John Chapple, Environmental Compliance Officer at North Coast Petroleum is responsible for overseeing North Coast Petroleum’s environmental obligations. John has experience managing the installation of underground monitoring wells as well as the development of Environmental Protection Plans (EPP).
At North Coast Petroleum minimising their environmental impact is a high priority. Having John as part of the team ensures that their own sites are fully compliant and specialist help and advice can be offered to their retail customers.
Environmental compliance issues are an area of much confusion for Service Station owners, so I asked John a couple of questions to help get a better understanding of the issues.
Are Environmental Protection Plans (EPP) a legal requirement under Underground Petroleum Storage System (UPSS) regulations? Could you give us a brief outline of what an EPP is?
An EPP is legally required under clause 19 of the UPSS Regulation 2014. An EPP is a document created to include the following information:
- Specific information about the storage system, including identifying the ‘person responsible’ for the system;
- A loss monitoring procedure (SIRA);
- An incident management procedure;
- Details about system maintenance;
- The current ‘as built’ drawings for the system;
- A plan of the storage site;
- A copy of industry standards that have been followed in constructing and maintaining the UPSS and
- A copy of the specifications of the UPSS.
Among Service Station Owners there is some confusion around the underground wells for monitoring groundwater. Is it a legal requirement that all Service Stations have these wells installed?
Part 3 of the UPSS Regulation 2014, requires a secondary leak detection system be installed on site (Groundwater Monitoring Wells). A storage system cannot be legally used unless a secondary leak detection system is in place. Some exemptions do exist when it can be proven that your site is not located within a NSW environmentally sensitive zone. These maps can be found at the link below.
http://www.epa.nsw.gov.au/clm/listUPSSexemptionmaps.htm
Which government department or council is responsible for checking that Service Stations are complying with UPSS requirements? Have you heard of them doing any site audits?
NSW EPA is currently responsible for checking that sites are currently complying with the UPSS Regulation 2014. This was due to change in June 2017 when local councils (being the local regulatory authority) would become responsible for compliance.
The handover date is yet to be ratified. NSW EPA and council are currently in the process of undertaking site audits to ensure that service station sites have made some effort to be compliant with the regulations which were initially implemented in 2008.
Are there any other aspects of the UPSS regulations that Service Station operators should be aware of?
All sites should have an approved SIRA (Statistical Inventory Reconciliation Analysis) program operating. It should be able to record losses of 0.76l/hr. It cannot be overstated how important this software can be when monitoring potential losses from the UPSS.