closed off and the tank more closely monitored when the 5000 discrepancy was first found?
Letters to the Editor Dear Editor I confess that when my copy of the Bulletin arrives I get a certain amount of excitement that that some might consider worrying. I have found it informative and interesting, however, I have some concerns over the accuracy of its articles. I recognise that the APEA is not part of Reuters and it also has an interest in selling advertising space, but I am sure that many of your readers like me have had the tendency to accept the articles as being accurate. I now feel that I need to return to the age-old principle of reading between the lines and accepting that some articles contain halftruths or incomplete information. As an enforcement officer I believe it is important that we get the facts as accurate as possible. Incorrect Information A recent article on "Mobile Phones" pertaining to be a warning issued by Shell, was also confirmed in a HSE release to EHO's. At last I thought, we have substantiated information from an oil company and the HSE on this issue. This was to be short lived as the Trading Standards " TS Link" was to inform us that the story was just Chinese whispers! Incomplete Information The "Contaminated supply Incident" article this month begs more answers to the following questions: 1) Licence conditions insist on daily monitoring, why did this not find the loss earlier ? With a hole the size of a ten pence piece this must have been leaking for some time? 2) Was too high a tolerance being used in their calculations? 3) At what stage were the losses reported to the Petroleum Officer? Were there on-going problems? 4) 10
Why
weren't
the
pumps
5) Was the site being operated by inefficient or untrained staff? 6) What of oil company area management checks? 7) Having worked on many tank gauge systems I can understand the 5,000 litres loss, but once corrected the 400 litres loss should still have been investigated. Was the 400 loss an acceptable loss or should further monitoring have taken place before putting the system back into use? 8) I believe BP use a third party to monitor some of their sites, if this was the case at this site it why was it not mentioned along with Marconi? 9) This might raise more questions about the reliability of third party monitoring. What is the time scale in finding a leak for these companies? And in the event of a major leak are they culpable? 10) A competent person monitoring wetstock should be able to recognise a pattern in gains and losses on their own site daily, how long before a third party company notifies the site of any irregularities and concerns? 11) Finally, a "Breakdown in communications" cannot be acceptable where there is a suspected petroleum leak. Petrol losses must be considered as of the highest priority. "Did we not learn anything from the "Bontddu Incident"? Some sites have systems such as a submerged turbine pump in one tank linked to other tanks using inefficient siphon systems also linked by vapour recovery to all the other tanks on site, how accurate are their tank gauge systems with continual pressure variation? and how well are they understood by engineers let alone forecourt staff and enforcement officers?
In concluding I believe there is no Due Diligence defence for petrol contamination of the ground and water supplies and therefore prosecution is quite likely to have a satisfactory result against the polluter. But even though the Environment Agency had a satisfactory prosecution in this case, incidents like this should not be allowed to happen. We are now in the 21st century and perhaps its time to insist on an age limit to tanks and pipe work or even insist that all tanks over twenty years old to be replaced with double skin tanks. Perhaps the Government could subsidise new tanks to protect our water supplies rather than tanks to fight wars. Colin Brewer Swindon Wiltshire
Recent comments from an attendee on a APEA LPG course: Dear Editor An excellent training course well presented and first class trainers. Now I know what DSEAR is - arriving in shortly. Accommodation great and really convenient for air travellers. The Association appears to be developing by leaps and bounds in a very professional way - well done and thank you for all your help and efficient administration. I like it when the airport is near by. Charlie Morrison City Inspector Derry City Council
