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Australian Department of Defence Pollution Prevention Environmental Management Guideline Infrastructure Development: Design and Installation of Chemical Storage Facilities.

June 2011

GUIDELINE 3, 27 APRIL 2011

Australian Department of Defence Pollution Prevention Environmental Management Guideline Infrastructure Development: Design and Installation of Chemical Storage Facilities ISSUED June 2011 Prepared by Environmental Resources Management Australia Pty Ltd For further information contact: Assistant Director Pollution Prevention Directorate of Environmental Impact Management Estate Policy Environment Branch Department of Defence Front Photograph: 324 Expeditionary Combat Support Squadron members work as a team to store chemicals in the correct environment. Photographer: LAC Mark Friend. Source: The Australian Army Website, Australian Defence Image Library, file image 20090529raaf8526970_0021.jpg

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Table of Contents

LIST OF ACRONYMS III

EXECUTIVE SUMMARY IV

1. PURPOSE OF THE POLLUTION PREVENTION ENVIRONMENTAL MANAGEMENT GUIDELINES 1

2. WHEN TO USE THIS GUIDELINE 2

3. STAKEHOLDERS RESPONSIBILITIES 2

4. POLLUTANTS ASSOCIATED WITH CHEMICAL STORAGE FACILITIES 3

5. SEGMENTS OF THE ENVIRONMENT POTENTIALLY AT RISK 5

6. PROCUREMENT CONSIDERATIONS 6

7. GUIDELINE REQUIREMENTS AND PERFORMANCE STANDARDS 7

7.1 MANAGEMENT AND ADMINISTRATIVE CONTROLS 9 Risk Assessment 9 Environmental Management Plan (EMP) 9 Preventative Maintenance Schedule 10 Licence Requirements 10 Dangerous Goods Manifest & Material Safety Data Sheets (MSDSs) 10 Infrastructure Plans 10 Staff Training 11 Record Keeping 11

7.2 DRAINAGE SYSTEMS 12 Waste Disposal 12 Infrastructure Plans 13 Record Keeping 13 Stormwater Management 13

7.3 DESIGN OF STORAGE FACILITIES 14 Design and Installation 14 Appropriate Storage Containers 15 ASTs 15 USTs 16 Risk/Hazard Assessment 16 Spillage containment 17 Maintenance and Inspection 17 Security 19 Fire Protection/Control 19

7.4 DESIGN OF EQUIPMENT/FACILITIES 20 Secondary Containment 20 Pipe Work 20

7.5 CHEMICAL HANDLING OPERATIONS 22 Procedures 22 Filling Area Design and Operation 22

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7.6 EMERGENCY RESPONSE AND CLEAN-UP 23 Design 23 Emergency Response Plan 23 Spill Management and Prevention 24 Incident Investigation and Notification 24

8. OTHER CONSIDERATIONS 25

9. CASE STUDY – BUNDING AND THE SOUTH AUSTRALIAN EPA GUIDELINES. 26

10. REFERENCES AND FURTHER READING 28

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List of Acronyms

AFFF Aqueous Film-Forming Foam

AST Above-ground Storage Tank

ATC Australian Transport Commission

CMS Comprehensive Maintenance Services

DECC Department of Environment and Climate Change

DECCW Department of Environment, Climate Change and Water

Defence Department of Defence

DMO Defence Materiel Organisation

DoW Department of Water

DPPS Defence Pollution Prevention Strategy

DSG Defence Support Group

EMG Environmental Management Guideline

EMP Environmental Management Plan

EMS Environmental Management System

EPA Environment Protection Authority

GSS Garrison Support Services

IAD Infrastructure Asset Development

JFLA Joint Fuels and Lubricants Agency

JLC Joint Logistics Control

kL Kilolitre

MHF Major Hazard Facility

MSDS Material Safety Data Sheet

NTC National Transport Commission

OH&S Occupational, Health and Safety

PFOA Perfluoro octanoic acid

PFOS Perfluoro octanesulfonic acid

PS Performance Standard

RAAF Royal Australian Air Force

REO Regional Environmental Officer

UST Underground Storage Tank

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Executive Summary

The purpose of this pollution prevention environmental management Guideline Number 3 for Infrastructure Development: Design and Installation of Chemical Storage Facilities is to assist the Department of Defence (Defence) with:

• Preventing and reducing the likelihood of pollution events;

• Promoting sustainable environmental management; and

• Advising internally on recommended standards and requirements for the design, installation and establishment of chemical storage facilities and tanks.

This Guideline takes a performance-based approach, which is intended to balance Defence operational and training requirements with its legislative and environmental polices and obligations, which include:

• Commonwealth Environment Protection legislation such as the Environment Protection and Biodiversity Conservation Act 1999 (the EPBC Act);

• Defence Pollution Prevention Strategy (DPPS), June 2007; and

• Applicable Defence guidelines, Commonwealth, State and Territory legislation regulations and guidelines and Australian Standards and Codes in relation to liquid waste storage systems and environmental protection.

Performance standards have been identified to enable demonstration of compliance with applicable legislation and Australian Standards for Defence activities related to design, installation and establishment of chemical storage facilities. Defence is obliged to comply with Defence and other Commonwealth Government environmental policies, initiatives and legislation/regulations. Defence also endeavours to meet the requirements of State and Territory legislation, regulations and guidelines and to performing tasks to best practice standards. Contractors, lessees or licensees operating or occupying Defence facilities, or undertaking activities on behalf of Defence, are obliged to also comply with State and Territory legislation, regulations and guidelines.

The performance standards discussed in this Guideline include the following key areas where compliance is required:

1. Supporting documentation requirements and required inspections and management reviews.

2. Management, monitoring and maintenance of water drainage systems.

3. Design of chemical storage facilities and tanks.

4. Design of chemical handling areas and dispensing equipment.

5. Procedures and operations for chemical handling.

6. Design of emergency response and clean-up procedures.

This Guideline is principally intended for stationary chemical storage facilities only. The Guideline does not include requirements for the chemical storage of munitions, radioactive, nuclear or biological materials (including sewage or effluent from treatment plants) or fire suppression chemicals (PFOS/PFOA etc).

This Guideline does not include detailed advice on specific regulatory requirements in relation to the use of mobile chemical storage units, such as tankers and transport vehicles, or the transport of liquid chemicals by road, rail or sea.

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1. Purpose of the Pollution Prevention Environmental Management Guidelines

The Environment Protection and Biodiversity Conservation Act 1999 (the EPBC Act) requires a proactive approach to waste minimisation by Commonwealth agencies and requires annual reporting of Defence’s alignment with the principles of ecologically sustainable development. The Defence Waste Minimisation Policy (2007) aligns with the requirements of the EPBC Act and requires Defence to:

“a. minimise the amount of material from Defence being diverted to landfill;

b. reduce consumption of natural resources by minimising the amount of packaging material purchased and continuously increasing demand for recycled content in Defence procurement;

c. enhance the Commonwealth’s reputation for environmental management; and

d. reduce waste management and disposal costs through waste streaming”.

Through these mandated requirements, Defence is required to take responsibility for the prevention of potentially polluting activities, thereby reducing wastes and potential impacts to the environment. Commonwealth, State and Territory legislation/regulations and Australian Standards contain guidance and obligations that also require those responsible for an activity with the potential to cause pollution, to ensure that the appropriate safeguards are in place to prevent the pollution.

This pollution prevention environmental management Guideline Number 3 for Infrastructure Development: Design and Installation of Chemical Storage Facilities is part of a set of Guidelines implemented in support of the Defence Pollution Prevention Strategy, 2007 (DPPS). The DPPS was initiated in order to promote policies and legislative obligations, consistent with the Defence Environmental Management System (EMS), relating specifically to pollution prevention within the range of activities that Defence performs. Broadly, regular Defence activities can range from the design, installation and establishment of equipment/infrastructure (e.g. construction and development), through to activities including operation of existing equipment/infrastructure and maintenance and repair activities. Defence also undertakes equipment/infrastructure disposal activities such as decommissioning and demolition.

This Guideline aims to set standards and procedures to ensure that Defence activities involving the design, installation and establishment of chemical storage facilities are environmentally sound and comply with Defence policy and legislative commitments. The Guideline will assist Defence with:

• Preventing and reducing the likelihood of major pollution events;

• Promoting sustainable environmental management; and

• Advising internally on recommended standards and requirements for the design, installation and establishment of chemical storage facilities and tanks for existing Defence equipment and infrastructure.

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2. When to use this Guideline

The use of specialised and potentially hazardous materials is sometimes unavoidable in a number of Defence activities and operations in performing its primary mission of defending Australia and its national interests. This environmental management Guideline for pollution prevention refers to activities associated design, installation and establishment of chemical storage facilities on Defence estate, which occurs throughout Defence assets at variable scales and quantities.

This Guideline is principally intended for stationary chemical storage facilities only. Chemical storage facilities refer to storage of any chemicals in tanks, which can be located above or below ground, or other storage facilities which may comprise of multiple storage tanks or containers. This could include bulk storage or minor storage of hydrocarbons, fuels, solvents and liquid wastes (e.g. effluent, wash water and hazardous liquids) as well as storage of hazardous solid chemicals.

The Guideline does not include:

• requirements for the chemical storage of munitions, radioactive, nuclear or biological materials (including sewage/effluent from treatment plants); and

• detailed specific regulatory requirements in relation to the use of mobile chemical storage units, such as tankers and transport vehicles, or the transport of liquid chemicals by road, rail or sea.

3. Stakeholders Responsibilities

This Guideline has been prepared for use by all Defence stakeholders likely to have responsibilities for design, installation and establishment of chemical storage facilities. This particular guide has broad application at all Defence sites. Stakeholders include:

• Infrastructure Division delivering storage facilities, such as Joint Fuels and Lubricants Agency (JFLA), Defence Materiel Organisation (DMO), Joint Logistics Control (JLC), People Strategies and Policy Group, Occupational Health and Safety (OHS) Branch, Royal Australian Air Force (RAAF), Royal Australian Navy and the Australian Army;

• Contractors managing the design, installation and establishment of chemical storage facilities on behalf of Defence, such as Garrison Support Services (GSS), Comprehensive Maintenance Services (CMS) and the Infrastructure Asset Development Branch (IAD);

• Regional environmental staff supporting environmentally sound practices;

• Resident units conducting routine maintenance activities involving the use of chemical storage facilities; and

• Base support staff, contractors, site users and Defence Support Group (DSG) estate managers all have a level of responsibility for the installation and establishment of environmentally sound chemical storage facilities.

Designated owners and operators of chemical storage facilities are responsible for implementing a management system, maintaining documentation of all installation and repair activities, and ensuring that all staff are appropriately trained in the operation of the facility. A commonsense approach should be taken to determine the appropriate extent to which the guidance should be applied. Advice should be sought from regional environmental staff in the first instance.

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4. Pollutants Associated with Chemical Storage Facilities

The pollutants of concern to be considered during the design of chemical storage facilities are wide ranging, depending on the chemical material to be stored.

A number of pollutants, earmarked for improved management in the DPPS (2007), may represent chemicals stored as part of Defence operations:

• Hydrocarbons (solids and liquids) from fuel installations and equipment.

• Pollutants that may be generated in the event of fire fighting/suppression activities, such as AFFF (and other resulting by-products, e.g. perfluoro octanesulfonic acid /perfluorooctanoic acid (PFOS/PFOA)) contaminated waste water (addressed separately in Defences’ Environmental Management Guidelines for Management of Fire Fighting Aqueous Film Forming Foam (AFFF) Products, June 2007). 1

• Explosives and unexploded ordinances from weapons ranges, burning grounds and munitions manufacture. 1

• Biological materials, including sewage from sewage treatment plants. 1

• General waste including grease traps created during activities within the living quarters and messes.

• Batteries used for maintenance, communications equipment and components or parts.

• Copper chromium arsenic treatments from wood preservation.

• Solvents and volatile organic compounds used within laboratory and maintenance usage situations.

• Heavy metals resulting from maintenance activities or found in weapons ranges and burning grounds.

• Ozone depleting substances found in fire extinguishers, air conditioning units, compressors and other equipment .

• Corrosives (acids/alkalis) used during maintenance, laboratories and within batteries.

• Perchlorate used within rocket fuel.

• Paints used in building and automotive maintenance.

• Resins from maintenance activities.

• Radioactive materials used in hospitals, laboratories and buildings 1.

• Resins found in maintenance activities.

• Pesticides, biocides and persistent organic pollutants from workshops, gardening/landscape and maintenance activities.

National and State guidelines indicate that even at trace concentrations (as low as parts per billion depending on the pollutant) in groundwater, soil and air, these pollutants may represent a risk to human health and the environment.

The Guideline does not include requirements for the chemical storage of munitions,

1 It should be noted that this Guideline does not include these pollutants.

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radioactive, nuclear or biological materials (including sewage/effluent from treatment plants) or fire suppression chemicals (PFOS/PFOA etc).

This Guideline does not include detailed advice on specific regulatory requirements in relation to the use of mobile chemical storage units, such as tankers and transport vehicles, or the transport of liquid chemicals by road, rail or sea.

Photograph: ASTs at Chowder Bay Naval Fuel Installation, NSW, were constructed in 1936/37 and are of high historic significance due to being amongst the earliest surviving and largest capacity storage tanks built for Defence purposes in Australia.

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5. Segments of the Environment Potentially at Risk

The key risk of an operational failure or incident during chemical handling and storage activities are impacts to air quality, soil, groundwater and surface water quality. The fluid nature of some liquid based chemicals and the leachable nature of some solid based chemicals upon contact with water means that any leaks/spills are highly mobile and may cause pollution of the atmosphere, soil, creeks, groundwater and the ocean.

Pollution of groundwater can occur when a chemical spilt to ground migrates down through the soil matrix until it reaches the subsurface groundwater. Many chemical storage facilities include the underground storage and pipe work and any leaks/spills may cause pollution of groundwater. Aged above ground storage facilities with inadequate pollution control coupled with inadequate management procedures also have the potential to impact local groundwater receptors.

Land, surface water and air quality may also be impacted by operational failure during chemical storage and handling activities. Spills can occur to land during transportation, or transfer between storage containers, and can cause contamination of the surrounding soil. Pollution of sensitive ecosystems present within surface waters (e.g. lakes or creeks) may result from spills occurring at facilities located adjacent to or up stream from these surface waters. Such impacts are often complex, expensive to rectify with certainty and at times may result in damage to the environment, and impairment to human health. Air quality may also be impacted by operational failure during chemical storage and handling as many chemicals are volatile in nature. Volatile components may be present in the chemical which may generate vapours during handling activities involving the chemical that has the potential to impact air quality.

Should groundwater, land, surface water and air quality become impacted as a result of operational failures during chemical storage and handling activities or structural failure of facilities, there may be significant risks to human health and the environment. They may also result in breaches of Commonwealth, State and Local regulatory requirements and/or environmental licences, which may in turn give rise to penalties or fines from environmental authorities and present potential reputational issues.

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6. Procurement Considerations

The design and installation of new chemical storage and handling facilities is the most effective and efficient opportunity to build pollution prevention systems into infrastructure, as most leak detection and prevention technologies (e.g. secondary containment and cathodic protection) and water drainage systems are integral to the design, and are only practicable for inclusion at the design, installation or upgrade stages.

All equipment for chemical storage should be procured in accordance with the relevant Australian Standards for the material to be stored within facility. In particular, for fuel storage all equipment should be procured in accordance with Australian Standard 1940 (2004) The storage and handling of flammable and combustible liquids, and where necessary, Australian Standard 4897 (2008) The design, installation and operation of underground petroleum storage systems.

The design, procurement and installation of a new chemical storage facility must be undertaken by qualified personnel and should be referred to the relevant Defence Agency (e.g. the Joint Fuels and Lubricants Agency for fuel tank installation). All equipment must be subject to a quality assurance and integrity testing prior to commissioning. The preferred chemical storage arrangement typically consists of a double walled aboveground fibreglass tank, with interstitial leak monitoring. Secondary containment areas should be constructed of impermeable materials and the design should ensure that all fill points, pumps, meters and gauges are located within the bunded area.

Federal Occupational Health and Safety (Safety Standards) Regulations, 1994 regulated by Comcare, apply to determine if the quantities of flammable or combustible materials stored require a Major Hazard Facility Licence (on Commonwealth land). In addition, different environmental licensing requirements exist in each State depending on the type of chemical being stored the volume of the storage facility and the location of the tank (underground or aboveground). Relevant licences should be obtained prior to the commencement of the activity.

Pipe work and dispensing equipment should be constructed with minimal joints to minimize the risk of leakage.

Several States have legislative requirements for the design of chemical storage systems (which are chemical type dependent), which should be followed.

The work performed by contractors for Defence is an extension of Defence’s activities. Therefore, due diligence must be taken to assure that the work performed by contractors are in line with Defence’s policies and guidelines and State specific regulations.

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7. Guideline Requirements and Performance Standards

The performance standards included in this Guideline aim to assist Defence with reducing key pollution risks (pollution prevention) and support compliance with applicable legislation and Australian Standards in relation to pollution prevention.

It should be noted that Defence is obliged to comply with Defence and other Commonwealth Government environmental policies, initiatives and legislation/regulations. Defence also endeavours to meet the requirements of State and Territory legislation, regulations and guidelines and to performing tasks to best practice standards.

Contractors, lessees or licensees operating or occupying Defence facilities, or undertaking activities on behalf of Defence, are also obliged to comply with State and Territory legislation, regulations and guidelines.

Table 7.1 details the pollution prevention guideline requirements associated with the design of chemical storage facilities. Table 7.1 is broken up into performance standards which make up the pollution prevention environmental management Guideline. Under each performance standard is a summary of the requirements/actions necessary to achieve the performance standard.

External references to each of these requirements and actions are detailed in the reference column of the table. The references have been provided to allow for further detail to be reviewed on the requirements/actions specified within the table, should this be needed. Further details of the reference documentation referred within the table are located in Section 10 of this document. This Guideline covers only key requirements related to pollution prevention and does not address all requirements detailed within the external reference documents in Section 10. Please review the external reference documents for comprehensive details on the Commonwealth, State and Territory legislation and regulations and the best practice requirements.

For application of the requirements and actions outlined for each performance standard, the specific design requirements of the chemical storage facility needs to be considered. It may be that only some of the requirements and actions are applicable to the chemical storage facility being considered. The onus is on the stakeholder(s) to ensure appropriate review of each requirement/action, and if necessary, the source reference documentation, to ensure specific requirements are undertaken to address the performance standard. The onus is also on the stakeholder(s) to ensure that the full level of application of the requirement is undertaken by the review of the source reference documentation.

For example, for the storage of more limited quantities of bulk fuel (one or two above ground storage tanks), the operational and design requirements outlined in Performance Standard 3, 4 and 5 (see Table 7.1) need to be applied based on review of the referenced documentation with knowledge of the type and quantity of fuel required to be stored. It may be that some requirements do not apply; but it is up to the stakeholder to document how the requirement/action does not apply for their fuel storage and handling situation.

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The performance standards included in Table 7.1 are:

1. Management and Administrative Controls: Chemical storage facility complies with supporting documentation requirements and required inspections and management reviews deemed necessary within applicable legislation and Australian Standards.

2. Drainage Systems: Drainage systems at the facility comply with maintenance and monitoring requirements and appropriately manage pollution risks associated with the discharge of water as outlined within applicable legislation and Australian Standards.

3. Design of Storage Facilities: Design of the chemical storage facilities and tanks complies with requirements outlined within applicable legislation and Australian Standards.

4. Design of Equipment/Facilities: Design of the chemical handling and dispensing equipment/facilities complies with requirements outlined within applicable legislation and Australian Standards.

5. Chemical Handling Operations: Procedures and operations for chemical handling comply with requirements outlined within applicable legislation and Australian Standards.

6. Emergency Response and Clean-Up: Emergency response and clean-up procedures and actions for liquid waste handling activities comply with requirements outlined within applicable legislation and Australian Standards.

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Table 7.1: Pollution Prevention Guideline Requirements and Performance Standards.

Requirements for meeting the performance standard.

Further details Reference

7.1 Management and Administrative Controls

Performance Standard 1: Chemical storage facility complies with supporting documentation requirements and required inspections and management reviews deemed necessary within applicable legislation and Australian Standards.

Risk Assessment

a) Preparation of an environmental risk assessment or site sensitivity assessment of the equipment and associated activities, assessing the potential exposure to sensitive receptors (best practice).

The risk assessment should identify potential sources of pollution (hazards), environmental receptors including exposure to sensitive ecosystems and pathways between the source and receptors. Data should be collected prior to undertaking the risk assessment regarding the selected locations groundwater, soil conditions, rainfall, surface water and stormwater drainage.

The environmental risk assessment should be completed in accordance with AS/NZS ISO 31000:2009 (Standards Australia, 2009) and the Defence DSG Risk Management Framework (available from Defence Infrastructure Management) prior to the commencement of the chemical handling and storage activities.

The Australian Standards for the storage of various chemicals specifies separation distances between defined protected places (that is, facilities and receptors, see Australian Standard) and the chemical or chemical waste storage, and segregation of classes and separation distances from other dangerous goods. The risk assessment should be used to identify any protected places within the vicinity of the storage facility design.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

AS/NZS ISO 31000 (2009)

State References

DoW (2006a)

Various State Dangerous Goods legislation

b) Prepare a hazard assessment of chemicals to be stored within the facility (as per Australian Standard).

Prepare a inventory of all the chemicals and dangerous goods classes for the chemicals to be stored within the chemical facility. Based on the chemicals to be stored, review the relevant Australian Standards and the Australian Dangerous Goods Code o assess where segregation of classes and separation distances of storages for chemicals is necessary.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

NTC (2007) Aust. DG Code

Environmental Management Plan (EMP)

c) Prepare an EMP for the chemical facility and tanks (best practice).

d) Undertake regular inspections against requirements in EMP and keep records of the completed inspection checklists (requirement as per Australian Standards).

e) Undertake regular management review of this guideline and the EMP and keep documented records of this process (best practice).

Prepare the EMP based on the outcomes of the environmental risk assessment, using the risk assessment hierarchy, focusing on hazard prevention measures and where necessary, engineering and administrative controls to ensure management of the risk. The EMP should address all aspects of on-going operation, including the required maintenance and inspection schedule, regular inspections of equipment, loss monitoring/investigation procedures, groundwater monitoring program, emergency response and requirements for regular management review of the implementation of this Guideline and EMP.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

DoW (2008, 2009)

EPA Victoria (2009)

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7.1 Management and Administrative Controls Preventative Maintenance Schedule

f) Chemical storage equipment is listed on a preventative maintenance schedule (best practice).

g) Show documented evidence that maintenance is completed in a timely manner (as per Australian Standards).

A maintenance program should be developed with frequency established based on the manufacturer’s guidelines and the criticality of the equipment. As a minimum, maintenance/inspections should be undertaken for all tanks, secondary containment systems, meters, leak monitoring systems, gauges and dispensing equipment, drainage systems and oil/water separators, monitoring equipment and vapour recovery equipment.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

DoW (2009)

Licence Requirements

h) Copies of all current licenses or notifications for the bulk storage of Dangerous Goods are to be held onsite (State legislative requirement).

i) Ensure that any licence specific requirements are transposed into the EMP (best practice).

For Defence sites, licence requirements Dangerous Goods are governed by Comcare.

Should the storage of Dangerous Goods be in quantities large enough to meet the requirements of a major hazard facility (MHF) further licence requirements must be adhered to under Comcare’s regulatory requirements governing Commonwealth land (see Commonwealth Occupational Health and Safety (Safety Standards) Regulations 1994). The Dangerous Goods Safety (Major Hazard Facilities) Regulations 2007 introduce the term "critical quantity" in respect of Schedule 1 substances to mark the level above which the operator of a facility must notify the Chief Officer as the first step in the regulatory process (notification of a MHF). The critical quantity corresponds to 10% of the threshold quantity of schedule 1 substances.

State References


Dangerous Goods Manifest & Material Safety Data Sheets (MSDSs)

j) Keep an up-to-date Dangerous Goods manifest for the facility (as per Australian Standard).

k) Keep a copy of MSDSs for all chemicals held onsite (as per Australian Standard).

The facility should maintain a register of the types and quantities of Dangerous Goods held onsite.

The facility should maintain copies of MSDSs for all chemicals held onsite in an easily accessible area for personnel. MSDSs must be updated every five (5) years.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References


Infrastructure Plans

l) Copy of ‘as-constructed’ plans detailing the site and tank layout (requirement as per Australian Standard).

The facility should maintain construction drawings and site layout plans for facility.

National References

AS4897 (2008)

State References

DECCW (2009)


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7.1 Management and Administrative Controls Staff Training

m) Records of staff training in the storage and handling of dangerous goods and the objectives and implementation of the EMP (as per Australia Standards).

All personnel involved in the handling and use of dangerous goods, including chemical storage facilities, should receive appropriate training in the environmental risks, health and safety impacts, the use of this Guideline and the associated EMP, and in the implementation of the emergency response procedures. Refresher training should also be scheduled at regular intervals.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

DoW (2006b)

DoW (2009)

Various State Dangerous Goods and OHS legislation

Record Keeping

n) All records related to the installation, repair, maintenance, operation and decommissioning of a chemical storage facility should be retained for future review (requirement as per Australian Standard).

Records related to the installation, repair, maintenance, operation and decommissioning of a bulk chemical storage facility should be retained for a minimum of five (5) years with a requirement for more than seven (7)years in some States (legislative requirement in various States)

National References

AS4897 (2008)

State References


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7.2 Drainage Systems

Performance Standard 2: Drainage systems at the facility comply with maintenance and monitoring requirements and appropriately manage pollution risks associated with the discharge of water as outlined within applicable legislation and Australian Standards.

Waste Disposal

a) All wastewater (including storm water) from areas where chemicals are handled or stored is passed through an oil water separator or other treatment process prior to disposal (requirement as per Australian Standard).

b) Wastewater discharge licenses for disposal from areas where chemicals are handled or stored to the surface water system or sewer must be obtained and held onsite (as per State based requirement).

c) Evidence that any licence specific compliance requirements have been transposed into the EMP (best practice).

All water from within a bunded area, or around areas where chemicals are used, handled or stored, must be captured. Any wastewater discharged to the surface water or sewer systems is required to be licensed or permitted as part of state based regulations, and as part of this licence/permit must be passed through an appropriate treatment process (e.g. an oil water separator for oil based chemicals) to achieve acceptable water quality for discharge.

Where a suitable sustainable drainage system exists, (e.g. a constructed wetland) this may be used to treat waste water prior to disposal; however this would still need to be regulated through a state-based licence or permit. Only certain wastewaters, with particular chemical characteristics (e.g. elevated nutrient loads) may be suitable for treatment in constructed wetlands. Oily or metal contaminated wastewaters are generally not suitable for treatment in constructed wetlands.

National References

AS 4452 (1997)

AS 1940 (2004)

State References

Various State-based water management legislation.

d) Documentation showing completed waste disposal records using licensed waste contractors for all chemical contaminated water, oils and sludges removed from the drainage systems which must be stored on site (as per individual State requirements and best practice). Includes details on location and quantity of waste disposal.

e) Use of compliant packaging, labelling and tracking of wastes for transport (as per individual State requirements).

All chemical contaminated waste including oily waste or sludge removed from the drainage systems should be disposed with an appropriately licensed waste disposal contractor. The facility should check that the waste disposal contractor is licensed to transport the waste, and that the waste is received by a facility that is licensed to accept it.

State References

Various State-based water management legislation and Dangerous Goods legislation

f) Documented records of regular visual inspections of the treatment process should be kept (requirement as per Australian Standard).

g) Monitoring data and comparison with requirements with the waste discharge licence conditions should be recorded and stored.

The discharge from the treatment process should be visually inspected on a regular basis, and any required monitoring completed in accordance with any site-specific licence.

National References

AS1940 (2004)

AS4897 (2008)

State References

Site specific licence conditions for discharge to surface water system or sewer

h) Presence of separate drainage for incompatible chemicals (as per Australian Standard).

Chemicals should drain away from the storage facility into a sump. Chemicals that are likely to react should be directed into separate drainage areas. The drain valve should remain closed at all times except under supervision during emptying.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004).

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7.2 Drainage Systems

Infrastructure Plans

i) Drainage plans are available for the chemical storage facility (requirement as per Australian Standard).

The facility should maintain drainage plans detailing the surface water and sewer connections, chemical storage drainage, liquid waste drainage and interceptors and treatment plant configurations.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

DECC NSW (2005c)

Record Keeping

j) Documented records of maintenance inspections on drainage systems should be kept (requirement as per Australian Standard).

A regular inspection maintenance program for drainage systems and interceptors must be implemented.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

Stormwater Management

k) A canopy or roof is present over the chemical tank and filling area with open bunds (best practice).

l) Separate drainage is provided for clean rainwater and potentially contaminated wastewater (NSW guidance).

Where possible a canopy or roof with an overhang should be provided to cover tank filling areas, chemical facilities and above ground storage tanks with open bunds. The purpose is to minimize the generation of polluted rainwater. The canopy should allow clean rainwater to be separated from potentially polluted water. These two water streams should be disposed through separate drainage channels. Roof drainage may normally be discharged directly to a stormwater drain without prior treatment such as an interceptor or chemical treatment unit.

National References

AS 4897 (2008)

AS 1940 (2004)

State References

DECC NSW (2005c)

DoW (2006a)

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7.3 Design of Storage Facilities

Performance Standard 3: Design of the chemical storage facilities and tanks complies with requirements outlined within applicable legislation and Australian Standards.

Design and Installation

a) Design and installation by approved appropriately qualified contractor / personnel (requirement as per Australian Standard).

b) Keep records of installation by approved appropriately qualified contractor / personnel should be kept on site (requirement as per Australian Standard).

All above-ground storage tanks (ASTs) and underground storage tanks (USTs) must be installed by qualified personnel according to the relevant Australian Standards, Defence Guidelines and State-based Dangerous Goods legislation.

National References

AS4897 (2008)

State References

DoW WA (2008)

c) Evidence that separation distances between storage areas and sensitive areas have been considered in the design and risk assessment (requirement in legislation and Australian Standard).

d) Evidence of an assessment of the different chemicals to be stored within the chemical storage facility and segregation requirements (as per Australian Standard).

Chemical storage areas must be provided with adequate separation from sensitive areas, such as residential and office accommodation, in accordance with the legislation.

A number of different chemicals may be stored within a single chemical storage facility. Some chemicals will need to be segregated to prevent a reaction from occurring if spilt. These chemicals should be placed in areas of separate secondary containment and drainage.

Separate bunding and drainage would be required to ensure the presence of compatible classes of chemicals within the facility. The presence of separate bunding and drainage for difference chemicals will allow the consideration of potential reuse of these material following spills into the bund or drain.

National References


AS1940 (2004)

AS4897 (2008)

State References

Various State Dangerous Goods legislation.

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Appropriate Storage Containers

e) The storage facility is designed to allow chemical storage in appropriate containers that are labelled (as per Australian Standard).

Chemicals should be stored in a sealed container based on the quantity of chemicals used. The drums, packages or tanks used for storage should comply with any State specific requirements for the storage of hazardous materials. At a minimum the drums, packages or tanks used for storage should be chemically inert, be sealed and resist corrosion.

Wherever possible, the chemicals should be stored above ground. For some types of chemicals (e.g. toxic chemicals) this is a requirement within the Australian Standard. If the chemicals are stored below ground, then a number of additional requirements are necessary which are detailed in the WA Department of Water, Water Quality Protection Note Tanks for Underground Chemical Storage (2008).

The distance between the containers and the bund wall should be designed to prevent a overspill from the secondary containment. This can be achieved by having a minimum distance between the container wall and the containers, not over stacking the containers or using shields.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

DoW (2006a)

DECC NSW (2005c)

DoW (2009)

f) Design plans demonstrate tanks are provided with protection against corrosion (requirement as per Australian Standard).

All ASTs and USTs should have some form of protection against corrosion. This may include construction using non-corrodible materials (e.g. fibreglass), specific cathodic protection, or protective coating (e.g. paints).

National References

AS 4897 (2008)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

ASTs

g) Use a double skinned, corrosion resistant ASTs for chemical storage (best practice).

h) AST and all relevant equipment are located within a bunded area (requirement as per Australian Standard).

i) Evidence that the bunded area is able to contain at least 100% of the maximum tank volume or 25% of the total volume of smaller containers, whichever is greater (as per Australian Standard).

Where possible, bulk chemicals should be stored within an AST. The AST should be provided with a chemical-impermeable secondary containment area (i.e. a bund), which is able to contain at least 100% of the largest tank volume. The Australian Standards recommend that spill compound capacities be about 110%, to facilitate the management of spill emergencies.

Bunds should provide total containment, and no part of the tank infrastructure (e.g. dispenser, filling hoses and valves) should protrude outside the bund. The bund should not have drainage holes. Removal of rainwater should be undertaken when required by pumping (either a manually implemented or dedicated pumping system).

If there is potential for rainwater to be contaminated by residual chemical spilt within the bund, care must be taken to ensure that rainwater removal from a bund is undertaken appropriately, with removal not automatically directed to stormwater, but to a treatment system (under state based licence/permit requirements). Monitoring of the potential for rainwater to be contaminated by residual chemical spilt within the bund can be undertaken via regular review of spill record documentation and appropriate actions to clean up spills via operational procedures.

National References

AS 1940 (2004)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

State References

DoW WA (2008)

DoW (2006a)

JUNE 2011 16




USTs

j) Use a double skinned, corrosion resistant UST for chemical storage (best practice).

k) Maintain design plans showing the construction of the underground tanks (requirement as per Australian Standard).

Where chemicals are required to be stored in an UST, the tank should be provided with a double skin and interstitial leak detection system.

Alternatively, the tank may be contained within a secondary structure (e.g. a concrete lined pit). An observation point should be provided in the pit to help detect leaks.

National References

AS1940 (2004)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS4897 (2008)

State References

DoW WA (2008)

DoW (2006a)

Risk/Hazard Assessment

l) Completed risk/hazard assessment of the chemical storage facility and tanks (as per Australian Standard).

The location of the chemical storage facility or tanks should be assessed to ensure that the risk to surrounding watercourses is low. Where the facility is located within 500 m of a watercourse (WA guidance) additional assessment of the risks are required by the regulatory authority.

1. During the assessment of the liquid waste storage facility the following factors should be considered:

2. presence of secondary containment;

3. separation of the facility from ignition sources and occupied buildings;

4. proximity of the facility to processing areas and ability to transfer the waste produced;

5. fire resistance and chemical impermeability of secondary containment area;

6. layout of the facility with respect to fire fighting, security, signage, ventilation, product segregation and manual handling.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

DECC NSW (2005c)

DoW (2006a)

DoW (2008)

JUNE 2011 17




Spillage containment

m) Secondary containment (e.g. a bund) of the chemical storage facility is sufficient to contain at least 100% of the maximum tank volume or 25% of the total volume of smaller containers, whichever is greater (as per Australian Standard).

n) It should be ensured that any pipe joints in the pipe tracks are located within the bunded storage area. There should be capacity within the secondary containment facility for all handling, storage and transfer of the chemical which includes leaks from pipe work (best practice).

o) An assessment of the capacity of the secondary containment area to account for the hazardous nature of the chemical and any potential rainwater flow into the containment area (as per Australian Standard).

p) A collection sump located below the base of the bund to contain spills (as per Australian Standard).

All handling and storage of chemicals should be undertaken within an area of secondary containment such as a bund. This includes secondary containment for:

• transfer of chemicals via pumping and decanting with all pipe joints located within the bund; as well as

• potential filling/unloading of transport vessels or containers.

Depending on the material stored within the bund the capacity, according to the Australian Standard, may be required at least 100% of the maximum tank volume. The amount over 100% of the tank volume is prescribed in some cases, depending on the chemical being stored. The capacity of the bund should be reassessed where a hazardous material is stored to account for any fire fighting water that may be released into the bund. A chemical storage facility that is outside should have the bund volume increased to account for any rain water that enters the bund.

The bund should be made from an impervious material that is resistant to the chemicals stored within the bund. The bund should be sealed and all piping should enter or exit the bund over the wall.

If only a small quantity of chemicals is temporarily stored this may occur in a single drum with a drum sump or drip tray.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

DECC NSW (2005c)

EPA SA (2007)

Maintenance and Inspection

q) Evidence of regular maintenance/inspection of the chemical storage facility, including removal of waste water within the base of the secondary containment facility (as per Australian Standard).

r) Evidence of regular house keeping and organised/planned design of drum storage (as per Australian Standard).

Regular inspection of the chemical storage facility should address the presence of stormwater within the secondary containment facility and any damage to the primary containment vessels (drums or tanks) or secondary containment facility (bund). If storm water is observed within the secondary containment facility or sump it should be pumped out and disposed of appropriately.

Primary containment vessels, including drums, packages and tanks, should be stored to ensure that any spill from the vessel is maintained within the secondary containment. Drums or packages within close proximity to the bund wall should not be over stacked. In some circumstances areas of the chemical storage facility (e.g. between a high bund wall and a tank) may act like a confined space. Therefore confined space procedures should be utilised. Mechanical and natural ventilation can be used to prevent the accumulation of vapours.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

DECC NSW (2005c)

EPA SA (2007)

DoW (2006a)

DoW (2009)

JUNE 2011 18




Leak Detection

s) Chemical storage facility is designed to include a leak detection system to assess the presence of a leak (requirement as per Australian Standard).

t) Records of interstitial leak monitoring, inspections and test are kept for at least 2 years (requirement as per Australian Standard).

Where chemicals are required to be stored in an UST, the tank should be provided with a double skin and interstitial leak detection system.

In order of preference, leak detection should be assessed using an:

• automatic leak detection,

• tank pit wells installed within the tank pit and regularly inspected

• wet stock monitoring of inventory;

• environmental monitoring through the measurement of fuel within groundwater monitoring wells; and

• integrity testing, using a method with a capability to detect a minimum leak of 0.38L/hour , with a probability of detection of 95 and a probability of false detection of 0.05 (different to the UST leak monitoring system capacity).

Tank pit observation wells can be checked for spilled liquid or vapour within the tank pit. Evidence of tank pit contamination may include visual or olfactory evidence.

Details and inspection of the leak detection system should be included in the environmental management plan including system checks.

Integrity testing is not the preferred method of testing due to the prohibitive costs and infrequency of testing. However it is considered to be good practice to conduct integrity tests (in addition to standard leak detection testing) every five (5) years and for single walled tanks more than 15 years old, integrity testing should be completed every two (2) years.

National References

AS 4897 (2000)

AS 1940 (2004)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

State References)

DoW (2008)

DoW (2006a)

Groundwater Monitoring

u) Installation of groundwater monitoring wells surrounding USTs as a supplementary method of leak detection (recommended as per Australian Standard).

v) A minimum of three (3) groundwater monitoring wells (1 upgradient, 2 downgradient) with monitoring every six (6) months is required (best practice and NSW regulations for UPSSs).

Consideration should be given to the installation of groundwater monitoring wells around underground storage tanks to assess any potential leaks and impacts to groundwater. This is particularly relevant for tanks which do not have interstitial leak monitoring devices, and in locations where the sensitive receptors (e.g. groundwater fed watercourses, abstraction bores) are present.

Installation of groundwater wells is technically complex and should be carried out by a qualified person. This person should select locations, design the wells and determine monitoring frequency. At the first monitoring event, samples should be analysed for pollutants depending on the tank contents. Subsequent monitoring may be limited to visual and olfactory inspection if there is no evidence that contamination is present. Further investigation may be needed if contamination is detected.

National References

AS4897 (2008)

State References

DECCW (2009)

NSW State Gov (2008)

JUNE 2011 19




Overfill Protection

w) Tanks should be designed with overfill protection (requirement as per Australian Standards).

Equipment should be fitted with overfill protection. The overfill protection can consist of either an automatic shut off device or an audible or visible overfill alarm.

The safe fill level should be clearly identified on the gauge and set at 90% (best practice) to prevent overfilling.

The tanks should be fitted with an overflow system and any discharges should be released into the bund.

National References

AS 1940 (2004)

AS 4897 (2008)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

State References

DoW WA (2008)

Signage

x) Evidence of appropriate safety signage on the tanks and bulk storage area (Australian Dangerous Goods Code requirement).

All areas where dangerous goods are stored should be provided with safety signage in accordance with the legislation. This should include the hazard warning labels (such as no smoking signs) where relevant.

National References


AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

Security

y) Appropriate security measures are present (legislative and Australian Standard requirement).

z) Repair and restore any evidence of vandalism (best practice).

Areas where dangerous goods are stored should be provided with adequate security, including fencing and locks on equipment if required.

Collision protection should be provided on storage facilities.

National References


AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

AS 4897 (2008).

Fire Protection/Control

aa) Risk assessment includes consideration of fire risk (legislative requirement).

bb) Evidence that any fire protection control measures in the risk assessment have been installed (requirement as per Australian Standard and legislation).

cc) Records of maintenance of fire control measures (legislative requirement).

Chemical storage facilities should be provided with adequate fire prevention and control equipment, in accordance with the legislation. This may include smoke detection and alarm system, access to fire extinguishers, fire hydrants or sprinkler systems as appropriate to the nature of the facility.

Servicing of fire protection measures should be included on a preventative maintenance system.

National References


AS1940 (2004)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

State References

Various State Dangerous Goods legislation.

JUNE 2011 20



7.4 Design of Equipment/Facilities

Performance Standard 4: Design of the chemical handling and dispensing equipment/facilities complies with requirements outlined within applicable legislation and Australian Standards.

Secondary Containment

a) A bund or inward sloping floor is located around equipment and the chemical storage facility to contain potential spills. The secondary containment facility should be able to hold at least 100% of the volume contained. This includes containment for the road tanker volume which could be larger than the tank being filled (this is a requirement as per Australian Standard).

All equipment, including tank fill points, pumps and meters, must be located within the secondary containment to contain potential spills.

For facilities requiring filling via road tankers, a rollover bund should be created within the compound area to allow for filling to occur within a containment area. This is because the location of the connection between the hose and the tanker is a high-risk spill location

The road tanker should be positioned fully within the roll over bund of the contained area when refilling bulk storage tanks.

Defence References

Defence (2006)

National References

AS 1940 (2004)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

State References

EPA ACT (2009)

Pipe Work

b) Tank and pipeline layout to minimise the need for bends, joints and underground pipelines (requirement as per Australian Standard).

c) New underground piping is fitted with a secondary containment system (requirement as per Australian Standard).

d) All equipment should be made from corrosion resistant material (requirement as per Australian Standard).

The number of bends and joints connecting pipelines and tanks should be kept to a minimum.

Piping should be placed over ground wherever possible.

Where underground piping is required, double contained systems should be installed on new pipelines.

National References

AS1940 (2004)

AS4897 (2008)

State References

DECCW (2009)

DoW WA (2009)

Permitting/Lock-out Tagging Procedures

e) Existence of a permit to work and lock-out tagging system for any maintenance procedures undertaken (requirement as per Australian Standard and legislation).

All maintenance on bulk chemical storage facilities should be undertaken using a permit to work and lock-out tagging system of storage infrastructure to prevent additional spills.

National References

AS 1940 (2004)

State References

Workcover NSW (2005)

Collision Protection

f) Protect dispensing equipment against collision damage (requirement as per Australian Standard).

Collisions between vehicles and dispensing infrastructure have the potential to result in spills; therefore all dispensers must be fitted with protection against collision damage (e.g. bollards) and unauthorized use.

National References

AS 1940 (2004)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

International References

UK Environment Agencies (2004)

JUNE 2011 21



Dispensing Equipment Design

g) Design of the filling and dispensing area is within secondary containment (requirement as per Australian Standard).

h) Design for transfer lines of less than 6 m to minimise the potential for spills (requirement as per Australian Standard).

Filling areas should be located within the secondary containment, including the entire delivery tanker. The transfer line between the tanker and the bulk container should be less than 6 m in length to minimise the potential area for spillage.

National References

AS 1940 (2004)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS4897 (2008).

i) Dispensing equipment has appropriate design and containment (requirement as per Australian Standard).

Dispensing equipment should be fitted with automatic shut off measures to prevent spills.

Dispensing systems include suction, pressure or gravity systems. Suction systems work under a partial vacuum, pressure systems pump at high pressure and gravity systems (for AST) use the weight of gravity to force the fuel down. Suction systems are recommended for dispensing equipment as it allows chemicals to flow back into the tank.

A sump should be located under any type of dispenser to capture losses. Dispensers attached to ASTs should be stored inside the bund.

Older dispensers should be fitted with break coupling, drip trays and pump valves to minimize fuel spills.

National References

AS 1940 (2004)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 4897 (2008)

State References

DECC NSW (2008)

JUNE 2011 22



7.5 Chemical Handling Operations

Performance Standard 5: Procedures and operations for chemical handling comply with requirements outlined within applicable legislation and Australian Standards.

Procedures

a) Display safe delivery procedures at the fill point and supervision of tank filling (requirement as per Australian Standard).

Delivery of chemicals and filling of tanks should be supervised by trained staff. Safe delivery procedures should be documented and discussed with the fuel delivery company. A notice specifying the tank volume and the delivery procedures should be located at the storage delivery point (i.e. on the AST or UST).

National References

AS 1940 (2004)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

State References

DECC NSW (2008)

Filling Area Design and Operation

b) The catchment basin is large enough to contain the spill (minimum of 15 L) during hose uncoupling and check valves used during connection (requirement as per Australian Standard).

c) Catchment basin is of appropriate design and is not connected to a drain which connects to the stormwater system, even via the interceptor (requirement as per Australian Standard).

d) Records of waste disposal kept (as per specific State requirement and best practice).

e) Spill kit is available and there are procedures to follow in the event of a spill (requirement as per Australian Standard).

Filling areas should be located on impermeable hardstand areas and be equipped with a catchment basin surrounding the delivery vehicle and fill points to prevent spillage during refilling of tanks or refuelling of vehicles. The catchment basin should have a pump to remove liquid to a containment system and should not transfer liquids directly to stormwater or the sewer (testing and confirmatory analysis of these stored materials should be done in accordance with State/Local regulations prior to disposal to stormwater or the sewer). All spills within the containment sump should be disposed of by an authorized waste disposal contractor.

Filling points should contain non-return check valves and sealed connections to prevent spills occurring.

The hose length should be kept as short as possible (no greater than 6 m in length) to minimize the spillage of fuel should hose rupture occur.

National References

AS1940 (2004)

AS 4897 (2008)

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

State References

DECCW (2009)

DoW WA (2009)

JUNE 2011 23



7.6 Emergency Response2 and Clean-Up

Performance Standard 6: Emergency response and clean-up procedures and actions for liquid waste storage facilities comply with requirements outlined within applicable legislation and Australian Standards.

Design

a) Design of the chemical storage facility to enable rapid emergency response and ease of emergency access (as per Australian Standard).

Good design and layout, operating practices, training and sound engineering can minimise the likelihood of an incident. Factors to be considered during design include:

• Sufficient space between bund and storage areas for emergency and maintenance activities;

• Method of reducing emissions to atmosphere (should this be a risk for type of chemical stored);

• Alarms connected directly to the fire brigade and access routes for fire brigade equipment;

• Location of water supply for washing, cleaning and fire protection;

• Fire protection equipment and protection of personnel;

• Evacuation route;

• Containment of leaks, spills and fire fighting water; and

• Location of the emergency plan and safety board.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

AS 4897 (2008)

Emergency Response Plan

b) An Emergency Response Plan is maintained onsite (requirement as per Australian Standard).

c) Training records demonstrate that personnel are trained to manage emergencies (requirement as per Australian Standard).

An Emergency Response Plan should be prepared as a part of the Environmental Management Plan.

The Emergency Response Plan should be site-specific and address emergencies appropriate to the location and circumstances (e.g. spills, leaks, vapour releases, vandalism, terrorism, fire, explosion, collisions, and floods).

All personnel working within the facility should be trained in the Emergency Response Plan. Refresher training should also be provided (frequency not specified).

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

EPA Vic (2009)

DoW (2009)

2 It should be noted that this just includes environmental considerations. There are likely to be additional safety requirements.

JUNE 2011 24



7.6 Emergency Response2 and Clean-Up

Spill Management and Prevention

d) The spill should be managed with the following key actions (if possible): • Locate spill source;

• Contain in agreement with approved procedures;

• Isolate from drains and waterways;

• Absorb/recover pollutant or contamination as efficiently as possible; and

• Classify spill incident severity.

Spill management action items and methodologies are discussed in further detail in Defence Standard DEF (AUST) 5695B (2006), Part 1, Section 2, Chapter 3.

Defence Reference

Defence (2006)

e) A spill kit including drain covers and absorbent material is available (requirement as per Australian Standard).

f) Clean-up and waste disposal procedures following a spill are annotated on the spill kit (requirement as per Australian Standard).

g) Suitable emergency booms should be available in close proximity to the storage area to prevent isolate spills (as per State requirements and best practice).

h) Training records demonstrate that staff are trained to install emergency booms, or evidence that competent contractor will attend at short notice (requirement as per Australian Standard).

A spill kit should be maintained at all times within all areas where liquid wastes are used, handled or stored. The spill kit should contain covers/booms to protect access to drains and absorbent material for containing the fuel spill. Any absorbent material used to contain the spill should be disposed of in accordance with the State/Local waste disposal regulations.

Where facilities are located adjacent to watercourses, emergency booms to prevent spread of released product should be maintained on site.

National References

AS 4681 (2000)

AS 4452 (1997)

AS 3833 (2007)

AS 1940 (2004)

State References

EPA Vic (2009)

DoW (2009)

Incident Investigation and Notification

i) Spills and Leaks should be reported as per Defence requirements depending on the spill size and level of containment (at minimum, uncontained spills less than 50 L must be reported).

j) For spills and leaks that have spread or have the potential to spread beyond the boundary of the installation the appropriate authority should be notified within 24 hours (requirement as per Australian Standard).

Should leak or spill monitoring suggest a potential fuel leak the appropriate regional environmental officer (REO), JFLA, and [email protected] should be notified.

Where necessary the state regulatory authority should be informed, depending on the size and level of containment of the spill.

Defence Reference

Defence (2006)

National References

AS1940 (2004)

State References

EPA Victoria (2009)

k) Evidence of accident / incident investigation records should be documented and maintained (legislative requirement).

Following notification of a potential spill or leak a full assessment of the leak or spill should be carried out. The assessment of leak or spill, where necessary, may include an intrusive soil and groundwater investigation for underground storage tanks (requirement as per Australian Standard).

National References

AS4897 (2008)

State References

Various State Dangerous Goods Legislation

JUNE 2011 25

8. Other Considerations

OH&S Considerations: There are numerous occupational, health and safety considerations associated with chemical storage and handling. A risk assessment in line with Defence’s DSG Risk Assessment Framework (available from Defence Infrastructure Management) should be undertaken to assess the potential risks associated with each chemical handling specific activity. All personnel must be trained and made aware of the risks associated with undertaking an activity.

MSDSs: Material Safety Data Sheets (MSDSs) must be present and readily available for each chemical stored within the chemical storage facility. Personnel must be trained and made aware of the emergency response and first aid measures associated with exposure to the types of chemicals being handled and stored.

JUNE 2011 26

9. Case Study – Bunding and the South Australian EPA Guidelines.

This case study discusses two examples of a chemical storage facility from the SA EPA Guidelines, an outdoor tank storage facility and a drum storage facility, as observed in Figure 9.1 and Figure 9.2 (EPA SA, 2007). Key features of the storage facilities are discussed in relation to the performance standards discussed in Table 7.1.

Example 1

Figure 9.1: An outdoor tank storage facility (EPA SA, 2007)

An outside tank storage facility is depicted in Figure 9.1 (EPA SA, 2007). Some key features of the outdoor tank storage facility are:

• A covered truck unloading area. The truck unloading area is covered and bunded with a separate drainage system. This allows any potential spills to be captured and disposed of separately to uncontaminated rain water.

• A secondary containment bund. The bund is capable of holding at minimum 100% of the maximum tank volume (Figure 9.1 suggests 120%) as per Australian Standard 1940 (2004). Rain water falling within the bunded area should be considered in determining the bund capacity.

• Pipe work passing over the bund wall. The bund should be made from an impervious material with no holes or flaws where leaks can occur. It should be noted that any pipe that passes through a bund must be designed to prevent excessive stresses as a result of settlement or expansion resulting from fire exposure. The joints for the pipe work are located within the bund area to enable any leaks to be captured.

• Overflow protection on the tank. The tank contains a high level detector to warn of potential overflows as per Australian Standard 1940 (2004). A sight window is also present on the tank for observation of the liquid level during filling.3

3 It is noted that a sight window on the tank may represent a risk for tank failure. Other methods of overflow protection during tank filling should be considered, as per discussion given in Performance Standard 3 on Overfill Protection.

JUNE 2011 27

• Collection sump to capture any contaminated rain water or spill within the bund. Any liquid within the sump would be pumped out and disposed of appropriately.

• Distance between the tank and the bund walls. The tank is located a distance from the bund wall to minimise the potential for spills to occur over the bund wall, allow ease of movement and to prevent the build up of dangerous gases. The wall height allows for a spill from the tank, even at height, to be captured within the bund.

Example 2

Figure 9.2: A drum storage facility (EPA SA 2007)

A drum storage facility is depicted in Figure 9.2. Some key features of the drum storage facility are:

• Partially undercover. Some areas of the drum facility are undercover to prevent the contamination of rain water.

• Separate drainage for different chemicals. Two separate drainage areas are identified within the drum storage facility (under cover and outdoor). Each area is bunded and drains to a separate sump.

• Secondary containment bund. The bund should be able to hold at minimum 25% of the total volume of drums located within the bund as per Australian Standard 1940 (2004).

• Stacking and layout of the drum pallets. The layout of the drums should allow easy access and movement of the drums. The drums are stacked to minimise the potential for spills occurring over the bund wall.

JUNE 2011 28

10. References and Further Reading

Australian Government Department of Defence (Defence), May 2006. Australian Defence Standard DEF (AUST)5695B, Petroleum, Oils and Lubricants Manual.

Australian Government Department of Defence. 2007. Defence Pollution Prevention Strategy: Advancing Defence’s Pollution Prevention Capability.

Australian Government Department of Defence. 2007. Environmental Guidelines for Management of Fire Fighting Aqueous Film Forming Foam (AFFF) Products.

Australian Government Department of Defence (Defence), 2007. Defence Waste Minimisation Policy, sponsored by the Assistant Secretary Environment, Heritage and Risk (ASEHR).

Australian Government Department of Defence (Defence), 2008. Defence Bulk Fuel Installation Facilities. Maintenance Instruction Document (Version 1.0a).

Department of Environment and Climate Change (DECC) NSW. 2005c. Liquid Waste Fact Sheet – Storing of Liquid Waste.

Department of Environment, Climate Change and Water (DECCW) NSW, 2009. Guideline for Implementing the Protection of the Environment Operations (Underground Petroleum Storage Systems) Regulations 2008.

Department of Environment, Climate Change and Water (DECCW) NSW. 2008. Waste Classification Guidelines, Part 1: Waste Classification.

Department of Water (DoW) WA. 2006a. Water Quality Protection Note: General and heavy industry near sensitive waters.

Department of Water (DoW) WA. 2006b. Water Quality Protection Note: Toxic and hazardous substances – storage and use.

Department of Water (DoW) WA. 2006c. Water Quality Protection Note: Tanks for temporary elevated chemical storage.

Department of Water (DoW) WA. 2008. Water Quality Protection Note: Tanks for underground chemical storage.

Department of Water (DoW) WA. 2009. Water Quality Protection Note: Industrial and waste water management and disposal.

Environment Agency for England and Wales, the Scottish Environment Protection Agency and the Environment and Heritage Service in Northern Ireland (UK Environmental Agencies), 2004. Pollution Prevention Guidelines, Refuelling Activities: PPG7.

Environment Protection Authority (EPA) South Australia. 2007. EPA Guidelines: Bunding and Spill Management.

Environment Protection Authority (EPA) Victoria, 2009. Guidelines on the Design, Installation and Management Requirements for Underground Petroleum Storage Systems (UPSSs). Publication 888.1.

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National Occupational Health and Safety Commission (NOHSC). 1994. National Code of Practice for the Labelling of workplace substances.

National Transport Commission (NTC), 2007. Australian Dangerous Goods Code. 7th Edition.

New South Wales State Government. 2005. Occupational Health and Safety Amendment (Dangerous Goods) Regulation (2005) under the Occupational Health and Safety Act 2000.

Office of Queensland Parliamentary Council. 2009. Dangerous Goods Safety Management Act (2001).

Standards Australia. 1997. Australian Standard 4452-1997. The storage and handling of toxic substances.

Standards Australia. 1998. Australian Standard 4494-1998. Discharge of commercial and industrial waste to sewer – General performance requirements.

Standards Australia. 2000. Australian Standard 4681-2000. The storage and handling of class 9 (miscellaneous) dangerous goods and articles.

Standards Australia. 2004. Australian Standard 1940-2004. The storage and handling of flammable and combustible liquids.

Standards Australia, 2006. Australian Standard 1692-2006, Steel tanks for flammable and combustible liquids.

Standards Australia. 2007. Australian Standard 3833-2007. The storage and handling of mixed classes of dangerous goods in packages and intermediate bulk containers.

Standards Australia, 2008. Australian Standard 4897-2008, The design, installation and operation of underground petroleum storage systems.

Standards Australia and Standards New Zealand, 2009. Australian / New Zeeland Standard ISO 31000:2009. Risk management - Principles and guidelines. Adopted by the Australian and New Zeeland Joint Technical Committee on Risk Management.

Victorian State Government. 2009. Victoria Dangerous Goods (Storage and Handling) Regulations 2000. Version incorporating amendments as at 1 January 2009.

WorkCover NSW. 2005. Storage and Handling of Dangerous Goods: Code of Practice.

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