Since 2019, the New South Wales Environmental Protection Agency (NSW EPA) has given local councils the responsibility of regulating Underground Petroleum Storage Systems (UPSS). To do so, sites must have a Fuel System Operation Plan in place. Without it, the site is banned by law from operating.
While the UPSS is responsible for the storage and supply of fuel, the FSOP is responsible for describing how the underground fuel system is configured, managed, and maintained and what steps are taken to monitor and rectify any leaks and spills. Essentially, these plans are meant to avoid fuel-related accidents that can put the safety of the station, employees, consumers, surrounding community and environment in danger.
Why Is It Important?
The FSOP is a legally compliant reference document regarding everything to do with the UPSS, allowing you to monitor your underground system carefully. Since these systems have the potential of leaking and causing soil and groundwater contamination, they pose a significant environmental threat. The FSOP provides a readily available plan to maintain these threats and prevent future occurrences.
Soils or groundwater affected by fuel leaks can result in your property being classified as contaminated, which means immediate shut down for your business. In addition, undetected leaks can cost a considerable amount of money and resources to clean up – another negative impact for your business. Small leaks can potentially cost tens of thousands of dollars to clean up, whereas large leaks can cost millions.
Bottom line: no matter the size of your operation, leaks can be disastrous, and an FSOP can be your saving grace.
Requirements of a Fuel System Operation Plan
Having a Fuel System Operation Plan is a requirement under Section 18 of the Protection of the Environment Operations Regulation specific only to a UPSS, excluding any above-ground fuel storage. The FSOP may be kept in a hard copy or electronic format and can be a single document or a collection of documents.
All operational UPSS sites must follow the sub-requirements under Section 18, including the following:
- Must be on the UPSS site at all times (either electronic or hard copy)
- Must be accessible to all operational personnel involved in fuel dispensing, as well as the Appropriate Regulatory Authority (ARA) upon request
- Must be continuously updated
- Must include details of the site’s loss monitoring system
- Must consist of an incident management procedure (leaks and contamination)
Building Your FSOP
If you’re looking to build or update your FSOP, ServoPro can help. Through our partnership with NEO Consulting we help businesses develop and implement legally compliant systems, among many other services. Members can access the Fuel System Operation Plan template (previously called an Environmental Protection Plan) in our member portal. This template can be edited to suit any UPSS site.
Got more questions? Get in touch with us and we can help you get your FSOP orgainsed. We can also help with other areas of environmental compliance through our partnership with NEO Consulting who provide a variety of environmental services ensuring petrol stations are compliant in Australia.