The backer of a proposed petrol station on the junction of Bromfield Road and Coronation Avenue has submitted a new report to support their case for underground petrol tanks. In a submission published last week, the developer’s adviser says that due to the design of the proposed underground petrol tanks, “the maximum volume that could be foreseeably lost would be limited to less than 1,000 litres of fuel.” The adviser says this “would impact the aquifer in the immediate proximity to the tanks only.”
I doubt this judgement. Oil and petroleum seep insidiously. The Corve is just 60 metres away and the Teme site of special scientific interest within half a kilometre. We need a second petrol station in Ludlow but not at the expense of our water supply and the delicate ecology of our river systems. Fifty petrol tanks of fuel leaked straight into the water table is never going to be good news.
The new report, by SLR Consulting, is up front in admitting that “diesel and petrol… contain a large number of constituent compounds which it is not feasible to assess on an individual basis” (16/04716/VAR).
The report says that the likelihood of any leak is small because the installation will use double skinned tanks and real-time leak detection systems. These will be complemented by a “groundwater monitoring network around the tank farm to enable monitoring of groundwater quality and recovery of fuel loss.”
The consultants say: “The shallow aquifer is likely aerobic and highly conducive to attenuation of hydrocarbons along the groundwater flow pathway.” Note those words – “likely aerobic”. The truth is that the consultants conducted a desk top exercise in Aylesbury. The analysis is not based on measured conditions in Ludlow. The report admits the calculations are “theoretical” because specific measurements on site are not available. They do not know whether the aquifer is aerobic or not.
“The results… indicate that the shortest travel time between the source and the receptor would be 55 years, which clearly demonstrate that there is sufficient time to respond to a release from the site in the event of an infrastructure failure.”
The report says this is based on a model with “uncertainty in the hydraulic conductivity” – doubt on how quickly hydrocarbons move in the ground. That is why another guess in the report suggests that benzene could migrate to the Corve within around fourteen years.
SLR claim there “would provide sufficient time to react to a fuel loss and implement a robust strategy before migration of hydrocarbons to the River Corve.” The company concludes that “the risk posed by the proposed development to controlled waters is acceptably low.”
The SLR report poses more questions than it gives answers. There is no information on what action would be taken if a leak was detected by detectors buried deep underground. Or even how any leak would be reported. There will be no inspection by the Environment Agency or any other external body. It will be up to the operator to report leaks. I fear it will not be in the operator’s interest to do so.
What happens if a detector fails? Will it be repaired or just ignored?
The report talks of remedial action but it gives no information on how this will be carried out. The tanks are below ground. Any remedial action will require closure of the site while the tanks are dug out of the ground, investigated and, if necessary, replaced. That will take months to arrange and complete. It will cost hundreds of thousands of pounds.
For every moment of inaction. carcinogenic benzene and other petroleum nasties will be seeping slowly but inexorably towards the Corve and the River Teme, a site of special scientific interest. Short of demolishing the entire petrol filling station and convenience store, nothing will prevent a poisoning of our delicate ecosystem.
The SLR report is an attempt to make acceptable the unacceptable.
This site has an approved application for above ground petrol tanks. The developers should get on with implementing plans we agreed.
. The report states: “The River Corve is located approximately 80m to the west of the Site, at its closest point.” The Corve is, according to my atlas, east of the site.