Another fair point too. (shh!) ;)
Please be aware that from my point of view very low risk sites are asked for Gas Monitoring, I'm not just being a funny bugger.
With regard to the commercial problem there are so many companies doing the various conland sections at rice and peas prices (or even a loss - re: loaded Desk Studies, Desk Studies without site visits, a page of A4 desk study by some architect, etc.) that it drives down quality. Then again, on the flip side, there are lots of companies offering substantial overkill on everything that people don't know what to believe or some developers think they are being shafted, which in some cases I'm sure they are. I'm sure you must have seen this on your travels too Keiron.
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A tangential example for me being that I was asked to do a soil validation exercise (of which there are many!) and I failed the soils due to the presence of various physical failings (wire, glass, concrete, asbestos tile, etc. - probably not wanted by residents in their topsoil) and the developer said that the report would be lost and could I do another one that is "favourable". Cheeky so and so.
As it goes the remittance for that didn't have enough zeros on the end! ;)
Seriously though, upon refusal of such a daft request the response was "well, I'll find someone that will". To which Good Luck but that leaves me in a commercial-moral dilemma. What do I do here? Anyone know? Or is it a stupid question?
I feel I should tell the EHO but then I also have client confidentiality. It is a position I really don't like being in.
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So expanding/extrapolating that if one consultant says you need a £3 or 4K gas SI and another says "I can risk it out" (shudder) for a hundred quid then the developer (who may not know much about such things) would go for the cheaper option as the other one seems like someone is trying to make a quick buck. This then perpetuates, or at least has the potential to.
Am I talking nonsense or does anyone else see that too?
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Cheers everyone
Russ
:)
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Keiron Finney
Sent: 23 February 2015 10:16
To: [log in to unmask]
Subject: Re: Hierarchy of guidance
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
E-mail 1 : [log in to unmask]
Email 2 : [log in to unmask]
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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