Permit to Innovate Granted: Remediation contractors unite to meet increasingly stringent sewer discharge consents
operations at former industrial sites across England and Wales comprised little more than standard components to permit sediment settlement prior to oil-water separation, removal of suspended solids via filtration and a method to facilitate removal of dissolved and immiscible hydrocarbons and other volatile organic compounds from wastewater generated during remediation activities. This made for standardised specifications, from which water treatment service suppliers and principal contractors alike could budget and programme project schedules accurately with confidence. So, the key variable of concern was that the treatment plant components should be capable of treating contaminated water at rates, typically between 2 l/s and 10 l/s, which ensures the programme was adhered to.
Andrew Barton Business Development Manager, QDS Environmental Limited
Industry-leading experts at QDS have recently installed a temporary wastewater treatment scheme at a remediation site in North West England, which, they believe, signals the dawning of an era which will demand a more innovative approach to how more challenging sewer discharge targets are addressed on future sites.
My colleagues have seen a steady stepwise evolution in wastewater treatment specifications over the last decade. However, a flurry of recent enquiries have highlighted to us that the increasing regulatory demands are certainly testing the creativity of the principal contractors to deal with non- routine substances or increasingly challenging discharge consent limits for waters they encounter during their site activities. It is not just the treatment technologies we have installed on this particular site that are more sophisticated but, going forward, the whole approach to how wastewater treatment is managed and planned needs an overhaul if stakeholders are to retain confidence when planning and budgeting future remediation projects. The flexibility and sophistication within our designs are now catching up with what is de rigour in permanent water treatment industry. The days of standard spec water treatment are over.
Traditional requirements for water treatment plant
Photo: Installed wastewater treatment equipment (adjacent to principal water storage area, far right almost out of shot)
The necessary equipment was supplied and, due to its relative simplicity and the principal contractor’s familiarity with it, was operated with adequate safety and proficiency by them, with the supplier input limited to maintenance of plant as and when requested. Operation was straightforward.
Without permission of the appropriate UK Sewerage Undertaker (a limited company appointed by the Secretary of State to provide, maintain and improve systems of sewers and sewerage treatment works) the discharge of wastewater would not be lawful under the provisions of the Water Industry Act 1991. With the improvement of environmental competence within the remediation fraternity, and with more environmental management systems becoming aligned with requirements of internationally recognised standards, such as ISO 14001, an increasing number of applications for temporary permits are being made to the UK Sewerage Undertakers.
The sewerage undertaker stipulates the conditions within a permit and they can be more stringent for temporary discharges of wastewater, as opposed to trade effluent entering the sewerage system under a trade effluent consent to discharge, because of the additional capacity burden it may place on particular sewers and wastewater treatment works and the increased environmental risk it may place on local sensitive water courses.
Paul Tipper (Trade Effluent and Waste Regulation Manager – United Utilities) explained, “Limits in the permit are set to protect the health and safety of the general public and the sewerage undertaker’s staff. Also, they protect the fabric of the assets, manage the risk of flooding and protect the receiving environment.”
An important point of law to note is that The Competition Act 1998 prohibits the sewerage undertaker from recommending how the applicant could eliminate or limit the levels of contaminants prior to discharge. So, the situation equates to a significant challenge and responsibility facing the permit holder, which in this case is the principal contractor, to be ready to address an ever growing list of potential contaminants of concern. The Water Industry Act 1991 specifies the need to control petroleum spirit or calcium carbide and The Trade Effluents (Prescribed Processes and Substances) Regulations 1989, alone, specifies 24 dangerous
|78| ENVIRONMENT INDUSTRY MAGAZINE
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