OPERATION AND MAINTENANCE OF PETROLEUM …erc.go.ke/images/docs/OPERATION OF PSS.pdf · UST...

PETROLEUM GUIDANCE NOTES PET /TGN/1.6

OPERATION AND MAINTENANCE OF PETROLEUM RETAIL SERVICE STATIONS

JUNE 2016

Operation and Maintenance of Petroleum Retail Service Stations

Contents

1. Introduction ...............................................................................13

2. Disclaimer ..................................................................................13

3. Retail Service Station –Operation and Maintenance ........13

4. Objective .....................................................................................14

5. Scope ............................................................................................14

6. Availability ................................................................................14

7. Legal Framework ......................................................................14

8. Environmental Concerns .........................................................14

9. Activities Posing Pollution Risk ...........................................15

10. Site Operator Responsibilities ...............................................16

11. Employees Responsibilities ...................................................16

12. Stock Loss Monitoring .............................................................16

13. Product Delivery .......................................................................18

14. Product Storage .........................................................................18

15. Product Dispensing ..................................................................19

16. Drainage .....................................................................................20

17. UST Conversion ........................................................................20

18. Maintenance and Repair .........................................................21

19. Pollution Prevention Practices ...............................................22

Control System ......................................................................................... 22

20. Management of the Forecourt ................................................23


Leaks and Spills ....................................................................................... 23Wetstock Accounting .............................................................................. 23Tank Testing ............................................................................................. 24Dispensers ................................................................................................. 25Pipework ................................................................................................... 25Storage Tanks ........................................................................................... 27OWSs ......................................................................................................... 27Tanker Standing Areas ........................................................................... 27Fill Points .................................................................................................. 27Portable Fuel Containers ....................................................................... 28Delivery Procedures ................................................................................ 28Periodic Inspections ................................................................................ 28

Inspections .............................................................................................................. 28

Hoses ........................................................................................................................ 28

Vent Pipes ............................................................................................................... 29

Vapor Recovery Systems ...................................................................................... 29

Overfill Protection .................................................................................................. 29

Dealing with Spillage ............................................................................................ 29

Stormwater .............................................................................................................. 29

21. Contractor Safety Management .............................................30

Contractor Management ........................................................................ 30Permit to Work System .......................................................................... 30Contractor Staff Training ....................................................................... 30

22. C-Stores .......................................................................................31

General ...................................................................................................... 31Siting/Location ......................................................................................... 31Beverages ................................................................................................... 31Grocery items ........................................................................................... 31Produce handling and Storage .............................................................. 31Food Preparation and Storage ............................................................... 32


Restaurant Supplies ................................................................................ 32Production and Service Areas ............................................................... 32Back of the House .................................................................................... 33Front of the House ................................................................................... 33Recycling ................................................................................................... 33Employees ................................................................................................. 33Purchasing ................................................................................................. 33Paper Supplies ......................................................................................... 34Grease ........................................................................................................ 34Hazardous Materials ............................................................................... 34Pests ............................................................................................................ 34

23. Training ......................................................................................35

General ...................................................................................................... 35Responsibility .......................................................................................... 35Importance of Training .......................................................................... 35Training Needs ........................................................................................ 35Performance of Training ........................................................................ 37

24. Records ........................................................................................37

25. References ..................................................................................39

26. Contacts .......................................................................................40


Acronyms

Acronym Description

ATG Automatic Tank Gauging

BP Best Practice

COP Codes of Practice

DOSHS Department of Occupational Safety and Health Services

EMC Environment Management and Coordination Act 1999,

ERC Energy Regulatory Commission

ESD Emergency Shut Down

GRP Glass Reinforced Plastic

HDPE High Density Polyethylene

KEBS Kenya Bureau of Standards

KS Kenya Standard

NFPA National Fire Protection Association

LDPE Low Density Polyethylene

LLDPE Light Low Density Polyethylene

OWS Oil Water Separator

PIRP Pollution Incident Response Plan

PPG Pollution Prevention Guidelines

PTW Permit To Work

PVR Pressure Vacuum Relief

SIR Statistical Inventory Reconciliation

SOPs Standard Operating Procedures

SUDs Sustainable Drainage Systems

UST Underground Storage Tank

VOC Volatile Organic Compounds


Terminology

Terminology Description

Aquifer Geological strata capable of storing and allowing migration and abstraction of groundwater.

Automatic Tank Gauging

Automatic Tank Gauge. Electronically operated system that automatically measures the level of product inside the UST.

Bottoming Removal of residual product from USTs prior to decommissioning.

Breathing Emissions from or intake of air into tank due to ambient temperature and/or pressure effects or due to vaporization/condensation of product

Chamber/Manhole A chamber in an UST. It might also contain pipes, valves, level gauges and other installed equipment. It is covered with a lid. Also known as sump, manhole, inspection well or maintenance well.

Change Any modification other than “replacement in kind.”

Company Company within the meaning of the Cap. 486 of Companies Act

Competent Person Means a person with enough practical and theoretical knowledge, training and actual experience to carry out a particular task safely and effectively.

Containment Means to prevent loss of liquid product in the event of a leak or spill

Contractor Any company or individual that is under contract to provide services.

Controlled Waters Includes burns, rivers, estuaries, canals, lochs, ponds and groundwaters.

Codes of Practice Codes of practice state ways to manage exposure to risks. If a code of practice exists for a risk at the workplace, the operator must:

• Do what the code says; or

• Adopt another way that identifies and manages exposure to the risk; and

• Take reasonable precautions and exercise due care.

C-Store Convenience Retailing Store located at a Petroleum Retail



Service Station

Danger Risk to the environment, health, life, person or property of anyone from pollution arising from operation and maintenance of petroleum facilities

Dipstick A measuring rod to determine the level of product inside a storage tank and is used for taking measurements manually

Dispenser Equipment used for transferring product from the UST to the customer’s vehicle

Double Skin Tank or pipe that has two separate walls.

Drop Pipe Fill pipe fitted vertically inside tank and reaching to the bottom of the tank, designed to reduce splashing during filling

Emission The episodic or ongoing release of materials to the environment (air, water or land).

Emergency Shut Down

Emergency Shutdown are critical safety devices that shutdown operations or processes during emergencies

Evaporation Conversion of a liquid to vapor without necessarily reaching the boiling point

Facilities Physical equipment and/or plant, including large mobile equipment, involved in the performance of affiliate operations.

Fill Pipe A pipe either fitted to a tank or inserted into a tank to permit filling

Flow Rate Litres per minute

Forecourt An area used to fill customers vehicles. Pump islands and dispensers are located here.

Fuel Delivery Area An area used by road tankers while filling USTs. The top parts of fill pipes and/or filling sumps are located here.

Gauging Device Device for the measurement of liquid level in a tank

Groundwater Water that is below the surface of the ground in the saturation zone, i.e. below the water table.

Hazard A potential source of serious harm to people, property or the environment.

Hazardous Area An area in which there exists or may exist an atmosphere containing flammable gas or vapor in a concentration capable of ignition



Hydrocarbon Chemical compounds containing carbon and hydrogen which are produced by the refining of crude oil and which are generally used as fuels.

Improvements Physical additions made during the lifetime of a facility or site.

Incident A specific event or extended condition that has a significant unwanted and unintended impact on the safety or health of people, on property, on the environment, or on legal/regulatory compliance.

Kenya Standard Specification or Code of Practice declared by The Standards Council under section 9 of the Standards Act

Management Site management is typically the most senior level of operations management working on site.

Managers Personnel with line management or supervisory responsibilities.

Monitoring Well A well for observing the conditions in underground spaces.

Near Miss An unintended or unwanted event or circumstance which under slightly different conditions would have resulted in an incident.

Occupational Health

Means the anticipation, recognition, evaluation, monitoring and control of conditions arising in or from the workplace, which may cause illness or adverse health effects to persons.

Off-set Fill Point A filling point on which connections for the hose of the delivery vehicle is at some distance from the tank

Operation Any activity involving the use, storage and movement of petroleum products. Also, the utilization of resources by a “unit” to produce an output.

Overfill Protection Equipment that halts the transfer of product from a road tanker to an UST when the tank is full.

Permit To Work (PTW)

Is a structured and formal written means of ensuring that potentially dangerous activities are approached and carried out using the correct safety procedures

Petroleum "Petroleum" includes petroleum crude natural gas and any liquid or gas made from petroleum crude, natural gas, coal, schist, shale, peat or any other bituminous substance or from any product of petroleum crude, natural gas and includes condensate

Pollution Pollution prevention describes activities that reduce the



Prevention Program

amount of pollution generated by a process. The pollution prevention approach seeks to increase the efficiency of a process, thereby reducing the amount of pollution generated at its source. Although there is wide agreement that source reduction is the preferred strategy, some professionals also use the term pollution prevention to include recycling or reuse.

Practice Approved method or means of accomplishing stated tasks.

Pressure Vacuum Relief

Pressure/Vacuum Relief Valves (Breather Valves). Direct acting pressure/vacuum relief valves are special types of relief valves which are specifically designed for tank protection. The range includes pressure only, vacuum only and combined pressure/vacuum valves, all available with flanged outlets or vented to atmosphere.

Pressure / vacuum relief valves are used extensively on bulk storage tanks, including fixed roof tanks with floating covers, to minimize evaporation loss. The valves prevent the buildup of excessive pressure or vacuum which can unbalance the system or damage the storage vessel

Project A planned undertaking with a specific objective and defined scope. Includes new construction and additions or revisions to existing facilities.

Pump Island Base for the dispenser

Quality The ability for a product, service or activity to meet or exceed requirements.

Recommendations Potential solutions to findings or observations.

Recommissioning Recommissioning is essentially the same process as commissioning, but applies to existing facilities and provides a systematic approach for discovering and solving problems associated with facilities operation and maintenance procedures.

Replacement In-kind

Replacement which is essentially identical to the original and satisfies all relevant standards and specifications.

Retail Service Station

Premises where petroleum is stored in bulk in one or more tanks and dispensed to consumers for their own use

Risk Risk is a function of the probability of an unwanted incident and the severity of its consequences

Risk Assessment The process by which a risk analysis is conducted and results used to make decisions, either through relative ranking of risk reduction strategies or through comparison



with risk criteria or other standards of acceptability.

Road Tanker Petroleum Tank Truck that delivers product to the site.

Safety Method Statement

An SMS can range from a simple statement to a detailed technical document depending on the scale of the task involved. The purpose of the SMS is to identify the hazards associated with each task and specify the necessary controls to them.

Shell The walls of a tank

Site The place where something was, is or is to be located. May be a marketing location, a refinery, gas plant or offshore platform. For the purposes of this document, a site refers to a petroleum retail facility.

Source Substance capable of causing pollution or harm.

Standard Operating Procedures

Standard Operating Procedures are documented series of steps to be carried out in a logical order for a defined operation or in a given situation.

Splash Loading Filling of a tank resulting in excessive splashing and vapor generation

Standard A defined product or result. Includes requirements for quality, content, review and conformance with regulations.

Street Way, road, lane, square, court, alley, passage or open space, whether a thoroughfare or not, over which the public have a right of way, and also the roadway and footway over any public bridge, or causeway

Suction Pipe Pipe for transferring product from the UST via a dispenser to customer’s vehicle.

Sustainable Drainage Systems

SUDS are a sequence of water management practices and facilities designed to drain surface water in a manner that will provide a more sustainable approach than what has been the conventional practice of routing run-off through a pipe to a watercourse.

Third Party A contractor providing services in accordance with specifications, terms and conditions documented by a contract agreement and signed by both parties.

Ullage Free space above the liquid in a tank

Underground Storage Tank

Underground Storage Tank for fuel, usually made of steel and installed underground. Capacity usually 10,000 – 60,000 Litres.



Vapor Pressure Pressure exerted by a volatile liquid

Vapor Recovery System

Vapor Recovery System is the process when vapor is collected and returned to a road tanker when filling the UST.

Vent Pipe A pipe provided for the USTs venting system. Necessary to prevent tank distortion due to variations in internal pressure resulting from the normal operational filling and emptying


1. Introduction

1.1. These Pollution Prevention Guidelines (PPGs), herein referred to as “guidelines”, are intended to help those who operate and maintain Petroleum Retail Service Stations, herein referred to as “sites”.

1.2. They have been produced by the Energy Regulatory Commission (ERC). Contact details can be found at the end of these guidelines.

2. Disclaimer

2.1. The information contained in the PPGs is not intended to be prescriptive, or to preclude the use of new developments, innovative solutions or alternative designs, materials, methods and procedures, so long as such alternatives provide a level of control over pollution appropriate to the risks identified.

2.2. The guidelines are provided for information and while every reasonable care has been taken to ensure the accuracy of its contents, the ERC cannot accept any responsibility for any action taken, or not taken, on the basis of this information.

3. Retail Service Station –Operation and Maintenance

3.1. Except where a dispenser is being tested for accuracy or during the course of repairs to the site or any part thereof, petroleum products shall only be dispensed into the fuel tank of a vehicle or into a suitable container. Any container used for this purpose shall immediately be securely closed and kept in a safe place.

3.2. These PPGs concentrate on the practical means of minimizing the potential impacts of petroleum products to air, soil and groundwater or surface water where they are stored and dispensed to the public.

3.3. In applying the PPGs, it should be recognized that actions to minimize the release of hydrocarbons to the environment may also lead to improvements in safety performance, healthier working conditions for employees and more cost effective operations.


4. Objective

4.1. The overall aim of the PPGs is fuel containment integrity from the tanker offloading point to the dispenser nozzle through correct operational and maintenance practices.

5. Scope

5.1. The PPGs provide the minimum standards of operation, maintenance and guidance on cost effective practices to minimize impact to air, soil, groundwater and surface water:

a. Operational activities which pose environmental risk

b. Factors which need to be considered during operational and maintenance activities

c. BPs for general operational control procedures, product loss detection and maintenance.

6. Availability

6.1. The PPGs are published by the ERC and are now available.

7. Legal Framework

7.1. The Regulatory Framework and useful guidance and publications are given at the end of the PPGs.

8. Environmental Concerns

8.1. The risk the site presents to the environment should be assessed.

8.2. The main factors to control are the presence or leaks, spills and/or vapor.

8.3. The level of risk can be affected by factors such as:

a. Frequency and method of delivery of fuel to the site

b. Capacity and method of storage

c. Number of vehicles passing through the site and dispensing operations taking place


d. Number of employees and members of the public regularly on or around site

e. Age and type of the equipment.

f. Siting of site equipment (dispensers, fill points, tanks, pipework etc) in relation to other activities and fixtures on the site such as a car wash or vehicle repair garage.

g. Layout of the site in relation to the maneuvering of vehicles and the supervision of dispensers;

h. Site-specific factors such as ground conditions and watercourses and vandalism.

9. Activities Posing Pollution Risk

9.1. During the operation of a site, release of hydrocarbons can occur not just from the UST itself but also from ancillary equipment and during the movement of product to and from the UST.

9.2. The release of product could occur during any of the following activities:

a. Delivery

b. Storage

c. Dispensing

d. Drainage

e. Maintenance and Repair.

9.3. Possible discharges in runoff to surface watercourses through leaks from:

a. Under dispenser valves and flexible couplings

b. Pipework

c. Tanks and offset fill pipes

d. Faulty Oil/Water Separator Operation

9.4. Possible discharges to soakaways through spills during:

a. Customer refueling including leaks from customer fuel tanks

b. Filling of site USTs directly by below ground or above ground offset fill points

c. Overfilling of portable containers

9.5. C-Stores also generate significant amounts of waste that can significantly pollute the environment.


9.6. The degree of pollution risk posed by the release of product during site operations will depend on the engineering and operational control measures in place, and on the location of the site.

10. Site Operator Responsibilities

10.1. Ensure that:

a. Staff and customers comply with site rules and procedures

b. Equipment is inspected and all maintenance and tests are carried out when required

c. MSDSs are provided

d. Environmental measures are immediately actioned and a record of them maintained

e. Accidents and incidents are recorded

f. Suitable stand ins are available in the event of absence

11. Employees Responsibilities

11.1. Ensure that:

a. Unplanned and non-approved discharges to the environment are recorded and management advised

b. Appropriate SOPs for controlling emissions to the environment are fully observed

c. Faults on equipment and fittings are entered into the site log to enable remedial action

d. Complaints from members of the public are recorded for follow up action

12. Stock Loss Monitoring

12.1. Methods for detecting loss of product include leak detection systems and wet stock monitoring, environmental monitoring and integrity testing.

12.2. On-going automatic leak detection without loss of product is only possible with double skinned equipment – provides warning of failure prior to release of product to ground.


12.3. Wetstock monitoring can take various forms ranging from statistical inventory reconciliation (SIR) to simple manual monitoring using a dipstick.

12.4. Whilst wet stock monitoring will not detect a leak before product is lost to the ground, the more sophisticated systems should provide a relatively rapid indication that a leak is occurring.

12.5. Environmental monitoring typically utilizes monitoring wells to monitor for the presence of vapors, dissolved product or free phase product. Leakage will only be detected once product has migrated through the ground and reached the monitoring wells.

12.6. Depending on the location of the monitoring wells and the sensitivity and frequency of monitoring, leakage might have been on-going for a relatively lengthy period before being detected. Additionally, there is a risk that, if not located properly, the monitoring wells could fail to detect a contamination plume.

12.7. When drilling monitoring wells on sites, methodologies should be used to ensure that any near-surface contamination is not transferred to any deeper aquifers.


12.8. Integrity testing based on pressurizing USTs and pipework to detect leaks or faults is usually carried out before a site is brought into service. Thereafter integrity testing based on precision UST or line tests is only normally carried out in support of a monitoring system or if a leak is suspected.

12.9. Integrity testing could include the use of environmental tracers. If integrity testing alone is used to monitor for loss of product, leakage could be ongoing for very long periods before being detected.

12.10. The preferred hierarchy for detecting the loss of product is as follows:

a. Automatic Leak Detection Systems >Wet stock Monitoring > Environmental Monitoring > Integrity Testing

13. Product Delivery

13.1. Steps shall be taken to prevent leaks and spills and to detect the sources of leaks, including leaks indicated as a result of monitoring products stocks.

13.2. Small leaks or spills shall be cleared up promptly by the application of dry sand or other absorbent material.

13.3. All sand or other material used for clearing or containing leaks or spills shall be disposed of safely as per EMC (Waste management ) Regulations. If retained for any length of time pending disposal, it shall be kept at a safe place in a closed container. Any other material contaminated with fuel shall be treated in a similar way.

13.4. Particular care is needed when the person responsible for the delivery is unfamiliar with the site.

14. Product Storage

14.1. Failures in the integrity of USTs and associated pipework could result in a significant loss of product.

14.2. The integrity of USTs could also be compromised by damage or corrosion. This could occur where USTs are at shallow depth, or have not been installed in such a way as to prevent settlement.

14.3. Factors to be considered in assessing the pollution risk as a result of the possible loss of product from UST include:

a. Age of USTs and pipework

b. Groundwater in relation to the base of USTs

c. Type of ground USTs are installed in


d. Type of USTs and pipework (i.e. single or double skinned)

e. Installation of UST and pipework

f. Potential for damage to USTs and pipework

g. Corrosion protection used for USTs and pipework (e.g. cathodic protection)

14.4. Factors to be considered in assessing the potential pollution risk resulting from the possible loss of product during delivery include:

a. Site has a separate tanker stand area

b. Site drainage system potential to capture delivery point spill and the capacity of the interceptor

c. Overfill prevention systems

d. Clear labeling of delivery pipes

e. Compliance with correct delivery procedures

15. Product Dispensing

15.1. During dispensing, loss of product can occur either from the pipework connecting USTs to the dispensing system or during the dispensing process.

15.2. Fuel is transferred from USTs to the dispenser by means of either suction or a pressure system.

15.3. The potential for leakage is increased with the number of joints along pipework.

15.4. There are both disadvantages and advantages associated with the use of pressure and suction systems. The most significant difference is that if there is a leak in a line, a greater volume of product could be lost over a given time period from a pressure system. Pressure systems have an advantage in that leaks are usually detected at an early stage, and it is possible to fit the systems with an automatic shut down system.

15.5. During the dispensing process itself, there is potential for spillage to occur. Modern pumps on sites should be fitted with nozzle shut-off valves.

15.6. A significant loss of product could occur if a dispensing system is accidentally left open. A similar situation could occur in the event of vandalism.

15.7. Operators should ensure that adequate measures are taken to prevent unauthorized access and that pumps and valves are closed or locked when not in use.


16. Drainage

16.1. Factors to be considered in assessing pollution risk as a result of the loss of product during dispensing include:

a. Conformance of dispensers to modern standards

b. Mode of feeding the dispensers - suction or a pressure system

c. Number of vehicles that can be refueled within the site area in specified time intervals

d. Regular maintenance and annual calibration of dispensers

e. Fitting of dispensers fitted with nozzle shut-off valves

f. Fitting of pumps (on suction system) with under pump check valves

g. Security against damage or vandalism

16.2. Effluent from vehicle washing facilities contains detergents that can increase the solubility of hydrocarbons.

16.3. Vehicle washings should therefore not pass into the same drainage system as the general surface water but should connect to foul sewer.

17. UST Conversion

17.1. The following steps should be taken when converting a spirit USTs to diesel USTs:

a. Empty and bottom out UST.

b. Check to ensure that the fill pipe is intact to prevent the possibility of splash loading.

c. Check to ensure electrical continuity between UST and the tanker.

d. Restrict initial flow of diesel to less than 1m/s until the end of the fill pipe has been covered.

e. Fill UST to its maximum capacity.

f. Flush through pipework to each dispenser connected to UST, drawing at least 100 Litres through each one. The flushings may be returned to the converted UST where its capacity is more than 4,000 Litres.

g. The UST fill pipe should be clearly relabeled.

h. Site records should be amended to reflect the change of storage

i. Disconnect vapor recovery pipework from UST and blank off.

j. Change or remove any signs associated with vapor balancing as appropriate.


k. USTs should be tested prior to conversion unless the tank is known not to be leaking.

l. When permanently decommissioning the UST, it must always be treated as an ex spirit UST and decommissioned accordingly.

m. If uplifting a converted diesel UST, it should be marked accordingly as being an ex spirit UST and removed in line with current guidance.

18. Maintenance and Repair

18.1. Regular maintenance and inspection programs are the most effective method of ensuring that everything is in good working order and that environmental risk is being managed effectively.

18.2. Maintenance includes examination, servicing, cleaning, repair, testing or calibration. The periods between these activities will depend on recommendations of manufacturers’, suppliers or installers, conditions at the site and the advice of the person who carried out the last examination.

18.3. SMSs and SOPs for maintenance activities will ensure that work is properly planned and that all changes are adequately documented.

18.4. Significant environmental risks to controlled waters could result during the course of maintenance and repair works. It is vital that a detailed plan of works is adhered to when any maintenance or repair work is carried out

18.5. Factors to be considered in assessing pollution risk that could occur during maintenance and repair activities include:

a. Pipelines/USTs drained sufficiently to minimize the potential for spills to the environment

b. Procedures in place to avoid accidental damage to USTs and associated pipe work during maintenance works

c. Monitoring and checks in place to ensure that all repairs have been performed to a satisfactory standard

d. Materials containing waste fuels, which arise during the course of repair works, be suitably disposed.

18.6. Factors to be considered in assessing pollution risk to groundwater arising from on-site surface water drainage systems include:

a. Classification and vulnerability of the underlying aquifer

b. Discharge of site waste materials/effluents

c. Location of soakaways on-site

d. Nearest water supply boreholes


e. Drainage intact and does it effectively deal with fuel spills

f. Drainage covers the whole site

g. Forecourt Oil/Water Separator is clean, functional and maintained to ensure effectiveness

h. Dispensing and monitoring procedures are employed

i. Age and condition of the drainage system

j. Linkage between drains and receptors

k. Vehicle washing facilities drain through a separate dedicated system

19. Pollution Prevention Practices

Control System

19.1. Operational control systems are important factors in mitigating identified risks and important components include:

a. General operational control procedures

b. Leak detection and environmental monitoring

c. Maintenance.

19.2. Periodic testing for the presence of water in USTs may indicate (through ingress of water) a failure in the UST shell, gaskets sealing the UST lid or pipework connections.

19.3. If operational procedures are developed and followed correctly, the risk of a pollution incident occurring can be dramatically reduced.

19.4. Significant activities for which development of SOPs should be considered include:

a. Product delivery

b. Dispensing

c. Wet stock Accounting

d. Regular and one-off maintenance activities

e. Control of visiting contractors

f. Customer Complaints

g. Staff awareness and training

h. Response to major and minor spillages

i. Response to alarms and other indications of leakage.

j. General site maintenance and housekeeping


k. Maintenance of site records

l. Equipment maintenance plan

20. Management of the Forecourt

20.1. Site management should periodically assess the ability of staff to supervise dispensing operations:

a. Staffing levels

b. Other duties expected of staff

c. Management of forecourt staff

d. Training of forecourt staff

Leaks and Spills

20.2. Site management should take steps to prevent leaks and spills and to identify the sources so that corrective action can be taken in good time.

20.3. Evidence of leaks can come from:

a. Trigger of automatic leak detection system

b. Hydrocarbons from monitoring wells

c. Monitoring of fuel stocks

d. Excessive fuel odors:

e. Leaks visible from USTs and pipework if poorly installed, inadequately maintained, or old.

f. Poor integrity of the UST System

g. Periodic testing for the presence of water in USTs may indicate failure in the UST shell, gaskets sealing the UST lid or pipework connections.

20.4. Spillages should be cleared up quickly by applying dry sand or other absorbent materials. Materials used in this way will be contaminated with petrol and must be disposed of safely.

20.5. If contaminated material is stored prior to disposal, use a safe place like a closed bin or other container, which has been suitably labeled. Treat other materials contaminated with petrol, such as clothing, rags or soil, in a similar way.

Wetstock Accounting

20.6. Wetstock Accounting should show losses and gains for each UST and pipeline system.


20.7. Effectiveness of Wetstock Accounting as a method for detecting leaks depends on the following:

a. Reliability of the measurement

b. Accurate recording of sales and deliveries

c. Competent assessment of the trend indicated by results

20.8. Inventory checks should integrate periodic checking for water.

Tank Testing

20.9. Suspected leaks should be thoroughly investigated and may involve taking the UST out of service, inspecting it and carrying out precision UST tests.

20.10. The investigation sequence should include:

a. For reconciliation figures, ensure the arithmetic is correct and all deliveries and other stock movements have been accounted for.

b. Wetstock control SOPs should be carried out properly


c. Check for:

i. Obvious leaks from pipe joints in manhole covers, drainage systems and around the dispenser base

ii. Increase in petrol smell

d. Check:

i. Dispensers for accuracy

ii. UST contents measuring devices for accuracy

iii. USTs for water ingress

e. Test pipework for leaks

Dispensers

20.11. It is recommended that dispensers be fitted with leak proof tray or membrane to ensure product from small internal leaks flows to the forecourt surface where it will be noticed and diverted to the site drainage system

20.12. Leak proof sumps may also be used and should be:

a. Impervious to the fuel

b. Adequately protected against corrosion

c. Sealed at all pipe entries to prevent fuel leakage into the ground and ingress of ground water

d. Designed to allow easy removal of fuel or water that may accumulate

e. Dispensers should be operated by dedicated personnel.

f. Provide, maintain and mark clear routes to, from and around dispensers

20.13. Check that dispensers are undamaged, working and properly maintained

20.14. Do not allow damaged dispensers to be activated/used

20.15. Use dispensers with time limited or volume limited cut offs

20.16. Ensure that dispenser nozzles and couplings are regularly inspected and properly maintained.

20.17. Do not allow dispensers with damaged hoses to be used

20.18. All installations should be inspected for integrity every six months

Pipework

20.19. Testing of pipework will be required if a leak is suspected

20.20. If pipework is subject to corrosive failure it should be replaced


20.21. If pipework is replaced consider fitting an under the dispenser check valve and removing angled check valve on the UST lid to provide immediate drain back

20.22. Excavated pipework should be removed from site as soon as possible and disposed of safely in accordance to EMC (Waste management) Regulations

20.23. Water used to flush out the pipework should be collected for safe disposal in accordance to EMC (Waste management) Regulations

Storage Tanks

20.24. Any corroded or defective UST should be taken out of use.

20.25. For existing USTs corrosion control can be using an impressed current system.

20.26. A method for testing the effectiveness of cathodic protection should be provided.

OWSs

20.27. The waste water from vehicle washes and steam cleaners produces large volumes of water, which are contaminated with detergents, oil and road dirt and should be managed in a totally separate drainage system to the one used to drain the forecourt to the OWS.

Tanker Standing Areas

20.28. The standing area should be maintained in good condition. If the area is not well located site management should implement control measures to ensure that fuel can be safely offloaded.

Fill Points

20.29. Vapors can accumulate near the fill points during offloading. Site management can mitigate the consequences of vapor emissions, leaks or spills:

a. Excluding non-essential people from the offloading area

b. Providing adequate spill and leak control

c. Ensuring warning and information notices are legible and in place.

d. Providing an adequate supply of dry sand and absorbent material


Portable Fuel Containers

20.30. Portable containers must be:

a. Suitable for storing fuel

b. Constructed and maintained so that they are reasonably secure against breakage and leakage

c. Fitted with a secure closure

Delivery Procedures

20.31. Delivery procedures should include UST ullage checks to avoid overfills.

20.32. Risks can be reduced if dedicated tanker unloading stands are provided or if fuel is delivered at quiet times when fewer people are on or around sites.

20.33. Site management should establish SOPs for product delivery and ensure staff are familiar with them and that they are followed.

20.34. The competence of the tanker drivers will also determine how safely vehicles move around sites and make deliveries.

Periodic Inspections

Inspections

20.35. Regular assessments involving site management and operators to identify improvements made and areas for further improvement are strong stimuli.

20.36. Complaints and incidents affecting soil, groundwater, surface water and air quality should be reviewed by site management.

20.37. Periodic visual inspections of the site can help ensure that it is in satisfactory operating condition

20.38. Certain equipment that is vulnerable to abrasive, impact or malicious damage needs to be inspected on more frequent basis.

Hoses

20.39. Daily inspections of hoses should reduce the risk of spillages resulting from bursts or cuts.

20.40. Gradual weakening of sections of hoses will occur where they chafe against the ground or through impact of damage if the hose is crushed against the pump island by the wheel of a vehicle or malicious damage by vandals


Vent Pipes

20.41. Vent pipe’s should be in the site’s inspection and maintenance program and examined for corrosion control.

Vapor Recovery Systems

20.42. An effective maintenance regime is required for vapor recovery systems.

20.43. Staff training plays an important role in safety/efficiency aspects of the vapor recovery system as they can recognize and report problems that would indicate a fault in the system.

20.44. If for operational reasons, it is necessary for the UST to remain empty of product on a short term basis, it should be isolated from the manifolded vapor recovery system if other USTs are to continue receiving products.

Overfill Protection

20.45. Where overfill protection devices are installed, they must be maintained in a safe working condition.

20.46. Accurate stock control will ensure that USTs receive the correct amount of product.

20.47. Where it is necessary to unload the road tanker by splitting a compartment between two USTs, procedures must be in place to reduce the risks of overfills occurring.

Dealing with Spillage

20.48. Site management must have SOPs and equipment to deal with spillages.

20.49. Site management should provide absorbent materials for mopping up spills.

Stormwater

20.50. Recommended practices to prevent Stormwater Pollution from sites include:

a. Prevent discharges when changing automotive fluids.

b. Use special care to prevent leaks from wrecked vehicles.

c. Quickly cleanup spills of all sizes.

d. Keep wastes from entering floor drains and storm drains.

e. Train employees on pollution prevention activities


21. Contractor Safety Management

Contractor Management

21.1. Contractors are routinely engaged to carry out maintenance work on equipment.

21.2. Before contractor starts work, site operator will need to certify that the contractor is capable of undertaking the work in a safe manner and is familiar with:

a. Hazardous nature of petroleum products and location of hazardous areas

b. Site Operating Procedures

c. Location of USTs and pipework

d. Other work that may be simultaneously taking place on site

e. Location of underground services

f. Items, equipment or information necessary for HSE compliance

21.3. Site management and contractor should be clear about:

a. How operations will affect each other’s work

b. Responsibility for managing work on site and controlling subcontractors

c. Timing and segregation of work to ensure that the activities of one person do not create risks for the other

21.4. It may be necessary to stop a particular activity in the area where contractors are working

21.5. Ensure safe work practices at sites through the use of detailed SMS. Responsibility of drawing up the SMS lies with the Contractor.

Permit to Work System

21.6. Some maintenance or repair work may be high risk because it has the potential to cause a serious pollution incident.

21.7. .

Contractor Staff Training

21.8. Every person undertaking on-site maintenance shall have received training on specific equipment being maintained.


21.9. Site operators should determine that maintenance contractors have undergone training and refresher training (within the last five years)

22. C-Stores

General

22.1. Convenience Stores including Fast Food Establishments and/or Cafeterias can do a lot to minimize or reduce potential cost increases by incorporating simple waste prevention and recycling programs and procedures that will eliminate much of the waste that is thrown away.

22.2. With proper purchasing, handling, careful preparation and storage, food service establishments can help reduce waste and save money.

Siting/Location

22.3. C-stores, as required with other buildings by NFPA 30, shall be sited at least 15.25 metres from the nearest dispenser.

Beverages

22.4. Serve non-alcoholic beverages from a beverage dispenser, , and buy prepackaged milk or juices . Alcoholic drinks shall not be served to patrons as required by KS 2506.

Grocery items

22.5. Buy shelf-stable food supplies in bulk when sales volume and storage space allows.

Produce handling and Storage

22.6. Check produce deliveries carefully for rotten or damaged product, and return any substandard product.

22.7. Rotate perishable stock at every delivery to minimize waste due to spoilage.

22.8. Clean coolers and freezers regularly to ensure that food has not fallen behind shelving and spoiled.

22.9. Arrange refrigerated and dry storage areas to facilitate easy product access and rotation.


22.10. Store raw vegetables and other perishables in reusable airtight containers to prevent unnecessary dehydration and spoilage.

Food Preparation and Storage

22.11. Adjust inventory levels on perishables to reduce waste due to spoilage or dehydration.

22.12. Whenever possible, prepare foods to order.

22.13. Adjust the size of meal portions, if left overs are consistently returned.

22.14. Pre-cool hot foods (in an ice bath) before refrigerating.

22.15. Wrap freezer products tightly, label, and date them. Ensure they are used in a timely fashion, to minimize waste due to freezer burn.

Restaurant Supplies

22.16. Use reusable table linen and dinnerware.

22.17. Use cloth towels for cleaning, rather than the paper equivalents.

22.18. Use plastic trash can liners made of recycled HDPE instead of LDPE or LLDPE.

22.19. Purchase cleaning supplies in concentrate form.

22.20. Use multipurpose cleaners that can be used for all types of surfaces rather than cleaners that are job specific. Whenever possible, use cleaning agents that are less hazardous or non-hazardous.

22.21. Use reusable hats for kitchen employees instead of disposable ones.

Production and Service Areas

22.22. Implement a monthly cleaning and maintenance program for equipment.

22.23. Keep refrigeration in good running order to prevent unnecessary spoilage and reduce energy costs. Clean the coolers and freezers regularly to ensure food has not fallen behind the shelving and spoiled.

22.24. Check syrup-to-water calibration on beverage dispensers regularly.

22.25. Keep oven equipment calibrated to prevent over baking.

22.26. Clean fryers and filter oil daily. Use a test kit to determine when to change fryer oil.

22.27. Effective product handling and storage prevents spoilage and unnecessary wastes. Rotate perishable stocks at every delivery to minimize waste due to spoilage. Use the back-to-front system where new products are placed on the back of the shelf, while the older products are rotated to the front.


Back of the House

22.28. Create incentives for staff to reduce breakage of china and glass wares.

22.29. Place rubber mats and dish washing stations to reduce china and glass wares breakage.

22.30. Have employees use permanent-ware mugs or cups for their drinks.

22.31. Check for discarded trays and flatware before throwing out trash.

Front of the House

22.32. Serve straws from health department-approved dispensers rather than pre-wrapped, and offer only one straw per drink.

22.33. Use serving containers in sizes that meet the packaging needs of menu items without having excess packaging material.

Recycling

22.34. Set up a rendering service for your waste grease, fat, or used cooking oil.

22.35. Set up a recycling program with local collectors (e.g. cardboard, glass).

22.36. If beverages are served in cans or bottles, place a recycling bin in the C-Store for customers' empty beverage containers.

Employees

22.37. Ask staff for their input and assistance on what can be done to reduce waste.

22.38. Reward them for good ideas. Including employees in the decision-making process will help ensure participation in efforts to reduce waste, and will result in higher productivity, better morale, and lower costs.

Purchasing

22.39. Smart purchasing will save C-Stores the most money of all waste management practices.

22.40. Demand that suppliers of new and existing products package products in ways which reduce the amount of material being disposed.

22.41. Purchase bulk and reusable products to save money and reduce waste.

22.42. Serve carbonated beverages from a beverage dispenser rather than by the bottle or can.


Paper Supplies

22.43. Purchase paper products made from recycled materials.

22.44. Use reusable coasters instead of paper napkins when serving beverages..

22.45. Store and handle unwrapped paper supplies to prevent the products from inadvertently falling on the floor.

Grease

22.46. Grease overflows are costly to cleanup, may expose customers or employees to health risks and pollute by entering local streams and rivers untreated.

22.47. If the C-Store produces grease wastes, ensure the grease removal device is properly sized. Never dispose of grease wastes directly to the sewer or in the trash dumpster.

22.48. Contract with a grease disposal company for waste grease pick-up.

Hazardous Materials

22.49. Hazardous Materials are contained in many commercial cleaning products. Never pour hazardous wastes down the drain.

22.50. Never mix different wastes. Use alternative materials that are less toxic. Look for “non-toxic,” “non-petroleum based,” “free of ammonia, phosphates, and dye, or perfume,” or “readily biodegradable” on the label.

22.51. Avoid chlorinated compounds, petroleum distillates, phenols, and formaldehyde.

22.52. Use phosphate-free, biodegradable detergents on the market.

Pests

22.53. Pests can be reduced with good housekeeping techniques.

22.54. Keep doors shut when not in use; place weather stripping on doors; caulk and seal openings in walls; install or repair screens; keep vegetation and shrubs at least one foot away from structures; and store food and wastes in tightly sealed containers. This will reduce the need for chemical controls.


23. Training

General

23.1. Assuming that engineered systems are properly installed and maintained, it is the operation of the site that presents the greater risk.

23.2. Risks can arise as a result of inadequate training or operator error.

23.3. Training requirements form an integral part of operational control measures.

23.4. The key issues to be addressed by training are:

a. Understanding of the need for environmental protection

b. Awareness of the risks posed by USTs

c. Implementation of risk management procedures and controls.

23.5. The regulatory regime requires proof that site staff has received training with regard to the safe storage and dispensing of petroleum products.

23.6. Additional training to meet legal requirements covers training to ensure the health and safety of personnel working at sites.

Responsibility

23.7. Site management is responsible for providing training when employees are recruited, repeat it periodically, and provide further training when changes occur.

23.8. Employees must use all work items provided by their employer in a safe way and in accordance with the training and instructions they receive.

Importance of Training

23.9. Training is vital in helping to prevent incidents and minimizing consequences if they do happen.

23.10. Employees need to know exactly what their duties are in normal and emergency situations. They need to identify potentially dangerous situations and know what to do to prevent incidents developing.

Training Needs

23.11. Employees need the right amount of training to enable them to perform their work safely.


23.12. Involve and consult employees as they know about hazards and risks occurring in everyday situations.

23.13. Cater also for unusual occurrences, such as a vehicle breakdown on the forecourt, which causes an obstruction.

23.14. Decide what training should cover and use risk assessment to identify what is appropriate for each person.

23.15. Employees with particular responsibilities will need specific training:

a. Product receipts

b. Activating and controlling dispensers

c. Safe dispensing procedures

d. Safe filling of containers

e. Spillage control and emergency procedures

f. Managing and checking wet stock

g. Competency of relief employees

h. On-site hazards and risks

i. Risk management measures and procedures

j. Emergency procedures

k. Control of visiting contractors

23.16. Particular issues which should be covered by training on environmental issues include:

a. Groundwater (and general) environmental sensitivity

b. Consequences of air, soil and groundwater pollution

c. Site specific risks

d. Site specific environmental protection measures

e. Individual’s specific role and responsibility.


Performance of Training

23.17. Training must take place during working hours and site management should not expect or ask people to use their own time.

23.18. Site management is free to decide how it should be carried out and ensure that all information, instructions and training are understood by those who receive it.

23.19. Carry out refresher training or practice exercises periodically. This is particularly important where skills are not regularly used, such as emergency procedures.

23.20. It is good practice to ask for feedback from staff on the training they have received and to keep a record of the training, qualifications and any results or assessments from supervisory staff.

23.21. The quality of training and the associated records are useful in assessing the competence of staff.

24. Records

24.1. The site operator shall ensure that adequate records are kept of product monitoring and reconciliation system or the operation of any other suitable leak detection system or leak prevention system such that any leak or spill of product from the site is detected before a hazardous situation can arise.

24.2. Such records and documents should be retained for a minimum of 3 years and if requested be made available to the ERC as soon as is reasonably practicable.

24.3. The site operator shall ensure that adequate records are kept of the maintenance regime and repairs carried out to the:

a. Site; including the USTs, pipework, pumps and dispensers

b. Spillage containment system; including drainage gullies and oil separators.

c. Details of the equipment on site (type, age and location)

d. Equipment testing and calibration

24.4. The site operator shall ensure that adequate records are kept of site operations including:

a. Current Retail Site License and conditions of licensing

b. Detailed Site Plans

c. Site Policies


d. Standard Operating Procedures

e. Diagram of hazardous zones

f. Current Site UST to Pump Diagram

g. Wetstock Accounting

h. Training

i. Results of Risk Assessments

j. Product Delivery Documents

k. Material Safety Data Sheets

l. Emergency Procedures

m. Pollution Response Plan

n. Correspondence and Reports from Regulatory Agencies


25. References

25.1. Energy Act 2006

25.2. Environmental Management and Co-ordination Act, 1999.

25.3. Environmental Management and Co-ordination (Controlled Substances) Regulations 2007.

25.4. Occupational Health and Safety Act 2007

25.5. KS 200 (2002) - Specification for storage tanks for

PETROLEUM INDUSTRY - Part 1: Carbon steel welded horizontal cylindrical storage tanks (Second Edition).

25.6. KS ISO 1998 – 5 - PETROLEUM INDUSTRY –

Terminology – Part 5: Transport, storage and distribution.

25.7. KS 1968 (2006) - The petroleum industry – Electrical

Installations in the distribution and marketing sector - Code of practice.

25.8. KS 1969 (2006) - The petroleum industry – The

Installation of underground storage tanks, pumps / dispensers and pipe work at SERVICE STATIONS and consumer installations - Code of practice.

KS 2506

KS 2506:2014 Petroleum facilities — Retail and consumer outlets — Specification Petroleum Tanks and Installations

NFPA 30 National Fire Protection Association

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26. Contacts

26.1. ENERGY REGULATORY COMMISSION (ERC)

Head Office: Eagle Africa Centre - Upper Hill

Telephone: 254-020-2717627/31/75; 254-020-2847000/200

Cell Phone: 0722200947; 0734414333

Fax: 254-02-2717603

Postal Address: P.O. Box 42681 - 00100 NAIROBI, KENYA

Email (General Information): Website: www.erc.go.ke

26.2. KENYA BUREAU OF STANDARDS (KEBS)

Popo Road, Off Mombasa Road

Behind Bellevue Cinema

P.O Box 54974-00200

Nairobi – Kenya

Tel: (+254 20), 605506,605550, 605573,605574,605610,605634, 605642,605673,603482, (+254 20) 6948000/605490

Mobile: +254722202137/8, +254734600471/2

Fax: (+254 20) 60403, 609660

Email: [email protected]

Website: www.kebs.org

26.3. NATIONAL ENVIRONMENT MANAGEMENT AUTHORITY (NEMA)

Popo Road, Off Mombasa Road

Behind Bellevue Cinema

P.O Box 67839 – 00200

Nairobi – Kenya

Tel: (+254 20) 6005522/6/7

Mobile: 0724 - 253 398 /0728-585 829 / 0735-013 046 / 0735-010 237

Fax :( 254)-020-6008997

Email:[email protected]

Website: www.nema.go.ke

http://www.erc.go.ke/�

mailto:[email protected]�

http://www.kebs.org.ke/�

http://www.nema.go.ke/�

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