IPPC Guidance Note on Storage and Transfer of Materials for Scheduled Activities

This guidance note provides assistance for industry to comply with Integrated Pollution Prevention Control (IPPC) licence conditions in relation to storage and movement of potentially polluting substances and thereby protect the environment. Although every effort has been made to ensure the accuracy of the material contained in this publication, complete accuracy cannot be guaranteed. Neither the Environmental Protection Agency nor the author accepts any responsibility whatsoever for loss or damage occasioned, or claimed to have been occasioned, in part or in full as a consequence of any person acting or refraining from acting, as a result of a matter contained in this publication. All or part of this publication may be reproduced without further permission, provided the source is acknowledged. 1. Introduction; The Environmental Protection Agency (EPA) can prepare and publish codes of practice to provide practical guidance for the purposes of environmental protection. This guidance note provides assistance for industry to comply with Integrated Pollution Prevention Control (IPPC) licence conditions in relation to storage and movement of potentially polluting substances and thereby protect the environment. The document is a general guidance document and sets out the minimum requirements for IPPC facilities. As described in the Protection of the Environment (POE) Act of 2003, Best Available Techniques (BAT) will be used to prevent, eliminate or, where that is not practicable, limit, abate, or reduce an emission from an activity which is listed in the First Schedule to the Act. The use of BAT is construed in the Act to mean the provision and proper maintenance, operation, use and supervision of facilities which are the most suitable for the purpose. In determining BAT for an activity, regard shall be had to: The use of low waste technology; the use of less hazardous substances; the furthering of recovery and recycling of substances generated and used in the process and of waste where appropriate; comparable processes, facilities or methods of operation, which have been tried with success on an industrial scale; technological advances and changes in scientific knowledge and understanding; the nature, effects and volume of the emissions concerned; the commissioning dates for new or existing activities; the length of time needed to introduce the best available techniques; the consumption and nature of raw materials (including water) used in the process and their energy efficiency; the need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risks to it; the need to prevent accidents and to minimise the consequences for the environment, and; the information published by the Commission of the European Communities pursuant to any exchange of information between Member States and the industries concerned on best available techniques, associated monitoring, and developments in them, or by international organisations, and such other matters as may be prescribed. The techniques identified in this guidance note are considered to be the current best practice, at the time of writing, and are representative of a wide range of currently employed technologies appropriate to particular circumstances. This document does not however replace the need to carry out site-specific assessments / investigations prior to determining the appropriate type of containment / retention facilities. Additionally, the guidance issued in this note in respect of the use of any technology, technique or standard does not preclude the use of any other similar technology, technique or standard which may achieve an equivalent level of environmental protection. 2. Scope; The scope of this guidance note covers tanks (including drums and containers), bunds and pipelines which store or transmit potentially polluting substances, be they solid, liquid, gas or combined, including; wastes, fuels, raw materials, products or intermediates, cleaning and disinfectant agents. The guidance note addresses design, construction, operation, maintenance and monitoring of such structures. The industrial sectors covered are those listed in the first schedule of the POE Act 2003, which is reproduced in Appendix A for reference. A wide section of industry types, which have varying processing conditions and pollution potentials, are covered by the first schedule of the POE Act. For particular conditions relating to similar industrial sectors, this guidance note highlights the following industrial sectors: Intensive Agriculture (Section 6 of the first schedule); Food and Drink (Section 7 of the first schedule); Other Industries (all other Sections of the first schedule); The issue of run-off from fire fighting operations is covered under a separate guidance note from the EPA (Fire-Water Retention Facilities; (Draft) Guidance Note to Industry on the Requirements for Fire-Water Retention Facilities). Storage and transfer systems for substances which are not potentially polluting substances, such as uncontaminated surface water drainage or fire water storage are not seen as a pollution risk and therefore do not fall within the scope of this guidance note. In general, the technologies identified in this guidance note, unless otherwise specifically stated, are regarded as representing BAT for new activities. However, it is also generally envisaged that existing facilities will progress towards attainment of a similar level of environmental protection in which the specific requirements and associated time frames will be identified on a case by case basis. For instance, many of the organisational measures outlined in this guidance document, such as testing of storage tanks and piping systems, can be implemented equally for both new and existing facilities. Technical measures, such as leak detection between a tank base and bund floor, may have to be implemented with due regard to the determination of BAT for existing facilities. 3. How To Use This Guidance Note; The steps involved in using this guidance note are illustrated in the following flowchart. This enables the user to access the Sections of the guidance note, which are most applicable to the relevant industrial sector. A worked example of a small pharmaceutical plant is provided in Section 12.

Table of Contents:
1. Introduction 1; 2. Scope 2; 3. How To Use This Guidance Note 3; 4. Interpretation 5; 5. General Requirements For All Facilities 7; 6. Design And Operation Of Retention Facilities (Bunds) For Potentially Polluting Substances 26; 7. Design And Operation Of Piping Systems For Potentially Polluting Substances 46; 8. Design And Operation Of Storage Tanks And Systems For Potentially Polluting Substances 53; 9. Specific Requirements For Food And Drink Industry 59; 10. Specific Requirements For Intensive Agriculture 60; 11. Requirements For Gases And Solids 65; 12. Worked Example 68; 13. Abbreviations 74; 14. References 75; Appendix A; First Schedule of POE Act; Appendix B; Calculation of Retention Volumes; Appendix C; Penetration Depths in Concrete; Appendix D; Design Details for Bunds; Appendix E; Piping Details for Systems Conveying Materials of Water Hazard Class WHC 2 and 3; Appendix F; Requirements for Existing Underground Piping; Appendix G; Testing of Vessels and Piping Systems; Appendix H; Summary of Swiss Method for Integrity Testing of Full Slurry Vessels.