Fuel Infrastructure Compliance, Ranking and Management by EPS Ltd
Shortlisted for Brownfield Awards Category 12 - Best Infrastructure Project
Since 2018 EPS has been working with a national retailer in the UK to understand and manage fuel storage at their depots and stores across the UK. The approach to this enormous task was to provide a meaningful management tool which could be understood by non-technical upper management to quantify the environmental liability, understand the risks and to make business decisions.
EPS created a risk management tool – Risk Ranking – which combined ‘infrastructure risk’ score, site management and ‘environmental risk’ as detailed below:
Environmental ranking, which considered
aquifer and SPZ status of the underlying geology,
proximity to surface water, and
proximity to residential housing.
Infrastructure ranking which considered infrastructures compliance with Oil Storage Regulations, and
Site management ranking, comprising:
availability and applicability of procedures,
maintenance schedules, and
By combining those elements into an overall risk score, EPS was able to rank the entire estate in terms of its relation to the ‘consequence’ of a failure of fuel infrastructure at a given location. The example output is presented below:
The work was conducted initially through desk top review exercise relating to the environmental site sensitivity followed by a programme of site-based audits which focused on the assessment of the fuel infrastructure, review of site management procedures & training and review of availability of the drainage maps on site and actual drainage routes observed during the walkover. Initially, EPS prepared a pre-questionnaire survey which focused on introducing EPS and informing the site managers of the upcoming audit whilst gathering some background information about the facility. The exercise was useful as it provided a baseline of knowledge for auditors prior to site visits.
Site audits at the client’s depot portfolio, which comprised over >30 facilities, were completed between 2018 and 2020. Store portfolio auditing of >300 facilities is still ongoing.
The results of the audits across the depots highlighted that the fuel infrastructure which is typically associated with re-fuelling is generally compliant and managed appropriately. The fuel infrastructure associated with the day-to-day operations of a facility (emergency generator tanks and sprinkler tanks) requires attention and remediation. In those instances, the findings indicated that the fuel infrastructure was commonly outdated. Training and site management varied between the facilities and could benefit from centralised coordination. The example summary of the identified Non-Compliances associated with sprinkler tanks is shown below:
In terms of site drainage EPS noted that in general understanding of the drainage routes across the depot portfolio was sketchy. Facilities were in some instances extended with new drainage routes added but not appropriately mapped. In some cases, due to a long operational history of the facility and many historical owners the drainage plans had been lost along the way.
Completion of the audit surveys enabled the launch of the Risk Ranking Tool, which focused on prioritisation of sites with high consequence in case of fuel infrastructure failure.
Through risk ranking and site audits, the risks from fuel infrastructure were now well mapped and understood by the business. The next stage in the process was the development of a focused and targeted strategy to improve the fuel storage at all depots, which in order to be cost effective, required bespoke solutions to be applied when conducting repairs relating to compliance fixes. This was driven by both appreciation of the vast financial consequences a project of this magnitude brings and also the sustainability aspect, where infrastructure deemed suitable was fixed and re-used on site rather than replaced. Since then, the client has completed estate wide improvements at all their depots with regards to the fuel infrastructure significantly improving their compliance with Oil Storage Regulations and reducing their associated environmental risks.
With regards to improvements relating to drainage it was recognised that an innovative solution was required. Fuel spills constitute an emergency and therefore they are stressful situations which require clear procedures. Drainage plans which comprise the entire site can be confusing and hard to read, and could be especially hard to read and understand in an emergency. As such, EPS proposed that instead of completing site wide drainage surveys, targeted drainage surveys are completed focusing on the areas where the fuel is stored. Since drainage can provide a migration route for the fuels to exit the site in the unfortunate event of a fuel spill, understanding of the drainage system in terms of risk / entry points and rescue points is vital.
Risk / entry points – are defined as points where fuel can enter the drainage system; and
Rescue points – are defined as isolation points where fuel can be isolated and prevented from further migration off-site.
The benefit of this approach is that it provides a clear action plan which can be used by non-technical personnel. It provides a route to the risk points (points at which fuel can enter drains) and rescue points (isolation points where fuel can be prevented from further migration) which will be critical for preventing the spread of any fuel in the event of an accidental release on site. Targeted drainage surveys were completed at all client’s depots and Targeted Drainage Plans identifying potential fuel entry points and rescue points (physically marked on site by a yellow manhole cover) were issued to all depots. An example of the Targeted Drainage Plan is provided below:
Where a drainage system was found to be leaving the site through the interceptor the message on the Targeted Drainage Plan instructed the personnel to inspect the interceptor and arrange its clean-up. On the rare occasions where site drainage system did not include interceptor, EPS provided an inflatable bung which was to be deployed at the rescue point to prevent off-site migration of fuel.
The client decided that site management, training and maintenance procedures were to be undertaken centrally through their in-house teams. Development and implementation of training programmes and developing coordinated maintenance programmes are currently on-going and being well received.
Since completion of the depot audits EPS has been involved in a similar exercise involving audits of fuel infrastructure at the client’s many national stores. The fuel infrastructure comprises tanks associated with emergency generators and sprinkler systems. The works are ongoing, and the audits are expected to be concluded in the second quarter of 2021. The preliminary results suggest that compliance repairs will be required at the majority of the stores. Given the vast number of surveyed facilities, application of EPS’ Risk Ranking will be prudent to inform the strategy for implementation of remedial measures for years to come. It is important to recognise that the approach to the assessment of fuel infrastructure developed by EPS results in producing the risk ranking tool which can be used as a decision-making tool in developing budgets and in the management of current and future liability. It also provides a clear route map for addressing the risks at sites where the consequence of fuel spillage is the highest, focusing the time and resource where it matters the most.
The most significant success of the work is with the clients’ project team to use the risk ranking as an effective estate management tool – identifying sites where the consequences of fuel infrastructure failure are high and highlighting the potential works that could be undertaken at those sites to lower their overall risk ranking score.
This proactive approach to fuel infrastructure management provides not only benefits to our client’s business protecting it from unexpected / unbudgeted clean-up costs and reputational damage but also provides benefits to the wider environment, protecting groundwater and surface water resources from unexpected fuel releases as well as protecting the neighbouring residents from fuel migrating beneath their properties.
A comment from the client: “The work EPS has delivered provided very much needed visibility of our fuel infrastructure systems. It has been extremely important to our business and identified areas of genuine environmental risk that are now resolved. The work also had an extremely positive impact on improving our management and response systems around oil storage across our national estate.”