Learning.
Other guidance
X-99 Oils Duty Assurance
X-99 Biofuels Assurance
HCOTEG170500 - Measurement:
Background
Introduction
It is important to remember that essentially no measurement method can be 100% accurate, and
that the environment in which they are operating can affect the accuracy of all means of
measurement.
To measure oil consistently for duty purposes, the volume must therefore be calculated at a
single temperature.
The volume of the oil to be accounted for at its actual temperature, at the time of measurement, is
known as bulk litres (or as ‘observed’ or ‘measured’ litres).
Principles of measurement
The principle of measuring, laid down in Public Notice 179, is that the trader uses the most
accurate method available to them. If this fails, we may allow a less reliable method to be used;
however the trader cannot then just pick and choose a method to suit themselves, and there must
be safeguards in place to protect the duty and to prevent any revenue loss where the trader
chooses to use an alternative method.
Metering for large oil companies is increasingly linked to computer systems and has a high
degree of automation, removing many of the physical checks that used to be carried out.
However as there are a growing number of bio-diesel and other fuel substitute producers
registering premises for small scale production, the use of physical checks may become
increasingly important.
Note that Section 51 was added by the Hydrocarbon Oil (Amendment) Regulations 1993 SI
1993/2267
Meter accuracy has to checked against a reference meter that meets National Standards
(Public Notice 179, 4.1)
How to deal with ‘standard temperature accounting’ ( Public Notice 179, 4.4)
When measurement to our standards is required ( Public Notice 179, 4.7)
Accuracy standards (Public Notice 179, 4.10)
Errors in equipment (Public Notice 179, 4.12)
An electronic copy of HM39 is held for reference purposes by the Oils UoE Immingham, and a
hardcopy version by the Oils Team (Policy) in Manchester.
HCOTEG171750 - Measurement:
Measurement Instruments Directive (MID)
Introduction
Known as the MID, details of this and the legislation to bring this EU directive into UK law can
be found on the National Weights and Measures Laboratory site at www.nwml.gov.uk.
The MID sets standards for the operation of most measuring devices sold, putting them into
classes of accuracy and laying down the marking and documentation that must accompany any
device, so that the user or anyone else checking knows how it should perform and the
environment it needs in order to be able to operate properly.
Please note however that any meter is part of an overall measuring system – for example, a
positive displacement meter’s revolutions will be within 0.2% of the volume passed through it,
but after an adjustment for temperature affecting density, the reading will be still within 0.3%.
(Please also note, that whilst Public Notice 179 states that all meters will need to perform within
an accuracy MPE of +/- 0.15%, which is what we would expect to see evidenced on any
calibration/proving reports for the meter under test, MID has set new standards to replace these
current values, for all equipment installed after October 2006).
The MID requires that (a) any measuring system is robust in the conditions within which it is
expected to operate ( that is it must be fit for the purposes it is being used for ) and (b) that the
conditions under which a meter is designed to operate are easily verifiable.
Not all of the MID is being put into UK Law, for instance Automatic (tank) Level Gauges,
(ALGs) are not covered, and whilst measures of length are covered, it is unlikely that this will
apply to dipping/ullaging rods and tapes
N.B. We no longer approve meters or ALGs before they are put into service. Instead we now
require that all meters or ALGs meet pre-determined levels of accuracy.
Main hazards
Oil has obvious hazardous properties, such as its ‘slippiness’ and other less obvious ones,
such as the lead additives which are still added to some fuels and which are carcinogenic.
Crude oil gives off flammable vapours which in certain circumstances can be highly
explosive. This is especially the case with ‘petrol’ or gasoline vapours which are highly
volatile.
Ladders up tanks for our inspection should go round the tank and have railings as
opposed to going vertically up the side.
Floating roofs on tanks should NEVER be stepped on.
The Energy Institute have issued the Vapour Recovery Hazards Bulletin in 2002, which made
specific recommendations relating to road tanker loading and which should have been fully
adopted by now following a series of incidents. At some point in the vapour recovery process,
the vapour is under pressure and potentially explosive. Vapour pressure can also build up in
pipes that are attached and detached.
(For further information on Vapour Recovery and its measurement please see HCOTEG178000)
For further information on Health and Safety, see HCOTEG11000 in the ‘Introduction and
overview of oils activity’ section of this guidance.
Given that a large number of meters either record or transmit (or both) their readings, placing
meters or their transmission wires near electrical equipment or high voltages can give false
results by introducing induced currents and false pulses. Meters with pulse transmitters should
have adequate protection for data transmission to levels A or B security as defined in the
Petroleum Measurement Manual Part XIII, Section 1 (IP 252/76).
Any bolts and screws giving access to the workings of a meter should be sealed with wire
passed through holes in bolts and sealed with a crimped on lead seal (a trader’s own seal).
There may be alternatively a system which automatically detects interference with the
meter, such that any attempts of unauthorised access to the meter will cause a system
alarm and stop any product flow.
Any tools to open and or to adjust meters should be kept under controlled access by the
trader.
Wires, computers and computer terminals and printers contributing to readings taken for
revenue accounting purposes must be free from either deliberate or inadvertent
interference.
For powered equipment, there must be adequate warning of power failure and back-up
systems in place to take readings, where a power failure occurs.
Where there is a power failure the system must retain the reading that last passed through
it for later recovery.
Computer or powered equipment must not be capable of being switched off
independently.
In practice:
You can agree with the trader if you think it impractical or unreasonable to use STA for
a. Road fuels and aviation gasoline for amounts of less than 4,000 litres
b. Other oil not for use as road fuel for amounts less than 80,000 litres
You would need to measure the temperature of oil in the tank (this is not easy or
straightforward manually as oil can form different layers of temperatures). Dips would
need to be taken at intervals over the height of the product in the tank and then averaged.
The guidance to the trade provided in HM39 should be followed. The trader needs to
have this and the equipment specified.
Density will be the density for the product to be accounted for. Conversion tables should
be used to look up the temperature corrections required (the trader should have these).
For further information on the Standard temperature accounting calculations, please refer to
Public Notice 179, paragraphs 4.4 and 4.6, and to HM38 ‘User Guidelines for Standard
Temperature Accounting’ which is published by the Energy Institute.
See Public Notice 179, Section 1H for further information on Standard Temperature Accounting
for excise duty purposes.
Introduction
This Section is intended as an introduction to the types of volumetric meters and their methods of
operation. We do not approve particular types of meter but do state the standards they must meet
in Public Notice 179.
Positive Displacement meters (PD) are the meters commonly used in the oil industry and are
incorporated in the product line. The interior of the meter bowl is divided into calibrated
measuring chambers by a number of blades. As product flows and enters the inlet section it
occupies each chamber and causes the blades to rotate. As each chamber passes the outlet section
of the meter bowl it is emptied into the delivery line. Either the rotating central spindle or the
rotor is linked to a drive shaft which is connected at the other end through gearing to the meter
register.
The drive shaft may be very short, with the register bolted directly to the meter bowl, or it may
be several feet in length if the register is situated on the platform of the loading gantry.
A PD meter uses energy derived from the moving oil it is measuring, not only to drive its own
mechanism but also those of any ancillary equipment fitted to it. The moving parts are subject to
friction, so any addition, removal or replacement of ancillary equipment may affect meter
accuracy. It is normal for the meter manufacturer to specify a range of rates of flow within which
compensation for the effects of friction and inertia has been made in the design of a meter.
Reliable measurements are only possible if there are no sudden fluctuations. A flow regulator is
often included in the pipeline upstream of the meter to prevent surges or excessive variations of
flow rates.
The rate of product flow governs the frequency of rotation of the blades and drive shaft, and this
is transmitted to the register by means of a variable gear mechanism, known as the calibrator.
The calibrator should never be altered other than during meter proving. Since the viscosity of the
oil being measured influences the inertia effect of the mechanism of a meter, a meter is
calibrated to measure oil of a limited viscosity range. The meter would be inaccurate for products
outside that range without re-calibration.
For further information on the most common types of meters and what affect them see
HCOTEG174280
Inferential meters
Inferential meters are designed to deduce the volume of oil passing through a pipeline by
measuring some physical characteristic such as speed of flow. There are several basic types of
inferential meters, including turbine meters, orifice plates, vortex-velocity and vortex- shedding
meters.
Turbine meters
Turbine meters are commonly used for raising revenue accounts. They are used mainly in long
distance pipelines (including receipts of crude oil from North Sea platforms) and the loading of
ships.
Turbine meters measure the rate of flow of oil in a pipeline and relate it to the pipeline diameter
to give a read out in terms of the desired units of volume.
They are virtually unaffected by friction and inertia, having no mechanical parts other than a
free-moving turbine with magnetic-tipped vanes. The meter should, in theory, be accurate over a
wide range of flow rates. The turbine is rotated by the oil as it passes through a metering
chamber made of non-magnetic material inserted in the pipeline and is mounted on special
bearings so that its axis of rotation is coincident with the axis of the pipeline. It is constructed so
that the pressure of the oil against it counteracts the thrust on its bearings, thus reducing friction
and inertia to negligible proportions.
Rotation of the turbine is detected by one or more sensing heads fitted to the metering chamber.
Meters may also be encountered on which sensing is by means of a photo-electric cell mounted
over a window in the metering chamber and activated by light reflected from a tiny mirror
incorporated in the turbine. In either case the sensing head generates and sends pulse to an
electronic computer which counts them and applies a pre-set factor (determined during proving
of the meter). A digital display registers the volume of oil which has passed through the metering
chamber.
An orifice plate meter measures the pressure differential caused by the presence in a pipeline of
a plate with a hole in it which restricts the diameter of the pipeline. It is sufficiently accurate for
revenue accounting.
In the vortex-velocity meter, a vortex develops in a cylindrical chamber off set in the side of the
meter tube carrying the main flow stream. There is a direct relationship between the number of
revolutions of the vortex and the volume of the main flow. The volume flowing through the
meter is recorded by counting the revolutions of a rotor mounted within the vortex chamber.
Connection between the rotor and the revolution counter is by magnetic or electronic means.
Vortex-shedding meters
A vortex-shedding meter measures the number of vortices created and shed per second around
a specially designed obstruction in the pipeline. Pulse signals are generated at a frequency
proportional to the flow rate.
For further information on the most common types of meters and what affect them see
HCOTEG174280
Note* The trade recommends that flow computers should only be used where you cannot depend
upon the accuracy of the meter alone.
This is because of the extra complexity flow computers add to the calculations involved in
measurements, and their potential for unintended and undetected errors which can affect the
accuracy of the measurement.
Turbulence caused by bends in pipe work before the meter – this can affect all types of
meter – indeed, some types of meter work by measuring turbulence caused by a fixed
obstruction – so that any additional turbulence will make the meter inaccurate.
Bubbles – anything that allows air or gas into the pipe could again cause most meters to
be inaccurate, by changing the volume.
Viscosity of the fluid – may be illustrated by the difference in viscosities between
lubricating oil and white spirit. Thicker lubricating oil has to be heated to thin it and then
pumped and stored in heated or insulated pipes and tanks. Thinner white spirit has 2
adverse effects: it has no lubricating properties to protect the meter through which it is
flowing, and its ‘thinness’ means that the meter has to maintain a very tight seal where
there are moving parts – accordingly they tend to wear out quickly.
Type of flow meter and What the meter Main usage and Weaknesses
description measures strengths
Positive displacement – Volume – this is in Accurate at low flow Needs clean fluids. If
there are various types fact the only meter rates – used for fluid (such as white spirit)
involving gears, ovals that is purely tanker loading has no lubricating
and screws – effectively volumetric – its gantries. properties the meter will
they are like a pump action is solely wear out quickly.
working in reverse – a dependent upon the Viscous fluids will find it
fixed volume is trapped volume of liquid that difficult to push through
in a chamber of the passes through the the meter.
meter whilst it rotates. meter. Compensations for
temperature have to be
made.
On loading gantries for road tankers that deliver to the customer - filling stations etc.
On jetties for coastal tankers
On pipe-lines direct to customers from refineries such as airports
On cross country pipe-lines
On rail loading gantries
A meter will operate within the maximum permitted errors of its designed class of
accuracy or it will be withdrawn.
‘Every measurement system shall be so positioned as to facilitate testing.’
If it needs it, a measurement system will be marked with the temperature range it must
work within, and similarly with a flow rate range.
Where a measuring system is marked for use for a particular purpose or manner of use, it
must be used in that way.
Static proving tanks – a very finely calibrated tank that is connected to meters where the
discharge from the tank is compared to the meter reading; or where the meter reading is
compared instead to receipt into the tank.
Mobile proving tanks – as above but of lesser capacity such as 1,500 litres. It needs to
be jacked up and levelled before use. However, the tanks used must be ones which have
been specifically designed for this purpose.
Reference meters – are high grade meters that are connected in line with the meter to be
tested and the results compared. The reference meters themselves need to be proved.
Corrections need to be made where the pressure goes over 1.5 bars (27 p.s.i.) against an
authenticated correction graph produced at the proving of the reference meter. The
reference meter must not be used to prove meters at flow rates that the reference meter
itself has not been tested at.
Prover loops – a loop in the pipe work that allows the flow to be diverted through a
proving meter or device rather than the working meter.
Pipe provers – often work in specially designed prover loops that accommodate a sphere
that is started and sensed at a stop point electronically and travels with the flow so that a
precisely known amount of oil travelling through the pipe travels through the meter and
results are compared. Instead of a sphere, sometimes a piston is used and this process can
be run backwards so that the same precisely known amount of fluid can be pushed
through in the same direction twice.
It is recommended that meters are tested or ‘proved’ on installation and then at 3 months and 6
months. If these results are satisfactory routine proving may be carried out at six-monthly
intervals.
Proving is often carried out by subcontractors who will provide the trader with a certificate, but it
is the trader who remains responsible for the accuracy of their meters. This is also true, even
where the trader sub-contracts out the metering as well, as can be the case for loading gantries.
Failing meters should be taken out of use immediately. If a replacement meter is not
The tank may be sited near the meters to be tested and connected with the pipeline system to
enable tests to be carried out without the meter. At large installations, however the excessive
length of pipeline connections to the tank might necessitate removal of meters to a separate
proving station. This would not reproduce the normal operating conditions of the meter and
would not therefore be acceptable for proving meters to be used for raising revenue accounts.
Reference meters
A reference meter, sometimes called a “master” meter, is normally a high-grade instrument of a
type similar to the meters which it is to test. It is installed ‘in series’ (as opposed to “in parallel”)
with the meter to be tested and the readings of the two meters are compared. It may be mounted
on a wheeled bogey and equipped with controls to form a mobile test rig.
When a meter is proved using a product, temperature and/or flow rate different from those used
to calibrate the reference meter, the appropriate corrections obtained from the reference meter
correction graph are to be applied to the reference readings. A correction is also necessary when
the difference between the pressures exceeds 1.5 bars(27 p.s.i.). The correction graph must have
been dated and authenticated at the time of the last proving of the reference meter.
A reference meter must not be used to prove meters which operate at a higher rate of flow than
that at which it has been tested.
Being a mechanical device, the reference meter may develop faults which are not immediately
apparent and it may be damaged during handling or transit. Proving by reference meter is,
however widely practised and is probably the most convenient method for most oils installations.
Unidirectional provers
“ Unidirectional” provers have the calibrated section of pipe in the form of a loop to facilitate
the installation of a device for the launching and recovery of a rubber or plastic liquid-filled
sphere. Solid spheres are sometimes used with the smaller provers.
The launcher is operated by electrical means from a control near the meter read-out indicator.
When a test is conducted, a sphere which completely fills the cross-section of the pipe is
launched into it and is carried along at the same speed as the oil. The sphere is detected as it
enters the calibrated section or “loop” and this starts a counting device incorporated in a
computer or similar ancillary equipment. As the sphere leaves the calibrated section it is detected
again, causing the count to cease. The sphere is recovered mechanically and returned to the
launching position.
The reading of the counting device showing the pulses generated by the meter during the passage
of the sphere through the calibrated section can then be related to the known content of that
section, corrected if necessary for temperature and pressure. The number of pulses generated for
the corrected volume is then used to determine the pulse/unit volume factor, which is applied to
produce the unit of measurement for the quantity register.
Bi-directional provers
“ Bi-directional” provers may have a straight calibrated section of pipe or they may be in the
form of a loop. They incorporate either a sphere or a piston which, after passing through the
calibrated section is reversed by the operation of valves to pass back through the calibrated
section to its original starting position. The proving run consists of the ‘round trip’ of the two
movements through the calibrated section.
Pipe provers test meters under working conditions without interference with the operation in
progress. They are particularly suitable for testing meters controlling cross-country pipelines or
long jetty lines.
Duty accounting measurement is now more often done instead by flow meters at the point of
loading to leave the premises.
a. Deadwood – anything that protrudes into a tank (a brace or reinforcing strut) which
takes up volume that would otherwise be measured as oil.
b. Water bottom – is the water in a tank on top of which oil floats. As water falls to
the bottom of the tank, a measurement made by ‘ullaging’, might not detect the
water bottom, which could then be assumed to be oil.
c. Floating roofs – the roof on top of large refinery tanks can literally be floating and
move up and down with the level of oil in the tank. They usually have bottom stops
Deadwood – the term for anything that sticks out into the inside of a tank, such as bracing, that
changes the volume of the tank – this is hidden from view and might only occur at a particular
height. This should be accounted for by having a tank calibration table that converts the height of
any measurement of liquid into the volume left in the tank.
Floating roofs – the weight of the roof displaces the oil on which it floats, but below a certain
level there will be stops to stop the roof sinking further. Consequently, at a certain point the
floating roof stops displacing the oil on which it is floating and affecting the volume calculation.
Temperature – because density decreases with temperature and the same amount of oil will take
up less space (volume) the colder it is, then the temperature of the oil needs to be known. ALGs
usually measure temperature as well as the height of any liquid in a tank.
For small storage tanks properly calibrated sight glasses (a clear tube up the side of the tank that
looks like a large thermometer) are acceptable.
a. Loading by volumetric meter (the use of meters is mandatory for road tankers loading all
light oils, derv, kerosene and gas oil from duty suspended installations).
b. Automatic loading gauges (a probe that ‘dips’ into the tank).
c. ‘Dipping’ and ‘ullaging’ (are no longer possible and not considered safe on most road
tankers).
d. Weighbridge.
Ship transport
The preferred measuring method is a volumetric meter. (Short sea shipping is the most cost
efficient method for large amounts outside of a pipeline). It is possible to dip (and ullage where
the tank is constructed to allow this) ships’ tanks but they present special problems that render
them generally inaccurate:
Accordingly, although a ship’s tanks will have appropriate calibration tables, using ‘dips’ or
‘ullages’ requires extreme care and their routine use as an alternative to metering (except in an
emergency) should be questioned and invite audit.
Whilst we prefer Automatic Tank Gauges to dipping and ullaging, ALGs are often relegated to
stock control rather being used for revenue accounting, where meters are now more commonly
used. We prefer ALGs to automatically measure and compensate for temperature.
Mechanical ALGs have a float attached to a wire that runs over a pulley and is kept taught by a
counter weight. ALGs can not only measure and compensate for the temperature of the oil, but
also the affects of oil temperature on the gauge itself. However, there are a range of other ALG
technologies that involve probes with non-moving parts. They can be connected up to software
that continuously monitors the ALG at the same time it monitors pumps and flow- meters, so
detecting leaks or other problems.
ALGs can be fitted to all types of tanks including floating roof tanks and fixed in the tank top,
bottom or indeed side.
Most tank gauges now in use in the UK are based on the same principle but progress in their
design and in the techniques of installation has brought about a continuing improvement in
accuracy and reliability. Some of the features which have brought about this improvement are as
follows:
Compensatory systems are incorporated to maintain the measuring tape under constant
tension and to correct its length for ambient temperature changes.
The apparatus is mounted so as to avoid deflections arising from distortion of the tank
sides or bottom caused by the weight of oil or bending of the roof due to vapour pressure
or persons moving on it. The gauge may be rigidly fixed to the bottom or to the top of the
tank.
Friction is as far as possible eliminated. Servo systems may be employed to provide
power to the liquid level detector, and may cause the detector to “hunt” up and down for
short distances around the surface level. In gauges which do not hunt, a device may be
incorporated which allows an operator to raise or lower the detector to check that it
returns to the same level.
The liquid detector may either:
displace a constant volume, irrespective of the temperature and density of the oil; or
ride in a vertical perforated tube and settle by electrostatic equilibrium at a pre-
determined height above (usually 1mm) or depth below (usually 2mm) the liquid
surface. The principle used to detect the oil-air interface can be used to detect an oil
water interface and so provide a dip of water bottoms in tanks. (This is rarely used in
practice).
“Damping” arrangements are sometimes used to smooth out ripples on the liquid surface
and give a steady reading at the mean level. Such arrangements can deal effectively with
ripples up to about 25mm in amplitude but are only partially effective with surface waves
having periods of oscillation exceeding 2 or 3 seconds.
ALGs fitted to ships tanks are in general similar to those installed in shore tanks. They have to
withstand more mechanical stress and higher corrosion and usually achieve lower accuracies.
Electronic gauges. The liquid level in wholly electrical gauges is determined by its effect
on the resistance or capacity of electrical circuits.
Ultrasonic devices. The depth is determined from the time taken by high frequency
sound waves to pass through the liquid.
HCOTEG176000 – Measurement:
Hydrostatic gauges including manometers
Hydrostatic gauges including manometers
The pressure at any given point in a liquid is proportional to the density and height of the liquid
above that point. The reading given by a pressure gauge showing the pressure at a fixed point
near the bottom of the tank may therefore be used to determine:
By assuming average densities or areas, gauges can be calibrated to read in dips or units or
weight. These devices are seldom sufficiently accurate for revenue accounting, but may be used
for spot checks on quantities.
HCOTEG176250 - Measurement:
Densitometers
Densitometers are most commonly required to indicate a change in density of the oil passing
through a pipeline, for example at an interface. Normally they are not used to measure density to
a high degree of precision.
“Balanced flow” type. A sample of the liquid flows through a fixed volume chamber
where it is weighed or compared with a predetermined weight.
“Displacer” type. A float or plummet is immersed in the liquid and the density of the
liquid determined from the effect on its buoyancy.
“Gamma-ray” type. A source of gamma radiation and a radiation detector are mounted
to measure the degree to which the radiation is absorbed by the liquid. Absorption
depends upon the density of the liquid.
“Vibrating” type. Mechanical energy, usually produced by electromagnetic apparatus is
used to set up vibrations in the liquid. The density, or change in the density, of a liquid
can be determined from the amplitude or frequency of the vibrations which vary with the
density of the liquid.
HCOTEG176500 - Measurement:
Telemetering
Electrical systems are normally used for transmitting the readings of automatic tank level gauges
and related equipment to remote points. Since the voltage and the current can be affected by
external disturbances, direct current measurement is used only if adequate safeguards can be
applied. (IP 252/76 provides for appropriate standards at different levels of specified security).
Most telemetering systems depend on the number of (or the time interval between) electrical
pulses generated mechanically or electrically. Spurious pulses may be produced by external
electrical interference, caused for example by the close proximity of the transmission lines to
power cables or telephone lines. Safeguards are required to prevent the transmission of spurious
pulses and to ensure that the amplitude of pulses arriving at the remote point is adequate for
accurate reading.
The fixings of the meter and all equipment that is used to adjust and maintain the meter and the
read-out system also need to be controlled effectively by the trader in order to stop fraudulent
interference.
Warehouse-keepers should have a control system in place that regularly (usually monthly)
compares the ALG to a manual dip/ullage. Any differences outside of the agreed tolerance
(currently +/- 8 mm) should be investigated and corrective action taken.
Please note that all new equipment installed after October 2006 should meet the new accuracy
tolerance of +/- 5mm when compared to the results of manual dipping.
1. The tank must be constructed so that the height from the top of the liquid to the ullaging
point (marked at the top of the tank) can be converted to the volume of liquid within the
tank, by using a calibration table compiled specifically for each tank, i.e. the tank must be
designed and built specifically in order to allow ullaging.
2. The ullaging rod should be graduated in 2mm gradations.
They could however, be checked by a weighbridge if flow meters failed and traders have asked
our permission. The wagon should be weighed both before and after loading with attention paid
to ensuring nothing is added or taken away that could affect the weight ( like the delivery driver
or a passenger ). It is also necessary to ensure that the road tanker is fully on the weighbridge. It
is possible for the weighbridge to be fitted with sensors that alarm if the wagon is not correctly
positioned
The trader, or his representative, who does the dipping must keep the tape or rod steady and it
must not swing or the reading will be affected. If water paste is used the tape, which will have a
weight attached to the bottom of it, must be held in place long enough to react – a minute in fuel
oil. The weighted tape must of course be held steadily against the dipping point marked on the
tank.
These need to be available for every tank used for holding oil on which potential revenue is to be
assessed whilst the oil is in the tank. They must use metric measures and show the volume in
litres for each height in no less than 2mm intervals. If the calibration was done at greater
intervals than 2mm, a supplementary table should be provided saying what the volume is
calculated to be at the 2mm intervals between the readings.
Like the tank calibration table, the dip tape or rod should also be marked in no less than 2mm
gradations. A dip tape must not vary over its length by 8mm (this is to be reduced to the new
standard of 5mm).
Weights are attached to the bottom of dip tapes (due to viscosity); the heavier the oil to be
measured then the heavier the weight to be used.
Water pastes
When applied to the bottom of the tape or rod, it changes colour. The tape or rod needs to be left
in place for up to 2 minutes in order for the colour change to take place. The volume of water
(water bottom) by reference to the tank calibration table needs to be deducted from the overall
dip volume calculation in order to accurately determine the remaining volume of oil in the tank.
This will normally be a fixed plate at the top of the tank (at the dipping point) which provides a
reference height.
Large cylindrical tanks should have a diagonally ascending railed in stairway around the side as
opposed to a vertical ladder if it is to be used for revenue accounting purposes and thus available
for inspection by our officers. Vertical ladders up the side of smaller and squared construction
tanks should have caged-in ladders. There should be a suitable guard rail around the top of the
tank.
HCOTEG177750 - Measurement:
Weighbridges
Introduction
The MID has a section dedicated to Rail Weighbridges: The Measuring Instruments (Automatic
Rail-weighbridges) Regulations 2006. However, there is no such section for road weighbridges.
There are legal requirements for public weighbridges that do not apply to private ones. After
checking on installation, the Trading Standards Officer (TSO) will check (reprove) the
weighbridge every six months and give it a stamp. This stamp will be obliterated by the TSO if it
fails a test, but will be reinstated if it passes. Any weighbridge certified by the TSO is acceptable
to us.
As above, the TSO will stamp the weighbridge on installation. However, from then on it is up to
the trade to have the weighbridge re-proved – the TSO will not test the weighbridge as a matter
of course and obliterate the stamp if it is found inaccurate. The weighbridge is only acceptable
therefore if it has been reproved at least annually.
Rail weighbridges
Like road tankers, the initial loading is at low flow rates to stop foaming and turbulence that
might cause either static or an electrical spark. Loading is then completed at a higher rate. Where
a printout is given for the Rail tank wagon it must give the weight of the wagon and its load.
Rail tanks, where checked manually are usually ullaged rather than dipped. However, if
automatic equipment fails we may give permission for a rail weighbridge to be used. If this is the
case wagons need to be weighed on a certified weighbridge separately, by being uncoupled, both
before and after loading.
Submission of claims
Reclaim of duty should be made monthly as a credit against the total duty shown on Form HO10.
A rough estimate of the amount of motor spirit expected to be recovered is one litre per 1,000
litres loaded, and for a 1,000 litres of distillates the recovery of liquid is about a quarter to a third
of a litre.
Because the amounts recovered are small and many units work by adding the vapour back into a
stream of product, it is often not considered possible or practicable to measure the recovered fuel
with meters. Accordingly we have a complex formula to work out the amount of duty that can be
reclaimed. Vapour recovery claims and this formula are under review by the Oils Team (Policy).
The current formula is said by one oil firm to result in errors costing it £580,000 a year – but this
is for all its operations and before vapour recovery, vapour was merely lost to the air. Claims
only began in 1999.
(Any amendment to this Formula will be publicised and reflected in amendments to this section
of the guidance in due course).
See HCOTEG178050
The percentage of efficiency is the difference between the vapour returned to the VRU less the
vapour emitted by the VRU; the formulae for calculating these factors are given in the EI
guidelines (Section 4.4). The performance factor has to meet exacting standards. UK legislation
requires a tri-annual compliance test which is monitored by the appropriate environmental
agency. The EI trade guidance requires the copy of the testing agency’s report to be made
available to Customs.
The VRU may not be always available due to breakdown or servicing. For the effect on the
operation of the formula see the EI Guidance Section 3.3.
To establish the percentage of hydrocarbons in the recovered vapour the warehousekeeper will
need to analyse samples drawn quarterly from the vapour line during the loading of RTW’s.
The percentage of oxygen is determined by an oxygen meter with a paramagnetic cell. As air
normally contains 20.9% of oxygen, readings of less than that are caused by the presence of total
organic compounds (TOCs).
Readings are taken manually every 30 seconds during the loading of the RTW and an average
reading for the vapour recorded.
If the final average for the RTW is 15.9% of oxygen, a value for the percentage of hydrocarbons
recovered can be determined, using the following:
Testing RTWs over 2 x 8-hour periods, i.e. an AM and PM, should give a mean value for the
percentage of vapour returned.
The test is repeated for the distillate (DERV) loading racks if the installation’s practise is to use
the same RTW’s for both motor spirit and distillate. Although distillates give off little in the way
of Volatile Organic Compounds (VOCs) an RTW may load DERV into a compartment
previously carrying motor spirit.
A rough estimate of the amount of motor spirit expected to be recovered is one litre per 1,000
litres loaded, and for a 1,000 litres of distillates the recovery of liquid is about a quarter to a third
of a litre.
A millimetre on a small tank will be equal to 30 to 40 RTWs of motor spirit vapour. Additionally
the loading tank may also be the tank used for deliveries and receipts from the absorber column.
Considering that the automatic tank gauge (ATG) or the automatic level gauge (ALG) accuracy
requirement is 8 mm this is a fair number of RTWs. Taking all the above into consideration, bulk
storage tank measurements are not accurate. The EI guidance gives detailed advice to the
operator in Section 4.
The EI guidance (see Section 4.3.5 and Annex 3) also gives methods of drawing and testing
samples of vapour for molecular weight and density which are performed in a laboratory by gas
chromatography. The test will also establish the components that make up the sample (typically
the various butanes, propanes and pentanes make up 70% or more of the vapour).
This will include distillate where the installation’s practice is to use the same compartments.
Only the motor spirit grades are included with the purpose of apportioning the different rates of
duty charged.
See HCOTEG178040
The fundamental principals of stock and revenue accounting are no different to computer
systems in other duty suspension regimes in that the systems hold details of products, stocks,
storage locations and movement transactions.
By retaining receipt and delivery transactions the systems can report stock balances and
summarise movements by type, by product etc. However “oil” systems have added complexity in
that:
From HMRC’s view, a unique feature of the oil industry is the use of on-line computer systems
to establish transaction volumes.
These systems with little or no operator intervention continuously monitor volume, temperature,
pressure and density measurement devices, control the positions of valves and the speeds of
pumps.
recognise products and their attributes such as heavy / light oil, tax code, regime status
maintain an accurate date & time to establish the applicable duty rate and accounting
date;
record details of physical stock locations, a record of transactions for that location and the
duty status of those movements; (as below)
Duty-status Duty-status
From: Un-taxed to: Un- taxed
From: Un-taxed to: Tax Paid
From: Tax Paid to: Tax Paid
From: Tax Paid to: Un-taxed
The information which can be requested from the flow computer will include:-
1. totaliser readings;
2. current values of temperature, density, pressure, volume correction factor, gross &
natural flow rate;
3. alarms;
4. constants used in calculations; and
5. standard operating range parameters, e.g. minimum & maximum temperatures, minimum
& maximum flow rates.
The flow computer can also be passed the information at 4 & 5 above.
Scope of guidance
The following is not intended as a definitive guide to all flow computers but instead as a general
guidance on their technical functions and possible controls.
Introduction
It is now the norm for volumetric conversions to be performed by a computer. Volume X of the
Petroleum Measurement Tables is dedicated to the computer procedures involved in the
conversion of volumes to volumes at 15ºC.
The volume correction factor to be applied to a volume of product at a known temperature is:
If the observed product density is supplied by an in-line densitometer and the product density at
15ºC is supplied by analysis then the STA volume correction is a simple matter.
When, as is normal with refinery production, the product density at 15ºC varies the calculation of
volumes at 15ºC becomes a complex mathematical equation.
Where there is a significant number of transactions then the use of a computer system to perform
the calculations can be expected.
The complexity of the calculations is brought about because the only available equation to
calculate the density of a product at a specified temperature requires the density of the product at
15ºC and it cannot be mathematically “reversed” to give a density at 15ºC if the density at the
observed temperature is provided.
Iteration
A “guess” is made as to the density at 15ºC (normally the measured density) and the equation
calculates a density at the observed temperature which is then compared to the known density.
The difference in the calculated and the known densities enables an improved estimate of density
at 15ºC to be made and the calculation repeated. The process is repeated until an acceptable
difference between the known and calculated densities is achieved and the last estimated density
is accepted as the density at 15ºC.
The conversion equations are referenced in Volumes IX and X of the Petroleum Measurement
Tables. Products which fall in the Jet / Gasoline Transition block are exceptional in that they use
a different equation in the conversion calculation.
The flow computer can be expected to perform the following calculations on the raw data to
achieve accurate results:
correction for the effects of pressure and temperature on the liquid at the prover and at the
meter under test;
correction for the effects of pressure and temperature on the prover and of the meter
under test; and
the flow computer will repeat prover runs until consistent data is achieved or the number
of runs exceeds a defined limit.
The flow computer calculates and reports the flowrate (m3/h) to ensure that the meter under test
is calibrated to the correct flowrate. For each run the flow computer will report the calculated K
factor and the percentage deviation of the factor from the average of the proving so far.
The K Factor is the relationship between the rotation of the turbine in the meter (measured in
pulses generated by the meter rotor) and the known volume of product flowing through it.
For Example: To ensure correct results, the flow computer would continuously monitor the inlet
Each proving operation should produce a report detailing each prover run reporting the constants
used, the recommended K factor, the product density, the stream pressure, temperature & flow
rate, the calculated K factor and the K factor deviation percentage.
www.flowmeterdirectory.com/flowmeter_for_beginner.html
Introduction
SCADA is not the name of a computer software package but a term applied to a system which
collects data and uses it for monitoring, simple control and trend analysis. Acquired data can be
passed to other systems. SCADA systems are employed throughout the oil industry but in
relation to departmental interests they are principally encountered controlling loading gantries
and cross country pipelines.
computer monitors displaying schematic diagrams of the pipeline and the position of valves and
the readings from pipeline sensors;
the ability of operators to operate valves & pumps remotely;
software modelling the pipeline to predict the arrival of interfaces, tracking the parcels in the
pipeline and detecting leaks & estimating the location;
automatic control of valves and pumps for operational and safety purposes; and
controlling and monitoring gas oil marker injection.
A SCADA system may have no completeness controls and retain no record of a completed
movement. The point at which meter tickets are produced and the controls over sequential
numbering must be established. The primary control over completeness is the daily
reconciliation of stock balances to reported movements.
The system may be configured so that a feeder valve is linked to a product and as such the
opening of the specified valve causes the system to assume, for example, unmarked gas oil is
being moved. The contents of source tanks may not be under the control or ownership of
SCADA system operator and the potential exists for changes of product storage tanks not to be
notified to the operator.
Meters may be remote from the operator site and the risks of interference and fallback
procedures in the event of meter or meter transmission failure should be evaluated.
The STA conversions can be expected to be performed within the system. The sources of the
required data (detailed in the section on flow computers above) should be established and the
accuracy evaluated.
Introduction
Road and rail loading systems are SCADA systems whose function is to manage product
deliveries. The revenue risks are considered to be:
Controls should be identified to control these risks and it may be found that the key controls do
not exist within the SCADA system but within systems providing and receiving information
from the SCADA system.
The loading system may have no integration with other systems with all information being
transferred on paper. This can be expected with rail loading systems where the number of
transactions is small.
Data concerning processes, storage plant and the connections between processes and plants is
defined.
The balance is produced by a computer system which models a refinery’s plant and production
processes. Each item of refinery plant which stores, receives and delivers product is defined. The
system is provided with details of every movement in the specified period and by reference to the
definitions a balance for each process and storage location can be established.
No refinery will produce a mass balance which has no losses or gains. The principal
discrepancies will arise through the tolerances in measurement devices. With the measurement
tolerances of each storage tank and meter defined the system, having identified a discrepancy,
will attempt to remove the discrepancy by attributing the loss to measurement tolerances and
correct the amounts moved.
Introduction
The fundamental feature of any duty calculation and reporting system will be the use of master
files to ensure the correct duty accounting. The master files will hold information concerning:
It is therefore essential that the contents of the master files are correct and that any changes to
these files can be identified and checked.
For example: the requirement for official sampling in duty-suspended premises and at RMPs was
previously withdrawn. Oils assurance officers should now seek similar assurance from the
warehousekeeper/operator owned on-site laboratory, either by an officer witnessing a test in
such a laboratory or from scrutiny of any quality assurance testing record maintained by the
trader.
Note: Nothing in this table constrains the need for taking oil samples as evidence to support
possible offence cases. Oils assurance officers should comply with Schedule 5 of HODA when
taking samples and any analyst used in lieu of the LGC must be “authorised” as defined in
paragraph 5 of that Schedule.
Warning
Attention is drawn to guidance in the HS series and particularly to volume HS-10 Hazardous
Substances, which requires that prior authority of HQ be sought before certain Category “A”
goods are sampled.
Samples are normally to be taken in duplicate and put into 250 ml tins. One sample is to be
forwarded to the LGC.
The owner or person in charge of the vehicle, or the occupier of the premises, as the case may be,
must be present or have been given the opportunity to be present when the sample is drawn.
Instruments and containers used in taking the samples must be clean. The officer is to draw a
quantity sufficient to fill three 250 ml sampling tins. These must be labelled and secured by wire
and plomb immediately.
A choice of one of the labelled tins is to be offered to the owner or person in charge of the
vehicle or the occupier of the premises for retention. If not present a written notification is to be
sent stating that a sample is available for collection if required.
One of the remaining samples is to be forwarded to the LGC. The test note is to be clearly
marked in red “Suspect” together with a reference to the appropriate part and paragraph of the
instructions and the plumbing iron number. On receipt of the samples the LGC will examine the
wire and plomb and certify their condition on the test note.
Duplicate samples
The duplicates of samples forwarded to the LGC are to be kept under lock in official custody. If
the samples are of light petroleum oil and likely to exceed 10 litres at any one time they must be
stored on premises for which a petroleum spirit licence has been granted under the Petroleum
(Consolidation) Act 1928 or the Petroleum (Consolidation) Act (Northern Ireland) 1929.
Period of retention
Routine duplicate samples are to be retained only until the result of the test is received. Samples
taken when an offence is suspected are to be retained until directions for their disposal are
received.
Disposal
In the absence of any other instructions, duplicate samples due for disposal are to be returned to
the trader. If the trader refuses to accept them, the Officer is to ensure that the samples are
destroyed in accordance with the Control of Pollution Act 1974. Disposal by pouring down the
common sewer is strictly prohibited. If an Officer has any doubts with or difficulties about a
proposed method of disposal, contact is to be made with the local waste disposal authority to
make appropriate arrangements.
After filling, each tin must be wired and plumbed through the lugs on the body and the top of the
tin. Sealing wax must not be used for sealing such tins.
All tins must be labelled with the special reinforced labels Form HO69 which are to be attached
by the wire securing the tin.
Samples of all light oils suspected to be such are to be conspicuously labelled on the external
package “Petroleum Spirit”, Highly Flammable, H.M. Revenue & Customs.
Samples of oil other than “dangerous goods” may be forwarded by the cheapest means. They
should not be marked “Flammable”.
For samples of Gas Oil or Kerosene to check for colour marker, commercial dye or other
additive, the test note is to be in duplicate and must relate only to one sample. The duplicate copy
will enable the LGC to advise the despatching Officer of the result of the test, as the LGC retains
the original test note.
On receipt of a test note or sample marked “URGENT” the LGC will contact the Officer if the
associated sample or test note has not been received within 2 or 3 days.
Public Notices
Customs Series
Excise Series
VAT Series
General
The following GLUs on Oils are either available now, or will be made available shortly in
Online Learning
2. Means of disposal
Destruction, provided that the oil is not burnt to produce useful heat. In any case where there is
a duty liability (i.e. other than TTC 551 and 570) duty is to be charged before removal to the
furnace operator.
Removal to oil recoverers and launderers. In this case an import declaration (C88) is required
so that the appropriate duty can be secured.
3. Water content
The importer is responsible for establishing and declaring the actual water content, and in the
absence of suspicion, official samples are not to be drawn.
4. Regular removals
At places where there are regular removals of large quantities of waste oils, e.g. Cross channel
ports, managers may agree a procedure, suitably adapted to take account of local circumstances,
involving:
The application should provide the essential details needed for full consideration of the impact
on official resources, and be accompanied by a line drawing (or map) of the whole length of the
The intended dates for laying the pipeline, pressure-testing it and initially flushing it should be
indicated as soon as known, together with the date that oil (or gas) is expected to flow.
As the Commissioners’ formal approval will be issued to the operator of the finished pipeline,
that operator should be named in the application.
(Note: the operator may be one legal person in a consortium of persons with a financial interest
in the pipeline).
The application should be made locally direct to the CRM when LBS traders are involved.
For further information on Pipeline Authorisation and Approvals see C7-6 ‘Pipelines’.
2. Acknowledgement of receipt
Receipt of the application must be acknowledged by letter; if the application is incomplete that
letter should ask for the further detail to be supplied as soon as it is known.
3. Issue of approval
Formal approval of an import pipeline should not be issued until the testing phase of construction
has been completed. Subject to HMRC being satisfied that the pipeline-operation presents no
unnecessary risks to official staff, nor to revenue-protection, and statistical reporting
requirements will be met, a letter of approval should be issued to take effect just prior to the
commissioning of the pipeline.
No letter of approval for pipelines format exists, but guidance is given in C7-6 ‘Pipelines’.
(a) On the first day of each month an import declaration is to be made in triplicate and in a
form agreed with the local officer of HM Revenue and Customs, of the Tariff description and
quantity of natural gas/oil expected to be imported through and delivered from the approved
pipeline during the month.
(1) information giving the sea areas from which natural gas/oil will originate;
(b) At the end of each month a declaration of the actual quantity of natural gas/oil imported
through and delivered from the approved pipeline during the month from each field.
(c) The import declaration at (a) above, supported by the monthly declaration at (b) above, when
signed and dated by the importer or a person duly authorised by the importer, shall be deemed
for the purposes of Section 37 of the Customs and Excise Management Act 1979, to constitute a
Customs import declaration of the gas/oil for home use.
(This text has been withheld because of exemptions in the Freedom of Information Act
2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
The warehousekeeper:
Checks that the owner of the oil in the warehouse has a valid contract with US visiting
forces and that they hold a signed requisition (C185) from a responsible officer of the US
Forces for each consignment delivered under the contract. As part of the nomination
process, the warehousekeeper should obtain a copy of the C185 for retention.
May deliver aviation fuel, motor spirit and heavy oil free of customs duty, excise duty
and VAT for use exclusively for official purposes by US Forces.
Is to obtain a valid certificate of receipt for each delivery and retain it for an officer’s
inspection.
Is only to accept as valid those certificates of receipt that are signed by (1) a responsible
officer or non-commissioned officer of the US Forces or (2) an authorised civilian
employee of the US Forces.
Is to produce the relevant certificate of receipt to the warehouse officer under locally
agreed procedures. Where such deliveries are numerous, a schedule of the receipts is to
be produced together with the supporting certificates.
Retain all written notifications of named civilian employees of US Forces authorised to
sign certificates of receipt.
Ensure that the warehousekeeper and/or owner of the oil in warehouse complies with
these requirements
Examine as part of a risk based programme the written notification of authorised
signatories and the certificates of receipt for satisfactory agreement and completion
Ask the local officer whether the consignment was received in full
Inform the warehouse-keeper by issue of a request for explanation (see paragraph 14.9.4,
‘Losses of oil removed under duty-suspension in the ‘Deficiencies in warehouse section
of this guidance) if the receipt of any consignment is not confirmed.
Institute normal transit loss procedure in respect of any quantity of oil not accounted for
satisfactorily.
Maintain a station record of verifications made and any enquiries and duty demands
resulting
May deliver motor spirit, kerosene and heavy oil for road fuel free of customs duty,
excise duty and VAT to the AAFES and USNX.
Is to follow the same procedure as applies to duty free deliveries to US Forces
The officer for the warehouse is to follow the guidance in the paragraph above *.
This enables approved suppliers to make supplies at duty exclusive prices from duty paid stock
Claims made by this method are subject to separate procedures and are controlled at the Central
Accounting point. Full details of the procedures for approval and accounting can be found in
Notice 179, Section 12.
HMRC Central Accounting Point Officers will exercise control of all adjustments made under
this procedure and initiate any verification action required to ensure the eligibility, accuracy and
completeness of any HO65 claims received.
(This text has been withheld because of exemptions in the Freedom of Information Act
2000)
( MGO) also Straight from the refinery Agricultural vehicles C1 Solvent Red 24
known as ‘Red (duty suspended warehouse),
Diesel’ or at a Remote Marking Point Vehicles used off- plus Quinazerin
(RMP) road
plus Euro-marker
Generators
Excepted vehicles
listed in schedule 1
of HODA
Heating Fuel
Marine Engines
Kerosene Straight from the refinery Waste AVTUR for Euro-marker plus
(duty suspended warehouse) use as light furnace
or because it is unmarked fuel. Coumerin
AVTUR that has become
contaminated or ‘Off- Primarily this is ( No Dye is added to
specification’. This is either Domestic Heating MKO)
marked at the RMP or on Oil (Paraffin)
collection by a remote marker.
Marking Oil in Marked under duty Approval to mark oil The Hydrocarbon Oil
Warehouse suspension at a refinery or may be included as regulations, 1973
in an excise warehouse, part of an Excise
following import, receipt Warehouse Customs and Excise
from another EC state or Application. Management Act 1979
production in the UK s92
Remote Marking Oil unable to be marked Writing to MORC The Hydrocarbon Oil
Premises under duty suspension at (Registered Remote
refinery or in an excise Markers) Regulations
warehouse or 2005
Emergency The local officer can see By contacting the local The Hydrocarbon Oil
Marking no alternative to covering officer (Registered Remote
duty by guarantee until the Markers) Regulations
oil is removed to a remote 2005
marking premises
Marking other than e.g. waste AVTUR Writing to local officer The Hydrocarbon Oil
at Remote Marking flushed out of aircraft (Registered Remote
premises tanks Markers) Regulations
2005
The possibility that marking might be an appropriate control can also be considered.
Typical Product Used for Has no marker Covered by Our controls are
because legislation covered in:
AVTUR (aviation Aviation To maintain purity Hydrocarbon Oil AVTUR and its
turbine fuel) or JET turbine fuel for of the fuel for Marking variants will run
A1 or any military jet engines technical and for Regulations, 2002 diesel engines.
Solvents, hydraulic Tied Oils or It is accepted that is Hydrocarbon Oil Tied OIL traders
fluids, trans-former oils ‘put to the oil is being Duties Act 1979, have to be
oils, and oils for certain use’ incorporated into Section 9 approved – see
other industrial being purposes other products, and Notice 184A. The
purposes, where other than for markers may have a disposal of waste
they are road fuel or detrimental effect Tied oil is also
incorporated into heating fuel on the end product controlled.
‘other’ goods such use.
as paints.
Fuel oil or furnace Dark Oil used Dark oil is often Prohibited for sale
fuel to be used to old or impure oil as vehicle fuel by
fuel marine oil- that should not be the Hydrocarbon
fired boilers, used as ‘rebated’ Oil Marking
but this fuel is oil because its Regulations 2002,
now rarely colour impedes the Section 17
burnt for identification of
emission fiscal dyes
reasons.
Removal Schedules from Refinery Warehouses and Direct Import Warehouse Premises,
Duty/Rebate Claims from Remote Marking & Shippers, and Pipeline Adjustment Schedules
from Pipeline Operators and Shippers are all received at the Trader’s Central Accounting Point.
On completion the HO10’s, together with the Duty/Rebate Claims and Removal and Pipeline
Schedules are sent to the Central Deferment Office (Oils Team), Southend.
See HCOTEG213275 for a Diagram which illustrates the flow of accounting documents to the
Central Accounting Point
In pursuance of their powers under Section 6 of the Hydrocarbon Oil Marking Regulations 2002,
the Commissioners of HM Revenue and Customs authorise:
[Name of Company, and address of premises at which the oil is to be received, stored and used];
to receive unmarked kerosene, [trade name(s) of product(s)] subject to the following conditions:
(a) that it is received duty-paid at the appropriate rebated rate and that it is used only for [full
purpose justifying marking waiver];
(b) that each supplier be provided with a letter signed by a responsible person confirming that the
Commissioners have authorised the above Company to receive [trade name(s) of product(s)] as
unmarked rebated kerosene for [purpose - may be less detailed than shown under (a)]
(c) that each order for such unmarked rebated kerosene be supported by a certificate signed by a
manager or other employee of the above company in the following form:
“Please deliver, under our HM Revenue and Customs authority number [ MWK/Serial
No./numbered according to local practice]; [quantity and description of oil] unmarked and at the
appropriate rebated rate of duty to [name and address of consignee]”;
(d) that evidence of receipts and disposal of unmarked rebated kerosene and of any waste oil
recovered from process be held for at least one year after actual use of the oil or disposal of the
waste;
(e) that up-to-date monthly balanced stock amounts of unmarked rebated kerosene and of any
waste oil recovered from process, showing suppliers of unmarked oil and full details of the
disposal or recycling of waste oil, be maintained and held for at least one year after the date of
the last entries in them;
(f) that the stock accounts be compared and reconciled with physical stocks or unmarked oil and
of waste oil on hand at the close of each calendar month, any apparent gains or losses being
included in the balanced accounts;
(g) that the records referred to in (d) and (e) above be made available at all reasonable times for
inspection and extraction of details by any officer of this Department on request;
(h) that stocks of unmarked rebated kerosene and of waste oil be effectively segregated from all
other stocks of oil by means of marked vessels set aside for their purposes;
(j) that facilities and access be provided at all reasonable times for any officer of this Department
for the purpose of inspecting premises and stocks of all oils, waste oils and finished products
held and processes conducted;
(k) that the above company be liable for repayment of rebate on any stock deficiencies of
unmarked rebated kerosene or waste oils recovered from process which, in the opinion of the
Commissioners, cannot be attributed to natural wastage or other legitimate causes, and on any
unmarked rebated kerosene or waste oil delivered to third parties or used for a purpose other than
in accordance with condition (a) above except as individually authorised by the Commissioners.
The Commissioners reserve the right at any time to impose additional conditions or, if necessary,
to withdraw this authority.
Date
I acknowledge receipt of an authority in the terms set out above, and agree to comply with the
conditions listed at (a) to (k). I understand and accept that the conditions may be varied, or the
authority withdrawn at any time.
(Signed)
(dated)
*Delete as appropriate
In pursuance of their powers under Section 6 of the Hydrocarbon Oil Marking Regulations 2002,
the Commissioners of HM Revenue and Customs authorise:
[Name of Company, and address of premises at which the oil is to be received, stored and used];
to receive unmarked gas oil, [trade name(s) of product(s)] subject to the following conditions:
(a) that it is received duty-paid at the appropriate rebated rate and that it is used only for [full
purpose justifying marking waiver];
(b) that each supplier be provided with a letter signed by a responsible person confirming that the
Commissioners have authorised the above Company to receive [trade name(s) of product(s)] as
unmarked rebated kerosene for [purpose - may be less detailed than shown under (a)]
(c) that each order for such unmarked rebated kerosene be supported by a certificate signed by a
manager or other employee of the above company in the following form:
“Please deliver, under our HM Revenue and Customs authority number [ MWK/Serial
No./numbered according to local practice]; [quantity and description of oil] unmarked and at the
appropriate rebated rate of duty to [name and address of consignee]”;
(d) that evidence of receipts and disposal of unmarked rebated gas oil and of any waste oil
recovered from process be held for at least one year after actual use of the oil or disposal of the
waste;
(e) that up-to-date monthly balanced stock amounts of unmarked rebated gas oil and of any
waste oil recovered from process, showing suppliers of unmarked oil and full details of the
disposal or recycling of waste oil, be maintained and held for at least one year after the date of
the last entries in them;
(f) that the stock accounts be compared and reconciled with physical stocks or unmarked oil and
of waste oil on hand at the close of each calendar month, any apparent gains or losses being
included in the balanced accounts;
(g) that the records referred to in (d) and (e) above be made available at all reasonable times for
inspection and extraction of details by any officer of this Department on request;
(h) that stocks of unmarked rebated gas oil and of waste oil be effectively segregated from all
other stocks of oil by means of marked vessels set aside for their purposes;
(j) that facilities and access be provided at all reasonable times for any officer of this Department
for the purpose of inspecting premises and stocks of all oils, waste oils and finished products
held and processes conducted;
(k) that the above company be liable for repayment of rebate on any stock deficiencies of
unmarked rebated kerosene or waste oils recovered from process which, in the opinion of the
Commissioners, cannot be attributed to natural wastage or other legitimate causes, and on any
unmarked rebated gas oil or waste oil delivered to third parties or used for a purpose other than
in accordance with condition (a) above except as individually authorised by the Commissioners.
The Commissioners reserve the right at any time to impose additional conditions or, if necessary,
to withdraw this authority.
Date
I acknowledge receipt of an authority in the terms set out above, and agree to comply with the
conditions listed at (a) to (k). I understand and accept that the conditions may be varied, or the
authority withdrawn at any time.
(Signed)
(dated)
*Delete as appropriate
If you receive a letter asking for a licence to use rebated heavy oil as fuel, containing details set
out in Public Notice 75 paragraph 6.3, from a large business refer the matter to the Large
Business Service Oil and Gas Sector team which covers the address where the rebated oil is to
be stored.
If you receive a letter asking for a licence to use rebated heavy oil as fuel, from a SME, refer the
matter via the appropriate Regional Risk Team to the Local Compliance Oils Assurance team
which covers the address where the rebated oil is to be stored.
On receipt of the referred application, you should decide whether a visit to the applicant is
As well as the items listed in HCOTEG122550 consider the following before making a decision
or arriving at a recommendation.
The issue of a licence allows the licensee to use marked/rebated heavy oil as fuel on the public
road.
A ready willingness to issues a licence could undermine the enforcement effort of the Road Fuel
Testing Unit (RFTU) and each application should be examined critically.
The application must demonstrate that ULSD or SFD cannot be used and why. It does not suffice
for the applicant to claim that ULSD or SFD is difficult to obtain.
Applications to pay the rebate (instead of using either ULSD or SFD) on heavy oil for use as fuel
in Fire Brigade appliances, Local Authority Ambulances and liveried Police vehicles are not to be
refused, but the licence must relate to specific “exceptional circumstances”. You should
withdraw the licence as soon as these circumstances change.
Make a recommendation to MORC on the basis of any knowledge of the applicant which you
already have or can obtain via HMRC databases.
MORC - When you have received a recommendation from either LBS or LC, you should issue
the licence (or not) based on the recommendation given.
The initial accounting period should begin on the day of issue of the licence and end on 31
March, 30 June, 30 September or 31 December.
You should determine whether subsequent accounting periods should be quarterly or annually
dependant on frequency of journeys and amount of payment.
You should use the specimen letter refusing authorisation given at HCOTEG213800 as a
template.
Post Authorisation
Action by LBS/Local Compliance Assurance Officers
If you recommend that the applicant be approved, you will subsequently receive copies of all
estimates, supplementary estimates, additional payments and returns that a licensee in your area
sends to the Tax Accounting Centre in Birmingham.
Those copies should allow you to establish the extent of legitimate use of rebated heavy oil as
fuel in the event of a detection by the RFTU.
Each vehicle legitimately using marked heavy oil as fuel in accordance with these Regulations
should have on board some indication that a valid licence is in force
If you decide/recommend that the applicant be approved, you may later be expected to conduct
an audit of the standard of compliance with the regulations by each licensee in their area.
Pay particular attention to record keeping and stock control of the oil.
Serious or aggravated breach of the regulations or repeated instances of under payment of rebate,
are grounds for withdrawal of the licence.
TAC should send the licensee 2 sets of Forms HO72 and HO73 to allow them to make their
Remind the licensee to complete the initial form and return this TAC with their remittance
before any rebated oil is used as fuel, and set up the records required by the regulations.
Should the volume of oil declared on Form HO72 (and paid for) prove insufficient in any
accounting period, the licensee is required to cease using rebated heavy oil as fuel until they have
completed Form HO73 and paid the amount of rebate declared on that form to the Accounting
Centre.
TAC should retain a small stock of Forms HO72 and HO73 for issue at any time.
If TAC does not receive Form HO72 within 10 days of their issue of the form, they should speak
to either LBS or Local Compliance.
If staff in either LBS or Local Compliance decide to withdraw the licence, TAC should not
cancel the database entry until MORC advises them of the cancellation of the licence and the end
date of the final accounting period. A declaration must be made by the licensee on Form HO75
for all accounting periods for which the licence is valid.
After placing the remittance accompanying Form HO72 (and any Form HO73 subsequently
furnished in an accounting period) on miscellaneous cash deposit (MCD), no further action need
be taken by the TAC until shortly before the end of the accounting period shown in the licence.
Then TAC is to despatch Form HO75 to the licensee at the address at which the rebated oil is
stored. That Form HO75 has to be completed and returned to the TAC within 10 days of the end
of the period. Form HO72 (and remittance), for the next period, may accompany it if the licensee
anticipates continued need to use rebated heavy oil as fuel.
On the eve of Budget Day the TAC will examine the MCD record and despatch Form HO74 to
each licensee who has presented Form HO72 or Form HO73 in their accounting period. Form
HO74 allows the licensee to declare the volume of heavy oil actually used before the Budget
change, and to declare the expected volume to be used in the remainder of the accounting period
at post-Budget rate(s). The trader must return the completed form (and remittance) to the TAC
within 3 days of the Budget.
On receipt of Form HO74 (and remittance) TAC should follow the procedure above. We have no
objection to all the outstanding sums paid by each licensee in the accounting period being
consolidated, and the total sum being re-deposited to one MCD per licensee.
Shortly before the end of an accounting period TAC is to despatch Form HO75 to those licensees
who have made a payment. (That form provides for the licensee to declare he actual volume of
heavy oil used in the period as fuel, and to claim refund of the sum overpaid.) At the same time
Form HO72 is to be sent (unless a licence has been withdrawn) so that the licensee can estimate
his likely usage in the next period, and make any payment due. When received at TAC, the
completed Form HO72 is to be dealt with in accordance with the accounting instructions above.
TAC will use the completed Form HO75 (which will not be accompanied by any remittance) to
adjust the MCD raised in the name of that licensee, bring to account the rebate due for the
accounting period and refund the balance overpaid. The Form HO75 provides for the rebate
amount payable for the period to be analysed against tax type codes.
Any sum overpaid in an earlier accounting period can be re-deposited to the credit of that
licensee for he next period provided that the licensee has submitted Form HO72 for that next
period ( and the amount payable shown on that Form HO72 equated to the sum refundable
shown on the Form HO75 for the earlier period). Otherwise it is intended that each accounting
period will end with the HO75 leading to a small refund to the licensee.
TAC is to make a copy of all Forms HO72 to 75 which are received from licensees,
retain the original forms for audit until they are ready for destruction See IM-2C -
Retention and Disposal: Operational records relating toExcise and Inland
Customs ‘Hydrocarbon Oils’ . Copy forms are to be sent to the RFCO for the
address at which the oil is stored.
Dear ( Applicant )
I refer to your letter [ date ] applying for permission to use rebated oil as road fuel on repayment
of the excise duty.
I should explain that authorisations to use rebated oil as fuel in road vehicles on pre-payment of
the duty rebate are allowed only in very exceptional circumstances, for example where the nature
of the vehicles concerned and operational requirements are such as to make the occasional use of
rebated oil as road fuel essential.
Your application has been carefully considered, but unfortunately it is not of a type which comes
within the very restricted range of these authorisations. I regret therefore that your application
must be refused.
If you do not agree with the decision in this letter, you can ask for a formal Departmental review.
Your request should be in writing, and set out the reasons why you do not agree with the
decision. It should be sent within 45 days of the date of this letter to [ address of the review team
]
Yours faithfully,
Form of Licence
“ Dear ( Applicant ) ,
The Commissioners of Revenue and Customs licence ( name of legal person ) operating at (
address at which stock of heavy oil is stored ) to make payment of the rebate on heavy oil to be
used as fuel in accordance with these Regulations.
The initial accounting period will begin ( show date of issue of licence ) and will end on ( show
31 March, 30 June, 30 September or 31 December ). Thereafter for the purposes of these
Regulations your accounting periods will be ( show quarterly or annual ) ending on ( show
appropriate date ) in each calendar year.
It is a condition of this licence that you comply generally with the requirements of the
Regulations, and in particular that you make and keep records of the use of all rebated heavy oil
in accordance with the Regulations. This Licence remains the property of the Commissioners and
may be withdrawn ( with or without replacement by a further Licence ) by the Commissioners at
any time.”
Yours faithfully,
HCOTEG220025 - Appendices:
Abbreviations
Abbreviation Meaning
A&CG Accountant and Comptroller General
AAD Administrative Accompanying Document. Control document for the movement of
excise goods between approved premises in the EU.
AAFES (United States) Army and Air Force Exchange Service
ALG Automatic Level Gauge/Automatic Tank Gauge. Instrument attached to a tank
that measures the level of product and displays it mechanically at the tank side, or
now electronically in a control room.
AS Audit Service
ASD Accounting Services Division
ASTM American Society for Testing Materials. Recommends standard methods for
testing many substances e.g. hydrocarbons. In association with other bodies it
publishes conversion tables, e.g. for the effects of temperature and pressure on
volumes of oil.
(This text has been withheld because of exemptions in the Freedom of Information Act
2000)
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because of exemptions in the the Freedom of Information Act 2000)
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because of exemptions in the the Freedom of Information Act 2000)
Freedom of Information Act
2000)
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because of exemptions in the the Freedom of Information Act 2000)
Freedom of Information Act
2000)
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because of exemptions in the the Freedom of Information Act 2000)
Freedom of Information Act
2000)