In March of this year, ACAPMA conducted a series of workshops with the petroleum equipment and supply industry to assess potential priorities for the development of best practice in the fuel retail industry.

The workshop series followed feedback from some retailers about an apparent lack of guidance on the design and installation of fuel system infrastructure – as well as concern about a lack of consistency in regulatory requirements for new site developments or fuel site refurbishment works.

The gradual transition of the fuel retail industry. from one largely controlled by corporate organisations to one now largely operated by small to medium businesses, has meant that many of the corporate disciplines and knowledge that used to apply is no longer available to many fuel retailers.

“New regulations in areas such as biofuels, UPSS monitoring and vapour recovery have also created a need for some basic guidance to be developed for fuel retailers”, said ACAPMA CEO Mark McKenzie.

Following the workshops – which were attended by equipment suppliers, fuel system designers and petroleum services contractors – a need for the development of four (4) plain English Guidelines for fuel retailers was identified. These topic areas included:

  • Biofuels storage
  • Vapour Recovery systems
  • UPSS Monitoring
  • Stormwater discharge (i.e. management of hydrocarbons in Stormwater)

In the past few months, ACAPMA has been working with four separate groups of stakeholders to prepare a draft of each Best Practice Guideline. These working groups comprised representatives of fuel retailers, regulators, equipment suppliers, fuel system designers and service providers.

“Our sincere thanks go to all members of our working groups who have given freely of their time to assist with this process including: government representatives, ACAPMA members, ACAPMA E&S Associates, and members of PICA WA”, said Mark.

“The challenge in developing guidelines in this space was to ensure that the Guidelines do not impose unnecessary costs or complex practices on fuel retailers, while still ensuring that the operation of our industry accommodates the Australian Community’s expectation of safe and environmentally-responsible operation of retail fuel sites by our industry”, said Mark.

ACAPMA’s Best Practice Guidelines do not provide detailed technical guidance, given that much of this guidance already exists in relevant Australian Standards and Industry Codes of Practice.

“While this guidance exists, fuel retailers aren’t engineers and designers and it is therefore unreasonable to expect them to wade through detailed technical standards or government regulations”, said Mark.

“Rather, ACAPMA’s Best Practice Guidelines seek to provide fuel retailers with a basic knowledge of the factors that should be considered with respect to the design, operation and maintenance of key pieces of retail site infrastructure”, said Mark.

Given some past examples of business losses arising from poorly designed and installed infrastructure, fuel retailers should always seek out suitably qualified contractors for the performance of site works and infrastructure maintenance.

“Recent past history suggest that that ‘taking shortcuts’ with unqualified contractors, or commissioning works without understanding basic system requirements, can result in disastrous business consequences for the owners/operators of fuel retail sites”, said Mark

“A lack of basic knowledge can result in fuel retailers paying for systems that are not effective in satisfying key environmental regulations, leaving them open to future prosecution for environmental breaches”, Mark continued.

To that end, ACAPMA has this week released two draft for industry and stakeholder comment – with another two to be released next week.

Biofuels Best Practice Guideline (Draft)

The first of these Guidelines relates to the safe and responsible storage of biofuels which can be viewed here: https://acapmag.com.au/wp-content/uploads/2017/07/Draft-Biofuels-Storage-Guideline-Consultative-Draft-4-July-2017.pdf.

The Biofuels Guideline discusses the key factors that should be considered in the transition from conventional fuels operation to the storage and dispensing of biofuels such as E10 and B5.

“Industry experience with the storage of these fuels has been mixed and there are some storage tank technologies that do not appear to be compatible with the storage of E10”, said Mark.

“We are also hearing reports from overseas that the move to low sulfur diesel blended with small amounts of biodiesel appears to be responsible for the rapid deterioration of underground tanks”, said Mark.

Vapour Recovery Best Practice Guideline (Draft)

The second Guideline covers the installation and operation of Vapour Recovery (VR) systems which can be viewed here: https://acapmag.com.au/wp-content/uploads/2017/07/Draft-Vapour-Recovery-Systems-Guideline-Consultative-Draft-4-July-2017.pdf.

VR systems (VR1 and VR2) are legally required in NSW (VR1) and VR1 systems are sometimes required in other Australian States and Territories for new sites.

The principal objective of these systems is to limit the release of volatile organic compounds from fuel tanks that react in the presence of sunlight (and other gases in air) to produce photo-chemical smog.

“We remain concerned that some regulators appear to be requiring installation of these systems where there is clearly no environmental business case for their use, and the new Guideline discusses this aspect of current inconsistent regulatory practice”, said Mark.

Vapour recovery systems involve modification of tank pressures and vacuums. It is therefore critical that these systems are correctly designed to ensure safe system operation and good asset life.

“There is currently considerable discussion about the need to ensure that the PV vents used in Vapour recovery systems are regularly maintained with one recent experience suggesting that the failure of these vents may have contributed to a catastrophic tank failure”, said Mark.

Give us your feedback

Thanks to the hard work of the members of both working groups, the above Best Practice Guidelines have been released for industry comment today.

“We encourage industry participants and regulators alike to review the guidelines and provide feedback on areas of concern or areas that may require clarification”, said Mark.

Comments will be received by ACAPMA until COB on Monday 31 July 2017 and should be emailed to markm@acapma.com.au.

Next steps

Once all comments are received, the Best Practice Guidelines will be reviewed by the relevant Working Group with a view to making a final recommendation for adoption by ACAPMA.

Subject to formal adoption by ACAPMA’s Equipment and Services Council (on behalf of the ACAPMA Board), the Guidelines will be launched during Day 1 of the 2017 Asia Pacific Fuel Industry Forum to be held in Melbourne on 13 and 14 September 2017.

The Guidelines will be produced in electronic format, updated annually and made available to industry and other stakeholders without charge.

Further information about the process can be obtained by contacting the ACAPMA Secretariat on 1300 160 270 or emailing communications@acapma.com.au.

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