Key points
Thames Water’s recent £20.3m fine for polluting the environment represents a wakeup call not only for the UK’s municipal water industry but for any process industry which has wastewater as a by-product of its operation. Clwyd Jones, Business Development Manager, Siltbuster Process Solutions explains…
Although the magnitude of the fines for pollution incidents have been going up following the introduction of new sentencing guidelines in 2014, the judgement against Thames Water established a new framework against which future fines will be set.
The 2014 Guidelines set out a standardised approach in which sentences for a pollution event are determined based on not only the significance of the incident but also the size of the company and the degree of corporate culpability.
In particular, the Guidelines provide a culpability range from “low or no culpability” (for example where the incident was the result of accident or action of a rogue employee) through to “deliberate” where there was an intentional or flagrant breach of the law by those in position of responsibility.
The systemic failures identified by the Thames Water case led Judge Sheridan to conclude that these events must have been the result of the deliberate action by those in authority within the company. In giving his judgement, Judge Sheridan took the sentencing process a step further by applying the following principles:
- It should not be cheaper to offend than to take appropriate precautions
- Shareholders need to understand that the environment is to be treasured and protected, and not poisoned
- Fines need to be sufficiently large to get that message across
He then fined Thames Water accordingly.
What does this mean for process industries?
Clearly the implications from this case are that all companies discharging water have little choice but to ensure they adopt best environmental practice. Those that don’t face the risk of incurring fines greater than the cost of complying.
Furthermore, companies found guilty of an environmental breach could also be faced with indirect costs such as the loss of corporate credibility, local goodwill and potentially future business opportunities – not to mention the public relations costs incurred in trying to restore a damaged reputation.
In light of this, now could be the ideal moment for all process industries to review their wastewater treatment operations, identify scenarios which could threaten compliance and mitigate against them. In short – contingency plan.
Our own research suggests such a review could be long overdue. After all, 30% companies Siltbuster Process Solutions recently studied have had a significant wastewater treatment problem in the past year. Furthermore, 8% overall and 20% of single site operators stated that when the problem occurred, they continued to discharge, even when it threatened their compliance. Contingency planning is clearly needed!
Identifying the weak spots
A key stage in contingency planning is identifying the weak spots in the production process.
Production spikes or new product lines
The introduction of a new product line or a sharp increase in production – typical scenarios for seasonal businesses – can affect effluent characteristics and put compliance at risk.
This is because, although these are typically planned events, the planning often doesn’t include considering the impact on effluent and its consequences.
With proper planning, contingency measures could be implemented. These could include using additional, temporary treatment equipment which boosts capacity when needed.
For instance, for the sixth successive year we’ve provided Heineken’s Universal Beverages Ledbury (UBL) with a bespoke large-scale temporary Dissolved Air Flotation (DAF) system. This has enabled the beverage specialist to treat peak effluent flows during the site’s annual apple milling period.
UBL’s Ledbury plant in Herefordshire was the UK’s first large-scale beverage production facility, and is now a dedicated fruit and vegetable milling operation, capable of processing up to 15,000 tonnes per day.
The apple milling period, which typically extends from late August to late November, pushes production to its peak, resulting in significantly higher levels of waste water with additional suspended solids and COD loading onto the site’s own large effluent treatment plant.
At other times of the year, the site’s existing advanced effluent treatment plant, which employs a combination of aerobic and anaerobic processes, can treat the flow and load generated from the site’s production activities.
However, during the apple milling period, as the flow and load massively increase, so existing treatment processes need to be supplemented. So UBL has contingency planned, deploying two D100 packaged lamella DAF units and all the ancillary mixed reaction tanks, containerised dosing and pumping equipment to provide the necessary pre-treatment capacity when it is needed.
Other production changes
There are many other un-planned events which can have a similar impact, such as spillages, out of specification product dumps and new hygiene regimes. All will impact on effluent characteristics and as such need to be part of a contingency plan.
It’s not just what comes down the pipe that can cause havoc. If a company has an on-site treatment facility to manage, problems can arise there too. So, it’s worth taking a critical look at all aspects of the treatment facility’s management.
Identifying those which have potential to cause harm (or a breach of compliance), considering the potential severity of the harm and its likelihood – and then agreeing measures.
Here are just some of the many aspects which may need to be considered.
Operators – your operator knows the plant inside out and is 100% reliable. But what happens when he is ill? Continuity of attention and ownership can make a vital difference. So, it’s important to have people in reserve and to invest time keeping them familiar with the plant and competent.
Critical Spares – the lead times that might apply for replacement of critical items could be a problem – so they need to be prioritised accordingly. Make sure spares inventories, if kept, are maintained and that items are re-ordered when used.
Sludge Disposal – most treatment plants generate a by-product;
- How secure is the disposal route?
- What happens if it becomes unavailable, either temporarily or long term – what alternatives have you got and what is the cost impact?
Chemical Supply – what are the re-order levels and which are the most critical ones? How often have you come close to running out and what would happen if you did?
Loss of power and/or control – this not just confined to standby power generation.
- What if you had a catastrophic panel failure?
- How would the plant operate?
- Who is familiar with your PLC program – where are the backups?
- Could temporary starters be rigged up if needed?
- Who can support you with this?
- Can part of your effluent volume be tankered away if needs be – to where?
- Who could do it – how much would it cost?
Pumping capacity – this could be lost due to loss of power or through mechanical failure.
- What happens if you lose that inlet pumping station or the recirculation feed to that critical high rate filter?
- How could you rig up a temporary diesel pump set?
- Where would flexible hoses be connected, what size pumps would be needed?
Get your pump hire company involved so you’ll know what to ask for should a problem arise.
Company Expansion
Part of contingency planning also needs to look at proposed company growth plans and their potential impact. This means sales and production functions recognising the close interplay between what they do. For instance, as part of such a review, Euro Quality Lambs, (EQL) recognised it needed to boost its wastewater treatment capacity at its abattoir in CravenArms, Shropshire.
EQL, is a lamb & sheep abattoir, with a capacity to process 15,000 carcasses a week and with onsite boning & further processing facilities. It produces a large variety of lamb products in terms of different weights, fat covers and breeds. Its ability to meet many demand specifications throughout Europe has given the company a strong export business, with customers in France, Germany, Belgium, Spain and Portugal.
Improvements and additions to the abattoir’s operations meant that the company had scope to further increase its throughput, but ‘what if’ scenario planning told it that it first needed to upgrade its wastewater treatment to meet this increasing demand.
EQL was already using a DAF unit which performed well – removing 94% of suspended solids, 79% of settled COD and 96% of total phosphate. EQL asked us to advise on the best way to boost this wastewater treatment capacity in anticipation of its expanding business.
We recommended a DAF D50 to replace the existing unit. The new DAF has a footprint of just 2.3m x 3.8m and yet this model can treat up to 50m 3 /hour of wastewater, therefore offering more treatment capacity for EQL.
Conclusion & Resources
As you can see, contingency planning involves a real mix of assessments. Some, such as seasonal production spikes or company growth are predictable vulnerabilities, whereas others may feel very hypothetical. But with all of them the risk is very real, and, as we’ve seen with Thames Water, the potential fines are high.
This isn’t a task to be put off. It’s an important part of good environmental practice – and is one which plant managers tell us is extremely valuable (and reassuring) once completed. Siltbuster helps companies develop contingency plans as part of its service.
Following on from its highly successful CPD courses for the construction sector, Siltbuster will run Contingency Planning courses for effluent treatment for process industries from September.
