Oil Storage and Pollution

1st September 2005 was the deadline date by when all oil storage facilities had to comply with the requirements of the Control of Pollution (Oil Storage) (England) Regulations 2001. These Regulations contained a phased introduction with new facilities having to be compliant from the date of installation whilst low risk facilities that were not situated near to watercourses have not had to comply until now. The Regulations only apply to England, with certain exemptions such as storage of less than 200lts, oil stored on domestic premises and agricultural premises - where more specific legislation applies.

The Regulations do not apply to Wales or Northern Ireland and whilst corresponding legislation has been proposed for Scotland it is not expected to be enacted until autumn 2005. However, the legislation for England represents good practice and property owners in the rest of the UK would be advised to adopt the requirements of the English legislation as good practice. In brief the law requires the following:

Tanks, drums and containers: These must be sufficiently strong to resist bursting or leaking during use
Secondary containment: Some form of secondary containment must be provided to catch oil leaks or drips from storage containers or ancillary pipework and equipment such as sight glasses, dispensing hoses and valves. Typically this secondary containment would consist of a drip tray under a drum or a bund for a larger container.
Bund Capacity - Drums: The secondary containment e.g. drip tray should be capable of holding 25% of the capacity of the drum or drums.
Bund Capacity - Large Containers: For larger containers the bund that provides the secondary containment must be of sufficient size to hold 110% of the maximum contents of the container. There are more detailed rules for those circumstances where one bund serves two or more containers.
Bund - Drainage: Secondary containment such as bunds must not be fitted with outlets, valves or drains. The walls and floor must be completely sealed to prevent oil escaping. It will be necessary to remove rainwater in order to preserve the integrity of the bund (the 110% rule) but this must be done by pumping the oil into containers for controlled, safe disposal.
Ancillary Equipment: Many oil containers will be fitted with pipework, dispensing hoses and valves, vent pipes, sight glasses etc. These should all be located within the secondary containment.
Impact Damage: Where possible an oil container must be positioned to reduce the risk of damage by impact or collision. If such a risk exists then protection must be provided such as bollards or a suitably robust crash barrier. It is possible that the construction of a bund will satisfy this requirement however, the risk of impact at higher levels must be considered e.g. by the raised forks of a fork lift truck.
Underground Pipework: All underground pipes and connections should be protected from physical damage and be fitted with leak detection facilities. Where the pipework has mechanical joints (as opposed to welded joints) these should be located where it is possible to inspect them e.g., in sumps or inspection chambers.
Double Skinned Tanks: Manufacturers of proprietary storage containers use a variety of terms to describe what is, in essence, a storage container - in plastic or metal - with another "skin" placed around, with a small gap or air space between the two. Such containers have some value for underground storage - when leak detection facilities can be located within the "gap". However, such double skinned tanks are NOT compliant with the Control of Pollution (Oil Storage) (England) Regulations 2001 unless secondary containment is provided. Such tanks may not be sufficiently strong to resist impact and in addition ancillary equipment such as dispensing hoses, valves and sight glasses will be outside the "double skin". Double skinned tanks need to be situated within a suitable bund in exactly the same way as a single skin vessel.

There are a number of more specific requirements and these, together with more detailed information can be found on the Environment Agency website.