Earlier this year, following consultation with fuel retailers and petroleum equipment and service providers, ACAPMA took on responsibility for the development of a series of Best Practice Guidelines for fuel retailers.
The Consultation Process suggested that there was an urgent need for the provision of straightforward guidance in the areas of Biofuels Storage, Management of Hydrocarbons in Stormwater discharges, Vapour Recovery Infrastructure and monitoring of the performance of UPSS (i.e. leak detection).
Shortly after, an Expression of Interest process was conducted to invite people to nominate for participation on the four working Groups that would oversee the development of these new guidelines and the integrity of the associated consultative processes.
“We were very encouraged by the strong response to our call for working group participants, with more than 44 people indicating a willingness to participate on the four working groups”, said ACAPMA CEO Mark McKenzie.
Working Group participants were drawn from a broad cross section of industry and government stakeholders with nominations from fuel retailers, petroleum equipment providers, petroleum service providers and key government agencies.
“These people and their organisations have given freely of their own time to support a process that is designed to deliver a benefit to the whole fuel retail industry in Australia”, Mark continued.
Over the past week, three of the four working groups have met to review the draft guidelines. These Guidelines included:
- Biofuels Storage and Management. This Draft Guideline seeks to provide Guidance on the key factors to be considered when transitioning fuel systems from conventional fuels operation to a mix of conventional and biofuels operation. The need for this Guideline was identified by fuel retailers as a result of State Governments introducing Biofuels Mandates in the absence of any definitive industry standards (or guidelines) on the process for the safe and environmentally responsible transition to biofuels operation.
- Management of stormwater discharge (Hydrocarbons only). This Draft Guideline seeks to address a persistent issue experienced by many fuel retailers in seeking approval for new service station works – that is, the design of stormwater systems to prevent the release of hydrocarbons into Stormwater and sewer from water collected from the hardstand areas of the fuel retail forecourt. The Guideline discusses the key design considerations as well as proposing the adoption of a minimum acceptable level of hydrocarbon discharge, given the absence of any such level in Australia.
- Vapour Recovery. The Guideline provides an overview of Vapour Recovery systems and identifies the key issues that need to be managed to ensure that asset longevity and continued safe operation of the fuel system infrastructure (i.e. storage and dispensing infrastructure) in the future.
The fourth Guideline will address issues associated with the installation and operation of UPSS Monitoring Systems and will be reviewed by the working group next week. This Guideline seeks to provide definitive guidance on the steps that should be taken to monitor the integrity of underground fuel storage systems (i.e. tanks and lines) with a view to preventing fuel contamination of soil or ground water.
“One of the challenges with developing Best Practice Guidelines is that they can inadvertently lead to fuel retailers being pressured to modify their retail sites, leading to increased costs”, said Mark.
But cutting corners on key safety and environmental responsibilities is foolhardy from a business perspective as breaches of key safety and environmental regulations can result in the retail business suffering severe financial losses as a result of prosecution by regulatory authorities.
“The reality is that fuel retailers do have legal obligations to ensure that their sites are safe and operated in a manner that minimise the risk of environmental harm – and so our approach has been to provide guidance on how to satisfy these obligations at the least possible cost”, said Mark.
Making changes to fuel infrastructure without using understanding the issues that should be considered, or using unqualified personnel, can also result in costly damage to fuel infrastructure that could have been avoided.
The draft Guidelines will be released for broader industry consultation during the month of July with a view to the Guidelines being finalised and released at the 2017 Asia Pacific Fuel Industry Forum, which will be held in Melbourne on 13 and 14 September 2017. Registration for this event is now live: www.apfiforum.com/register.
Inquiries about the guidelines development process can be made by contacting ACAPMA on 1300 160 270 or sending an email to firstname.lastname@example.org.