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Vapour Recovery Stage 2 - How do we ensure it works?
By Nigel Plumb, director David Plumb &Co
There are two huge sources of pressure on all those involved in decommissioning refuelling sites –safety and the environment. Many companies see these as opposing forces and feel they are being pulled in two directions by equally urgent issues. It can, even, sometimes seem that two different environmental concerns will oppose each other. You cannot, for example, remove pollution from a site without creating noise, dust and vibration. Whenever there is an apparent conflict between safety and the environment, most responsible companies, ourselves included, will always come down on the side of safety; but we believe there is no real conflict.
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At the beginning of 2006, we began a continuing campaign to address the issue of industry safety and quality, with the aims of: -
·Ensuring contractors maintain the highest levels in staff training, safety of staff and members of the public, and all areas of environmental
concern.
·Ensuring customers have a way of knowing the company they are dealing with is working to these highest levels.
·Providing a guide to potential customers to enable them to ensure all quotes they receive from contractors are comparatively based with due consideration to safety and the environment.
To further this campaign we have used press releases, worked with trade magazines on feature articles, and used any opportunities at seminars and exhibitions to further our case.
While we want to spread the word to the wider industry, the first thing to do is, of course, ensure that we operate to the highest standards ourselves – and that is what I hope we do, but we do not see why that should compromise our environmental credentials.
One of the biggest areas of dispute at the moment is over the method of actually cleaning tanks before they are taken from a site for recycling. We believe it is essential that, when a tank leaves a site for which we are responsible it should be as free of contamination as we can make it, and certainly safe to handle at a recycling site. In our view, there is only one way to ensure that happens; to actually get inside the tank and scrub it by hand.
Many people say that it is safer to jet wash from the outside, but we believe that this does not remove all the contamination and you are left with gallons of contaminated water to deal with. As long as you take the right precautions, have the right training and use the right equipment, working inside the tank can be carried out as safely as working on the surface.
Working this way our people are protected, the environment is protected and the people further down the line who have to handle the metal from the tanks are protected. There is no need to choose between safety and the
environment.
As well as knowing ourselves that we do things properly, we believe that it is even more important that our customers, and potential customers, also know that we are competent, safety conscious and environmentally aware. To this end, we have produced a checklist, which we will be distributing to those in charge of site decommissioning, so they can see, in a simple and straightforward way, how we work and the measures we take.
We also hope they will use this to compare other companies with us. Which, in turn, we hope will encourage those companies, which currently do not come up to standard, to improve.
While we are as competitive as anyone, we want to compete on price, service and efficiency, not on the environment and safety. On these issues, we want to see the whole industry come up to standard. This is neither altruistic nor an attempt to appear noble. It is entirely in our own interest. It only takes a few customers to have bad experiences, or for a few bad headlines to hit the press and all the companies in the industry are tarred with the same brush.
Of course, not all problems are solved with standards, however good. Some problems do not have a right answer, such as when two environmental issues clash head on.
For example, to ensure a site is clean and safe when we leave it, we have to safely remove the tanks and all the contamination. This will inevitably require the use of large machinery, cold cutting equipment, pumps and possibly pile drivers if we have to insert an underground barrier.
All of this, and the demolition process that precedes it, will cause noise, dust and vibration. If the weather is wet, you will not get the dust, but you will get copious amounts of mud. All these things can, if they are allowed to, ruin the local environment for the duration of the job and upset the neighbours.
There is no way of avoiding this, but there are ways of mitigating it.
Vibration levels can be monitored, so that the way of working can be modified if possible. Dust can be hosed down and lorries carrying soil away can be covered. Mud can be washed off wheels before vehicles leave the site. Unfortunately, the only practical way of limiting noise from a site is by time – by not starting until a reasonable time in the morning and limiting its duration.
Because these environmental disturbances have generally to be endured rather than cured, the best way we have found to keep the site’s neighbours happy (or as happy as possible) is to keep them as genuinely informed as possible. To this end we have developed a Neighbours Special version of our normal David Plumb News newsletter. In it we set out what we do, why we are doing it, how long it will take and the measures we are taking to prevent disturbance as much as possible.
People are not unreasonable – if you give them information they will put up with much.
Of course, we hope that the efforts we are making, to improve safety and be as environmentally responsible as possible, are going to gain us business from customers that are increasingly conscious of these issues. However, this should really not be a commercial issue; it is something for the whole industry to take seriously to improve our image to the outside world. While we are doing that, we might just save a few injuries and improve the environment!
Articles Second consultation on proposals for creating a streamlined environmental permitting and compliance system
By Nigel Atkinson, Head, Environment Regulation Policy Division, DEFRA
Today the Government has, in collaboration with the Environment Agency and the Welsh Assembly Government, published a consultation paper seeking views on proposals to create a streamlined environmental permitting and compliance system in England and Wales. Electronic copies of this consultation are available at www.defra.gov.uk/environment/epp.
Background
Historically, environmental permitting regimes in England and Wales have developed largely independently of each other, in response to the particular pressures and circumstances prevailing at the time. This has led to an overall regulatory system that is widely felt to be excessively complex and to impose unnecessary administrative burdens. This view has found support from the Better Regulation Taskforce and the National Audit Office. In response to this, Defra’s Five Year Strategy, “Delivering the Essentials of Life”, contains a commitment to launch a programme to modernise environmental permitting systems. This programme – the Environmental Permitting Programme (EPP) –proposes to combine the Pollution Prevention & Control (PPC) and waste management licensing systems into a common permitting and compliance system. As a result, savings of around £90m over 10 years are forecast. The existing PPC and waste management licensing systems are considered to be good candidates for reform for a number of reasons, including that some businesses operate with both types of permit, sometimes on the same site, and because some waste operations are currently permitted under PPC, while others fall under the waste management licensing system.
Responses to first EPPconsultation
The first EPPconsultation, on options for creating a streamlined environmental permitting and compliance system, ran between 20 th February and 15 th May 2006. The Government received over 100 responses to that consultation. Each response was carefully considered. An analysis of the responses may be found on the EPP website at www.defra.gov.uk/environment/epp. Overall, feedback from respondents was positive, expressing broad support for the aims of the Programme. However, respondents were keen to see more detailed proposals. These are the subject of the present consultation. Responses from stakeholders helped to shape the proposals in the second EPP consultation. Chapter 2 of the second EPPconsultation document contains a summary of responses received to each consultation question in the first EPP consultation, together with a Government view.
About this second EPPconsultation
The proposals set out in the consultation paper aim to streamline and simplify the mechanics of the permitting and compliance systems for waste and PPC without undermining environmental protection or human health. They set out a new system consisting of fewer, simpler rules and clearer guidance. This unified approach would allow industry, regulators and the public to focus more on environmental outcomes and less on how they are achieved. Specific proposals include: changes to the way applications are made and determined; changes to the variation, transfer and surrender of permits; and changes to procedures for demonstrating the competence of operators. The proposals involve greater change to the waste management system than to the newer system for PPC. The partial Regulatory Impact Assessment (RIA) which accompanies the consultation paper and seeks to quantify the impact of the proposals predicts that these changes will bring about a reduction in the administrative burden on the waste industry in particular. The RIAalso forecasts wider economic benefits to industry and efficiency savings for regulators. Together, these are forecast to amount to around £90m over ten years. The proposals are designed in such a way as to facilitate the extension of this new approach to other existing and future environmental permitting and compliance systems in due course. Alongside the consultation paper and RIA, the Government has produced a set of draft Regulations for comment. Amongst other things, these set out how the permitting system works; what needs a permit, what environmental requirements apply and who regulates what; and what is exempt from the need to have a permit. Your comments on how the draft Regulations deliver the policy proposals are very welcome.
Complementary Defra/DCLG review of interface between pollution control and land use planning
The first EPPconsultation identified that stakeholders had some concerns regarding the interface between pollution control and land use planning. Today, therefore, the Government has also launched a separate but complementary consultation on this interface. If you have any comments about the interface between pollution control and land use planning, you are invited to respond to the complementary consultation. Electronic copies of the complementary consultation are available from the DCLG website at www.communities.gov.uk/index.asp?id =1502826
How to respond
We would welcome your comments on the proposals in the second EPP consultation paper, on the forecasts in the second partial RIA, and on the draft Regulations. All responses will be considered before final decisions are taken on the proposals.Please note that responses must be received by 1700 Wednesday 6 December 2006. Please send your response to one of the addresses below. Where possible, we would be grateful if consultees could submit comments by email and clearly state which consultation questions they are addressing – this will assist us in processing responses as efficiently as possible.
By email: epp@defra.gsi.gov.uk
By post: Defra Environment Permitting Consultation 4th Flr, Zone C2 Ashdown House 123 Victoria Street London SW1E 6DE
Enquiries: 020 7082 2472
Wales
By email: EPPConsultationResponses@wales.gs i.gov.uk
By post: Waste Policy Branch Welsh Assembly Government Environmental Permitting Consultation First Floor, CP2 Cardiff CF10 3NQ
Enquiries: 029 2082 3213Electronic copies of the consultation paper and partial RIA, together with further information on the Environmental Permitting Programme are available at: www.defra.gov.uk/environment/epp
Confidentiality statement
In line with the Government’s policy of openness, at the end of the consultation copies of the responses we receive may be made publicly available through the Defra Information Resource Centre, Lower Ground Floor, Ergon House, 17 Smith Square, London SW1P3JR.
The information they contain will also be published in a summary of responses. If you do not consent to this, you must clearly request that your response be treated confidentially. Any confidentiality disclaimer generated by your ITsystem in email responses will not be treated as such a request. You should also be aware that there may be circumstances in which Defra will be required to communicate information to third parties on request, in order to comply with its obligations under the Freedom of Information Act 2000 and the Environmental Information Regulations.
The Information Resource Centre will supply copies of consultation responses to personal callers or in response to telephone or email requests (020 7238 6575, defra.library@defra.gsi.gov.uk). Wherever possible, personal callers should give the library at least 24 hours' notice of their requirements. An administrative charge will be made to cover photocopying and postage costs. If you have any comments or complaints regarding the consultation process these should be addressed to Defra’s Consultation Co-ordinator, Area 7D Nobel House, 17 Smith Square, London, SW1P 3JR consultation.coordinator@defra.gsi.gov .uk).
Water Finding Tank Dipping System
By Risbridger Ltd
The latest product innovation from Risbridger is their RIS-PRESSURE-DIP system, which is designed to allow safe dip testing for water contamination in underground storage tanks.
There is currently no reliable electronic method of checking for suspended water contamination, which can occur in the latest fuel cocktails. As we know, water in fuel can corrode and block engine components and contributes significantly to tank corrosion & bacterial growth.
The Pressure Dip system allows the dipstick to be safely removed and secured within the storage tank following the application of a water detecting paste.
The system incorporates many built in safety features including:
•Two level positions to prevent the dipstick from resting on the tank base when not in use.
•A secure locking mechanism prevents unauthorised use or access to the dip cap assembly.
•Designed to prevent fluid loss at maximum ullage pressure of 35 mbar - with a built in safety margin. •Supplied with a dip rod drill jig to aid installation.
It is specifically designed to operate with Stage 1B and or Stage 2 vapour recovery systems without releasing high volumes of vapour to the atmosphere. This is achieved by containing the dipstick within an internal liquid sealed drop tube.
For further information please contact either Steve Foley at Risbridger Tel: 08456 44 23 23 or Trevor Mason at Purfleet Forecourt Services Tel: 01708 864380.
Data Released July 2006
This fact sheet provides a summary of the data in the latest release of the Catalist UK database. If you would like further information or explanation please contact your Catalist Country Manager. Full contact details are provided at the end of this document.
All data in the following tables and charts is based on ‘open’sites (including sites under development and unsurveyed, but excluding non-retail sites).
Market Share by Brand
Brands are listed in order of market share for motor fuel volume sales (see definition below).
* Brands include sub-brands or subsidiaries as appropriate (identified as Share Brand in the database).
** Open sites includes all currently operating petrol stations and those sites that are under development or unsurveyed at time of publishing.
*** MF Volume refers to all grades of fuel bought on the forecourt by cars, vans and light commercial vehicles (Petrol, diesel, LPG etc.) and is based on Catalist estimates. This excludes fuel sold to the Heavy Goods Vehicle (HGV) commercial sector usually through separate facilities away from the normal forecourt.
Brand* Number of open sites** Average MF volume per site (kl p.a.) *** % Market share MF Volume % Outlet Share Effectiveness***
BP 1223 4787 16.1 12.7 1.26
Tesco 414 11372 12.8 4.3 2.99
Esso 923 4570 11.5 9.6 1.20
Shell 994 4230 11.5 10.3 1.11
Total 1086 2899 8.6 11.3 0.76
Morrisons 274 10899 8.2 2.8 2.88
Texaco 1140 2555 8.0 11.8 0.68
Sainsburys 243 11630 7.8 2.5 3.08
Asda 165 9237 4.2 1.7 2.44
Jet 533 2665 3.9 5.5 0.71
Unbranded 1036 718 2.0 10.8 0.19
Murco 357 1606 1.6 3.7 0.42
Minor Brand 460 776 1.0 4.8 0.21
Gulf 142 1467 0.6 1.5 0.39
Pace 137 1375 0.5 1.4 0.36
Food Store 62 2784 0.5 0.6 0.74
Maxol 91 1697 0.4 0.9 0.45
CPL 223 597 0.4 2.3 0.16
Somerfield 23 4283 0.3 0.2 1.13
Rix 100 943 0.2 1.0 0.23
Total 9626
Brand Number of open sites Average volume per site (kl p.a) % Market share MF volume % Outlet share Effectiveness
Company 2296 4799 30.1 23.9 1.26
Dealer 6184 2142 36.2 64.2 0.56
Hypermarket 1146 10724 33.7 11.9 2.83
Total 9626
Definitions:
Company: Owned by the supplying Oil Company whose name appears on the brand sign.
Dealer: An independently owned site usually supplied under an agreement with an Oil Company whose name usually appears on the brand sign. Also includes unbranded sites with no Oil Company identification.
Hypermarket:Owned and operated by the multiple retailers (Hypermarket groups). Also includes sites that may be away from the main Hypermarket store but are owned and branded by the Hypermarket.
Market Development by Brand
The table below compares the number of open and under development sites by brand, for the current release of data and the same period last year. It also shows the percentage change in site numbers for each brand during the last 12 months to give a clearer picture of which brands are expanding and which brands are reducing their site numbers.
Brand Number of open sites V2 2005 No. open sites V2 2006 % Change in site numbers
Adsa 157 165 5.1 BP 1282 1223 -4.6 CPL 263 223 -15.2 Esso 971 923 -4.9 Food Store 85 62 -27.1 Gulf 163 142 -12.9 Jet 595 533 -10.4 Maxol 90 91 1.1 Minor Brand 502 460 -8.4 Morrisons 282 274 -2.8 Murco 375 357 -4.8 Pace 170 137 -19.4 Rix 104 100 -3.8 Sainsburys 242 243 0.4 Shell 1041 994 -4.5 Somerfield* 0 23 100.0 Tesco 383 414 8.1 Texaco 1179 1140 -3.3 Total 1113 1086 -2.4 Unbranded 1155 1036 -10.3
