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Regulatory changes
surrounding sewage treatment,
and the need for future
groundwater risk assessments
Dr P J Aldous
Shrewsbury Reading Cardiff
www.esinternational.com
© ESI Ltd
Content
• The Pollution Prevention and Control
Regulations 2000
• The House of Lords Decision 2007
• Groundwater Risk Assessments
• Industrial Emission Directive (IED) and
Environment Permitting Regulations
• The future into AMPVI
© ESI Ltd
Regulatory field + timeline
PPC
Directive
House of Lords
Decision
IED
Directive
UWWT
Directive
Paragraph 37
2010 1991 1996 2007
UWWT
Regulations PPC
Regulations EPR Regulations
(Amendment) 2013
1994 2000 2013 1/13 7/15
Existing
new
sites
New
sites
7/14
Existing
IPPC
sites
© ESI Ltd
Pollution Prevention and Control
Regulations 2000
• Part 1 Disposal of waste other than by incineration or landfill
• Para (c ) - Disposal of non-hazardous waste in a facility with a
capacity of more than 50 tonnes per day by —
• (i) biological treatment, not being treatment specified in any paragraph
other than paragraph D8 of Annex IIA to Council Directive 75/442/EEC,
which results in final compounds or mixtures which are discarded by
means of any of the operations numbered D1 to D12 in that Annex (D8);
or
• (ii) physico-chemical treatment, not being treatment specified in any
paragraph other than paragraph D9 in Annex IIA to Council Directive
75/442/EEC, which results in final compounds or mixtures which are
discarded by means of any of the operations numbered D1 to D12 in
that Annex (for example, evaporation, drying, calcination, etc.) (D9).
© ESI Ltd
The House of Lords 2007
In brief the HoL considered :
The application of the PPC Regulations in relation to
• satellite sewage works where sewage sludges/solids removed
from the wastewater stream were initially treated by:
• Screening; and
• Primary sedimentation
• And then finally
• Thickening
• Primary and secondary digestion
• Dewatering
The sludges were finally transferred to a final sewage works by either
pipeline or road where they were subject to both recovery or disposal
operations. The disposal operations were:
• Landfill and Incineration
• Decision (in brief)
– Sewage solids once removed from the wastewater stream
constituted a waste
– Thickening and dewatering were physico-chemical treatment
processes
– Primary and Secondary Digestion were biological treatment
processes
– The satellite sewage works should be regulated under the PPC
Regulations 2000
The House of Lords 2007
© ESI Ltd
PPC Regulation
• Permit requirement
• Full application required
• Application of best available technology (BAT) to wastewater assets
• Based on BAT documents not directly developed for the
wastewater industry sector
• Protection of groundwater from pollution required
– Operational investigation of integrity of plant covered by permit
– Operational disturbance
– Asset plans and improvements required
– Double lining of tanks at extensive cost to protect groundwater
proposed
– Environmental risk versus cost highlighted
© ESI Ltd
Groundwater risk
assessments
• Basis to asses the risk to groundwater from a pollution
source
• Outcomes determines the necessary measures to reach
an acceptable risk
• Historically applied to pollution sources such as:
– Landfill, pollution incidents, contaminated land
© ESI Ltd
© ESI Ltd.
Conceptual model
• Need to demonstrate a conceptual understanding of the site
• Realistic conceptualisation and accurate parameterisation provide key foundation to RA
• Define relevant ‘contaminant linkages‘ – a contaminant (source)
– a pathway
– a receptor
© ESI Ltd
© ESI Ltd.
• RAM3 risk assessment model developed for the assessment of risk
to the water environment from contaminated land.
• Typical assumptions
– Leaks are continuous over a period > asset life and over an area of
asset
– Source concentrations are constant and 95th percentile data used
– Ammonium , Cadmium and Nickel key parameters
– No self healing/blinding of leaks/cracks assumed
– Viscosity not taken into account
– Three leak scenarios
• Small (0.04 l/s) Medium leak (0.4 l/s) Large leak (40 l/s)
Quantifying the risk
© ESI Ltd
© ESI Ltd.
Groundwater Risk
Assessment (GRA) Summary
• Groundwater Risk Assessment model
• Relatively cheap (use existing info) (£5-£10k)
• Identifies data gaps
• Provides framework for decision making and discussion
• Iterative process
• Balances cost and environmental risk
• Cost effective in many situations providing client with
confidence
• >20 completed to date
© ESI Ltd
Where next ?
PPC
Directive
House of Lords
Decision
IED
Directive
UWWT
Directive
Paragraph 37
2010 1991 1996 2007
UWWT
Regulations PPC
Regulations EPR Regulations
(Amendment) 2013
1994 2000 2013 1/13 7/15
Existing
new
sites
New
sites
7/14
Existing
IPPC
sites
© ESI Ltd
IPPC
LCP
diff
IED
Increasing regulatory burden on operator (compliance and cost)
Incre
asin
g level of re
gula
tion a
nd
regula
tory
contr
ol
ART 13
Best available
techniques
(BAT)
ART 10
Annex 1 5.3 (b)
Recovery
operations
WID
ART 28/29
>50MW threshold,
<15 MW individual plants
not included in
aggregation rule.
IMPLICATION : Significant potential impact on the treatment of sewage sludge,
especially when recycled to agricultural land Requiring new permits and implications
to existing permits
IMPLICATION : Tightening of existing
permit conditions, new permits, new standards,
impact on asset design e.g. digesters
ART 48
Monitoring of
emissions
IMPLICATION : Original
proposal to
reduce threshold to 20 MW not
Transposed, impact not
significant.
IMPLICATION :
Tightening
of some specific
emission limits.
PPC to IED
Deve
lop
ed
with
Th
am
es W
ate
r
SK
M E
nvir
os a
nd
UK
WIR
© ESI Ltd
EP Regulations 2013
• Regulation 37
– Now covers Disposal, recovery and a mix of disposal and
recovery of non-hazardous waste
– Part (a) Disposal includes
• Biological and Physico- chemical + pre treatment for incineration
– Part (b) Recovery or mix
• Biological + pre treatment for incineration
• Threshold (>75 t/day) (or 100 t/day if only process AD)
– Exclusion in both (a) and (b) for UWWT Directive activities
• >170 sites potentially covered (UKWIR 2011)
© ESI Ltd
Current Status
• Guidance awaited
• Applies to all new installations after 7th January 2013
• Applies to existing IPPC installations after 7th July 2014
• Permits required for existing installations newly brought
under permitting control by 7th July 2015
• BAT in the form of a revised Waste Treatment BAT is
currently under development
© ESI Ltd
Regulatory field + timeline
PPC
Directive
House of Lords
Decision
IED
Directive
UWWT
Directive
Paragraph 37
2010 1/13 1991 1996 2007
UWWT
Regulations PPC
Regulations EPR Regulations
(Amendment) 2013
1994 2000 7/15 2013
Existing
new
sites
New
sites
7/14
Existing
IPPC
sites