The latest Petroleum Regulations came into force from October 1, 2014 and allowed for a transitional period of three years for the Petroleum Licences that were in force at the time, to be converted by the Petroleum Enforcing Authorities (PEAs) into Petroleum Storage Certificates (PSCs). The three years have nearly passed, and by September 1, 2017, all petrol filling stations should have been issued with a PSC. There are some people within the industry that haven’t grasped the significance of the change even though PEAs should have sent letters and guidance explaining the changes at the time when the licence was due to expire.
One of the main aims of the new regulations was to reduce the bureaucratic burden on site operators by limiting the situations when they are required to seek approval for work on their sites. One way of achieving this was for not only the tanks that currently contained petrol to be listed on the PSC, but all the tanks that did, and could, be used to store petrol. This eliminated the need for approval to be sought for grade changes across the listed tanks. The transitional arrangements allowed for the site operators to challenge the PEA if the tanks that they believed to be suitable for petrol were not listed on a letter that was sent in advance of the issuing of the PSC, but my impression is that not everyone took advantage of the opportunity.
If you are now considering a grade change at your site, the first thing you need to do is to see if any tanks that you now wish to use for petrol are identified on the PSC. If they are you do not have to notify the PEA. If you intend changing a petrol tank to store diesel, again, there is no requirement to notify the PEA, (you can also change it back at any time without giving notice).
However, if a tank (or tank compartment) isn’t shown on the PSC you must give notice (minimum of 28 days), and seek agreement for a new PSC to be issued including the tank. Obviously, you are still required to carry out the necessary works to facilitate the grade change, but you don’t need to inform the PEA that you are doing the change if the tank is already shown on the PSC.