Regulatory changes

surrounding sewage treatment,

and the need for future

groundwater risk assessments

Dr P J Aldous

Shrewsbury Reading Cardiff

www.esinternational.com

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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

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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

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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).

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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

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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

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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

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Basics of a GRA

Pathway

Source

Receptor

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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

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A generic example

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• 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

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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

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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

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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

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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)

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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

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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

Regulatory fog

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Conclusions

• IED/EPR impact remains uncertain

• Timescales to implementation short

• BREF (BAT) currently being re-drafted

• Groundwater Risk Assessments

Cost effective approach

Balance to engineered BAT solutions

Informs design approach

Reduces operational interruptions

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