Underground fuel storage: how to manage a common pollution risk
Leaks from underground fuel tanks and pipework are a common source of soil and groundwater contamination in Australia. Many of the contaminated sites notified to the various state Environment Protection Authorities (EPA) have involved underground petroleum storage systems (UPSS). There is a clear need for operators of a UPSS to guard against, monitor for, and fix fuel leaks promptly. This can reduce environmental impacts, save costly clean-ups and protect the public.
Regulatory Framework
In 2008, the NSW Government implemented a new law mandating that operators of UPSS must install tanks, pipes, and monitoring equipment for underground fuel systems following industry best practices. Additionally, the Protection of the Environment Operations (Underground Petroleum Storage Systems) Regulation 2008 required operators to conduct leak monitoring and establish documented management procedures for their underground fuel system. Updates to the Regulation occurred in 2014 and 2019 to incorporate changes in fuel systems terminology, technology, and best practices. These guidelines, created under the Regulation, aid in its implementation. If any discrepancies arise between the Regulation and these guidelines, the Regulation takes precedence where inconsistencies exist.
Challenges and Remediation
Detecting and managing leaks is challenging due to the UPSS being located underground, leading to leaks going unnoticed until significant damage has occurred. While remediation involving soil vapor & groundwater extraction and bioremediation are available, they require time and significant investment. More effective prevention methods, such as double-walled or fiberglass tanks, secondary leak detection monitoring (i.e. groundwater and or tank pit observation wells), and advanced electronic monitoring systems are recommended to minimise the likelihood and duration of leaks.
Appropriate regulatory authority
On 1 September 2019 local councils resumed responsibility for regulating most UPSS sites in their local areas. The (NSW) EPA remains responsible for regulating UPSS sites that are:
operated by a public authority
subject to an Environment Protection Licence
in the unincorporated areas of NSW where there is no local council
subject to a notice, direction or requirement made, issued or given by the EPA before 1 September 2019 for a matter under the Regulation until the actions in that notice, direction or requirement have been complied with.
Further Guidance
The NSW EPA Underground Petroleum Storage Systems Guidelines for implementing the Protection of the Environment Operations (Underground Petroleum Storage Systems) Regulation 2019 provide details on the environmental requirements for operating underground petroleum storage systems in NSW. Although limited to NSW, this document provides a solid guide for the appropriate management of UPSS in Australia.
Link to the above document is provided below
20p2700-underground-petroleum-storage-systems-guidelines.pdf (nsw.gov.au)
