PFS Training pack knowledge, skills and good practice knowledge, skills and good practice Guidance on the implications of GP3 Part 2 Section D on the refurbishment or redevelopment of petrol filling stations (PFS) www.energyinst.org To view as a presentation, please click 'view' on the menu bar and select 'full screen mode'. Then use your arrow keys to navigate.
PFS Training pack Legislative and regulatory context 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). www.energyinst.org
PFS Training pack Environment Agency position statements 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 Objection to (new) storage of pollutants below storage the water table in principal or secondary aquifers. Mitigating factors needed for retention of sub-water table storage for redevelopment sites. www.energyinst.org
PFS Training pack Implications for petroleum fuel storage? 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. www.energyinst.org
PFS Training pack Clarification within GP3 Part 2 Section D 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…' www.energyinst.org
PFS Training pack Lines of evidence which will be considered? 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. Additional considerations? Material planning considerations to local PFS provision. Previous historical infrastructure fully assessed and removed where possible. www.energyinst.org
PFS Training pack Need for a training pack 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. www.energyinst.org
PFS Training pack Use of diagrams to aid training www.energyinst.org
PFS Training pack Look-up tables Component Potential for accidental discharge Pollution prevention control measures Further useful information Underground Single-skin USTs Leak detection systems, such as Tank construction: Double-skin tanks represent storage tanks Fuel leakage from USTs is largely monitoring wells, are sometimes used to recognised good practice. Tanks constructed to standards (USTs) [typical due to corrosion of the single-skin monitor a leak should the UST fail. set out within EN12285-1 are considered best practice historical single- steel variety without secondary The outside of the external tank skin is due to the high level of quality assurance achieved skin systems and containment in place, based on typically polyurethane-coated to resist through certification. The USTs should be tested modern double- industry experience. corrosion, and the coating is certified for following installation. skin systems] A release will always be to ground consistency and uniform thickness by the Corrosion protection: Certified corrosion protection for for the single-skin USTs. tank manufacturer. applicable tanks is recognised good practice. Certified For older UST installations without Automatic Tank Gauge (ATG) systems corrosion protection with cathodic protection is secondary containment and/or leak provide accurate data for use in considered best practice. Note GRP tanks are not detection systems in place, the wet-stock management, with tank susceptible to corrosion. Corrosion protection does not volume of a release can be ullages, delivery and sales volumes often improve the risk management, but may extend the life of significantly higher than for USTs remotely monitored by specialist 3rd the tank. conforming to current best practice parties. Leak containment: Leak containment class 3 is guidelines. Dynamic reconciliation or Statistical considered good practice (vapour/hydrocarbon sensors This is due to the likely time delay Inventory Reconciliation (SIR), based on monitoring interstitial space). Class 1 or 2 considered best between the leak occurrence and ATG data, may also be used to further practice (interstitial monitoring using liquid, gas or detection of stock loss, which limit the volume of release and provide pressure) as detects breach in either inner or outer tank. results in an extended leak early warning of component failure. Leak detection systems: Leak detection class 4a/b/c duration, alongside the absence of (approved ATG with inventory reconciliation) considered secondary containment. good practice. Leak detection class 6a/b/c (approved ATG with statistical inventory reconciliation) considered best practice, potentially supplemented by leak detection class Double-skin USTs Double-skin tanks are used to 5 (monitoring wells with discriminating liquid/vapour Double-skin USTs have significantly significantly reduce the probability of sensors). lower probability of releasing fuel releases to ground, with the second skin See sections 8.2, 8.3, 8.6, 11.2-11.6 (EI and APEA 2011) to ground as any leaks will be acting as secondary containment. and wetstock monitoring under site operation and identified by the leak detection The interstitial space between tank skins maintenance. system(s) and then adequately can be continuously monitored by a contained whilst the source of the proprietary leak detection system. leak is rectified. www.energyinst.org
PFS Training pack Preparing a planning application 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. www.energyinst.org
PFS Training pack 1. Feasibility of above vs underground storage 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. www.energyinst.org
PFS Training pack 2. Low or significant reduction in risk to groundwater 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. www.energyinst.org
PFS Training pack 3. Compliance with appropriate engineering standards Range of information sources which can be referred to (e.g. The 'Blue Book ' 3 rd 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. www.energyinst.org
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