Hi all
Interesting comments about boreholes from Nicola (ever seen the reforming bentonite pellets!) and about interpretation. My experience when I was a regulator was that it was a frequent occurrence to have monitoring points that were lacking but we were not allowed the time to go and look...all part of "lighter regulatory touch". You can work out whether boreholes are functional by using common sense logic, you can also work out whether the numbers are being made up - all from your office desk. Interpretation based on CH4, CO2 and O2 very rarely tell you what the full picture is....of course my specialism is landfill gas and not so much ground gas, but the same principles apply. A really big issue is the competitive nature of employing consultants as it all comes down to price.
Low price frequently means low quality and if you are not allowed to have a look at the installations and carry out audit on your data it opens up the doors for poor bentonite seals, slotting down to silly depths, bungs and taps that leak, installation into fractured geology, sampling for 2 minutes (probably sampling the unslotted zone) and assuming you have a representative sample from a 30 metre deep borehole...I could go on.... so I think there are issues, but then do you want results that show you have a problem when you have no cash to put it right? It is sometimes a case of "the emporers new clothes" Difficult times..I am no longer a regulator by the way and act as an independent consultant on landfill gas/ground gas and have now seen these issues from 360 degrees.
Regards
Keiron Finney MSc, FHEA, PGCHE, MCIWM, MRSC, CChem, CSci, CEnv, Chartered Waste Manager, Grad IOSH, QP283
Director
Exea Associates Limited
Mobile: 07939625002
Home: 01902 742639
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Web: www.exeaassociateslimited.co.uk
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Rushton, Nicola
Sent: 23 February 2015 09:30
To: [log in to unmask]
Subject: Re: Hierarchy of guidance
I would also like to add my LA perspective two penneth as you put it Matt.
I have recently had cause to go out and watch as the consultant undertook extra monitoring at my behest and was shocked to find that there appeared to be no bentonite seal to any of the boreholes. The gas monitoring was also undertaken by measuring the concentration first and then the flow - which I would be interested to hear your collective comments on too.
Whilst there is guidance on how much monitoring to do, the quality of a report may give or take away confidence in the quality of the work undertaken in the field and this is factored into any decision to cost a developer more by getting their consultants out there again. For clarity I'll add that the conceptual site model for the site concluded that there could have been a risk from a landfill source off site at this particular site.
Nicola Rushton
Pollution Control Officer
Tel: 01827 715 341 (contact centre)
The Council House
South Street
Atherstone
Warwickshire
CV9 1DE
For and on behalf of North Warwickshire Borough Council
-----Original Message-----
From: Matt Rhodes [mailto:[log in to unmask]]
Sent: 19 February 2015 11:08
To: [log in to unmask]
Subject: Re: Hierarchy of guidance
Hi Russ/Simon
If I may add my two penn’orth and add a LA perspective.
Often it’s not possible to accept reduced gas monitoring, or no gas monitoring because the report/consultant is unwilling to shoulder the risk and caveats the risk assessment so thoroughly as to severely water down its conclusions. That said if the report clearly states that monitoring is not required, and provides ample evidence it should be accepted by the regulator. Where evidence is less clear (grey) the LA is perfectly entitled to express their own professional opinion and disagree with the conclusions of the report, they should of cause be able to provide a suitable rational for this.
Matthew Rhodes
Pollution Control Officer
High Peak Borough Council, Town Hall, Buxton, Derbyshire. SK17 6EL Website - www.northwarks.gov.uk<http://www.northwarks.gov.uk>
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