Last month, the NSW EPA released new Guidance in the form of a new Draft Practice Note entitled: Managing Run-Off from Service Station Forecourts (For a copy of the Guideline Click Here)
The Guideline was released with a view to seeking feedback from stakeholders -both industry and government -on the suitability of this document as a future guideline for approvals of stormwater systems installed on service station forecourts across NSW.
“Our hope is that, together with the ACAPMA Best Practice Guideline for fuel retailers, these Guidelines resolve a longstanding issue about the lack of consistency of local council decisions in respect of approvals of stormwater management systems for new service station works and service station upgrades”, said ACAPMA CEO Mark McKenzie.
Having now had a chance to the review the document, and hear industry stakeholder perspectives at a consultative workshop hosted by the EPA on 8 November 2018, ACAPMA believes that the Guideline is a marked improvement on previous documentation.
ACAPMA, however, remains concerned that the document is silent in respect of guidance on hydrocarbon concentration of stormwater discharges from service stations sites.
“We believe there is a clear need for the inclusion of guidance in respect of the design hydrocarbon concentration of hydrocarbons in any discharge of stormwater from sites – and we will be saying so strongly in our submission”, said Mark
“Failure to provide such guidance will merely continue the inconsistency and confusion of past approval processes”, continued Mark
ACAPMA’s submission is likely to be finalised around a proposal that the new Guidelines include a design limit of 5ppm hydrocarbon concentration in discharge waters (as identified in the ACAPMA Best Practice Guideline) with the opportunity for higher discharges to be considered subject to an assessment of impact on the surrounding ecosystem.
“This two-step approach will provide a consistent target for most projects – one that is well below the hydrocarbon concentration of waters discharged from Council roads and carparks into stormwater systems – while allowing sites that are less environmentally sensitive to seek approval for higher limits if they can prove that such limits would not damage the environment”, said Mark
ACAPMA members, particularly Associate Members involved in petroleum contracting and equipment supply activity, are strongly encouraged to make a submission to this consultation by the end of next week.
“Equally, the ACAPMA Secretariat will continue to receive input from members to COB on Wednesday 28 November 2018 before finalising our submission and forwarding it to the EPA on the 30th, said Mark
Any members wishing to have their comments included in the ACAPMA submission can do so by emailing email@example.com
Further information about the NSW Consultation can be obtained via the NSW EPA website (https://www.epa.nsw.gov.au/-/media/epa/corporate-site/resources/clm/18p1046-practice-note-managing-run-off-from-service-station-forecourts.pdf).