MCHP A R C HI I E C I S

SUITE 5, 38-46 ALBANY ST, ST LEONARDS NSW 2065 TELEPHONE 02 9436 2222 www.mchp.com. au

FACSIMILE 02 94391340 ABN 21 096 632 450

01 May 2020

MOTOR SPIRIT PRELIMINARY HAZARD ANALYSIS - (PHA)

SEPP 33 REVIEW

PROPOSAL:

SITE:

ADDRESS:

Installation of two (2) x ?Oki Double Walled Compartmented Underground Fibreglass Motor Spirit Storage Tank

Metro Lucknow

4613 Mitchell Highway Lot 101, DP 1053642 LUCKNOW NSW 2800

Foreword

This PHA is prepared as support for a Development Application lodged with Orange City Council

It has been prepared due to the fact that the proposed underground fuel storage tank installation as proposed by this application may fall under the category of "potentially hazardous" as defined in SEPP 33.

It has also been prepared to provide details of the proposed works to be in accordance with both the "Protection of the Environment Operations (Underground Petroleum Storage Systems) Regulation 2014" and the document, "Environmental Action For Service Stations" as prepared by the NSW Department of Environment and Conservation.

The Proposal

The proposed work involves the removal of the existing underground fuel storage tanks and installation of 2 x new 70kl compartmented underground fibreglass fuel storage tanks, new fuel fill box & vent pipes and associated pipework, new concrete pavement to forecourt area as required and new 10 hose multi product fuel pumps in similar locations to existing.

Details of the site layout including underground tanks can be found on the drawings accompanying the Development Application.

Nominated Architect DAVID CAHILL B.Arch (Hons) NSW Architects Registration Board No 7135

H\MCHP\Metro Petroleum\Lucknow\2020 DA\Correspondence\Metro Lucknow SEPP 33 2020.05.01.d0cx

Existing Tanks to be removed

• Tank 1 --4.5kl capacity, Unleaded Ethanol Petrol (ULP+E10) • Tank 2-4.5kl capacity, Not in use • Tank 3-2.5kl capacity, Unleaded Petrol (ULP) • Tank 4-17.8kl capacity, Unleaded Petrol (ULP) • Tank 5-12.0kl capacity, Automotive Diesel Fuel (ADF)

Tanks to be removed will be removed in accordance with all Council, UPSS regulations, NSW Workcover requirements and in accordance with the requirements of AS 4976 - Removal and Disposal of underground petroleum storage tanks.

New Tanks to be Installed (2 x ?Oki/ double walled compartmented fibreglass u/g tanks)

• Tank 1- 30kl capacity -- Unleaded Ethanol Petrol (ULP+E10) • Tank 2-40kl capacity -- Automotive Diesel Fuel (ADF) • Tank 3-25kl capacity -- Unleaded Petrol (ULP) • Tank 4-45kl capacity- Premium Unleaded Fuel (PULP 98)

Definitions; ADF -- Automotive Diesel Fuel UADF -- Ultimate Automotive Diesel Fuel ULT - Ultimate Grade Petrol ULP -- Unleaded Petrol PULP -- Premium Grade Unleaded Petrol E10- Ethanol blend 10% Unleaded Petrol

For calculation of product weight; Petrol, 737kg per 1000 litres Diesel, 875kg per 1000 litres

In accordance with SEPP 33 Screening thresholds, total motor spirit fuel storage capacity is 140,000 litres, as the fuel storage is located underground the screening capacity can be divided by five (5). The revised screening capacity is therefore considered to be 28kL or based on weight,

Based on the above the total weight of Flammable/ Combustible products stored on site; 21.74 tonnes.

Location

4613 Mitchell Highway, Lucknow, NSW, 2800. Lot 101, DP 1053642 The site is surrounded by residential properties to the South East, South West & North East separated by Mitchell Highway. Commercial property (Goldfields Tavern) abuts the site to the West with commercial properties to the North West & North East separated by Mitchell Highway.

The nearest property boundary is located approximately 2.6m from the tank farm (South East Residential property) The nearest road boundary (Mitchell Highway) is located approximately 5.3m from the tank farm (6.0m from actual underground tank)

The nearest property boundary (South West Residential property) is located 12.3m from the nearest adjacent most Motor Spirit fuelling pump. The nearest street boundary (Mitchell Highway) is located 7.6m from the nearest Motor Spirit fuelling dispenser.

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The tanker unloading point is located 7.7m from the nearest property boundary (Mitchell Highway Boundary)

In accordance with Threshold Screening Method as defined in the document "Applying SEPP 33" Figure 9, for a screening weight of 21.74 tonnes. The separation distance from the closest product dispenser to the nearest property boundary is 12.3m.

By applying "The Risk Screening Method" table 3 and figure 9 screening threshold quantities of the document "applying SEPP 33" it can be seen that the proposed development does not fall within the partially hazardous region.

Not withstanding the proposed works not being considered hazardous and as such SEPP 33 is not applicable, we provide the following analysis;

Figure 9: Class 3PGII and 3PGIII Flammable liquids

Heat Radiation Effects

1000 == Separation Distance

L / Screening Volume

l for site 1111 I ,.

E 100

4 1-0'.r~ruse-s € ~ C Sen5l'E !J 2 ::.--- 0 10

Potentially Hazardous Region

1 Ill 1111 1111

f 10 100 1000 10000 100000

Quantity (tonne)

Transport Screening

The document "Applying SEPP 33" table 2 indicates that the development may be potentially hazardous if the number of generated traffic movements carrying significant quantities of hazardous materials are above the annual or weekly threshold.

For Class 3 PG II products (motor spirit) the screening value is an annual figure of 750, As we believe the proposed development will require a maximum of 3 weekly motor spirit fuel deliveries per week (150 annual). It is clear that the development falls well below both the weekly and annual threshold figures.

Risk Classification

In accordance with the results of the screening threshold as determined above, and the fact that the facility does marginally exceed the screening threshold, the tables below will determine the level of further assessment required:

Figure 11" Multi Level Risk Assessment Approach" - Applying SEPP 33 Table 4" Levels of Analysis and Assessment" - Applying SEPP 33

Page 3 of 13

Figure 11: Multi-Level Risk Assessment Approach

I Preliminary screening I (consequence based}

No

I PHANol I Required

Is the development potentially hazardous?

(i.e has it potential for significant injury, fatality property damage or harm to the environment in the

absence of mntrcts)

I l

Yes

Carry out risk screening and prioritisation

I

Use risk screening techniques in

Appiyn SEPP 33

] PHA II Ii Required II

..................... Use risk prioritisaton techniques in Mu#ti­

level Risk Assessment ······················

tt significant but not serious potential for -~

~--~--~

,············*-············, ! tt medum potential ! l for harm !

,··········~ ···········, ! tt high potential for l

tam h

__J Not potentially hazardous

(apply code.sand standards)

Qualitative analysis

(level 1)

l [

• Semi­

quantitative analysis

(level 2)

Quantitative analysis

{level 3)

Assess risk according to HIPAP

6

Table 4: Levels of Analysis and Assessment

Key Elements Assessment Basis

Level 1- Essentially Qualitative

hazard identification using summary diagram, FMEA, fault and event trees, HAZOP etc.

identification of key scenarios and qualitative estimate of risks

comparisons with qualitative criteria.

thorough discussion of protective technical and management measures, including codes and standards

appropriate methods used for identification

all key scenarios thoroughly examined

• realistic estimates of risk

• relevant qualitative criteria met

proposed measures appropriate and sufficient

compliance with all relevant codes and standards

Level 2-- Partially Quantitative

qualitative elements as for level 1

rigorous quantification of consequences of all events with significant off-site effects

quantification of the likelihood of events with significant off-site' consequences

• indicative estimate of risk vs. criteria

thorough discussion of technical controls, risk reduction and management measures

qualitative elements as for level 1

sound consequence methodology used and appropriate failure data used

technical methods and results appropriately documented

relevant criteria shown to be met

• appropriate controls and safeguards

Level 3-Fully Quantitative

• qualitative elements as for level 1

comprehensive quantification of significant consequences and their likelihood

evaluation of risk against all relevant criteria

thorough discussion of technical controls, risk reduction and management measures

qualitative elements as for level 1

sound consequence methodology used

appropriate failure data used

• technical methods and results well-documented

• all relevant criteria met

ALARP principles followed

appropriate technical and procedural controls and safety management system

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Hazardous Substances

The proposed hazardous material storage is Motor Spirit with a dangerous Goods (DG) Classification 3 Packaging Group 11 and Diesel Fuel with a D.G. Classification 3 Packaging Group C1.

Maximum Distance and Area of Effect:

From IAEA Table Ill, we get the following: For Petrol Maximum Distance = 25- 50 m Area of Effect, A = 0.4 ha

Population Density

Using a land use methodology for 50m radius around the new underground fuel tanks location (50m radius is very close to 1 hectares (ha)), we can estimate the number of people within the above region at any one time.

Other site considerations are:

The property at present is surrounded by low density residential & commercial uses, in accordance with IAEA table IV we have based the population density of those surrounding areas as being a density of 40 persons per ha based on the following;

A 57m radius (1 ha area) encompasses an area including the site, is developed with a combination of residential & commercial uses. All these uses represent medium intensity uses with transient vehicle movements in and out of the assessment zone.

Note that IAEA table IV: population density of document 'Multi Level Risk Assessment' Indicates the following densities; Farmland, Scattered houses ­ Individual Dwellings Village, Quiet Residential Residential

5 persons/ha 10 persons/ha 20 persons/ha 40 persons/ha

In light of no available data from Council in relation to actual population densities in this location we believe that an assumption of 20 person per ha is accurate for this location

Effect area and distances are determined using IAEA table V For petrol = a distance of 50m with an area of 0.4ha

Population Correction factor:

The Population Correction Factor is to determine what percentage of the area within a 50 m radius from the site is populated, therefore: using formula for area; A =Pix R?

Total Area considered= 7850 sq.m (50m radius area) Site area = 1245 sq.m Population correction factor = fa

fa = (total effected area - site area ) I total area

fa = (7850-1245)/ 7850 =0.841

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Mitigation Correction Factor From IAEA Table VIII, Correction factor for mitigation, fm =1

Estimate of External Consequences To identify the extent of external consequences the formulae C(a,s) = Ax d x fax fm is applicable

A= Population density within Affected area D = Population Density (people per Ha) Fa = Area Correction Fm = Correction for mitigation (in this case flammable liquids)

For this development

C(as) = 0.4 x 20 x 0.841 x 1.0 = 6.73 fatalities per accident

Probability Numbers

The probability number is given by the formula:

N(is) =N*(is) + nl + nf + no + np

The average probability number N*(is) for underground fuel storage is = 7

Correction Factor for: Loading, nl =-1 (Refer IAEA Table X) Flammables, nf = 0 (Refer IAEA Table XI) Organizational Safety, no= 0 (Refer IAEA Table XII) Wind Direction, np = 0 (Refer IAEA Table XIII)

Based on IAEA table XIV for Fuel conversion of probability number N(is) = 7 +(-1) + 0 + 0 N(is) = 6

And converting Probability Numbers into Frequency of Events per year, (Refer IAEA Table XII)

p = 1x 10°

Level of Risk Figure 6: Indicative Societal Risk Criteria

,.[IE-IL:,-------------------~

Q 1 ctE-a3 €

• g +-3u i : ~ 1.!IE-!E

! [ 1.IIE-ll6 ;-,----

'- C ta:E-!i'7 z e UIE-ill > C C ~ UIE-{B r

° LL 1.CIE-1□+-----~---------------< f

6.73

legligible

1

Number of Fatalities, N 1. 1.00

Page6 of 13

By intersecting frequency with consequence 6.73 in graph above, it can been seen that the risk to society from the proposed development falls within the negligible area, all possible measures shall be taken during design, construction and operation to ensure that the level of risk remains as low as possible

Hazardous Identification

There are two primary hazards associated with underground MS storage and then Retail Sales during normal operations

1. During handling procedures such as filling U/G tanks when tanker is delivering into the tanks and dispensing fuel into customer's vehicle fuel tank.

2. A fracture and/or failure of the underground storage vessels and/or a failure of the underground product delivery pipe work.

A description of the design safeguards that are to be implemented to reduce these hazards are outlined in greater detail as part of this analysis.

The flammable and combustible system at this site has been designed with the intention of minimising all unnecessary risks associated with the storage and handling of these types of dangerous goods. It has been designed in full compliance with AS1940-(latest edition) 'The storage and handling of flammable and combustible liquids'. The tanks have been chosen to be located underground and are double walled fibreglass tanks. By installing tanks underground nearly all issues associated with storage are eliminated.

As can be concluded from the assessment below there is nothing in this review that would indicate that the design of this installation at this site is not acceptable

Risks and control measures associated with the Flammable and Combustible Liquid system:

Customer over fill. Risk: Yes Possible Outcome: Spill/Fire Ranking: C4/C5/C5 Control Measure: Dispensers are equipped with nozzles that incorporate a mechanism that automatically shuts down fuel flow when the level of liquid reaches the end of the nozzle. Should a spill occur, staff are adequately trained to clean up any minor spill. The site is supplied with fire protection equipment as an added precaution. Customer drives off with nozzle attached. Risk: No, Possible Outcome: Minor Leak Ranking: C5/C5/C5 Control Measure: Should this situation arise staff are trained and provided with appropriate clean up materials to deal with this incident. Minimal fuel in the hose will be lost.

Collision between vehicle and dispenser Risk: Yes Possible Outcome: Spill/Fire Ranking: C4/C5/C5 Control Measure: Protective bollards are to be installed on the approach side of the island. In the event that damage does occur to the dispenser, minimal fuel loss would occur as the units contain small fuel amounts. Staff have been adequately trained to deal with this situation as well as provided with adequate clean up materials and fire protection/fighting equipment.

Delivery overfill Risk: Risk: Yes Possible Outcome: Spill/Fire Ranking: C4/C5/C5

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Control Measure: Drivers are trained to ensure that there is enough ullage in a tank prior to delivery, and also stay in attendance at the fill area during delivery. Spill kits are on site.

Use of mobile phone/transmitting devices Risk: Yes Possible Outcome: Spill/Fire Ranking: D3/D4/D4 Control Measure: Appropriate warning signs are installed at all dispensers. Customers are monitored by appropriately trained staff at all times

Spill of product onto customer Risk: Yes Possible Outcome: Spill/Fire Ranking: D3/D4/D4 Control Measure: Appropriate safe use instructions are installed at all dispenser however should this incident occur staff are trained and supplied with First Aid. equipment for a minor situation and are able to contact emergency services for serious incidents.

Equipment wear and tear Risk: Yes Possible Outcome: Spill/Fire Ranking: C4/C4/C4 Control Measure: Regular on site maintenance checks are undertaken to remove the chance of general wear and tear which may result in a leak. Staff are trained to deal with any potential incident that may result.

Customer misuse of equipment Risk: Yes Possible Outcome: Leak/Fire Ranking: D4/D5/D5 Control Measure: This site displays various instruction and warning signs to prevent customers misusing equipment. Customers are monitored by staff at all times.

Vandalism of equipment Risk: Yes Possible Outcome: Leak/Fire Ranking: D3/D4/D4 Control Measure: Staff carry out regular checks of equipment for vandalism and tampering. A service contract is in place which ensures prompt equipment replacement. The dispenser can be shut down if required.

Fire on adjoining property Risk: Yes Possible Outcome: Fire Ranking: D3/D4/D4 Control Measure: The entire fuel system can be shut down in the event of a fire. Staff are trained and aware of emergency evacuation procedures and are provided with adequate fire protection in the case of a minor incident. Storage tanks underground protect any product from fire.

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Risk Ranking Criteria

Risk is assessed as a combination of Probability and Consequence utilising the following; Probability - A -- common or repeating occurrence

B-has been known to occur C-- could possibly occur D-- not likely to occur E- practically impossible

Consequence to People ­ 1- fatality or permanent disability 2- serious lost time injury or illness 3 -- moderate lost time injury or illness 4-- minor lost time injury or illness 5--no lost time

Exclusion Zones and Classified Hazardous Areas

The new Fuel Storage and Handling Facilities are designed in accordance with the requirements of AS 1940 and AS 4897

Classified hazardous areas due to the presence of flammable liquids and /or gases as defined in AS/NZS 60079.10.1, shall be delineated as either Zone 1 and Zone 2

All new electrical equipment is required to be installed within a classified hazardous area ( i.e. product U/C fuel dispensers/ pollution control equipment) the electrical equipment must be designed and installed in accordance with AS/NZS 3000 & AS INZS 2381.1)

All equipment must be rated according to the following classifications:-

> Flameproof ( Exd ) ► Increased Safety ( Exe ) > Non sparking ( Exn ) > Intrinsically Safe ( Exi)

Classified Hazardous Areas and Exclusion Zones due to Flammable Liquids

Separation distance below are defined within AS 1940 and AS/NZS 60079.10.1.

► Fuel dispensers --4.0 metres > Vents - 1.5 metres radius around vent pipe/ 2.0 metre lineal from any building opening

I 4 metres above ground. > Fill Points -- 3.0 metre radius ► Dip Points -- 3.0 metres radius > Submersible Turbine turrets -- 1.5 metre radius ► Pollution Control Holding Tanks/ Drains with a potential to contain flammable

Liquids- 0.5 metres

The double wall underground tank will be installed and anchored to industry standards and in accordance with Section 5 of AS 1940 are to be a minimum of 2 metres from property boundaries.

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Mechanical Hazard Identification and Controls

Event PETROL

Cause Consequence Mitigating factors

Petrol tank rupture Mechanical damage

Corrosion

Spill of contents to bund Design to AS1940

Possible bund fire or tank fire • Regular maintenance and if ignited inspection

f-ire fighting equipment to be installed

Bund sized for adequate containment

Cathodic protection

Control ignition sources

Tank hole - liquid leak • Mechanical damage

Pressure relief • valve failure

Corrosion

Release of large quantity to • bund

Likely bund fire if ignition source

Possible tank fire

Design to AS 1940

Regular maintenance and inspection

Fire fighting equipment to be installed

Cathodic protection

Control ignition sources

Pipe rupture or leak Mechanical damage

Corrosion

Release of significant quantity· Regular maintenance and to bund inspection

Likely bund fire if ignition source

Possible tank fire

Fire fighting equipment to be installed .Cathodic protection

Control ignition sources

Tanker rupture or leak • Mechanical Release of significant quantity • damage from tanker

Traffic accident • Fire may result if ignition source present

May disperse without ignition

Design to AS1940

Regular testing and maintenance of tanker

Fire fighting equipment to be provided

Tanker hose rupture or • Mechanical Release of significant quantity· leak damage to environment

• Wear and misuse

Fire may result if ignition source present

May disperse without ignition

Regular inspection and testing or hose and fittings

Tanker brakes interlocked to prevent drive away while connected

Unloading operations should be in bonded area

Fire fighting equipment to be provided

Specific Design Elements to be incorporated

In the event of a fire at Tank Openings

Dip Points - Are protected in a steel lock box, not in view of the general public. Caps are vapour tight/ lockable to prevent illegal access.

Vent Pipes - 63 mm dia. and are located 4 metres above the finished ground level ( driveway ) The u/g vent pipe work always have a positive fall back from the visual above ground vent pipes - back to the u/g fuel tanks, thus ensuring only vapour in the lines not product. A vapour recovery system is installed underground, taking vapours back into tank and thus greatly decreasing the quantity of vapours escaping into the atmosphere.

Fill Points - are located within a Spill containment box which is fitted with a heavy duty trafficable lid. All fill line/s have a 100 mm dia. vapour tight lockable cap fitted to fill point. In the event of a fire from an external source i.e. Equipment , vehicle, building, vegetation etc, all the exposed pipe work, fixtures and fittings of dips, fills, vents, are fire resistant as they are manufactured from non-combustible material.

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Motor Spirit Spillage from tankers filling underground tanks

During filling of product (filling) to the underground tanks, any residual product within the tankers delivery hose will drain back into the Spill Containment Box which is set down in the concrete pavement. The fill box has capacity to contain minor fuel spills and will be contained in the box. A manual operated valve within the spill containment box can be activated by hand and any spillage will drain back into the underground tanks.

Fuel Tankers are fitted with a "Fail Safe" air brake system which will not allow the vehicle to be driven in any direction whilst a hose is connected and discharging product into an underground tank.

This Industry Standard Procedure has been adopted to avoid any overfilling of any individual tank under the ground and any subsequent potential spillage.

Motor Spirit Spillage from Fuel Dispensers

All dispensers located on the concrete forecourt under the canopy, are fitted with automatic shut off valves in the fuel dispensing nozzles when the customers tank become full. All nozzles are fitted with splash guards to prevent splash back onto the customer whilst filling their tanks

Motor Spirit Fuel nozzles will only operate in an attended mode. i.e. In accordance with AS/NZS 1940, the nozzle cannot be latched in an open position.

Each dispenser is installed with an "under dispenser containment sump" below driveway level to retain any leak or spillage that may occur from under the dispenser. Intermittent monitoring of these sumps is a continuing maintenance item.

Tank leakage

All underground motor spirit storage tanks are constructed from double walled fibreglass tanks. The tanks are all compatible with all fuels and manufactured to Underwriters laboratories UL1316.

Fibreglass tanks have a warranty period minimum of 30 years against failure if they are installed and maintained in accordance with the manufacturer's written specification.

Underground tank farms are installed with two water monitoring wells. Additional Monitoring wells as required will be installed and maintained to ensure strict compliance with the Protection of the Environment Operations (Underground Petroleum Storage Systems) regulation 2014.

The tanks are subject to integrity testing by the manufacturer prior to delivery and again tested by the installing contractor during and immediately after installation and completion of backfill. Thereafter, tank integrity can be monitored continuously. The tanks have a space between the primary and secondary shell walls to allow for free flow and containment of all leak product from the primary tank. Tanks are fitted with a liquid monitoring reservoir located on the top surface of the tank and allows the liquid within the secondary shell (interstitial space) between the shells to be monitored. This allows for continuous testing for the life of the tank.

An Automatic Tank Gauging System (ATG) will be installed in the new tanks on site. Tanker drivers on coming to drop fuel at the site always determine the current volume of product storage in the tanks by taking a print out of the ATG system. This will allow them to verify that the individual tanks can receive a predetermined liquid volume required prior to connecting the tanker hose to the fill box and subsequent fill line to the product tank.

Electronic monitoring of tank is to be installed utilising electronic probes with each tank compartment. A Veeder Root TLS-450 tank gauging console will be provided at the sales

Page 11 of 13

counter and will monitor and reconcile fuel volumes and monitor fuel levels in tanks and fuel delivery lines.

Electronic liquid level monitoring of the tanks occur on a daily basis (usually at the change of each shift). This reconciliation of inward and outward movement against the current stock will highlight any discrepancies i.e. Loss of fuel to unknown factors. A regimented process of investigation then follows if the discrepancy is outside the acceptable limits. These measures allow the detection of any system anomalies insuring that any contamination is quickly identified and remedial steps taken to avoid any major detrimental impact to the environment.

Fire at Fuel Dispensers

Dispensers are installed with ignition source exclusion zones as previously noted. 100mm diameter steel bollards are installed on the approach side of the dispensers providing additional protection for the dispenser from any vehicle impact damage (any minor impact to dispenser by vehicle will cause damage to the dispenser casing but will cause the dispenser to move thus prevents little danger). In the event of a large impact on a dispenser the dispenser can be removed from its base and will cause the electrical supply cabling to be sheared off. The fuels supply pipes from the tanks to the dispensers are also fitted with shear valves as required by AS/NZS 1940, these shear valves will close off cutting off any fuel to the dispenser should the dispenser suffer a large impact.

If fire were to occur at the dispenser pump console operator is trained to shut down all pumps via the console emergency stop and try and extinguish the fire with a 9 kilogram dry chemical fire extinguisher.

Ignition by Static Electricity

All fuel dispensing locations are earthed via their bases. All fuel hoses are electrically continuous and remove the potential for static discharge between vehicles and equipment.

All the fuel delivery points, the fill boxes, are earthed by being fitted with static spikes and also equipotential bonding. Tanker hoses are fitted with static leads which discharge static charges to ground prior to the delivery of the product.

At the vents there is no potential for static build up as there is no flow of liquids to create a static charge and furthermore the vent pipes are all metal installation connected to earth ( equipotential bonded).

Fire Fighting Measures

9 kilogram dry powder type fire extinguishers are located on the canopy columns adjacent to the pumps as well as externally and/or internally in the sales building in accordance with Relevant Australian Standards.

Service Station staff are trained in the use of fire extinguishers and are trained in emergency procedures and have a list of emergency contact telephone numbers.

Additional Precautions

Mandatory "Non Smoking" signage is prominently located adjacent to the dispensers in accordance with AS/NZS 1940. Should the notices be ignored by any customers the console operator on self serve sites are instructed to shut down the dispensers until the situation is made safe.

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Tank Excavation Validation

In accordance with the Protection of Environment Operations (Underground Petroleum Storage Systems) Regulation 2019 testing of the excavated area will be undertaken. A validation report will be provided to the council of the existing underground tanks removal or completion of any remediation should this be required. This validation report will confirm that the site is suitable for continuing use in accordance with the requirements of the State Environmental Planning Policy 55 --Remediation of Land.

Stage 1 (VR 1) Vapour Recovery

In accordance with the requirements of the Protection of the Environment Operations (Clean Air) Amendment (Vapour Recovery) Regulation 2009 a VR1 system will be provided as part of the proposed works. The VR1 system will ensure fuel vapours will return the fuel delivery tanker during unloading of fuel, a pressure vacuum valve will also be provided to the tank vent line as part of this installation.

Vapour recovery monitoring is carried out in conjunction with tank monitoring utilising the Veeder Root TLS 450 console, this ensure that optimal operations, alarms and fail safes are provided in accordance with the requirements of the Protection of the Environment Operations (Clean Air) Amendment (Vapour Recovery) Regulation 2009

Summary and Conclusion

In accordance with the document applying SEPP 33 a level 1, qualitative assessment has been undertaken, this is due to the fact that risks are shown not to pose a significant risk and risks can be managed by design, construction and ongoing operations;

The implementation of many safe guards in compliance with the various applicable Legislative requirements, Australian Standards as previously outlined, the WorkCover Dangerous Goods Department requirements, self regulating industry standards, the high level of operational and safety education of tanker drivers and site staff together with general good business and management standards required by the industry, all act to ensure there is no significant risk to the locality as a consequence of the new proposed motor spirit storage.

The installation and operation of the Motor Spirit facility will be strictly in accordance with AS/NZSD 1940 (latest edition). The site operators and tanker drivers will be highly trained personnel and this preliminary hazard analysis indicates that the safeguards to be incorporated into this automotive retail facility will minimise any potential hazards.

We hope the above information is sufficient to enable Council to approve the motor spirit and ADF installation component of this application, if additional detail or information is required please contact the above.

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