Operation and Maintenance of Petroleum Terminals PDF

TECHNICAL GUIDANCE NOTES
OPERATION AND MAINTENANCE OF PETROLEUM TERMINALS
NOVEMBER 2015
Operation and Maintenance of Petroleum Terminals
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 ...................................................................................................... 17
Vapour Recovery System ....................................................................... 17
Top Loading ............................................................................................. 18
Bottom Loading ....................................................................................... 18
Top Filling ................................................................................................ 18
Bottom Filling .......................................................................................... 18
9. OPERATIONS AND MAINTENANCE PRACTICES ......18

Operational Activities ............................................................................ 18
Standard Operating Procedures ........................................................... 19
Pollution Incident Response Plan........................................................ 20
Preventive and Housekeeping Requirements ................................... 21
Labelling of AST ..................................................................................... 22
Security ...................................................................................................... 22
10. High Pollution Risk Operations............................................23

11. Road Tanker Operator Responsibilities ..............................24
12. Terminal Operator Responsibilities .....................................24
Energy Regulatory Commission Page 2

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 ...................................................................................................... 30
Periodic Inspections ................................................................................ 31
Third Party Inspections .......................................................................... 32
In-service Inspections ............................................................................. 33
Out of Service Inspections .................................................................... 34
Hoses .......................................................................................................... 35
Vent Pipes ................................................................................................. 36
Vapour Recovery Systems ..................................................................... 36
Stormwater................................................................................................ 36
Annual Equipment Check ..................................................................... 36
Frequency of Inspection......................................................................... 36
22. Contractor Safety Management .............................................37

Contractor Management ........................................................................ 37
Permit To Work System ......................................................................... 38
Contractor Staff Training....................................................................... 38
23. Monitoring Requirements ......................................................38

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

Weekly Monitoring ................................................................................. 38

Monthly Monitoring ............................................................................... 38
Leak Detection ......................................................................................... 39
Corrosion Protection ............................................................................... 39
Record Keeping ....................................................................................... 40
24. Control Practices for Pollution Prevention .........................40

Control System......................................................................................... 40
Management of Terminal Operations................................................. 41
Leaks and Spills ....................................................................................... 41
Oil Loss Accounting................................................................................ 42
Tank Testing............................................................................................. 42
Loading Arms ........................................................................................... 43
Product Receipts by Road ...................................................................... 43
Pipework ................................................................................................... 43
Storage Tanks ........................................................................................... 43
Stormwater Systems ............................................................................... 44
Separators.................................................................................................. 44
Product 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 ...................................................................................................... 45
Responsibility .......................................................................................... 45
Training Needs ........................................................................................ 46
Performance 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 2 Carbon Dioxide
COP Codes of Practice
DOSHS Department of Occupational Safety and Health Services
ERC Energy Regulatory Commission
ESD Emergency Shutdown
GMW Ground Monitoring Well
H2S Hydrogen Sulphide
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 Electrical, vapor recovery, access or other systems and
Equipment 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 Automatic Tank Gauge. Electronically operated system that
Gauging 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 Premises consisting one or more tanks for storing petroleum
Terminal 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 Anything built, installed or established which comes in
Structure 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 The protection of metal from deterioration. The
Protection 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 A containment structure which serves toconvey, capture
Containment 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 Critical safety devices that shutdown operations or
Shutdown Device processes during emergencies
Emission The episodic or ongoing release of materials to the
environment (air, water or land).
Environmental Periodic inspection of a facility to check continuous
Audit 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 “Ground Monitoring Well” means any cased excavation or
Well 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 A scheduled aboveground storage tank external inspection
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 to inspect all or a part of storage tank system or
Activities 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 A piping arrangement for filling in a truck.
Arm/Hose
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 Includes all activities addressing workplace health hazards
Health 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 A well, interconnection with a public water supply,
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 Pressure/Vacuum Relief Valves (Breather Valves). Direct
Relief 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 A system which provides water to the public for human
System 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- Replacement which is essentially identical to the original
kind 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 The purpose of the SMS is to identify the hazards associated
Statement 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 Standard Operating Procedures are documented series of
Procedures 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 These are a sequence of water management practices and
Drainage Systems 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 cm/sec. or

tighter, the AST site must be visually monitored at least weekly.
23.3. If the secondary containment area is constructed of soil that is more
permeable than 1 x 10-7 cm/sec., the tank site must be visually monitored
at least every 72 hours.
23.4.
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. ENERGY REGULATORY COMMISSION (ERC)

Head Office: Eagle Africa Centre - Upper Hill
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. KENYA BUREAU OF STANDARDS (KEBS)
Popo Road, Off Mombasa Road
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: info@kebs.org
Website: www.kebs.org
29.3. NATIONAL ENVIRONMENT MANAGEMENT AUTHORITY (NEMA)
Popo Road, Off Mombasa Road
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:dgnema@nema.go.ke
Website: www.nema.go.ke

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TECHNICAL GUIDANCE NOTES

OPERATION AND MAINTENANCE OF PETROLEUM TERMINALS

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

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

Energy Regulatory Commission Page 2

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

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

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

Energy Regulatory Commission Page 3

Weekly Monitoring ................................................................................. 38

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

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

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Purchasing................................................ Error! Bookmark not defined.

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

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

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Energy Regulatory Commission Page 7

Energy Regulatory Commission Page 8

Energy Regulatory Commission Page 9

Energy Regulatory Commission Page 10

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1.1. These Technical Guidance Notes, herein referred to as “guidelines”, are

2.1. The information contained in the PPGs is not intended to be prescriptive,

3. Operation and Maintenance

Energy Regulatory Commission Page 15

5.1. The guidelines provide minimum standards of operation, maintenance

Energy Regulatory Commission Page 16

Vapour Recovery System

Energy Regulatory Commission Page 17

9. OPERATIONS AND MAINTENANCE PRACTICES

9.1. Terminal operations mainly consist of receiving/unloading and

Energy Regulatory Commission Page 18

pipelines, rail, and truck tankers) to ASTs, and onward to distribution

Standard Operating Procedures

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• Providing information, instruction and training to all terminal

Pollution Incident Response Plan (PIRP)

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h. An up-to-date and tested PIRP should be posted in a location known to

Preventive and Housekeeping Requirements

9.15. Terminals operators shall establish and implement preventive

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areas of wear, excessive settlement and deterioration of the

9.19. An owner/operator is responsible to assure AST Systems are

9.23. The operator is responsible to assure that security measures and

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10. High Pollution Risk Operations

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11. Road Tanker Operator Responsibilities

12. Terminal Operator Responsibilities

12.1. Ensure that:

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n. Records showing date, the training received and employee’s

13. Employees Responsibilities

13.1. Ensure that:

14. Loss Investigation

Energy Regulatory Commission Page 25

14.5. When drilling boreholes on sites, methodologies should be used to ensure