All across the air, land and water
A common regulatory system for all emissions has just come into force. Dr Ian H Pallett explains what it will mean in practice for the water industry.In England and Wales the regulation of all discharges to the environment whether to air, land or water are gradually being brought under a common set of regulations, the Environmental Permitting Regulations. The Environmental Permitting (England and Wales) Regulations 2007 are to be augmented by the Environmental Permitting (England and Wales) Regulations 2010, which came into effect last week (April 6).
The 2007 EP Regulations cover the larger waste and PPC regimes and replaced 41 separate regulations by a common permitting system. This month the EP Regulations have been extended to introduce this common permitting system to seven other previously separately regulated activities.
The new regulations require all small wastewater discharges to be registered either for a permit to discharge or simply as an exempt activity if certain requirements are met.
So this comprehensive Environmental Permitting Programme brings into force a common regulatory system for all emissions ranging from nuclear power stations, through municipal wastewater treatment works, industrial manufacturing sites, to commercial buildings and the small single domestic dwelling.
The specific (eg nuclear) and larger discharges will have bespoke permits tailored to the site's specific or complex emissions. Standard permits will be available for the more straightforward discharges while small discharges, mainly of treated domestic wastewater, will be able to register as exempt activities.
Naturally all discharges covered by bespoke or standard permits will be registered (as previously), however, the new regulations require all exempt activities, which include the small domestic treated wastewater discharges, to register as well. This is a major change that will affect owners of properties with non-mains wastewater treatment systems which discharge treated effluent to water or to land.
So the many owners of septic tanks that have been in existence for generations will need to be made aware of the registration requirement even though it is to register their system as an "exempt activity" with no need to apply for a permit of any type.
Admin hoops The first quarter of 2010 has seen Defra consult on general interpretative guidance and the Environment Agency consult on more detailed guidance to clarify the details and process requirements that must be met to ensure compliance with the new regulations.
The regulations have been scrutinised under the "Better Regulation" procedures. This should hopefully ensure that they have been streamlined to minimise the administrative hoops for all owners of discharges to negotiate in order to achieve the anticipated level of environmental protection whether by permits, standard rules or exemptions.
The preparation of Standard Rules for different industrial sectors was the result of discussions between the environmental regulators and each industry to arrive at a fixed set of rules for compliance with a standard permit and relevant guidance for that industry.
However, there is no such "industry body" for what could be viewed as "straightforward" discharges from domestic properties that for the majority will be registered as an "exempt facility". Consequently the development of the regulations and guidance applicable for domestic discharges has required a different approach in that the regulators have supplemented the guidance with information available from the industry supplying the relevant equipment and services.
It is anticipated that most small discharges will qualify to be registered as exempt facilities. In order to register as an exempt facility the discharges must be of treated domestic wastewater and be 5m3 or less from a sewage treatment plant to surface water or 2m3 or less from a septic tank or sewage treatment plant to groundwater.
For discharges to surface water the registration date was April 6, 2010 and for discharges to groundwater there is nearly a two-year delay with registrations being required by January 1, 2012.
The discharge volumes should be calculated by the method specified in the industry code of practice Flows and Loads 3, published by British Water.
As well as being sized according to Flows and Loads 3 the septic tank or sewage treatment plant should designed and constructed according to the British Standard design requirements that are in force at installation. They should also be compliant with the performance requirements of the BS EN.
The current standard is BS EN 12566 part 3 for sewage treatment plant and parts 1 and 4 for septic tanks. For new groundwater discharges the outlet should comply with BS 6297:2007+A1:2008. They should all be installed following the recommendations in the British Water code of practice for installation.
Even if a plant is constructed and certified to perform according to the requirements of the relevant part of BS EN 12566 this will only provide long lasting environmental protection if it is installed, operated and maintained according to the manufacturer's instructions and the industry code of practice published by British Water.
Maintenance should also be carried out by personnel competent in all aspects of plant maintenance, including desludging.
There are approaching 300 service engineers who have successfully completed the British Water PTP Service Engineers maintenance course that is delivered by Develop Training.
Industry standards The new Environmental Permitting Regulations bring together under a common format the regulation of all types of discharges to the environment and the April 2010 Regulations in particular address and clarify the regulation of small wastewater discharges.
There are many such small discharges across the UK all of which contribute to diffuse pollution. Better design and installation of new plant and regular competent maintenance of all installed systems should reduce such pollution to contribute to meeting the diffuse pollution targets of the Water Framework Directive.
The Package Treatment Plant Focus Group of British Water has brought together the major manufacturers of small sewage treatment systems and major installing and service companies who between them have lead the development of industry standards.
The representation at BSI and CEN has ensured that the UK position on design and maintenance has contributed to the development of standards for the industry. Of particular significance to the industry in the UK has been the development of codes of practice and a service engineers training scheme that have all received the support and endorsement from all of the regulatory agencies in the UK.
Dr Ian H Pallett is technical consultant at British Water. T: 020 7957 4554
*The codes of practice (including a User's Guide) are all accessible for download from www.britishwater.co.uk/publications/publications_and_technical_guides.aspx
Details of the training course can be obtained from www.britishwater.co.uk/ptp_engineers/Accredited_Service
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