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TECHNICAL GUIDANCE NOTES

PET/TGN/1.2

DESIGN AND USE OF OIL SEPARATORS IN SURFACE DRAINAGE SYSTEMS

JUNE 2016
EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

Contents

1. Introduction .................................................................................................................... 9

2. Disclaimer ....................................................................................................................... 9

3. Oil Water Separators ..................................................................................................... 9

4. Objective ........................................................................................................................ 10

5. Scope .............................................................................................................................. 10

6. Availability.................................................................................................................... 10

7. Legal Framework ......................................................................................................... 10

8. Best Practice .................................................................................................................. 10

9. Site OWS ........................................................................................................................ 11

10. Design of OWS ............................................................................................................. 12

General........................................................................................................................... 12
Separator Classes ......................................................................................................... 13
Choosing the Correct Separator ................................................................................. 14

11. Closure Devices ............................................................................................................ 14

Automatic Warning Devices/Alarm System ........................................................... 15


Installation..................................................................................................................... 15
Labeling ......................................................................................................................... 15

12. Operation of OWS ........................................................................................................ 16

13. Cleaning of OWS .......................................................................................................... 17

14. OWS Sampling ............................................................................................................. 18

15. Inspection and Maintenance of OWS ........................................................................ 19

16. Waste Management ..................................................................................................... 21

17. Emergencies .................................................................................................................. 21

18. Decommissioning of OWS .......................................................................................... 21

19. Record Keeping and Retention .................................................................................. 22

20. References ..................................................................................................................... 23

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

21. Contacts ......................................................................................................................... 24

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

Acronyms

Acronym Description
AST Aboveground Storage Tank
DOHSS Department of Occupational Health and Safety Services
ERC Energy Regulatory Commission
KEBS Kenya Bureau of Standards
KS Kenya Standard
MSDS Material Safety Data Sheet
NEMA National Environment Management Authority
OWS Oil Water Separator
PPG Pollution Prevention Guidelines
UST Underground Storage Tank
VOC Volatile Organic Compounds

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

Terminology

Terminology Description
Bulk Storage Premises consisting one or more tanks for storing
Terminal petroleum or liquefied petroleum gas in transit or for sale
Chamber/Manhole A provision of access in an UST. It might also contain
pipes, valves, level gauges and other installed equipment.
It is covered with a lid. Also known as sump, manhole,
inspection well or maintenance well.
Change Any modification other than “replacement in kind.”
Community Those residing near to an operating location/tank truck
route to whom the facility activity is easily detectable either
visually, aurally or by another means. It also encompasses
key decision makers or those having a significant influence
over local opinion for the locality.
Company Company within the meaning of the Cap. 486 of
Companies Act;
Compliance Meeting legal, regulatory or company requirements.
Containment Means to prevent loss of liquid product in the event of a
leak or spill
Contractor Any company or individual that is under contract to
provide services.
Controlled Waters Controlled waters refer to rivers, streams, estuaries, canals,
lakes, ponds, ditches and groundwater
Danger Risk to the environment, health, life, person or property of
anyone from pollution arising from operation and
maintenance of petroleum facilities
Emission The episodic or ongoing release of materials to the
environment (air, water or land).
Environmental A document describing potential environmental impacts
Management Plan and activities of a project/site and ways to manage and
mitigate these.
Facilities Physical equipment and/or plant, including large mobile
equipment, involved in the performance of affiliate
operations.
Forecourt An area used to fill fuel to customers vehicles. Pump
islands and dispensers are located here.
Fuel Delivery Area An area used by road tankers while filling USTs. The top
parts of fill pipes and/or filling sumps are located here.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

Terminology Description
Groundwater Water that is below the surface of the ground in the
saturation zone, i.e. below the water table.
Hazard A potential source of serious harm to people, property or
the environment.
Hydrocarbons Chemical compounds containing carbon and hydrogen
which are produced by the refining of crude oil and which
are generally used as fuels.
Improvements Physical additions made during the lifetime of a facility or
site.
Incident A specific event or extended condition that has a significant
unwanted and unintended impact on the safety or health of
people, on property, on the environment, or on
legal/regulatory compliance.
Incident A pollution incident is a specific event that may have a
(Pollution) negative environmental impact.
Kenya Standard Specification or Code of Practice declared by The Standards
Council under Section 9 of the Standards Act
Management Site management is typically the most senior level of
operations management working on site.
Managers Personnel with line management or supervisory
responsibilities.
Occupational Process encompassing all activities addressing workplace
Health health hazards and employee health.
Oil Liquid hydrocarbons that float on water such as diesel,
petrol and engine oil.
Operation Any activity involving the production, manufacture, use,
storage or movement of material. Also, the utilization of
resources by a “unit” to produce an output.
Overfill Protection Equipment that halts the transfer of product from a road
tanker to an UST when the tank is full.
Pathway Route by which contaminants can reach the receptor.
Permit Authorization granted to a person to enable the carrying
out of any activity in the energy business, where a license is
considered onerous
Petroleum "Petroleum" includes petroleum crude natural gas and any
liquid or gas made from petroleum crude, natural gas, coal,
schist, shale, peat or any other bituminous substance or
from any product of petroleum crude, natural gas and

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

Terminology Description
includes condensate
Pollution Pollution prevention describes activities that reduce the
Prevention amount of pollution generated by a process. The pollution
Program prevention approach seeks to increase the efficiency of a
process, thereby reducing the amount of pollution
generated at its source.
Practice Approved method or means of accomplishing stated tasks.
Procedure A documented series of steps to be carried out in a logical
order for a defined operation or in a given situation.
Product Generic term within the petroleum industry for
hydrocarbon fractions.
Project A planned undertaking with a specific objective and
defined scope. Includes new construction and additions or
revisions to existing facilities.
Quality The ability for a product, service or activity to meet or
exceed requirements.
Receptor (or Something which could be adversely affected by the
Target) contaminant
Recommendations Potential solutions to findings or observations.
Replacement In- Replacement which is essentially identical to the original
kind and satisfies all relevant standards and specifications.
Retail Service Premises where petroleum is stored in bulk in one or more
Station tanks and dispensed to consumers for their own use
Risk Risk is a function of the probability of an unwanted
incident and the severity of its consequences
Risk Assessment The process by which a risk analysis is conducted and
results used to make decisions, either through relative
ranking of risk reduction strategies or through comparison
with risk criteria or other standards of acceptability.
Road Tanker Petroleum Tank Truck that delivers product to the site.
Site The place where something was, is or is to be located. May
be a marketing location, a refinery, gas plant or offshore
platform.
Source (or Hazard) Substance capable of causing pollution or harm.
Standard A defined product or result. Includes requirements for
quality, content, review and conformance with regulations.
Sustainable SUDS are a sequence of water management practices and

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

Terminology Description
Drainage Systems facilities designed to drain surface water in a manner that
will provide a more sustainable approach than what has
been the conventional practice of routing run-off through a
pipe to a watercourse.
Terminal Premises (sometimes referred to as bulk depot) on which
the capacity for the storage of flammable goods or
combustible goods (or both) exceeds 200m3 in above-
ground tanks.
Third Party A contractor providing services in accordance with
specifications, terms and conditions documented by a
contract agreement and signed by both parties.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

1. Introduction

1.1. These Technical Guidance Notes, herein referred to as “guidelines”, are


intended to help those who design and operate Oil/Water Separators in
Surface Drainage Systems to separate oil and water at Petroleum Retail
Service Stations, herein referred to as “sites” and/or Bulk Petroleum
Terminals, herein referred to as “terminals”.
1.2. They have been produced by the Energy Regulatory Commission. Contact
details can be found at the end of these guidelines.

2. Disclaimer

2.1. The information contained in the Guidance Notes is not intended to be


prescriptive, or to preclude the use of new developments, innovative
solutions or alternative designs, materials, methods and procedures, so
long as such alternatives provide a level of control over pollution
appropriate to the risks identified.
2.2. The guidelines are provided for information and while every reasonable
care has been taken to ensure the accuracy of its contents, the ERC cannot
accept any responsibility for any action taken, or not taken, on the basis of
this information.

3. Oil Water Separators

3.1. OWS also referred as oil interceptor act as a potential pathway from the
source of pollution to the receptor. Where separator chambers are unable
to hold water due to porous brick work or damaged pointing, the oily
effluent will soak into the surrounding ground.
3.2. Options for such chambers include upgrading to a new model, relining
with GRP, re-pointing or injection grouting.
3.3. The limitations of OWS should be recognized when designing a drainage
system, as they do not treat dissolved phase hydrocarbons.
3.4. These Guidance Notes will help in the selection and sizing of OWSs
during the design phase and the safe operation of OWSs at sites and
terminals.
3.5. The Guidance Notes use the term ‘separator’ rather than the term
’interceptor’. These terms have the same meaning.

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Design of Oil Separators in Surface Drainage Systems

4. Objective

4.1. Surface water may be contaminated by oil at a site or terminal. The site or
terminal needs to have measures in place to prevent this oil from polluting
the environment.
4.2. Separators are installed to contain oil leaks and accidental spillages and to
be effective, oil separators need to be correctly designed, installed and
maintained.

5. Scope

5.1. The Guidance Notes provide detailed information regarding the design,
operation, maintenance and decommissioning of separators at sites or
terminals.
5.2. Sites or terminals must design and operate separators that function
effectively by properly separating oil and water and trapping silt.

6. Availability

6.1. The Guidance Notes are published by the ERC and can be accessed at ERC
website.

7. Legal Framework

7.1. NEMA, KEBS, DOSHS together with ERC are responsible for protecting
“controlled waters” from pollution, for preventing waste from polluting
the environment and causing harm to human health.

8. Best Practice

8.1. Sites or terminals can work towards the use of pollution prevention
solutions (e.g., waste-minimizing process changes and product
substitutions) to modify or eliminate activities that have the potential to
cause a violation of the national environmental law or regulation.
8.2. Design and construction should seek out and institute process changes
that will eliminate the need for a separator.
8.3. Floor drains in designated areas may not be necessary in all cases,
particularly if a "dry" process can replace a "wet" process and eliminate a
wastewater stream.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

8.4. If a drain is necessary, it should be protected against spills of non-


petroleum products and/or large spills of petroleum products.
8.5. If an existing separator is not needed, it should be removed to eliminate
potential liabilities and hazards associated with its improper use or
abandonment.
8.6. Policies, guidelines, technologies, and process changes that can
significantly reduce the compliance burden associated with the use, and
misuse, of separator units include solutions that result in complete
removal of separators to improvements in their design, operation, and
maintenance.

9. Site OWS

9.1. Sites or terminals are normally equipped with separators, which receive
all drainage and retain the oily (hydrocarbon) wastes and solids.
9.2. This is a gravity separation system with oil and grease (hydrocarbons)
rising and solids settling as a sludge.
9.3. Oily water (effluent) passes through several compartments, repeating the
oil/water separation process.
9.4. The water phase ultimately passes to municipal sanitary sewers or to a

septic system in a rural setting.


9.5. Discharge of water from the separator to an open ditch, ground or
waterway requires prior approval from the County Government
9.6. Properly designed and maintained, separators can provide up to 98%
removal of oil and solids from the original mixture.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

9.7. Separator must be a ‘full retention’ separator, large enough to serve the
catchment area of the site or terminal and have a sufficient oil storage
volume to retain foreseeable spillages.
9.8. It is important to install a separator of an appropriate size. On a site or
terminal where tanker deliveries are received or loaded, a separator with
an oil storage capacity of 7,600 litres will meet requirements.
9.9. If a smaller unit is proposed, the size should be determined by
undertaking a risk assessment incorporating catchment size, potential
spillages during delivery, and other risks such as safety issues.
9.10. If the compartment size of the tanker that delivers is greater than 7,600
litres, the separator should be sized accordingly.

10. Design of OWS

General

10.1. Techniques that control pollution close to the source, such as permeable
surfaces or infiltration trenches, can offer a suitable means of treatment for
run-off from low risk areas and non-operational areas.
10.2. Higher risk areas might need other SUDS facilities such as constructed
ponds, wetlands or swales. Where there is a high risk of oil contamination,
it may be appropriate to use a separator as part of the SUDS Scheme.
10.3. Consider where the separator will discharge. The site or terminal may
require a license from NEMA or the County Government in order to
discharge to surface water drains, to a watercourse or to the ground.
Licenses are not issued automatically and if issued, strict controls on the
level of polluting substances in such oils might be imposed.
10.4. Drainage from vehicle cleaning, washing and servicing areas are likely to
be contaminated with substances other than oil and should normally drain
to the foul sewer with the approval of the County Government. Discharge
from such areas is not suitable for drainage to surface water drains, a
watercourse or to the ground.
10.5. Drainage containing detergents should not pass to a separator that
discharges to surface water because the detergents prevent the separator
from working properly.
10.6. Other catchbasins on the site or terminal, which collect stormwater from
areas not at risk from fuel spills, will be routed directly to the sewer or
ditch, without passing through the separator.
10.7. Separators must be designed such that when the silt chamber or silt area of
the separator is full of silt, this will not affect the operation of the
separator, the skim pipe or the by-pass device.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

10.8. The design criteria should be in accordance with the Kenya Standard. The
separator capacity should be determined by:
a. Drainage capacity feeding the unit
b. Separator performance required
c. The likely size of the spill
d. Maintenance Practices
e. Contaminants in the wastewater stream
10.9. In general 7,600 Liter OWSs are adequate for sites or terminals.
10.10. Separators may be two or three chambered brick or concrete block
structures that should contain hydrocarbons in the first chamber.
10.11. Newer separators are single GRP Units, making visual assessment more
difficult as the unit will still function when there is visible product in the
main chamber.
10.12. All roof drains which collect clean, uncontaminated water may be to
bypass the OWS to avoid reducing the capacity of the unit to contain the
spill.
10.13. Modern separators can be fitted with hydrocarbon sensors and alarms to
indicate the presence of fuel and the need for non-routine maintenance.
10.14. Most separators are equipped with a shut-off valve at the outlet which
should be in closed position with controls in place for authorized opening
to ensure that in the event of a spill the contents of the separator are
isolated until a licensed hauler attends at the site to pump out the spilled
material for disposal.
10.15. Separators should also have a valve on the inlet piping that is used to
isolate the vessel for safety in the event that it needs to be entered into for
maintenance purposes.

Separator Classes

10.16. Classes of separator are based on performance under standard test


conditions.
10.17. Class 1 Separators are designed to achieve a discharge concentration of
less than 5 mg/litre of oil under standard test conditions. These separators
are required for discharges to surface water drains and the water
environment. Many Class 1 separators contain coalescing devices, which
draw the oil droplets together and facilitate the separation.
10.18. Class 2 Separators are designed to achieve a discharge concentration of
less than 100 mg/litre of oil under standard test conditions. They are
suitable for dealing with discharges where a lower quality requirement
applies such as discharges to the foul sewer.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

10.19. Both classes can be produced as ‘full retention’, ‘bypass’ or ‘forecourt’


separators.
10.20. The oil concentration limits of 5 mg/litre and 100 mg/litre only apply
under standard test conditions. Separators may not always perform within
these limits under field conditions. In addition, these levels of oil might be
too high in some environmentally sensitive areas to allow the discharge to
pass into the water environment without additional treatment.

Choosing the Correct Separator

10.21. More than one separator might be required on larger sites or a site or
terminal or where many activities occur.
10.22. Factors to be considered that cover local circumstances and risk include:
a. The discharge point of the proposed separator
b. The environmental sensitivity of the location
c. Activities on the site or terminal
10.23. Where SUDS are incorporated into the surface water drainage, they may
remove the requirement for the separator.
10.24. Seek prior permission from the County Government before installing the
separator and making any discharge. Where the discharge is to the
environment, permission should be sort from NEMA.
10.25. Drainage from higher risk areas such as vehicle maintenance yards and
goods vehicle parking areas should be connected to foul sewer in
preference to surface water.

11. Closure Devices

11.1. If too much oil is allowed to accumulate inside a separator, it will not
work effectively and oil will escape. To avoid this, separators must be
provided with an automatic closure device that will prevent flow passing
through the separator when the quantity of oil in the separator exceeds the
oil storage volume (V).
11.2. Also, during emptying or maintenance the separator should be isolated to
prevent the escape of waste oil. Open all isolation valves when the
operation is complete.
11.3. Do not fit automatic closure devices to bypass separators unless they have
been designed specifically to operate on such separators.
11.4. If the automatic closure device is activated the operator should be alerted
by a high level alarm so that immediate maintenance can be carried out.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

Automatic Warning Devices/Alarm System

11.5. Separators should be provided with a robust device to provide visual and
audible warning (if necessary to a remotely located supervisory point)
when the level of oil reaches 90 per cent of the oil storage volume under
static liquid level conditions.
11.6. This automatic warning device indicates that the separator is in need of
immediate emptying for it to continue to work effectively.
11.7. Also, as the buildup of silt will prevent the separator from working
effectively, it is recommended to install a silt level alarm or another
suitable device in the separator to alert to the build-up of excessive levels
of silt.
11.8. Oil and silt alarms can be fitted to an existing separator. Silt alarms are
most useful on those sites or terminals where high volumes of silt are
likely to enter the separator.
11.9. Further equipment can be fitted to the separator, alongside a closure
device and warning device, to alert the site or terminal operator to the
routine maintenance requirements of the separator.
11.10. Regular maintenance and testing of equipment is essential.

Installation

11.11. Clean water should be discharged downstream of the separator. If clean


water is drained through the separator, consider the extra water volume
when selecting the separator type and size.
11.12. If the discharge for the separator is subject to the controls of a permit to
discharge granted, a sampling chamber will be required downstream of
the separator, to allow representative samples to be taken.
11.13. Provide separators with sufficient access points to allow for the inspection
and cleaning of all internal chambers.
11.14. Keep access to the separator clear and do not use this area for storage.
11.15. If the separator is installed to retain flammable liquids, provide
appropriate ventilation.

Labeling

11.16. Provide separators with a visible and durable label that can be read after
installation and which contains the following information:
a. Manufacturer’s reference number
b. Oil storage capacity

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

c. Year of manufacture
d. Volume of separator
e. Unique identifier for the design of separator
f. Oil level warning device details (name or number)
g. Depth of oil storage
h. Closure device details.
i. Nominal size
11.17. Mark the position of all separators clearly on all drainage plans and
identify the separator on the ground by marking the manhole cover
‘Separator’.

12. Operation of OWS

12.1. If hydrocarbon is visible in the third downstream chamber, the unit


should be cleaned by a trained and experienced waste contractor.
12.2. There is also tendency for the first chamber to act as a grit arrestor and
unless it is cleaned regularly, the second chamber will become obstructed
thereby reducing the efficiency of the unit.
12.3. The waste water from vehicle washing and steam cleaners produces large
volumes, possibly at high pressures, which are contaminated with
detergents, oil and road dirt.
12.4. Cleaning detergents can form stable emulsions, which take time to break
and separate to oil/water phases, and should be managed in a totally
different drainage system.
12.5. Most separators are equipped with a shut-off valve at the outlet which
should be in closed position with controls in place for authorized opening
to ensure that in the event of a spill the contents of the separator are
isolated until a licensed hauler attends at the site to pump out the spilled
material for disposal.
12.6. Some installations also have a valve on the inlet piping that is used to
isolate the vessel for safety in the event that it needs to be entered into for
maintenance purposes.
12.7. The valve position should be labeled with “open” and “closed” positions,
or otherwise readily identifiable to help prevent them from being left in
the wrong position. Another option is to post a schematic nearby that
details valve operation.
12.8. At some sites or terminals, oil collecting in the separator is skimmed and
routed to a separate tank for storage and subsequent disposal.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

12.9. Staff should be familiar with the system and know which catchbasins are
connected to the separator.
12.10. Eliminate unpermitted pollutants and prohibit discharge of wastewater
from operations containing hazardous wastes and heavy metals.
12.11. Implement dry cleanup procedures and only use floor drains to carry
residual amounts of floating petroleum pollutants.
12.12. Plug floor drains to separators that carry wastewater from vehicle
maintenance activities.
12.13. Collect, treat, and dispose of industrial waste separately.
12.14. Compartment covers must be tightly sealed to ensure that all floor
drainage is directed to the first compartment.
12.15. Water must be maintained at normal operating levels to retain the seal and
prevent oil from leaving the first compartment.
12.16. No changes can be made to the piping or baffles in the separator except as
approved by the manufacturer/designer.
12.17. No gasoline, gasoline contaminated products, cleaning solvents, anti-
freeze, windshield washing fluids or wastewaters containing surfactants
from exterior washing of vehicles should be intentionally sent to the
separator.

13. Cleaning of OWS

13.1. The manufacturer of the separator or designer of the system usually


defines maximum allowable sludge thickness. The separator needs to be
cleaned out when the thickness of oil is 5 cm or more and when the
maximum allowable sludge thickness is reached to prevent deterioration
in the performance of the separator.
13.2. As the design and capacity of OWSs may vary, the manufacturer’s
maximum recommended levels may be used as alternative maximum
floating oil and grease levels.
13.3. Manufacturers may have special procedures that need to be followed for
cleaning or start-up.
13.4. The most effective and preferred method of cleaning a separator is by
purging. This requires the uplift and disposal of all liquid and sludge in
the unit and re-filling with clean water and can include pressure washing
of the surface gullies on site to ensure they are free from debris or cleaning
using a power vacuum unit.
13.5. Clean-out is accomplished by applying suction near the top of the oil layer
in the first compartment until it is completely removed, then proceeding
directly to the sludge layer and removing the same.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

13.6. The intermediate water layer is left (or should be replaced) to act as a seal.
13.7. The other chamber(s) should also be checked to ensure no significant
quantity of oil or sludge is present.
13.8. The frequency of cleaning may be reduced where the separator only
receives rainwater runoff from the peripheral pavement areas or the
canopy and is unlikely to contain hydrocarbons.
13.9. All peripheral drains of the forecourt or the bulk loading/offloading areas
should be pressure washed clean as part of the same operation.
13.10. Coalescing separators or ones with other special internals have procedures
for cleaning, including proper installation of the internals if they are to be
removed for cleaning. Improper installation can result in the separator not
being able to achieve the required separation. Coalescing oil filters should
only be removed for cleaning when the unit is empty to avoid damaging
the filter.
13.11. Never enter the separator. Most separators are confined spaces, and
require special procedures to be followed for entry, typically done by a
trained contractor.
13.12. Record the date of separator cleaning and retain a copy of the waste
manifest sheet.

14. OWS Sampling

14.1. At some sites or terminals, NEMA requires that effluent from the
separator be periodically sampled and analyzed by a Laboratory.
14.2. It is a site or terminal operator’s responsibility to be in compliance with
the regulatory requirements in his/her jurisdiction.
14.3. The NEMA sampling location will depend on the system installed at the
facility. It could be from a sampling port that is built into the separator
and allows sampling of effluent that is leaving the vessel. Alternatively, it
could be from a manhole that the separator discharges to or from the
discharge of a pump (through a sampling connection) that pumps effluent
to the discharge point. A sampling port could also be a simple tee or an
opening for a pump sampling tube.
14.4. The Laboratory normally supplies jars or bottles for collecting the samples
and sampling must be done in accordance with recognized procedures.
14.5. Samples should be kept cool and shipped to the laboratory as soon as
possible.
14.6. Laboratory results should be kept with other records and logs.

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15. Inspection and Maintenance of OWS

15.1. To prevent pollution and minimize costs, manage the separator effectively.
15.2. Separators must be regularly inspected and routinely maintained
according to manufacturer’s recommendations and can vary with the
amount and type of service bay activity but should be undertaken at least
once every three months. The separator must be refilled with clean water
following such an inspection.
15.3. Experienced personnel should:
a. Physically inspect the integrity of the separator and all mechanical
parts
b. Measure the amount of accumulated oil and solids in the first
compartment to determine if a clean-out is required.
c. Service all electrical equipment - alarms and separator management
systems
d. Check the condition of any coalescing device and replace it if necessary
15.4. Inspect the last compartment to ensure that the water being directed to
municipal sewers does not contain solids or oils and greases
(hydrocarbons).
15.5. To make this easy, all parts of the separator that have to be regularly
maintained must be accessible at all times.
15.6. Some heavily used or high-risk sites might require more frequent
inspections.
15.7. Forecourt maintenance which involves degreasing either by steam
cleaning or using a solvent or a combination of both must be carried out
with the shutoff valve downstream of the separator in the closed position
to prevent escape of contaminants.
15.8. Sites or terminals should empty their separator as soon as a significant
quantity of oil and/or silt has built up. The retained waste, including the
silt, must be removed and the separator must be refilled with clean water
before being put back in to service to prevent damage and to prevent oil
passing through it.
15.9. In addition to normal emptying of the separator, it will also need to be
emptied right away if oil or silt levels exceed 90 per cent of the storage
volume of the separator and the alarm is activated.
15.10. When the oil or silt reaches this level or after a spillage, employ a NEMA
licensed waste removal company to empty the separator.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
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15.11. The separator should be inspected by the operator immediately after


servicing to ensure that it has been properly cleaned and that the water
level has been restored for operation.
15.12. Separators should always be inspected after a spill and at least once
annually.
15.13. Keep a detailed log of when the separator is inspected, maintained,
emptied and serviced.
15.14. Also record specific events relating to the separator system such as
cleaning, repairs, accidents and incidents.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

16. Waste Management

16.1. All waste must be handled, stored and disposed of correctly to avoid
pollution. Waste oil is designated as hazardous waste and as a waste
producer and holder; the site operator is responsible for complying with
Waste Management Regulations.
16.2. Ensure that waste oil:
a) Does not escape from the control of the site or terminal
b) Is transferred only to a registered waste carrier to be sent for recycling or
disposal at a suitably licensed facility
c) Is accompanied by an appropriate tracking document with a full written
description of the waste
16.3. For all waste removal operations, the site or terminal operator must ensure
that the waste removal company has experience in emptying separators
and that they do not allow any of the contents to escape from the outlet
during emptying.
16.4. The waste contractor is registered with NEMA and should satisfy
themselves that waste is properly dealt with.

17. Emergencies

17.1. Draw up a Pollution Incident Response Plan (PIRP) that includes all
OWSs.
17.2. Keep a spill kit on site or terminal.
17.3. All oil deliveries to the site or terminal must be supervised.

18. Decommissioning of OWS

18.1. Wherever practicable, separators should be removed for off-site disposal


after cleaning and removal of connected surface water drainage system.
18.2. Regardless of the fate of the separator, all residual liquid and sludge
should be removed (for off-site disposal) and all inlet and outlets should
be sealed.
18.3. Any drainage systems that are to remain active should be modified to
ensure that they do not present a significant migration pathway for
pollutants to reach surface waters or groundwater.

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

19. Record Keeping and Retention

19.1. Good records are very important to the site to show that procedures have
been followed.
19.2. The following records should be kept on site or off-site in a secure location
if on-site retention is not practical or possible for at least 3 years:
a. Records of employee training, including dates, name of employee and
employee’s acknowledgement.
b. Records of inspections, including date and measured thickness of oil
and sludge layers in the separator.
c. Records of clean-outs, including date, and copies of waste manifests or
name of company handling the material removed for disposal or
recycling.
d. Details of spills, including date, time, volume spilled, who it was
reported by, names of government officials spoken to, and what was
done to clean up.
e. Name of disposal or recycling company or facility handling the
material removed from the separator
f. Analytical results of any effluent sampling done.
19.3. Sites or terminals keep all information related to the separator in one
binder (records listed above, copy of regulatory permits or approvals,
drawings of system, operating and maintenance requirements,
information supplied by the manufacturer of the separator).

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

20. References

Energy Act, 2006

Environment Management and Coordination (Waste Management) Regulations,


2006

Environment Management and Coordination (Water Quality) Regulations, 2006

Environmental Management and Co-ordination (Controlled Substances)


Regulations, 2007.

Environmental Management and Co-ordination Act, 1999

KS 1967 (2006) - The petroleum industry – The storage and distribution of petroleum
products in aboveground bulk installations.

KS 1968 (2006) - The petroleum industry – Electrical Installations in the distribution


and marketing sector - Code of practice.

KS 1969 (2006) - The petroleum industry – The Installation of underground storage


tanks, pumps / dispensers and pipe work at SERVICE STATIONS and consumer
installations - Code of practice.

KS 200 (2002) - Specification for storage tanks for petroleum industry - Part 1:
Carbon steel welded horizontal cylindrical storage tanks (Second Edition).

KS ISO 1998 – 5 - The petroleum industry – Terminology – Part 5: Transport, storage


and distribution.

The Occupational Health and Safety Act 2007

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EHS Performance Assessment of the Downstream Petroleum Sub-sector
Design of Oil Separators in Surface Drainage Systems

21. Contacts

21.1. ENERGY REGULATORY COMMISSION (ERC)


Head Office: Eagle Africa Centre - Upper Hill
Telephone: 254-020-2717627/31/75; 254-020-2847000/200
Cell Phone: 0722200947; 0734414333
Fax: 254-02-2717603
Postal Address: P.O. Box 42681 - 00100 NAIROBI, KENYA
Email: info@erc.go.ke
Website: www.erc.go.ke
21.2. KENYA BUREAU OF STANDARDS (KEBS)
Popo Road, Off Mombasa Road
Behind Bellevue Cinema
P.O Box 54974-00200, Nairobi – Kenya
Tel: (+254 20), 605506,605550, 605573,605574,605610,605634,
605642,605673,603482, (+254 20) 6948000/605490
Mobile: +254722202137/8, +254734600471/2
Fax: (+254 20) 60403, 609660
Email: info@kebs.org
Website: www.kebs.org
21.3. NATIONAL ENVIRONMENT MANAGEMENT AUTHORITY (NEMA)
Popo Road, Off Mombasa Road
Behind Bellevue Cinema
P.O Box 67839 – 00200, Nairobi – Kenya
Tel: (+254 20) 6005522/6/7
Mobile: 0724 - 253 398 /0728-585 829 / 0735-013 046 / 0735-010 237
Fax :( 254)-020-6008997
Email:dgnema@nema.go.ke
Website: www.nema.go.ke

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