Pollution Control - Don't get caught by COP01 February 2005

According to the Environment Agency there are more than 5,000 oil incidents reported every year. In 2000, one sixth of all pollution incidents affecting the environment involved oil: most incidents were caused by oil leaking from tanks either during storage or delivery. DEFRA has stated that inadequate fluid storage is five times more likely to be involved in a pollution incident than storage that is adequate.

There are approximately 900,000 storage tanks in England and it is estimated that 60% of these tanks do not conform.

Insurers require best practice to be adopted to reduce the risk of claims on public liability insurance policies. Typically, the company must demonstrate that pollution "was not the direct result of the Assured failing to take reasonable precautions to prevent such Pollution".

The Control Of Pollution (Oil Storage) Regulations 2001 (abbreviated to the COP Regulations) apply to anyone storing more than 200 litres of oil above ground at an industrial, commercial or institutional site. This includes shops, offices, hotels, schools, public sector buildings and hospitals. The regulations are being implemented in phases: all new oil stores and existing stores "at significant risk" have had to comply since March 2002 and September 2003 respectively, while all remaining stores must comply from 1 September 2005.

All types of oil, with the exception of waste oil, are covered by these regulations, including petrol, diesel, vegetable, synthetic and mineral oil. In the case of flammable liquids, additional health and safety requirements apply.

The key requirements of the regulations relating to above ground oil storage tanks are set out opposite. They should not be taken as exhaustive: expert advice should be sought to establish the actions required to conform in your particular circumstances.

Key requirements

Responsible person

This is the person with custody or control of the product; (s)he is required to ensure compliance.

Location

Tanks should be positioned, or other steps taken, to minimise the risk of damage by impact. Ideally oil should not be stored in significant risk locations - within 10m of a watercourse or 50m of a well or borehole. Storage above roof level should be avoided.

General requirements

Oil should be stored in a tank of sufficient strength and structural integrity to ensure that it is unlikely to burst or leak in ordinary use. It is recommended that tanks have a design life of 20 years with proper maintenance.

Tank specifications

Storage tanks should be type tested to a recognised standard and produced under a quality assurance system complying with BS EN 9002:1994. OFTEC (the Oil Firing Technical Association) has developed a standard for integrally bunded steel tanks, OFS T200.

Secondary containment

Secondary containment prevents oil escaping to the environment in the event of leakage. All tanks and ancillary equipment should be situated within an oil-tight secondary containment system, which must be able to store at least 110% of the tank's maximum capacity.

Ancillary equipment

Any valve, filter, sight gauge, vent pipe or other ancillary equipment should be situated within the secondary equipment system and arranged so that any discharges of oil are contained.

Pump sets

Any pump should be positioned to minimise the risk of damage, fitted with a non-return valve in its feed line and protected from unauthorised use.

Security

Any permanent taps or valves through which oil can be discharged from the tank to open areas should be fitted with a lock and be locked shut when not in use.

Pipework

All pipework should be properly supported and be positioned to avoid collision damage. Flexible pipes for filling should comply with BS EN 1360:1997.

Deliveries

Where a fill pipe is outside the containment system, a drip tray should be used to catch any oil spilled during delivery. If a serviceable screw fitting or other fixed coupling is available, it should be used when filling the tank. An automatic overfill prevention device should be fitted if the tank and any vent pipe cannot be seen by the person controlling the delivery.

Survey

If you are not certain that your above ground system complies with the regulations, you can contact the Environment Agency for advice. Alternatively you can contact a suitable service provider who will carry out a survey, submit a report on the current situation and actions necessary, and supply and install replacement equipment, which should be guaranteed to comply. The surveyor should hold the OFTEC 600A certificate.

Chris Clarke is engineering manager at Powerpoint Fluid Management Services (T: 01782 824007)

SOE

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