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Bunds are good value

22nd January 2004
Page 26
Page 26, 22nd January 2004 — Bunds are good value
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Which of the following most accurately describes the problem?

JAM WRITING about your article headlined "Friend or Flow?" setting out areas of concern for the storage of oils or solvents at the depots of transport undertakings (CM 20 November 2003).

Your article should additionally have referred to the requirement — under the Control of Pollution Regulations — for any oil storage tank with a capacity of 200 litres or more to be bunded not later than 31 August 2005. For oil stores at significant risk (eg those located close to a water course, open drain etc) bunded storage should have been in place by 31 August 2003.

The need for bun ding is fundamental. The absence of a bund protecting the oil storage tank contents has been enough for Environment Agency prosecutions to be successful in eases of oil spillage. This custodian of the oil storage tank must take responsibility to properly assess risk and to act on risks identified. It is not necessarily the case,for example, that an oil spill caused by vandalism can be regarded as a successful defence to an Environment Agency prosecution.

The presence of a bunded oil storage tank may be a mitigating factor, but it might be argued that the risk of vandalism should have been foreseen and addressed. You were right to identify the very high costs associated with an oil spillage: the costs of a fully bunded 5,000-litre oil storage tank complete with a pump and flow meter at less than £3,000 is a sensible investment.

Neil Donald MD, Southern Counties Fuels

Tags

Organisations: Environment Agency
People: Neil Donald

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