Enviroman
OVER the past two months I’ve had the ’pleasure’ of dealing with a number of Compliance Assessment Report (CAR) forms, on behalf of operators in England and Wales.
A common theme amongst the CARs - (several have involved a first inspection on a site for over a year) is that basic issues have been missed or ‘things have slipped a bit,' with the issues below featuring most often.
Continuing competence
I still receive enquires about continuing competence from waste operators throughout England and Wales. I covered the issue a few months ago, so I will keep it brief.
If you are the technically competent manager for a waste site and your last certifi cate, whether original or continuing competence, is over two years old, then you have missed the boat and need to do the computer based test.
Book via
wamitab.org.uk and don’t forget to select your activity specifi c test for the type of site you are managing. If you need help selecting the correct test contact WAMITAB or your site inspector (who should know what qualifi cation is relevant, but rarely does).
Site drainage
How many of you have an up-to-date drainage plan for your site, and can say for certain whether the site drains discharge to the foul sewer or surface water/surface sewer? Not knowing can be costly, so take time this month to check them out and mark your surface water manhole covers and grids with BLUE paint, and your foul drainage points with RED paint.
Putting a small sign next to the drain would also help. Builders don’t always get the drains right, and if the site hasn’t been built for you and is a former industrial site, the drains can be a nightmare to check out. If you have to prepare a Fire Prevention Plan (FPP) you will require detailed knowledge of your site drainage, the surrounding area, hydrant locations etc.
It is worth knowing who is responsible for the surface and foul systems serving a site for emergency planning. Your management system should include
20 SHM November, 2017
A surface or pavement constructed and maintained to a standard suffi cient to prevent transmission of liquids
2. Unless stored or treated outside as specifi ed waste
a) All bulking, transfer or treatment of waste shall be carried out inside a building
b) All waste shall be stored in a building or within a secure container
c) All waste shall be stored and treated on an impermeable surface with sealed drainage system
3. Specifi ed waste shall be stored and treated on hard standing or on an impermeable surface with sealed drainage system
The important defi nitions are: 'building' means a construction that has the objective of providing sheltering cover and minimising emissions of noise, particulate matter, odour and litter.
'Impermeable surface' means a surface or pavement constructed and maintained to a standard suffi cient to prevent the transmission of liquids beyond the pavement surface, and should be read in conjunction with the term 'sealed drainage system' (below).
'Sealed drainage system' in relation to an impermeable surface, means a drainage system with impermeable components which does not leak and which will ensure that: (a) no liquid will run off the surface otherwise than via the system; (b) except where they may lawfully be discharged to foul sewer, all liquids entering the system
contact details for the water company, local fire & rescue service, and local authority.
Many recently issued permits have drainage conditions similar to those set out in standard rules permits (if we use the SR2008 No.3 (version 5.0) as an example, which is the latest set that applies to many existing transfer stations).
Table 2.3 ‘Operating Techniques’ in condition 2.3.1 states the following:
are collected in a sealed sump.
So if your permit refers to a sealed drainage system for any part of your site, it should eff ectively be a concreted surface which drains to a sealed sump, or to the foul sewer.
If you do drain to the foul sewer you may require a Trade Effl uent Consent (TEC) from the relevant water company, the application for which will be processed by Water Plus. Check where the drains inside your building drain to and if possible install a sealed sump, which is the most cost eff ective and pollution proof option.
If any part of your site does drain to surface water and/or does not have an impermeable surface, then it is important to check what your permit says about storing waste on those areas.
Standard rules and permits restrict the storage of ‘specifi ed waste’ in such areas, and is eff ectively a list of EWC codes for less polluting wastes such as minerals, soils, aggregate, rubble etc.
This is a brisk whiz through drainage issues, but the important point to understand is that if you do not sort your drainage out, you could be committing a criminal offence even if you do not cause pollution.
Don't put your permit at risk, get a survey now - including the condition of drains to make sure your foul system isn’t leaking into the surrounding ground.
On that cheerful note, I hope all my readers enjoyed bonfire night and didn’t get a visit!
MARCO MUIA Marco Muia BSc (Hons) MSc MCIWM is
a Director of Oaktree Environmental Limited. He specialises in all aspects
of waste planning and regulation
consultancy. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer. You can contact Marco on: 01606 558833.
If you have any questions about this article, e-mail him via:
marco@oaktree-environmental.co.uk Follow him on Twitter @wastechat
www.skiphiremagazine.co.uk
MARCO MUIA: DIRECT AND TO THE POINT
www.oaktree-environmental.co.uk
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