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TECHNICAL GUIDANCE NOTES

OPERATION AND MAINTENANCE OF PETROLEUM TERMINALS

NOVEMBER 2015

Operation and Maintenance of Petroleum Terminals

Energy Regulatory Commission

Contents

1. Introduction ...............................................................................15

2. Disclaimer ..................................................................................15

3. Operation and Maintenance ...................................................15

4. Objective .....................................................................................16

5. Scope ............................................................................................16

6. Availability ................................................................................16

7. Legal Framework ......................................................................16

8. Environmental Concerns .........................................................17

General ...................................................................................................... 17Vapour Recovery System ....................................................................... 17Top Loading ............................................................................................. 18Bottom Loading ....................................................................................... 18Top Filling ................................................................................................ 18Bottom Filling .......................................................................................... 18

9. OPERATIONS AND MAINTENANCE PRACTICES ......18

Operational Activities ............................................................................ 18Standard Operating Procedures ........................................................... 19Pollution Incident Response Plan ........................................................ 20Preventive and Housekeeping Requirements ................................... 21Labelling of AST ..................................................................................... 22Security ...................................................................................................... 22

10. High Pollution Risk Operations ............................................23

11. Road Tanker Operator Responsibilities ..............................24

12. Terminal Operator Responsibilities .....................................24



13. Employees Responsibilities ...................................................25

14. Loss Investigation .....................................................................25

15. Product Deliveries by Road Tankers ....................................26

16. Storage System ..........................................................................27

17. Loading .......................................................................................27

18. Oil Spills .....................................................................................29

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

20. Drainage .....................................................................................29

21. Maintenance and Repair .........................................................30

General ...................................................................................................... 30Periodic Inspections ................................................................................ 31Third Party Inspections .......................................................................... 32In-service Inspections ............................................................................. 33Out of Service Inspections .................................................................... 34Hoses .......................................................................................................... 35Vent Pipes ................................................................................................. 36Vapour Recovery Systems ..................................................................... 36Stormwater ................................................................................................ 36Annual Equipment Check ..................................................................... 36Frequency of Inspection ......................................................................... 36

22. Contractor Safety Management .............................................37

Contractor Management ........................................................................ 37Permit To Work System ......................................................................... 38Contractor Staff Training ....................................................................... 38

23. Monitoring Requirements ......................................................38

Product Transfer ...................................................................................... 38



Weekly Monitoring ................................................................................. 38Monthly Monitoring ............................................................................... 38Leak Detection ......................................................................................... 39Corrosion Protection ............................................................................... 39Record Keeping ....................................................................................... 40

24. Control Practices for Pollution Prevention .........................40

Control System ......................................................................................... 40Management of Terminal Operations ................................................. 41Leaks and Spills ....................................................................................... 41Oil Loss Accounting ................................................................................ 42Tank Testing ............................................................................................. 42Loading Arms ........................................................................................... 43Product Receipts by Road ...................................................................... 43Pipework ................................................................................................... 43Storage Tanks ........................................................................................... 43Stormwater Systems ............................................................................... 44Separators .................................................................................................. 44Product Receipt Procedures ................................................................... 44

25. Canteens .................................... Error! Bookmark not defined.

General ..................................................... Error! Bookmark not defined.Beverages .................................................. Error! Bookmark not defined.Produce Handling and Storage ............ Error! Bookmark not defined.Food Preparation and Storage .............. Error! Bookmark not defined.Restaurant Supplies ............................... Error! Bookmark not defined.Production and Service Areas .............. Error! Bookmark not defined.Back of the House ................................... Error! Bookmark not defined.Front of the House .................................. Error! Bookmark not defined.Recycling .................................................. Error! Bookmark not defined.Employees ................................................ Error! Bookmark not defined.



Purchasing ................................................ Error! Bookmark not defined.Paper Supplies ........................................ Error! Bookmark not defined.Hazardous Materials .............................. Error! Bookmark not defined.Pests ........................................................... Error! Bookmark not defined.

26. Training ......................................................................................45

General ...................................................................................................... 45Responsibility .......................................................................................... 45Training Needs ........................................................................................ 46Performance of Training ........................................................................ 46

27. Records ........................................................................................47

28. References ..................................................................................49

29. Contacts .......................................................................................50



Acronyms

Acronym Description

API American Petroleum Institute

AST Aboveground Storage Tank

ATG Automatic Tank Gauging

BP Best Practice

CO Carbon Dioxide 2

COP Codes of Practice

DOSHS Department of Occupational Safety and Health Services

ERC Energy Regulatory Commission

ESD Emergency Shutdown

GMW Ground Monitoring Well

H2 Hydrogen Sulphide S

KEBS Kenya Bureau of Standards

KS Kenya Standard

LPG Liquefied Petroleum Gas

NEMA National Environment Management Authority

OSR Oil Spill Response

OWS Oil Water Separator

PIRP Pollution Incident Response Plan

PPG Technical Guidance Notes

PVC Poly Vinyl Chloride

PVR Pressure Vacuum Relief

RVP Reid Vapor Pressure

SCS Secondary Containment System

SOPs Standard Operating Procedures

SUDs Sustainable Drainage Systems

VOC Volatile Organic Compounds



Terminology

Terminology Description

Ancillary Equipment

Electrical, vapor recovery, access or other systems and devices, including, but not limited to, devices, such as piping, fittings, flanges, valves and pumps used to distribute, meter, monitor or control the flow of regulated substances to or from a storage tank system.

Aquifer A geologic formation, group of formations or part of a formation capable of a sustainable yield of significant amount of water to a well or spring.

Automatic Tank Gauging

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

Best Practices Best Practices are generally-accepted, informally-standardized techniques, methods, or processes that have proven themselves over time to accomplish given tasks.

Often based upon common sense, these practices are commonly used where no specific formal methodology is in place or the existing methodology does not sufficiently address the issue.

The idea is that with proper processes, checks, and testing, a desired outcome can be delivered more effectively with fewer problems and unforeseen complications.

Bulk Storage Terminal

Premises consisting one or more tanks for storing petroleum or liquefied petroleum gas in transit or for sale

Breathing Losses Emissions that occur when vapors are expelled from the tank due to changes in temperature, barometric pressure, or both. Breathing losses are also known as standing losses.

Cathodic Protection A technique to prevent corrosion of a metal surface by making that surface the cathode of an electrochemical cell.

Certified Inspector A person certified by DOSHS to conduct inspections of tanks or storage tank facilities and who may conduct environmental audits. A certified inspector may not be an employee of a tank owner.

Change Any modification other than “replacement in kind.”

Cleaning Process of removing vapor, sludge, or rinsing Liquid from a storage tank.




Community Those residing near to an operating location/tank truck route to whom our activity is easily detectable either visually, aurally or by another means. It also encompasses key decision makers or those having a significant influence over local opinion for the locality.

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

Compatible The ability of two or more substances to maintain their respective physical and chemical properties upon contact with one another for the design life of the tank system under conditions likely to be encountered in the tank system.

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

Compliance Adhering to legal, regulatory or company requirements.

Connected Piping All piping including valves, elbows, joints, flanges and flexible connectors attached to a tank system through which regulated substances flow.

Contaminant Any substance with potential to degrade the environment and cause harm to people.

Containment Structure

Anything built, installed or established which comes in contact with regulated substances that are spilled, leaked, emitted, discharged, escaped, leached or disposed from a storage tank or storage tank system. The term includes, but is not limited to, a vault, dike, wall, building or secondary containment structure around an underground or above-ground storage tank, or any rock or other fill material placed around an underground storage tank.

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

Code of Practice • Documented and generally accepted rules of carrying out a practice

Corrective Action Taking measures to prevent, mitigate, abate or remedy releases, pollution and potential for pollution, nuisances and damages to the public health, safety or welfare.

Corrosion Protection

The protection of metal from deterioration. The deterioration may be due to a natural electrochemical reaction between the metal and the soil or other electrolyte, or because of stray direct currents.




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

Degassing Process of removing organic gases or vapors from a storage tank.

Emergency Containment

A containment structure which serves toconvey, capture and contain the total volume of an anticipated release of regulated substance from an aboveground or underground storage tank system and which is expeditiously emptied.

Emergency Shutdown Device

Critical safety devices that shutdown operations or processes during emergencies

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

Environmental Audit

Periodic inspection of a facility to check continuous compliance to environmental laws

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.

Gantry A framework on loading islands, under or besides which one or more loading bays with articulated loading arms.

Gauging Device A device to measure to measure the state of product in pipelines and tanks

Ground Monitoring Well

“Ground Monitoring Well” means any cased excavation or opening into the ground made by digging, boring, drilling, driving, jetting or other methods for the purpose of determining the physical, chemical, biological, or radiological properties of groundwater.

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 a hazard e.g. noise, toxic substances, flammable vapors and gases

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.

In-service Inspection

A scheduled aboveground storage tank external inspection to determine tank system serviceability and compliance with requirements in applicable industry standards. This inspection shall be conducted by a certified API Inspector. The tank system may be in operation during this inspection.

Inspection Activities

Activities to inspect all or a part of storage tank system or storage tank facility. These activities include, but are not limited to, evaluation of:

• Storage tank system structural integrity. • Construction and major modification. • Facility operation.

Install Activities to construct, reconstruct or erect to put into service a storage tank, a storage tank system or storage tank facility.

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

Landing Losses Emissions that occur from floating-roof tanks whenever the tank is drained to a level where its roof rests on its deck legs (or other supports).

Liquid Trap Sumps, well cellars and other traps used for the purpose of collecting oil, water and other liquids. The liquid traps may temporarily collect liquids for subsequent disposition.

Loading Arm/Hose

A piping arrangement for filling in a truck.

Loading Bay An inlet for trucks to stay under product loading.

Loading Facilities Facilities consist of pumping and filling installations.

Maintenance The normal operational upkeep of a petroleum storage facility

Major Modification An activity to upgrade, repair, refurbish or restore all or any part of an existing petroleum storage facility which:

• Alters the design of that petroleum storage facility. • May affect the integrity of that petroleum storage facility.




The term includes an activity directly affecting the tank portion of the petroleum storage facility or an activity directly affecting an underground component of the storage tank system.

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

Managers Personnel with line management or supervisory responsibilities.

Minor Modification An activity to upgrade, repair, refurbish or restore all or part of an existing storage tank system or storage tank facility which does not alter the design of that storage tank system or storage tank facility, but, which may affect the integrity of that storage tank system or storage tank facility.

The term does not include an activity directly affecting the tank portion of the storage tank system or an activity directly affecting an underground component of the storage tank system.

Modify To conduct an activity that constitutes a major modification or a minor modification.

Monitoring System A system capable of detecting releases in connection with an aboveground or underground storage tank.

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

Occupational Health

Includes all activities addressing workplace health hazards and employee health. It includes identification, evaluation, and control of health hazards; monitoring of worker exposures; communication of health hazards knowledge, determination of employees medical fitness to do their work and providing or arranging for medical services necessary for the treatment of occupational illnesses or injuries.

Operation Any activity involving the production, manufacture, use, storage or movement of material. Also, the utilization of resources by a “unit” to produce an output.

Operational Life The period beginning when installation of the tank system has commenced until the time the tank system is properly decommissioned.

Operator A person, who manages, supervises, alters, controls or has responsibility for the operation of a storage tank.

Out of Service A scheduled AST tank inspection that encompasses both internal and external examination to determine tank system serviceability and compliance with applicable industry




standards. This inspection shall be conducted by a certified AST Inspector. The tank system may not be in operation

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

Pathway A route by which the contaminant can reach the receptor high pressure hand washes

Permanent Water Supply

A well, interconnection with a public water supply, extension of a public water supply, similar water supply or a treatment system, capable of restoring the water supply to the quantity and quality of the original unaffected water supply.

Permit Authorization granted to a person to enable the carrying out of any activity in the energy business, where a license is considered onerous

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

Petroleum System A storage tank system that primarily contains petroleum, and may contain additives or other regulated substances. The term includes systems containing motor fuels, jet fuels, distillate fuel oils, residual fuel oils, lubricants, petroleum solvents and used oils.

Pipework A hollow cylinder or tubular conduit that is constructed of non earthen materials. The terms include the associated fittings such as unions, elbows, tees and flexible joints.

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

Public Water System

A system which provides water to the public for human consumption.




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.

Release Spilling, leaking, emitting, discharging, escaping, leaching or disposing from a storage tank into surface waters and groundwaters or soils or subsurface soils in an amount equal to or greater than the reportable released quantity

Replacement In-kind

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

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.

Sanitary Sewer A collection system for waste water

Safety Method Statement

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

Site The place where something was, is or is to be located. May be a marketing location, a refinery, gas plant or offshore platform.

Source Substance capable of causing pollution or harm.

Spill Response Plan A written plan developed by the operator to respond to any spills at Vehicle Cleaning, Washing and Servicing facility at a site. As a minimum the plan shall define roles and responsibilities for spill response, contact names and numbers for appropriate agencies and a checklist for all spill response equipment.

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.

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.

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

Stormwater A pipe conduit, drain or other equipment or facilities for the collection and transmission of storm water or uncontaminated water.

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

Sustainable Drainage Systems

These 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.

Working Losses Emissions related to the movement of the liquid level in the tank. Working losses from fixed-roof tanks occur as vapors are displaced from the tank during tank filling and emptying.

Working losses from floating-roof tanks occur as the liquid level (and therefore the floating roof) is lowered, causing the liquid on the exposed tank walls and fittings to evaporate.



1. Introduction

1.1. These Technical Guidance Notes, herein referred to as “guidelines”, are intended to help those who operate and maintain Bulk Petroleum Terminals/Depots, herein referred to as “terminals”.

1.2. They have been produced by the Energy Regulatory Commission (ERC) in consultation with key government agencies. 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. Operation and Maintenance

3.1. It is a legal expectation that the Oil Industry will conduct its activities in such a way that proper regard is paid to the conservation of the environment. This not only means compliance with the requirements of the relevant legislation, but also constructive measures for the protection of the environment, particularly in respect to avoidance/containment of spillages.

3.2. The receipt, storage, loading operations and maintenance of terminal equipment vary with the size and complexity of the terminal, location and requirements of the consumers. Because of seasonal and other variations and product distribution, terminals shall be quite flexible.

3.3. The PPGs concentrate on good practices of operation, maintenance and repair of terminals to minimize the occurrence and environmental risks of releases and discharges.

3.4. In applying the PPGs, it should be recognized that actions to minimize the release of hydrocarbons and other contaminants 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 receipt, storage, loading of bulk petroleum products at terminals and the maintenance of terminal equipment are activities which give rise to significant safety risks. It is therefore necessary that proper safety procedures be set up and followed.

4.2. The PPGs will guide on good and correct practices for the operation and maintenance of terminals and describe the functions and responsibilities of operations and maintenance organizations in this activity.

5. Scope

5.1. The guidelines provide 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. BP for general operational control procedures, product loss detection and maintenance.

6. Availability

6.1. The PPGs are published by the ERC and can be accessed on ERC website.

7. Legal Framework

7.1. NEMA, DOSHS, KEBS together with ERC are responsible for enforcing laws that prevent pollution.

7.2. It is an offence to pollute the air, soil and water environment - deliberately or accidentally and the formal consent of NEMA will be required for the control and management of discharges and disposal of waste under the appropriate regulatory framework. Such consents are granted subject to conditions, and are not issued automatically.

7.3. Certain wastes are defined as “Hazardous Wastes” and are subject to more rigorous controls by NEMA.



8. Environmental Concerns

General

8.1. The risk the terminal presents to the environment should be assessed by controlling the presence of liquid hydrocarbons, spills and/or vapor. The level of risk can be affected by factors such as:

a. Frequency and method of receipt of petroleum products

b. Capacity and method of storage

c. Number of vehicles loading and unloading petroleum products

d. Number of employees and road tanker drivers regularly on or around the terminal

e. Age and type of the equipment.

f. Siting of terminal equipment (loading gantries, fire protection equipment, ASTs, pipework etc) in relation to other activities and facilities at the terminal.

g. Layout of the terminal in relation to vehicle access, exit and maneuvering

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

Vapour Recovery System

8.2. The recovery of product vapors is of interest for economic, safety and environmental reasons.

8.3. In most locations where bulk lorries are loaded, the total vapor emissions have not been considered a significant factor affecting the quality of the local environment.

8.4. At the design stage, the system should be reviewed to see if it becomes necessary to install a vapor collection system return line for poisonous, hazardous and high vapor pressure products.

8.5. It is essential to minimize the generation and emission of vapors during loading or unloading by eliminating the free fall of volatile products and reducing jetting and splashing. To minimize vapor emissions at loading facilities, bulk vehicles may have to be filled with a closed vapor system.



Top Loading

8.6. As the majority of loading facilities in service are top loading, the best solution would be to replace (or modify) the existing loading arms so that when volatile products are loaded, the manhole is sealed and vapors are diverted into a vapor return system.

Bottom Loading

8.7. Bulk vehicles equipped for bottom loading require a pipe connection from the vapor emission vent of each compartment into a vapor recovery manifold, which should terminate in a position which is easily accessible from ground level for use at both the loading bay and retail outlets as required.

8.8. The coupling connections for liquid and vapor must be different types.

8.9. Apart from installing a full vapor recovery system, considerable reduction in vapor emissions can be achieved by avoiding free fall and splashing of volatile products in top and bottom filling operations.

Top Filling

8.10. The loading arms should be designed to reach the end compartments of a vehicle tank in such a manner that the down pipe can penetrate vertically to the bottom of the compartment.

Bottom Filling

8.11. It may be necessary to fit deflectors in the vehicle tank at the point of entry of the product into the compartment.

8.12. Such measures have the following advantages:

a. Minimizing the amount of vapor formation

b. Reducing product losses.

9. OPERATIONS AND MAINTENANCE PRACTICES

Operational Activities

9.1. Terminal operations mainly consist of receiving/unloading and issuing/loading petroleum products from supply links (e.g. vessels,



pipelines, rail, and truck tankers) to ASTs, and onward to distribution links, typically rail and truck tankers.

9.2. Petroleum product terminals generally employ above ground piping systems, consisting of pipelines, hoses /loading arms, valves, instrumentation connections, meters, and pump stations, to transfer the product between tanks and transport links.

9.3. Other equipment includes vapor recovery systems and components of secondary containment zones in the loading bays for rail/tank trucks. Depending on the product, handling systems involving gravity, pump and/or compressor techniques are employed to move the product in and out of tanks.

9.4. The design, construction, and operation of these systems are subject to international standards.

9.5. Terminals involving tanker ships have distinct loading and unloading considerations and equipment.

9.6. Products may be contaminated with water from ship storage holds or from accumulation during storage due to condensation.

9.7. Water is regularly drained from tanks using manual and automatic systems, and diverted to a retention unit and a separator.

9.8. Recovered product is then pumped back into the original storage tank, and separated water is treated prior to discharge.

9.9. In addition to water drainage, the interior of tanks should be clean and corrosion free to avoid product contamination.

9.10. Tanks are typically cleaned and inspected according to an established maintenance schedule based on the characteristics of the product being stored.

9.11. For most petroleum products tanks, the inspection interval is typically 10 years, but this may be varied depending on condition of the tank in the last inspection cycle.

Standard Operating Procedures

9.12. Terminal operators shall implement and have documented operations and maintenance plans which assure conformance with applicable safety and operational standards, compliance with applicable pollution regulations and shall use safe work practices and procedures including:

• Understanding petroleum products and their properties. This is readily seen from the MSDS.

• Ensuring good ventilation by working in open atmospheres

• Working at ambient temperatures.



• Providing information, instruction and training to all terminal operatives.

• Reporting of all incidents e.g. leaks and providing clean-up and disposal facilities.

• Providing secondary containment solutions such as bunding or oversize drums.

• Taking special precautions when loading or unloading vehicles.

• Developing a succinct Emergency Plan.

Pollution Incident Response Plan (PIRP)

9.13. The root causes of incidents in the terminal is most frequently a lack of understanding of the nature of petroleum products and their hazards including:

a. Lack of training, meaning insufficient Manager/Supervisor/Operator understanding, awareness and competence

b. Poor control of petroleum products movements

c. Badly designed equipment or installation, leading to unnecessary emissions or even leaks

d. Poor selection of equipment (not suited to job)

e. Equipment failure

f. Poorly managed maintenance activities (especially in dismantling or disposal)

g. Badly managed transfer operations such as product receipts

h. Loading and unloading of petroleum products without taking adequate precautions

9.14. A PIRP and future updates, which address emergency response requirements shall be developed and sustained including:

a. Immediate notification of authorities as per PPG 1.12 Pollution Incident Response Planning for Petroleum Terminals

b. Dealing with fires, spills or leaks. Clean up of spills and leaks

c. Raising the alarm

d. Calling emergency services

e. Tackling fires, leaks or spills using suitable emergency response equipment in line with defined procedures

f. Shutting down the terminal in a safe way

g. Evacuating the terminal safely



h. An up-to-date and tested PIRP should be posted in a location known to and readily accessible by employees, including a list of names and telephone numbers of persons that should be contacted and under what situations.

i. A sufficient amount of clean up equipment and supplies should be kept in stock at all times, appropriate for the size of terminal.

j. Keep records of date and time of spill, authorities contacted and staff spoken to, steps taken in spill cleanup and recovery. In some cases, a written report will need to be submitted to a government body detailing the events. Having all the facts readily available will be helpful in this event.

k. Capacity of a separator at a terminal will be reduced when the flow of water is high, such as during a storm. When this retention capacity may be exceeded, the emergency shut-off valve on the discharge piping should be closed to ensure that oil does not escape into the storm sewer.

Preventive and Housekeeping Requirements

9.15. Terminals operators shall establish and implement preventive maintenance and housekeeping programs which protect the integrity of the system from degradation and protects the public health and environment.

9.16. Routine maintenance inspection procedures shall be established and implemented at each terminal.

9.17. An operator is responsible to assure that a visual inspection is performed once every 72 hours. The visual inspection may be accomplished by or supplemented with electronic surveillance and shall include:

a. A check of the terminal to ensure that no potential hazardous environmental conditions exist. This includes a check for evidence of a release for example, spill, overflow or leakage.

b. A check of the containment areas for accumulation of water and a confirmation that containment drain valves are secured in a closed position when not in use. If excessive water has accumulated, it shall be drained off and disposed of in accordance with applicable regulations of the Environmental Management and Coordination (Water Quality) Regulations, 2006.

9.18. The operator is responsible to assure that a maintenance inspection of the terminal and equipment is performed per service requirements. The maintenance inspection shall include:

a. An inspection of the AST System exterior surfaces for deterioration and maintenance deficiencies including a visual check for cracks,



areas of wear, excessive settlement and deterioration of the foundation and supports.

b. Ancillary equipment and appurtenances shall be visually checked for operational malfunctions.

c. An inspection of containment and transfer areas for cracks, defects and fire hazards.

d. A check of overfill prevention equipment and monitoring of the leak detection system.

e. The monthly maintenance inspection report shall be completed and signed by the individual who conducted the inspections and maintained for 3 years.

f. An operator is responsible to establish a process to assure that AST vents are operational and free of restrictions.

g. Housekeeping practices shall be established and implemented in a manner that reduces the possibility of accidental spills and safety hazards to terminal personnel.

Labelling of AST

9.19. An owner/operator is responsible to assure AST Systems are labeled/marked in accordance with API650.

9.20. Each AST must be labeled in accordance with API650 with the following minimum requirement :

a. tank number

b. tank contents

c. tank capacity

d. Installation, inspection and calibration date

9.21. Tank labels/marks shall be easily legible from outside the containment area and shall be capable of readily identifying the regulated substance stored.

9.22. The operator shall be capable of readily identifying the product transferred into and out ASTs and be able to determine flow control points, including pumps, valves and loading arms through labeling or other suitable means.

Security

9.23. The operator is responsible to assure that security measures and procedures based on the terminal location are established and implemented to protect the environment and the public.



9.24. Security measures and procedures may include, but are not limited to monitoring, fencing, lighting, access control, locked entrances and securing of valves and loading facilities.

9.25. Permanent valves through which oil can be discharged to open areas should be locked when not in use.

9.26. Display a notice informing users to keep valves and loading arms locked when they are not in use.

9.27. Pumps should also be protected from unauthorized use.

9.28. Valve and/or levers should be corrosion resistant, strong enough to be tamperproof when locked and marked to show whether they are open or closed. When not in use, they should be locked shut.

9.29. If the tank is being decommissioned then valve and/or levers should be fitted with a blanking cap or plug.

10. High Pollution Risk Operations

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

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

a. Receipt

b. Loading

c. Storage

d. Drainage

e. Maintenance and Repair.

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

a. Loading Gantries

b. Flexible couplings

c. Pipework

d. ASTs

e. Faulty OWS Operation

f. Possible discharges to soakaways through spills

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



11. Road Tanker Operator Responsibilities

11.1. Road Tankers will be issued with permits following inspection to KS 2180 and must be provided with a means of shutting off all the foot valves in an emergency.

11.2. Road tanker operators must have a procedure in place to deal with spillages that occur during loading and transportation.

11.3. Road Tanker drivers should be trained to implement that procedure if necessary.

12. Terminal Operator Responsibilities

12.1. Ensure that:

a. Staff and drivers comply with terminal rules and procedures

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

c. MSDS are provided

d. Employees are trained whenever new equipment or procedures are implemented.

e. They should be familiar with the hazards that accompany the material they are handling and be aware of potential sources of pollution

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

g. Accidents and incidents are recorded

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

i. Every AST has a suitable means of measuring the quantity of fuel inside it.

j. Measuring device are tested and calibrated at the time of installation to ensure accuracy, and are checked at regular intervals for damage and correct operation.

k. Manual dipping is accurate as automatic gauging and provides an adequate indication of AST contents.

l. Employees are aware of the emergency response plan and properly trained to carry it out so that they can respond in an emergency.

m. Employees should be familiar with the site layout and drainage. They should also understand the functioning of the components of the stormwater drainage system and to where they discharge.



n. Records showing date, the training received and employee’s acknowledgement should be kept of all employees training.

13. Employees Responsibilities

13.1. Ensure that:

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

b. Procedures for controlling emissions to the environment are fully observed

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

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

e. An opening for manual AST gauging and/or compartment manholes may release vapors into the atmosphere. This creates a fire and explosion hazard in the immediate area; therefore, such openings should be closed when not in use, particularly after loading and unloading.

f. Adequate information about the ullage of each AST at the terminal is available, at the time of receipt and delivery to tanker drivers who are to unload fuel there.

14. Loss Investigation

14.1. Methods for detecting loss of product include leak detection systems and oil loss monitoring, environmental monitoring and integrity testing.

14.2. Oil Loss Monitoring can take various forms including statistical inventory reconciliation (SIR) and while it may not detect a leak before product is lost to ground, the more sophisticated systems should provide a relatively rapid indication that a leak is occurring.

14.3. Environmental monitoring typically utilizes boreholes 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 boreholes.

14.4. Depending on the location of the boreholes 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 boreholes could fail to detect a contamination plume.



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

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

14.7. The preferred hierarchy for detecting the loss of product in accordance with API 2610 and API 653 is as follows:

Automatic Leak Detection Systems >Oil Loss Monitoring > Environmental Monitoring > Integrity Testing

15. Product Deliveries by Road Tankers

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

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

15.3. All sand or other material used for clearing or containing leaks or spills shall be disposed of safely. 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.

15.4. Particular care is needed when the person responsible for the delivery is unfamiliar with the terminal

15.5. The design of product receipt equipment and the operational procedures for receipt must assure the absence of measurable pollution during receipt.

15.6. On reaching the product offloading point and before starting the unloading operation, the driver must do the following:

a. Once the truck is parked, choke the wheels of the vehicle.

b. Put on the individual protection equipment, making sure that they conform to the safety equipment rules.

c. Verify that the offloading point complies with operational standards, there is no leakage and no functional anomaly

15.7. If the offloading is made using a pump driven by an electrical motor, confirm that the electrics and earthing of the offloading point are in good condition.

15.8. On completing the unloading, the driver should do the following:



a. Close the offloading valves

b. Disconnect the hose from the vehicle to the receipt pipework and return it to its place.

16. Storage System

16.1. Failures in the integrity of ASTs and associated pipework could result in a significant loss of product.

16.2. The integrity of ASTs could also be compromised by damage or corrosion. This could occur where ASTs have been erected in a manner that results in settlement.

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

a. Age of the storage tanks and pipework

b. Groundwater in relation to the base of the tanks

c. Type of ground tanks are installed in

d. Types of materials the tanks and pipework are constructed from

e. Installation of AST and pipework

f. Potential for damage to ASTs and pipework

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

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

a. Terminal has a separate tanker stand area

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

c. Overfill prevention systems

d. Clear labeling of pipework

e. Compliance with correct receipt and loading procedures

17. Loading

17.1. The terminal site typically includes the following equipment downstream from the storage:

a. Pipework

b. Valves



c. Transfer pumps

d. Loading gantries

e. Product measurement devices

f. Others.

17.2. Terminal Management is responsible for developing and implementing safe bulk loading procedures

17.3. It is essential that the quantities loaded into the delivery vehicles be measured. Flow meters at loading points are suitable and will be used to determine vehicle loading completion.

17.4. All drivers entering a terminal to load vehicles must abide by the operating rules and regulations. This naturally implies that such rules must be in writing and on display, and have been communicated to the drivers.

17.5. On arrival, the driver must be able to present any regulatory documents relating to him/herself and the truck. Pre-entry checks will be performed. The pre-entry checks shall include ERC license and certification status for the truck and the driver.

17.6. Any driver who is unaware of the operating rules of the terminal should first find out the rules from a terminal supervisor.

17.7. On arriving at the loading gantry, the driver must:

a. Choke the wheels of the vehicle.

b. Put on the personal protection equipment.

c. Identify the working area (where unauthorized persons are not allowed).

d. Ensure that the product to be loaded is correct as marked on the loading authority.

17.8. The driver or operator must be present to oversee the entire loading process, to ensure that all the steps are carried out correctly and to take appropriate actions should some unexpected event occur.

17.9. Product should be filled via bottom loading and where not available through the top into the tanker compartment space of the vehicle tank.

17.10. The loaded vehicle must be sealed before it is released for delivery.

17.11. The driver must carry out a further check of the vehicle, with special attention to valves closure. In particular, the main liquid outlet valve at the bottom of the tanker should be closed during transport.

17.12. Once the documentation and checks are complete, the driver can drive off.

17.13. All road tankers must be clearly identified with the names and types of products loaded.



18. Oil Spills

18.1. If the terminal experiences a spill, operatives should take immediate action to stop oil getting into drains or watercourses or contaminating the soil by soaking up the spilt oil with the contents of the oil spill kit, without endangering themselves.

18.2. Operatives should not hose the spillage down or use detergents to try to get rid of it; this action could make the pollution worse.

18.3. Store materials that are soaked in oil in containers that will not let the oil run away until it can be disposed according to NEMA regulations.

18.4. Surface and subsurface soil and groundwater samples shall be taken and tested for products relating to the incident.

19. Overfill Protection

19.1. Overfill protection devices must be maintained in a safe working condition.

19.2. Accurate stock control will ensure that tanks receive the correct amount of product.

20. Drainage

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

a. Conformance of loading facilities to codes of practice

b. Regular calibration and service of product measurement devices

c. Fitting of loading arms with emergency shut off devices and dead-man valves

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

e. Security against damage or vandalism

20.2. The facility shall keep the site drainage layout and maintain the drainage system in a working condition.



21. Maintenance and Repair

General

21.1. 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.

21.2. Maintenance includes examination, servicing, cleaning, repair, testing or calibration. The periods between these activities will depend on recommendations of manufacturers’, suppliers or installers, regulations, standards, conditions at the terminal, industry best practices and the advice of the person who carried out the last examination as may be applicable.

21.3. The production of safety method statements and operating procedures for maintenance activities will ensure that work is properly planned and that all changes are adequately documented.

21.4. 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 maintenance or repair work is carried out

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

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

b. Procedures in place to avoid accidental damage to tanks 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.

21.6. 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 terminal waste materials/effluents

c. Location of soakaways on-site

d. Nearest water supply boreholes

e. If drainage is intact and if it effectively deal with fuel spills

f. If drainage covers the whole terminal

g. Separator is clean, functional and maintained to ensure effectiveness



h. Whether or not loading and monitoring procedures are employed

i. Age and condition of the drainage system

j. Linkage between drains and receptors

21.7. Owners and operators must minimize rust on the tank exterior and must dispose of water drawn from the bottom of the tank in accordance with regulations.

21.8. The secondary containment area must be kept free of cracks, open seams, open drains, siphons, and vegetation other than grass. Grass is used to reduce erosion.

21.9. Precipitation must be removed as often as possible to maintain proper containment volume.

21.10. Stormwater that collects in the containment area must be discharged in accordance with the Energy Management and Coordination (Water Quality) Regulations, 2006.

21.11. Safeguard systems must be installed and maintained in accordance to the manufacturer’s schedules and standards.

Periodic Inspections

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

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

21.14. Periodic visual inspections of the terminal will help ensure that it is in satisfactory operating condition

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

21.16. ASTs that are not secondarily contained must be inspected daily.

21.17. A record of all inspections, including inspector's name, date of inspection, deficiencies observed, and corrective actions taken, must be maintained by the operator.

21.18. All petroleum containing ASTs that are secondarily contained must be inspected at least weekly. A record of all inspections, including inspector's name, date of inspection, deficiencies observed, and corrective actions taken, must be maintained by the operator.

21.19. Storm water from tank secondary containment structure(s) must be visually inspected or tested prior to discharging into the sanitary sewer or into the landscaping.



21.20. ASTs must be certified for integrity by an independent professional engineer

21.21. Where present, the following must be inspected at least once each day:

a. Overfill/spill control equipment (e.g. waste-feed cutoff systems, bypass systems, and drainage systems) to ensure that it is in good working order

b. The aboveground portions of the tank system, to detect corrosion or releases of waste

c. Data gathered from monitoring equipment and leak-detection equipment (e.g. pressure and temperature gauges, monitoring wells) to ensure that the tank system is being operated according to its design

d. The construction materials and the area immediately surrounding the externally accessible portion of the tank system, including secondary containment structures (e.g. dikes) to detect erosion or signs of releases of hazardous waste (e.g. wet spots, dead vegetation).

21.22. Where present, the cathodic protection systems must be inspected according to, at a minimum, the following schedule to ensure that they are functioning properly:

a. Proper operation of the cathodic protection systems must be confirmed within six months after initial installation, and annually thereafter

b. All sources of impressed current must be inspected and/or tested, as appropriate, at least bimonthly.

Third Party Inspections

21.23. AST owners and operators shall have their storage tank systems inspected by a certified AST inspector

21.24. Inspections will check for compliance with ERC requirements and adherence to current codes of practice developed by tank manufacturer’s instructions and design engineer’s specifications.

21.25. Inspections will check for compliance with EMCA, 1999 and OSHA, 2007 requirements

21.26. Only API 653 certified inspectors shall be used to satisfy requirements for:

a. In-service inspections.

b. Out-of-service inspections.



In-service Inspections

21.27. The in-service inspection must follow the guidelines of recognized association such as API 653, API 570 and applicable engineering criteria relating to AST modifications; containment requirements and leak detection requirements.

21.28. The in-service inspection must evaluate the following:

a. Containment areas.

b. Foundation.

c. Tank shell.

d. Tank roof.

e. Appurtenances.

f. Ancillary equipment including piping.

g. Leak detection method.

h. Cathodic protection system, if installed.

i. Tank system integrity and suitability for service.

21.29. Inspection information report shall be submitted to ERC and include the results of the evaluation and the following:

a. A determination of the corrosion rate of the shell and piping.

b. A calculation of the life of the tank shell and piping based on corrosion rate.

21.30. The next inspection schedule based on the API 653 calculated service life method or 1/4 of the corrosion rate life with a maximum of 5 years between inspections.

21.31. Other site-specific conditions, for example, maintenance practices, previous repairs, the nature of the substance stored or soil conditions that may affect corrosion rate life or tank system integrity and should be considered when projecting tank service life and the next inspection interval.

21.32. Inspection intervals for in-service inspections are as follows:

a. Tanks shall have an in-service inspection within 1/4 of the corrosion rate life with a maximum of 5 years from the previous inspection or installation.

b. An out-of-service inspection may replace an in-service inspection.

c. An in-service inspection interval may be delayed for a tank that is temporarily removed from service. The delayed inspection shall be conducted prior to placing product in a tank and returning the tank to operating status.



d. Deficiencies noted during inspection shall be addressed and remedied prior to returning the tank to operating status.

e. Inspection recommendations shall be addressed and deficiencies remedied. When substantial modifications are necessary to correct deficiencies, they shall be made in accordance with manufacturer’s specifications and engineering design criteria

f. Tank handling activities involving major modifications shall also be inspected by a certified AST inspector and reported to ERC.

21.33. The complete inspection report shall be kept at the facility until the next out-of-service inspection is completed.

Out of Service Inspections

21.34. Inspections must follow the guidelines of a recognized association such as API 653, API 570 or ASME and applicable engineering criteria

21.35. The out-of-service inspection must evaluate the following:

a. Containment areas.

b. Foundation and supports.

c. Tank shell.

d. Tank roof.

e. Tank bottom.

f. Appurtenances.

g. Ancillary equipment including piping.

h. Leak detection method.

i. Cathodic protection system.

j. Internal linings and coatings, if installed.

k. Tank system integrity and suitability for service.

21.36. The tank bottom evaluation of metallic floors must be based on ultrasonic testing and visual examination and include at least one other method of nondestructive examination such as magnetic flux tests or vacuum tests of bottom lap welds

21.37. The ultrasonic evaluation must be statistically representative of the whole floor, excluding the release prevention barrier or secondary containment on double bottom tanks.

21.38. Inspection report shall be submitted to ERC and include the following:

a. A determination of the corrosion rate for tank shell, bottom plates and piping.



b. A calculation of the tank life and piping life based on the corrosion rate.

c. The schedule for next out-of-service inspection, based on the API 653 calculated service life method or 1/2 of the corrosion rate life, with a maximum of 20 years between inspections.

d. Other site-specific conditions, for example, maintenance practices, previous repairs, internal linings, the nature of the substance stored or soil conditions that may affect corrosion rate life and should be considered when projecting tank service life and the next inspection interval.

21.39. The recommendations for maintaining tank system integrity and meeting performance standards.

21.40. Inspection intervals for out-of-service inspections are as follows:

a. Tanks shall have an out-of-service inspection at their API 653 calculated service life method or 1/2 of the corrosion rate life, with a maximum of 20 years from the last out-of-service inspection.

b. An out-of-service inspection interval may be delayed for a tank that is temporarily removed from service.

c. The delayed inspection shall be conducted prior to placing product in a tank and returning the tank to operating status.

d. Deficiencies noted during inspection shall be addressed prior to returning the tank to operating status.

e. Deficiencies shall be remedied before the tank is returned to service. When substantial modifications are necessary to correct deficiencies, they shall be made in accordance with manufacturer’s specifications or an engineer’s design criteria

f. Tank handling activities involving major modifications shall also be inspected by a certified AST inspector and reported to the ERC.

g. ASTs which can be completely examined from the exterior are exempt from out-of-service inspections except for tanks that are internally lined.

h. The completed inspection report for out-of-service inspections shall be kept with the facility records

Hoses

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

21.42. 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

Vents

21.43. Vents should be in the terminal’s inspection and maintenance program and examined for corrosion control.

Vapour Recovery Systems

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

21.45. 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.

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

Stormwater

21.47. Recommended practices to prevent Stormwater Pollution from terminals include:

a. Prevent discharges when receiving or loading bulk petroleum products.

b. Quickly cleanup spills of all sizes.

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

d. Train employees on pollution prevention activities

Annual Equipment Check

21.48. Equipment that is used for release, detection, monitoring or warning must be maintained in good working order.

21.49. Equipment must be checked at least yearly or in accordance with the manufacturer’s guidance to ensure it is calibrated and working properly.

Frequency of Inspection

21.50. Field-erected tanks at major facilities are initially inspected according to the schedule contained in the facility permit.



21.51. API 653 requires a maximum allowable interval of five years for external inspection and twenty years for internal inspection in most circumstances.

21.52. New tanks must generally receive an initial out-of-service inspection within ten years of initiation of service. It is common for an internal inspection to include an external inspection when the scheduled inspection timings coincide. This provides some efficiency for inspection scheduling and generally some cost savings.

22. Contractor Safety Management

Contractor Management

22.1. Contractors are routinely engaged to carry out maintenance work on equipment. Contractors carrying out engineering works shall be certified by National Construction Authority (NCA) for the relevant class of work. Electrical contractors shall possess the relevant ERC license

22.2. Before a contractor starts work, terminal management will need to satisfy themselves that the contractor is capable of undertaking the work in a safe manner considering:

a. Hazardous nature of petroleum products

b. Location of hazardous areas

c. Terminal Standard Operating Procedures

d. Location of ASTs and pipework

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

f. Location of underground services

g. Items, equipment or information necessary for health, safety and environmental compliance

22.3. Terminal management and contractor should be clear about:

a. How operations will affect each other work

b. Responsibility for managing work on the terminal and controlling subcontractors

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

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

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



Permit To Work System

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

22.7. A Permit To Work (PTW) System is a structured and formal written means of ensuring that potentially dangerous activities are approached and carried out using the correct safety procedures.

22.8. Detailed PTW guidance notes are available as ERC/TGN/1.15 Permit to Work Guidelines

Contractor Staff Training

22.9. Every person undertaking terminal maintenance shall have received training on practices for the specific equipment being maintained.

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

23. Monitoring Requirements

Product Transfer

23.1. At least one person must be present during loading and unloading of an AST to visually monitor and complete the product transfer.

Weekly Monitoring

23.2. If the secondary containment area has permeability of 1 x 10-7

23.3. If the secondary containment area is constructed of soil that is more permeable than 1 x 10

cm/sec. or tighter, the AST site must be visually monitored at least weekly.

-7

23.4.

cm/sec., the tank site must be visually monitored at least every 72 hours.

Monthly Monitoring

23.5. On a monthly basis, all ASTs at a terminal must be visually monitored.

23.6. Monthly monitoring includes:

a. Walking the terminal to identify cracks in the containment and product transfer areas



b. Visually examining all tank, piping, valve, pump and other equipment surfaces for cracks, corrosion, releases and maintenance deficiencies

c. Identifying poor maintenance and operating practices, or malfunctioning equipment

Leak Detection

23.7. If the containment area meets the 1 x 10 cm/sec. permeability requirement, monthly leak detection must include visual monitoring, interstitial monitoring, or vapor monitoring.

23.8. Monthly visual monitoring can be used for:

a. Elevated ASTs

b. ASTs on continuous concrete slabs

c. ASTs on a continuous concrete slab that is impermeable to the product being stored

d. ASTs on containment constructed of fabricated steel

e. ASTs on containment constructed of fiberglass

23.9. Interstitial monitoring between the inner and outer shell of a double-walled tank or the AST’s shell and the containment area satisfies the leak detection requirement.

23.10. Vapor monitoring in the soil directly under the tank bottom, as well as above the water table, is also an acceptable leak detection method.

23.11. If the containment area does not meet the 1 x 10-7

cm/sec. permeability requirement, monthly reconciliation of substance measurements or statistical inventory reconciliation must be used to satisfy the leak detection requirements.

23.12. Interstitial monitoring between the inner and outer shell of a double-walled USTs or the AST’s shell and the containment area satisfies the leak detection requirement.

23.13. Vapor monitoring in the soil directly under the tank bottom, as well as above the water table, is also an acceptable leak detection method.

Corrosion Protection

23.14. Cathodic protection systems for ASTs and underground piping must be inspected by a qualified cathodic protection specialist within six months of installation and then every three years.

23.15. Impressed current systems must be inspected for proper function every 60 days.



23.16. A lined AST must be internally inspected every ten years if it lacks external cathodic protection.

23.17. If monitoring results indicate inadequate corrosion protection, corrective action must occur within 180 days.

Record Keeping

23.18. Owners and operators of ASTs must keep the records of all periodic monitoring activities for at least three years.

23.19. The person performing the monitoring activity shall document the:

a. Name of the person doing the monitoring

b. Monitoring method or methods used

c. Monitoring date

d. Monitoring results

23.20. For the life of the AST, owners and operators must keep all documentation of corrosion protection, internal AST inspections, and a written summary of the results.

23.21. Owners and operators must keep records demonstrating compliance with out-of-service AST requirements for three years after the AST has been out of service

23.22. These records must be kept by the owners and operators who took the AST out of service and the current owners and operators of the terminal.

23.23. Owners and operators must keep records of all internal and external inspections for the life of the AST.

24. Control Practices for Pollution Prevention

Control System

24.1. 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.

24.2. Periodic testing for the presence of water in ASTs may indicate (through ingress of water) a failure in the AST bottom or roof.

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



24.4. Significant activities for which development of operational procedures should be considered include:

a. Product Receipts

b. Product Loading

c. Oil Loss Monitoring and Accounting

d. Regular and one-off maintenance activities

e. Control of visiting contractors

f. Response to major and minor spillages

g. Response to alarms and other indications of leakage.

h. General terminal maintenance and housekeeping

i. Maintenance of terminal records

Management of Terminal Operations

24.5. Terminal management should periodically assess the ability of staff to supervise operations:

a. Staffing levels

b. Other duties expected of staff

c. Management of terminal operatives

d. Training of terminal operatives

Leaks and Spills

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

24.6. Evidence of leaks can come from:

a. Monitoring of oil stocks

b. Leaks from ASTs and pipework if poorly installed, inadequately maintained, or old.

c. Poor integrity of ASTs

d. Periodic testing for the presence of water in ASTs as a result of failure in ASTs bottoms or pipework connections.

24.7. Terminal management must have procedures and equipment to deal with spillages and should provide absorbent materials for mopping up spills.

24.8. Spillages should be cleared up quickly and clean up materials used must be disposed of safely.



24.9. 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 contaminated, such as clothing, rags or soil, in a similar way.

24.10. All underground lines must be annually leak tested.

Oil Loss Accounting

24.11. Oil Loss Accounting should show losses and gains for each AST and pipeline system.

24.12. Effectiveness of Oil Loss Accounting as a method for detecting leaks depends on the following:

a. Reliability of the measurement method

b. Accuracy of the measurement equipment

c. Competency of the operations personnel

d. Accurate recording of receipts and deliveries

e. Competent assessment of the trend indicated by results

f. Inventory checks should integrate periodic checking for water.

Tank Testing

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

24.14. 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. Oil Loss Monitoring and Investigation control procedures are carried out properly

c. Check for:

a. Obvious leaks from pipe joints in manhole covers and drainage systems

b. Increase in petrol smell

d. Check:

a. Loading accuracy

b. AST contents measuring devices for accuracy

c. ASTs for water ingress

d. Test pipework for leaks



Loading Arms

24.15. Loading arms should be operated by dedicated personnel.

24.16. Provide, maintain and mark clear routes to, from and around loading gantries

24.17. Check that loading arms are undamaged, working and properly maintained

24.18. Do not allow damaged loading arms to be activated/used

24.19. Use loading arms with preset volume cut offs

24.20. Ensure that loading arms are inspected for integrity every six months and properly maintained.

Product Receipts by Road

24.21. Vapors can accumulate near product offloading points. Terminal management can mitigate the consequences of vapor emissions, leaks or spills:

a. Road Tanker Offloading Area should be maintained in good condition. If the area is not well located terminal management should implement control measures to ensure that fuel can be safely offloaded.

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

Pipework

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

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

24.24. Excavated pipework should be removed from terminal as soon as possible and disposed off safely

24.25. Water used to flush out the pipework should be collected for safe disposal

Storage Tanks

24.26. Corroded or defective AST should either be repaired or taken out of use.

24.27. For existing ASTs, corrosion control can be using an impressed current system.

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



Stormwater Systems

24.29. Various terminals have different facilities for stormwater management. It is important that spilled fuel is prevented from entering the sewer system and then subsequently into the environment.

24.30. Fuels are lighter than water and will float when not disturbed. At some terminals, particularly those that transfer higher flow rates and volumes of fuels, this property is used to contain spilled fuel in separators and prevent it from contaminating nearby lakes and rivers.

24.31. Prevent pollutants from mixing with stormwater runoff:

a. Either wipe up spills with rags or clean up any spills with sorbents. Never hose down spills with water unless there is a separator to capture runoff.

b. Never pour wastes into drains, onto the ground, or into a separator.

c. Never clean paved areas with a hose and water unless there is a separator to capture runoff. Sweep with a broom instead.

d. Pick up litter on the lot and dispose of in trash to prevent the litter getting into the stormwater drains and potentially clogging them.

e. Daily, inspect for evidence of spills that may have happened. If evidence of a recent spill is discovered, inspect the surrounding stormwater collection system to determine if product has migrated into the catch basins or the separator.

f. Clean up spilled fuel.

g. Loading areas have a concrete surface that is impervious to hydrocarbons and allows most spills to be contained. Repair and replacement of cracked or otherwise damaged paved areas is recommended if the damage could lead to product escaping to the ground soil.

Separators

24.32. Waste water produces large volumes of water, which could be contaminated with oil and road dirt and should be managed in a totally separate drainage system to the one used to drain the loading gantry to a separator.

Product Receipt Procedures

24.33. Product Receipt Procedures should include AST ullage checks to avoid tank overfills.



24.34. Terminal management should establish procedures for product receipt and ensure staff are familiar with them and that they are followed.

24.35. The competence of the tanker drivers will also determine how safely vehicles move around the terminal.

25. Training

General

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

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

26.3. Risks can arise as a result of inadequate training or operator error. Training requirements form an integral part of operational control measures.

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

a. Understanding of the need for environmental protection

b. Awareness of the risks posed by ASTs

c. Implementation of risk management procedures and controls.

26.5. The regulatory regime requires proof that terminal staff have received training with regard to the safe receipt, storage and loading of bulk petroleum products.

26.6. 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.

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

Responsibility

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

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



Training Needs

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

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

26.12. Cater also for unusual occurrences, such as road tanker breakdown at the loading gantry, which causes an obstruction.

26.13. Decide what training should cover and use risk assessment to identify what is appropriate for each person. Employees with particular responsibilities will need specific training:

a. Product receipts

b. Activating and controlling loading arms

c. Safe loading procedures

d. Spillage control and emergency procedures

e. Managing and checking bulk petroleum stocks

f. Competency of relief employees

g. On-site hazards and risks

h. Risk management measures and procedures

i. Emergency procedures

j. Control of visiting contractors

26.14. 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. Terminal specific risks

d. Terminal specific environmental protection measures

e. Individual’s specific role and responsibility.

26.15. The AST/monitoring device manufacturer (or designee) typically trains onsite personnel on new AST Systems. Personnel requiring training on existing AST Systems may need to contact the tank manufacturer and arrange for a training session.

Performance of Training

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



26.17. Terminal 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.

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

26.19. 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.

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

26. Records

27.1. Owners and operators of terminals shall ensure that adequate records are kept of Oil Loss Monitoring and Performance and the operation of leak detection systems or leak prevention systems such that leaks or spills of product from the terminal are detected before hazardous situations arise.

27.2. If records are maintained offsite, the records shall be easily obtained and provided to ERC upon request.

27.3. Permanent records for new systems and available records for existing systems shall be maintained for the operational life of the terminal and retained for a minimum of 3 years after ASTs are removed. Permanent records include the following:

a. Original installation and modification of AST System design specifications. Details of the equipment on site (type, age and location)

b. Any variance issued for the terminal

c. The permits issued under to operate terminals

d. AST handling activity installation, relocation, reconstruction and major modification inspection results.

e. Applicable manufacturer’s documentation for the terminal and ancillary equipment.

f. Third party out-of-service inspection reports.

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

h. Equipment testing and calibration

i. Records of maintenance regime and repairs carried out.

27.4. Temporary records shall be maintained as follows:



a. The current registration certificate.

b. The leak detection records for the past 12 months.

c. The last two results of cathodic protection monitoring, when a cathodic protection system is in use.

d. The routine monthly maintenance inspections for the past 36 months.

e. The last third party in-service inspection report.

f. A properly completed closure report and results of the site assessment conducted at permanent closure or change-in-service

27.5. The terminal operator shall ensure that adequate records are kept of terminal operations including:

a. Current Terminal License and conditions of licensing

b. Terminal Policies

c. Standard Operating Procedures

d. Diagram of hazardous zones

e. Stock Accounting

f. Oil Loss Monitoring and Performance

g. Training

h. Results of Risk Assessments

i. Product Delivery Documents

j. MSDS

k. Emergency Procedures

l. Pollution Incident Response Plan

m. Correspondence and Reports from Regulatory Agencies

n. Calibration Records

o. Monitoring Records

27.6. All service check and equipment calibration records must be kept for three years.

27.7. All periodic monitoring (72-hour, weekly and monthly) records must be kept for three years.

27.8. Documentation for monitoring must include the name of the person conducting the monitoring, the method used, the date of the monitoring, and the monitoring results.

27.9. The owner or operator must keep records indicating that the AST was taken out of service in compliance with regulations. These records must be kept for three years.



27. References

28.1. Energy Act, 2006

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

28.3. Environment Management and Coordination (Water Quality) Regulations, 2006

28.4. Environment Management and Coordination (Waste Management) Regulations, 2006

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

28.6. Occupational Safety and Health Act 2007

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

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

28.8. KS ISO 1998 – 5 - PETROLEUM INDUSTRY –

Terminology –Part 5: Transport, storage and distribution.

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

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

28.10. KS 1967 (2006) - The petroleum industry – The

28.11. KS 2180

API 650/653/2610

ASME

ASTM



28. Contacts

29.1.

Head Office: Eagle Africa Centre - Upper Hill

ENERGY REGULATORY COMMISSION (ERC)

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

29.2.

Popo Road, Off Mombasa Road

KENYA BUREAU OF STANDARDS (KEBS)

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

29.3.

Popo Road, Off Mombasa Road

NATIONAL ENVIRONMENT MANAGEMENT AUTHORITY (NEMA)

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/�

mailto:[email protected]�

http://www.nema.go.ke/�