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Guidance on the implications of GP3 Part 2 Section D on the refurbishment or redevelopment of petrol filling stations (PFS)

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Water Framework Directive (2000/60/EC): greater need to understand the potential risks to groundwater posed by activities carried out on industrial and commercial sites.

Environment Agency: framework for the regulation, protection and management of groundwater (Groundwater protection: policy and practice, GP3).

Part 2 Section D of GP3: sets out the Environment Agency’s associated and complementary position statements.

Some activities: represent a particular hazard to groundwater (combination of activity type, duration and potential for failure of controls).

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Legislative and regulatory context

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Range of position statements, including:

D1 Principles of storage Considers the risk posed to groundwater (overarching position statement)

D2 Underground storage Objection to underground storage of hazardous substances in source protection zone (SPZ) 1. Mitigating factors needed for agreement to underground storage on principal and secondary aquifers outside SPZ1.

D3 Sub-water table storage

Objection to (new) storage of pollutants below the water table in principal or secondary aquifers. Mitigating factors needed for retention of sub-water table storage for redevelopment sites.

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Environment Agency position statements

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Position statements in theory directly impact upon the construction and redevelopment of retail petrol filling stations (PFS).

Storage of hazardous substances using above ground storage is currently the exception rather than the norm for PFS.

Recognition that position statements could encourage the development of above ground storage which may pose different environmental or health and safety risks.

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Implications for petroleum fuel storage?

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Greater clarity to implementation of Section D2 within E905 training pack →

'If the Environment Agency is consulted regarding a planning application for the redevelopment or refurbishment of a PFS in principal or secondary aquifers, in situations where redevelopment or refurbishment of underground storage at sites is unavoidable, the Environment Agency position will be to review the risks, contamination history and the proposed improvements to the site…'

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Clarification within GP3 Part 2 Section D

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No suitable alternatives to underground storage. No increased risk to groundwater from redevelopment.

Proposals comply with appropriate engineering standards. Effective management systems will be in place. Underground storage will not be brought closer to any abstraction source at

risk.

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Lines of evidence which will be considered?

Additional considerations?

Material planning considerations to local PFS provision. Previous historical infrastructure fully assessed and removed where possible.

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Concern that stakeholder training was required relating to PFS construction and operation, to help implement the position statements as intended.

An Energy Institute and Environment Agency collaboration to address training needs at a high level, and promote further awareness of the continued improvement in PFS design and promotion of best practice including double containment systems and remote monitoring.

End result → short, concise publication which describes potential release points, associated pollution prevention control measures (good and best practice), and factors which can impact upon PFS design.

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Need for a training pack

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Use of diagrams to aid training

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Look-up tables Component Potential for accidental discharge Pollution prevention control measures Further useful information

Underground storage tanks (USTs) [typical historical single-skin systems and modern double-skin systems]

Single-skin USTs Fuel leakage from USTs is largely

due to corrosion of the single-skin steel variety without secondary containment in place, based on industry experience.

A release will always be to ground for the single-skin USTs.

For older UST installations without secondary containment and/or leak detection systems in place, the volume of a release can be significantly higher than for USTs conforming to current best practice guidelines.

This is due to the likely time delay between the leak occurrence and detection of stock loss, which results in an extended leak duration, alongside the absence of secondary containment.

Leak detection systems, such as monitoring wells, are sometimes used to monitor a leak should the UST fail.

The outside of the external tank skin is typically polyurethane-coated to resist corrosion, and the coating is certified for consistency and uniform thickness by the tank manufacturer.

Automatic Tank Gauge (ATG) systems provide accurate data for use in wet-stock management, with tank ullages, delivery and sales volumes often remotely monitored by specialist 3rd parties.

Dynamic reconciliation or Statistical Inventory Reconciliation (SIR), based on ATG data, may also be used to further limit the volume of release and provide early warning of component failure.

Tank construction: Double-skin tanks represent recognised good practice. Tanks constructed to standards set out within EN12285-1 are considered best practice due to the high level of quality assurance achieved through certification. The USTs should be tested following installation.

Corrosion protection: Certified corrosion protection for applicable tanks is recognised good practice. Certified corrosion protection with cathodic protection is considered best practice. Note GRP tanks are not susceptible to corrosion. Corrosion protection does not improve the risk management, but may extend the life of the tank.

Leak containment: Leak containment class 3 is considered good practice (vapour/hydrocarbon sensors monitoring interstitial space). Class 1 or 2 considered best practice (interstitial monitoring using liquid, gas or pressure) as detects breach in either inner or outer tank.

Leak detection systems: Leak detection class 4a/b/c (approved ATG with inventory reconciliation) considered good practice. Leak detection class 6a/b/c (approved ATG with statistical inventory reconciliation) considered best practice, potentially supplemented by leak detection class 5 (monitoring wells with discriminating liquid/vapour sensors).

See sections 8.2, 8.3, 8.6, 11.2-11.6 (EI and APEA 2011) and wetstock monitoring under site operation and maintenance.

Double-skin USTs Double-skin USTs have significantly

lower probability of releasing fuel to ground as any leaks will be identified by the leak detection system(s) and then adequately contained whilst the source of the leak is rectified.

Double-skin tanks are used to significantly reduce the probability of releases to ground, with the second skin acting as secondary containment.

The interstitial space between tank skins can be continuously monitored by a proprietary leak detection system.

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Step by step guide which highlights information to consider when preparing a planning application.

Focused specifically on upgrade or redevelopment of existing PFS sites.

Onus on presenting sufficient information to allow a site-specific decision as to whether redevelopment should be allowed to proceed as planned.

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Preparing a planning application

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Identifying the factors which are driving the decision as to whether above or below ground storage is more feasible.

Site-specific, but alongside the potential risk to groundwater, may need to consider factors such as:

Health and safety (e.g. proximity to neighbouring properties, safe site access).

Site sensitivity (with respect to surface water).

Sustainability.

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1. Feasibility of above vs underground storage

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Site may be located in a low sensitivity location (e.g. unproductive strata) or at low risk due to existing PPC measures which are to be maintained.

For upgrades in a more sensitive location, evidence through a combination of engineering practices and site operation is to be presented to support the conclusion that there is a significant reduction in risk of release to groundwater.

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2. Low or significant reduction in risk to groundwater

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Range of information sources which can be referred to (e.g. The 'Blue Book' 3rd edition, Environment Agency pollution prevention guidance publications). Consider each aspect of the site construction

separately, and document the engineering standards to be applied:

Storage tanks. Fuel pipework and dispensers. Tank access chambers.

Oil/water separator and drainage.

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3. Compliance with appropriate engineering standards

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As important as the construction of the PFS; to monitor and maintain efficacy of pollution prevention control measures.

Elements to consider:

Forecourt operations (including wetstockmonitoring, training records, incident response plans).

Maintenance and inspection procedures (documented evidence, including inspection frequencies).

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4. Effective management systems

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Primarily focused on abstractions or surface water fed by groundwater.

No change to site layout means fuel storage area will not be closer to either an abstraction or surface watercourse, but if a new layout is proposed, further evidence may need to be provided.

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5. Redevelopment does not bring fuel storage nearer to a sensitive environmental receptor

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Intended to aid decision-making regarding the construction and operation of existing PFS sites undergoing redevelopment or refurbishment.

The assessment of each facility will be site- specific but this document promotes the consideration of multiple factors which can impact upon the design solution.

Should be read in conjunction with GP3 Part 2, Section D and good practice design, construction and operation procedures within EI and APEA (2011).

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Summary