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NEBOSH National Diploma | Unit C

C O N T E N T S

Element Title Page C10 Environmental Pollution and Waste Management INTRODUCTION ............................................................................................................................................. 10-2 ENVIRONMENTAL POLLUTION ....................................................................................................................... 10-3

RELEASES ............................................................................................................................................................... 10-3 PRINCIPLE OF SOURCE, PATHWAY, TARGET AND IMPACT IN RELATION TO EFFECTS OF POLLUTION ................................................. 10-4 BEHAVIOUR AND DISPERSION OF GASES ......................................................................................................................... 10-5 RELEASE AND DISPERSION OF TOXIC SUBSTANCES............................................................................................................. 10-6 ENVIRONMENTAL IMPACTS ........................................................................................................................................ 10-11 POLLUTION CONTROL STRATEGIES .............................................................................................................................. 10-15 NEED FOR CONTINUOUS AND GRAB SAMPLING AND MEASUREMENT AGAINST SET STANDARDS ..................................................... 10-18 NEED TO KEEP THE REGULATORY AND LOCAL AUTHORITIES INFORMED OF ENVIRONMENTAL PERFORMANCE .................................... 10-21 DEFINITIONS ......................................................................................................................................................... 10-24 ROLE OF THE ENVIRONMENT AGENCY/SCOTTISH ENVIRONMENT PROTECTION AGENCY .............................................................. 10-26 REVISION QUESTIONS .............................................................................................................................................. 10-29

CLASSIFICATION OF WASTES ...................................................................................................................... 10-30 DEFINITIONS ......................................................................................................................................................... 10-30 WASTE ................................................................................................................................................................ 10-32 METHODS OF CATEGORISING WASTE AND DIFFERENT TECHNIQUES REQUIRED FOR EACH WASTE CATEGORY ................................... 10-40 REVISION QUESTIONS ............................................................................................................................................. 10-42

PRACTICAL WASTE MANAGEMENT .............................................................................................................. 10-43 MINIMISATION ....................................................................................................................................................... 10-43 STORAGE ............................................................................................................................................................. 10-43 LABELLING ............................................................................................................................................................ 10-43 CARRIAGE ............................................................................................................................................................. 10-43 THE DUTY OF CARE ................................................................................................................................................. 10-43 REVISION QUESTIONS ............................................................................................................................................. 10-45

WASTE DISPOSAL ........................................................................................................................................ 10-46 TYPES OF WASTE TREATMENT .................................................................................................................................... 10-46 REVISION QUESTIONS ............................................................................................................................................. 10-51

LEGAL REGIMES APPLICABLE ...................................................................................................................... 10-52 CONCEPT OF DUTY OF CARE ...................................................................................................................................... 10-52 REVISION QUESTION ............................................................................................................................................... 10-54

EMERGENCY PROCEDURES .......................................................................................................................... 10-55 NEED FOR EMERGENCY RESPONSE MEASURES IN THE EVENT OF AN UNCONTROLLED RELEASE ..................................................... 10-55 ENVIRONMENTAL ASPECTS OF THE CONTROL OF MAJOR ACCIDENT HAZARDS REGULATIONS ........................................................ 10-56 REVISION QUESTION ............................................................................................................................................... 10-63

SUMMARY .................................................................................................................................................... 10-64

NEBOSH National Diploma - Unit C | Workplace and Work Equipment Safety

NEBOSH National Diploma | Unit C

Element C10 | Environmental Pollution and Waste Management

Learning Outcomes On completion of this element, you should be able to:

Identify potential sources and impacts of environmental pollution and appropriate monitoring strategies.

Describe the various types of waste, their categorisation, treatment, disposal, and documentation.

Outline the need for emergency response measures.

Unit 10:

© RRC Training Element C10 | Environmental Pollution and Waste Management 10-1


INTRODUCTION You should note that the Diploma syllabus contains references to recommended prior learning (RPL). These are highlighted in blue and red in the NEBOSH Diploma guide. In most cases, RPL will have been covered in a suitable lower level course such as the NEBOSH National General Certificate (Unit NGC1 and Unit NGC2). It is important for you to remember that RPL material is examinable, and has indeed featured in examinations, so you are expected to be familiar with it. In accordance with NEBOSH guidelines, and to reduce wholesale and unnecessary duplication, some RPL content may not be repeated in the RRC Diploma course notes, although some aspects may be developed further. To facilitate revision of RPL material, you are provided with an electronic copy of the RRC Unit NGC1 and Unit NGC2 course notes. Please note that the recommended minimum hours of study for each element does not include recommended prior learning.

RPL content relating to this Element may be found in Element 6 of Unit NGC2.

You should read your course materials in conjunction with RRC’s online Health and Safety Law and Case Law Guide; log in to RRC’s support website at www.rrc.co.uk to access this learning resource.



ENVIRONMENTAL POLLUTION Many substances and processes used by differing industries can involve the release of potentially harmful materials (see the COSHH Regulations 2002). When such substances are released they could also potentially cause harm to the environment. Many well-known health and safety disasters, e.g. Seveso, 1976, or Chernobyl, 1986, have had widespread environmental implications, causing harm to people not involved in the workplace as well as to the land and water in the environment, with consequent effects on agriculture and the food chain. For example, in the case of Aznacollar Mine, Spain, in 2002 toxic material contaminated feeding grounds for numerous wild bird species.

Similarly, many common industrial activities, for example: combustion, cleaning, de-watering, degreasing, stripping insulation materials, all have environmental implications when we dispose of the wastes, the fumes, the liquids or the gases from these operations.

Some industries have a greater effect than others on the environment (see table that follows).

Examples of How Different Industries Can Affect the Environment

Industry/Process Potential Environmental Impact

Agriculture Wastes, use of pesticides, herbicides, fertilisers

Construction Dust nuisance, noise nuisance, use of raw materials, contaminated water run-off

Food production Effluent containing food solids and fats, cleaning chemicals, solid food waste, combustion gases, packaging, transport, etc.

Brick manufacture Quarrying (landscape changes, noise, dust, transport, water run-off, visual effects, loss of natural resources, etc.), manufacture (noise, dust, energy use, transport, gaseous emissions)

Metal finishing Acids, alkalis, effluent containing toxic metals, energy use, fumes, VOCs*, detergents, toxic metals, waste water, cakes or sludges contaminated with toxic metals, combustion gases from boilers, etc.

Timber Sustainability of raw materials, noise, dust, transport

Offices Use of energy including air-conditioning systems, hardwood furniture, paper use

*VOCs = Volatile Organic Compounds

(For more information on VOCs, see later in this element.)

The types and quantities of waste, waste water, energy and raw materials vary greatly from one industry to another but the principle remains the same: one ton of product can mean many tons of waste in the form of solids, liquids, gases and energy.

Releases The release of these substances can affect people outside the workplace and also affect the environment.



Intended Releases A chemical plant may have a waste water effluent treatment plant for removal of metals and pH adjustment, and a similar one for treatment of substances emitted to air, e.g. sulphur dioxide. Provided the treated effluent to water or air is within authorised limits of purity, the treated effluent at the end may then be released directly to the environment. There are many examples of processes of this type, for example: combustion of oil, coal, gas and waste treatment plants.

Pollution of this type is governed by the process of Environmental Permitting under the PPC (Pollution Prevention and Control) regime contained in the Environmental Permitting (England and Wales) Regulations 2007. The companies wishing to operate such processes need to apply to the appropriate environment agency for a permit to operate. The processes affected are described in Schedule 1 to the regulations The schedule is divided into various industrial sectors according to their potential to pollute the environment, for instance, Part A(1) A(2) or Part B processes, e.g. coating processes and printing. The permits detail the conditions and emission levels under which they are allowed to operate as well as the prescribed substances which may be released. Instances include: to air, for example, oxides of carbon, particulate matter; to water, for example, mercury and its compounds, PCBs; to land, for example, organic solvents, pesticides, organometallic compounds. The permits themselves are reviewed every four years and are also subject to change. The control mechanism used for this regime, BAT, is described later. Further legislation relating to authorisation of substances includes the Radioactive Substances Act 1993 and the Solvent Emission Directive 1999/13/EEC - requirements implemented through the PPC regime above.

Abnormal Conditions Giving Rise to Occasional Releases Abnormal conditions might lead to unintended releases to the environment or releases which are greater than normal. These might be situations where abatement controls temporarily fail or are unable to cope (say at an effluent treatment plant that receives a sudden large surge of effluent). Similar situations might occur on plant shut down, start up, decommissioning or due to some human error, as happened at Camelford, Cornwall, in 1988 where aluminium sulphate was deposited into the wrong tank.

Major Releases Following Plant Failure These are, of course, abnormal and infrequent occurrences arising as a result of some accident or dangerous occurrence – due to plant design or management failure. So, for example, an out of control reaction at a chemical plant may cause an explosion or venting of large quantities of vapour or gas into the atmosphere. Such incidents may give rise to fires, explosions leading to spillages of chemicals, radiation, etc. The COMAH Regulations require the effects of potential Major Accidents To The Environment (MATTEs) to be assessed. Quenching a large fire may allow large quantities of contaminated fire water run-off to escape to local waterways or sensitive environments, etc. There are a number of incidents of this type which have caused not only environmental problems, but also had serious health and safety implications, e.g. Bhopal, India (leak of methyl isocyanate); Chernobyl, Ukraine (radioactive release); Seveso, Italy (release of TCCD, a dioxin).

Principle of Source, Pathway, Target and Impact in Relation to Effects of Pollution Toxic substances can be released and dispersed by way of three environmental media:



• Land releases can be by way of a number of different substances ranging from non-polar organic solvents to organometallic compounds.

• Releases to the atmosphere as air pollutants can be in the form of oxides of sulphur and nitrogen. Other toxic and polluting compounds may include carbon monoxide, hydrocarbons and lead.

• Pollutants released to water are manifold and can be highly toxic in small quantities. Oils, solvents and pesticides are common examples.

The behaviour and dispersion of pollutants to water, gases to the atmosphere and toxic substances to ground all have features in common. In each case there is a man-made source of pollutant, a pathway and an environmental target upon which there is a measurable impact.

Pathways may be atmospheric by means of gaseous pollutants. They may be through water supplies by means of liquid effluent or through the medium of ground water. The targets in each case (see the figure later in this section – Source, Pathway and Target Model of Related Substances) are people in the local population, fish in the waterways as potential effluent and ground water targets. Finally, ground water pollution may have a significant effect on drinking water supplies.

Behaviour and Dispersion of Gases The way that toxic and/or flammable gases behave following a leak or spillage determines the degree to which they are dispersed into the atmosphere. This dispersion depends on a number of factors including:

• The density and temperature of the gas or vapour.

• Atmospheric conditions such as:

− Wind speed.

− Wind direction.

− Turbulence.

− Humidity.

− Air temperature.

• The quantity of material released.

• The rate of release of gas or vapour.

• The nature of the area surrounding the release, such as buildings or hills.

The quantity, rate of release and weather conditions will have a significant effect on the rate of dispersion. This will determine whether toxic substances are quickly and safely diluted or remain for some time at levels in excess of the relevant exposure limits. Similarly, there are specific explosive limits for flammable substances and the conditions present at the time of the release will determine whether the flammable gas cloud is able to reach or maintain explosive concentrations. High wind speeds will accelerate dispersion; calm, light winds will delay dispersion; temperature inversion conditions can trap the gas or vapour release and maintain significant concentrations for a considerable time. Density and temperature also influence the behaviour of the gas or vapour cloud with denser-than-air gases tending to remain at ground level and light/hot gases dispersing upwards.



Release and Dispersion of Toxic Substances To Ground Companies operate various processes under the Environmental Permitting (England and Wales) Regulations 2007. They have to comply with the conditions of their permits under the regulations, which detail the conditions and emission levels under which they may operate.

These permits are ‘live’ documents, i.e. are subject to regular review and potential change. This takes place approximately every four years, in line with the adoption of BAT (see later) and the principles of higher standards for processes and less pollution in the EU environmental policy and action plans.

In addition to prescribing processes, the Regulations also prescribe substances for release to the environment. This includes substances released to land, for example: organic solvents, azides, halogens and their covalent compounds, metal carbonyls, organometallic compounds, oxidising agents, etc.

To Water Certain pollutants are particularly harmful, for example, just 250 grams of pesticide could be enough to exceed the permitted limits in the whole of London’s water supply. Oil is another substance of particular harm, because a gallon of oil can pollute an area of water the size of two football pitches. Solvents are also very polluting substances when allowed to reach a watercourse or underground water; one litre of the common degreasant trichloroethylene could contaminate 100,000,000 litres of drinking water (the equivalent of 50 Olympic sized swimming pools).

In 2002, there were some 14,510 pollution incidents reported in England and Wales, of which 82 had a major, and 784 a significant impact. The dispersion of pollutants to water is often caused by oils and fuel or sewage. The passage of water along a waterway both spreads and dilutes a pollution event. The extent of dilution will therefore depend on the flow rate of the watercourse and on any tidal effects.

Sources of Water Pollution Water pollution is often caused by some, or all, of the following:

Point sources such as:

• Outfalls from sewage systems.

− Storm water overflows from sewage systems or combined sewers.

− Silage clamps or slurry stores on farms.

− Factory wastes, e.g. contamination deposited on drained surfaces, such as: oil, rubber, chemicals, pesticides, and mud and silt from construction.

− Wrong connections of foul or surface water drains, either by ignorance or accident; all companies should check their drain connections to ensure they are correct.

− Public ignorance of drainage systems and where they flow.

− Spillages or deliberate disposal, of oil in particular, flushed into surface water drainage systems.

− Surface water pollution caused by sudden flooding of contaminated drains/soakaways.



− Groundwater pollution from contaminated land, landfill sites or accidental spillage.

− Excess storm or fire water run-off.

• Diffuse sources, e.g.:

− Agricultural use of fertilisers and pesticides.

− Acid precipitation.

− Landfill sites and contaminated sites.

• Accidental releases, e.g.: road traffic accidents, spillage from industrial sources, ground-water pollution from mining or metal working.

• Flow reduction due to over-abstraction.

To Air Major Air Pollutants In March 1997, the UK Government published its National Air Quality Strategy (revised in 2000 and 2007). This sets air quality standards and objectives for eight priority pollutants which affect health, namely benzene, 1,3-butadiene, carbon monoxide, nitrogen dioxide, sulphur dioxide, VOCs (including formaldehyde and PAHs), hydrocarbons and lead. The following table details where common pollutants are found and what hazards they engender. Major pollutants have been assigned control limits under Part IV of the Environment Act 1995.



Common Air Pollutants

Pollutant Occurrence Health Hazard/Effects

Benzene Naturally in crude oil and forms during the upgrading of fuel oil. It is present in petrol, not in diesel.

Persistent exposure or exposure to high levels, as found in some occupational environments, may cause anaemia. It is a carcinogen, particularly linked to leukaemia.

1,3-Butadiene

Formed from olefins during the combustion of petrol and diesel fuel. Also used in the manufacture of synthetic rubber tyres.

Damages the genetic structure of cells and can cause cancer.

Carbon monoxide

Produced by the incomplete combustion of carbon-containing materials like wood, coal and oil and is a major air pollutant. The main sources which affect human health are smoking, car exhausts and unflued heating or cooking appliances.

This gas prevents the normal transport of oxygen by the blood. It can progressively lead to oxygen starvation. The escalating symptoms of carbon monoxide poisoning are headaches and vomiting and in severe cases, collapse and death, although the effects of brief exposure are reversible. Harmful exposure to carbon monoxide is most common indoors due to faulty heating equipment, blocked flues or inadequate ventilation. This can lead to a significant reduction in the supply of oxygen to the heart, particularly in people suffering from heart disease.

Carbon dioxide (CO2)

When anything organic is burned, CO2 is produced. It is one of the greenhouse gases that absorbs heat in the atmosphere, keeping the earth warm. Road vehicles produce 20% of the UK's CO2 emissions.

CO2 levels in the atmosphere are rising, causing concern about possible global warming.

Nitrogen dioxide (NO2)

Main source is the combustion of fossil fuels (along with nitrogen oxide) - road vehicles, power generation, heating plants, and industrial processes. Indoor sources are unvented gas cookers and other unflued gas appliances, paraffin stoves and cigarette smoke.

Nitrogen dioxide is highly toxic at elevated concentrations and can cause throat and eye irritation. However, it is not normally present in sufficient amounts to have serious effects. As an outdoor pollutant it is involved in photochemical smog formation.

Sulphur dioxide (SO2)

A colourless gas with a choking taste which is a harmful air contaminant and a constituent of winter smog. As it is acidic it corrodes stonework and other materials. It is produced by the burning of sulphur compounds which are a natural constituent of coal and oil.

Asthmatics and others suffering from respiratory disorders may be exposed, particularly if exercising out of doors, to levels of SO2 which might produce a feeling of tightness in the chest and some coughing.

Volatile Organic Compounds (VOCs)

Present in exhaust fumes, cigarette smoke, synthetic materials and household chemicals. VOCs are involved in the formation of ground level ozone.

Air pollution.




Formaldehyde A colourless gas emitted from foam insulation, chipboard, plywood, some fabrics, motor exhausts, bonfires and cigarettes.

Formaldehyde may cause eye, skin and throat irritation, nausea and allergic reactions. High concentrations increase the risk of lung disease, although such levels of exposure are uncommon.

PAHs Emitted from coke production, coal burning and motor vehicles. With the introduction of smoke control areas and the decline in use of coal in domestic heating, atmospheric concentrations have fallen.

Some PAHs are carcinogenic, but adverse effects are only likely in an occupational situation.

Hydrocarbons (HCs)

Compounds made of hydrogen and carbon; they are present in petrol, diesel, gas and some solvents. Road traffic is responsible for 35% of HC emissions in the UK. Of this, about ⅔ comes from vehicle exhausts as unburnt fuel and the rest from evaporation through the vehicle's fuel system, or from the distribution and sale of petrol. HCs react with NOx in sunlight to produce harmful compounds called photochemical oxidants which include peroxyacetyl nitrate (PAN) and ozone.

Can cause throat and eye irritation and damage plants. Ozone also contributes to acid rain and the greenhouse effect.

Nitrogen oxides (NOx)

Given off wherever fuel is burned. Road traffic is responsible for 46% of total UK emissions.

As well as reacting with HCs to produce photochemical pollution, NOx emissions are further oxidised in the atmosphere, contributing to acid rain. This has been responsible for increasing the acidity of soil and water in many parts of Europe, and is implicated in effects on trees and plants.

Lead For many years lead was added to petrol to improve engine performance. When petrol is burned, lead is emitted from the exhaust, and concern has focused on health effects. Lead emissions from road vehicles are falling as a result of use of unleaded petrol.

Known to be a poison which builds up in the body; may affect the development of children.

Particulate matter (PM10)

Consists of partly burned fuel. Road vehicles, especially diesel-engined vehicles, are now the largest source of smoke in the UK. Diesel exhaust is not only smelly, it also produces dirt, soiling city buildings. 26% of PM10 in the atmosphere comes from road vehicles.

Fine particles can be carried deep into the lungs where they can cause inflammation and a worsening of the condition of people with heart and lung diseases. Particulate air pollution can contribute to an increased likelihood of myocardial infarction (heart attacks), although the overall burden of this on Western society is less than that of tobacco smoking. Particle pollution can soil buildings and materials and harm health. It also contributes to poor visibility.




Radon A radioactive gas, a decay product of radium and uranium metals, which occur naturally in various rocks, notably granite. Areas such as Cornwall which are on granite have unusually high radon levels but it presents no risk in open air because it disperses. DEFRA has issued guidance to householders on whether precautions are necessary as it may percolate through wooden floors and concrete screeded floors, and accumulate in living areas. Will disperse where good ventilation exists.

Inhalation of radon gives a risk of lung cancer which is in proportion to its concentration and time exposure. Particularly likely in smokers.

Dispersion of Air Pollutants The same principles apply to air dispersion as to other forms of pollutant spread, as illustrated by the diagrams below.

Source, Pathway and Target Model of Released Substances, after HMSO Released Substances 1996

Emissions to air are illustrated in the following diagram which also shows the principal types of air emission, i.e. continuous, discrete and fugitive sources.




Emissions to Air

In order to define a discharge to the environment, the following should be taken into account and included in any emission inventory:

• The mass discharge rate of the pollutant gas.

• Volume flow of the gas based on stack diameter and efflux velocity.

• Temperature at release.

• Whether the release is continuous or intermittent.

• Height of the release.

• Location of the release relative to the environment, i.e. proximity to hills, buildings, other pollution sources and potential targets.

• Presence of any fugitive emissions (e.g. from pipework or flanges).

Environmental Impacts The term environmental impact is to be found in environmental management systems and in other legal requirements such as the Town and Country Planning (Environmental Impact Assessment) Regulations 1999.

BS EN ISO 14001: 2004 – “Environmental Management Systems” defines an environmental impact as:

“…any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation’s environmental aspects.”

An environmental aspect is defined as:

“… an element of an organisation’s activities or products or services that can interact with the environment.”

Examples of environmental impacts may be pollution of land, air pollution and consequent health issues or traffic nuisance. These impacts may be local, regional or even global.

Buoyant rise

Continuous

Fugitive

Discrete

Sources Pathway Target


Examples of Environmental Hazards The following are very different types of environmental hazards, e.g.:

• Release of environmentally harmful gases, such as chlorofluorocarbons (CFCs).

• Fires and explosions.

• Spills of chemicals.

• Dry weather leading to lower river flows.

• Planting a crop of genetically modified organisms.

• Depositing a harmful substance on the land.

• Past uses of a site.

• Lack of control systems or training.

Hazards which impinge directly on the environment, for example, emissions to air, discharges to water, and waste disposal may additionally cause harm to the health and safety of people outside the workplace, e.g. Minimata Bay, Japan in 1952 - dumping mercury catalysts into the bay. The strong correlation between health and safety and environment continues when considering environmental hazards. There is such a strong correlation between health and safety and environment that some areas of physical, chemical or biological hazards and risks are jointly administered in a single Competent Authority. There is a joint arrangement between the Health and Safety Executive (HSE) and the Environment Agency, as in the Control of Major Accident Hazards Regulations 1999 (COMAH).

The environmental media are air, water and land and they are interconnected within and by the Earth’s natural cycles, of which humans are a part. It is often difficult to separate environmental effects according to the different media which are affected by a particular pollutant release, a fact acknowledged by the modern concept of Integrated Pollution Prevention and Control (discussed later in this element).

The following are examples where releases of hazardous substances could cause harm directly to the health and safety of people outside the workplace:

• Releases of pollutants to watercourses could affect recreational users or prevent its use as drinking water.

• Releases from Local Exhaust Ventilation systems could affect neighbours and neighbouring property.

• Chimney emissions could affect a wide swathe of the locality.

• Uncontrolled waste disposal could cause land or water pollution or pollute the groundwater.

• Discharge of pollutants to land could pollute groundwater which is used for drinking or cause harm to people using the land by virtue of its chemical or physical properties.

These effects can be short or long term; they could affect wide areas and whole populations, a fact that can be demonstrated by using as examples key environmental disasters caused by uncontrolled releases from industrial plants (see earlier in this element).

Components that Affect the Atmosphere The deterioration of the environment has been the result of a variety of human developments such as industrialisation, urbanisation, and population growth. The public perceives industry



as a major polluter. Pollution effects are not just limited to industrial activities, however. In Northern Europe, for example, one of the most damaging pollutants affecting air quality results from the use of private cars. The principal components that have a significant effect on the environment are:

• Sulphur Dioxide

The major source is the combustion of fossil fuels containing sulphur, mainly coal and fuel oil. Natural gas and petrol have much lower sulphur contents.

• Particulate Matter

Particulate air pollutants are very diverse in character. They can be organic or inorganic, soluble or insoluble with diameters ranging from 0.01 to 100μm. The majority of particulate matter (by weight) exists in the range 0.1-10μm (PM10) but the main causes for concern are particulates below this upper range because of their ability to enter the lungs.

In the UK, the main sources of particulate matter are internal combustion engines, processing plants and fuel combustion.

• Oxides of Nitrogen

The major source of NOx is the high temperature reaction of atmospheric nitrogen and oxygen in combustion processes. Power stations and road transport are the main sectors for this type of pollution. Nitric oxide and nitrogen dioxide are significant in the formation of ozone in lower parts of the atmosphere. Here ozone is harmful to health, as opposed to stratospheric ozone, which protects us from the sun’s ultraviolet radiation.

• Oxides of Carbon

Carbon monoxide is associated with petrol engines. Most other combustion processes are more efficient and cause little CO emission.

• Volatile Organic Compounds (VOCs)

‘Volatile Organic Compound’ is a general term, covering any organic compound that is gas at normal temperature and pressure. It covers hydrocarbons and compounds also containing other elements such as oxygen, nitrogen, and chlorine.

Water and Land Pollution Water Pollution Water pollution is the reduction in quality of rivers, lakes, streams, and oceans by the introduction of chemical, physical, or biological pollutants. These can include:

• Waste

This includes: industrial effluents, domestic and agricultural sewage, radioactive discharge, and thermal pollution.

• Urban Run-Off

The discharge of storm water drains directly to watercourses.

• Agricultural Run-Off

Fertilisers, pesticides and weedkillers.



• Oil Spills

These can be locally from a company’s operation into a stream or through accidental or deliberate discharge into the sea.

• Acid Precipitation

Rainfall polluted by contaminants in the atmosphere and subsequently deposited in lakes may cause acidification of the body of water and is an example of the movement of pollution from one medium to another.

Land Pollution Land, like water and air, is vulnerable to pollution from a range of sources:

• Atmospheric Deposition

Deposition of radionuclides (as happened in the Chernobyl disaster) can lead to extensive soil contamination and the precipitation of acidic pollutants can result in acidification of soils.

• Waste and Spills

Hazardous waste buried in landfill, fly-tipped or buried on company premises, as well as spills and leaks associated with company activities, are frequent causes of land contamination.

• Agricultural Practices

Soil contamination is an accepted but undesirable consequence of the application of pesticides.

Global Impacts Examples of global impacts include:

• Emissions of carbon dioxide (and other greenhouse gases), contributing to the greenhouse effect, global warming, and climatic changes.

• Man-made halocarbons (CFCs, tetrachloromethane, 1.1.1-trichloroethane, hydrofluorocarbons (HCFCs), halons and methyl bromide), contributing to stratospheric ozone depletion.

• Use of hazardous substances that have persistent toxicity (mercury, DDT, polychlorinated biphenyls (PCBs), dioxins and furans), contributing to their accumulation in living organisms and toxicity to both man and ecosystems.

• Consumption of non-renewable resources (e.g. metals and fossil fuels), contributing to resource depletion, and the economic and social issues associated with this.

Regional Impacts Damage to Forests and Other Vegetation This is caused by:

• Emissions of sulphur dioxide, oxides of nitrogen and ammonia, which attack leaves and acidify the soil.

• Emissions of organic compounds that lead to the formation of ozone and other reactive compounds.



Damage to Lakes and Coastal Waters This can result from excessive deposition of water-borne or airborne substances containing nitrogen and phosphorus. Many Scandinavian lakes have been acidified as a consequence of airborne pollution.

Persistent Toxicity Examples include:

• Agricultural pesticides have found their way into drinking water from pollution of groundwater.

• Industrial chemicals or their degradation products with a variety of actions such as oestrogen-like effects, increase frequencies of allergy and the risk of cancer and decrease reproductive capacity.

Local Impacts Examples of local impacts include:

• Physical impacts such as soil erosion, loss of arable land, flooding due to reduced drainage capacity of rivers and watercourses, loss of aesthetic qualities and cultural assets.

• Consumption of renewable resources at a higher rate than production (for instance, depletion of fish populations, regeneration of forests lacking the same biodiversity, and impoverishment of the soil with intense agricultural practices).

Managing the Impact Whether pollution results from routine processes or indeed accidents, it is inevitable that other impacts may also be caused, such as human health effects and financial costs.

All these impacts can be managed by understanding the environmental risks associated with our activities and implementing control mechanisms to eliminate or minimise those risks. In the following sections we will look at various systems and procedures to identify, evaluate and control environmental impacts from operations.

Pollution Control Strategies The importance of an environmental control strategy is to identify, prioritise and reduce the liabilities arising from the environmental issues. In order to do this, the issues must be understood and their importance to the business recognised.

Prevent Waste prevention employs various strategies which revolve around the basic principle of not making waste in the first place, i.e. preventing waste being produced by eliminating certain material from the waste stream.

Minimise When designing waste minimisation programmes for industry, all types and forms of waste are considered. Whichever wastes are considered - solid, liquid or gases - certain principles apply. The wastes collected are then disposed of either by landfill, incineration or other disposal routes.

There has to be an emphasis on reducing the total amount of waste in all waste streams, at plants, within companies, nationally and internationally. The basic principles of waste



management may be summarised below. These principles are occasionally referred to as the 4R rule, which stands for Reduce, Re-use, Recycle and Responsibly dispose.

The generation of waste is counter-productive and is often the result of inadequate planning, processes control or operational management. One of the objectives of quality control and loss control is to manage the manufacturing process to make the most effective use of raw materials and energy and reduce the number of wasted or rejected finished products. In many cases, waste reduction has achieved results with very little capital expenditure.

Waste minimisation has been recognised as an important financial management concept in industry for several years. The need to improve environmental performance to achieve legal compliance and the inability of end-of-pipe technology to achieve the reduction in emission levels necessary to meet tightening standards has re-focused attention on this issue. In 1992, the Centre for Exploitation of Science and Technology (CEST) designed a waste minimisation project based on the catchment areas of the Aire and Calder Rivers in West Yorkshire. The project was called the “Aire and Calder Project” and it was sponsored by BOC Foundation for the Environment, the former HMIP (Her Majesty’s Inspectorate of Pollution), the former NRA (National Rivers Authority) and Yorkshire Water. CEST summarised the achievements of the project as follows:

“Reduction in pollution and improvements in profitability are not mutually exclusive. In the first 18 months of a project established to demonstrate the benefits of waste minimisation and cleaner technology, eleven participating companies made savings of over £2 million a year. Further savings of a similar magnitude are possible in subsequent years. Reductions in the use of inputs such as water, energy and raw materials exceeded savings in effluent production by a significant margin, thereby confirming that companies can profit from cleaner production through improved process efficiency.”

Just over 10% of the measures to reduce waste were cost neutral and a further 60% had a payback of less than one year. Indeed, only 10% had a payback of over two years. The financial benefit from this approach is so substantial that all companies should have no difficulty in implementing programmes on their own initiative. However, there are additional benefits in club type projects and companies may consider it worthwhile joining, either locally or in supply chain relationships.

Waste minimisation projects require a detailed analysis of the process and the waste products, but the results will almost certainly repay the effort expended, for example, the recovery and recycling of packaging waste is governed by the Producer Responsibility Obligations (Packaging Waste) Regulations 2007.

Most organisations keep their water use under constant review under their waste minimisation programmes and many good examples can be found. Water use will also be part of the PPC Permit.




Matters

Which Should Be Investigated As Part of a Waste Minimisation Project

The Environmental Technology Best Practice Programme (ETBPP) also has many examples of water minimisation taken from different industries.

Render Harmless A number of options are available for rendering harmless certain substances for particular industries, skilled trades and the general public. These include: recycling, neutralisation, controlled discharge, incineration and water purification.

Pollution Control Methods Pollution refers to contamination or damage to the environment caused by human activity. We can identify three broad classes of pollution:

• Atmospheric pollution – fumes, smoke and dust discharged into the air from incinerators, traffic exhausts or other by-products of industrial processes.

• Water pollution – liquid waste (effluent) comprising toxic substances such as detergents discharged into ground water, rivers or sea-water directly from sewers, factories or surrounding land, such as fertilisers being washed away from farm land by the rain.

• Land pollution – solid waste from industrial processes deposited on land.

Control of Atmospheric Pollution Control of atmospheric pollution is achieved by a system of permits or consents from government agencies. This is backed up with regular atmospheric monitoring of the stack. To be within permitted emission limits usually requires some form of abatement technology, such as scrubbers. The available techniques need to be balanced against the cost involved. What is appropriate is considered in the light of the nature of the industry and the desired level of environmental protection.

PROCESS

Wastes

Effluent

Raw Materials

Ancillaries and Consumables

Air Emissions Energy (heat, noise)

Solids Liquids

Water

Energy

Packaging

Product

An Improvement in any of these indicates waste minimisation

Transport

Packaging


Disposal of Waste and Effluent The general approach to waste disposal should take account of a hierarchy of waste management options:

• Waste reduction – the primary emphasis should be on not producing waste in the first place, by process change and optimising process efficiency.

• Reuse – for example, returnable glass bottles.

• Recovery of waste – including recycling (such as glass, metal and paper), composting and incineration with energy recovery.

• Disposal – generally to landfill.

The keeping, treatment or disposal of solid waste is regulated, and requires the waste operator to be permitted to operate.

Control over water pollution is based on a system of water discharge permits or consents, obtained from the relevant government agency. These apply in respect of any discharge of trade effluent or sewerage effluent into controlled waters. Controlled waters cover, essentially, all moving water, including inland and underground waters and estuaries, as well as the actual river bed and, in certain circumstances, territorial and coastal waters. Again, regular monitoring may be required to ensure that the discharge consent is not exceeded.

Need for Continuous and Grab Sampling and Measurement Against Set Standards There are a number of monitoring techniques available to monitor environmental quality (for example, of air or water).

Technical Guidance Notes (Environmental Monitoring) These provide information on subjects related to the Environmental Permitting (England and Wales) Regulations 2007 and to the Radioactive Substances Act 1993. They are applicable across a wide range of processes and activities, and are grouped and numbered according to subject. They are available from the Stationery Office. Series designator letters are:

• A − Abatement.

• D − Dispersion.

• M − Monitoring.

Monitoring and Control Monitoring is not a control method. It is a means of demonstrating control and of enabling failures to be recognised.

Many companies discharge a trade effluent to the sewer or to surface water. The regulatory agencies may check these from time to time, but the checks cannot be considered to be a control method by the company producing the effluent, since the results will only confirm something that happened perhaps several days or even weeks before. Reliance on them for confirmation of day-to-day controls is not a valid method of ensuring that there are no compliance failures.



Monitoring Techniques These include:

• Routine visual inspection.

• Instrumental monitoring.

Techniques available for instrumental monitoring include: continuous measurement, and grab or spot testing.

The type of monitoring required will depend on the level of risk. A large incinerator, for example, will have continuous monitoring (of which there is a permanent record), whereas a chimney stack where there is a low risk may only require monitoring on an annual basis. Similar factors apply to water discharges.

Some of these techniques are most appropriately used in environmental testing where the exact method may be specified in consents or licences, often with reference to a standard which specifies precisely how the tests are to be carried out, e.g. “Sampling for particulates will be carried out isokinetically (i.e. at the same linear flow velocity) in accordance with the principles of BS 3405: 1983 − Measurement of Particulate Emission including Grit and Dust (simplified method).” There are standard methods for most parameters which are measured on a regular basis. Most licences, authorisations and permits require, in addition, that the results of the monitoring or testing are submitted to the regulatory authorities, who have additional powers to require information, or to have works done or even, in extreme circumstances, to do work themselves and recoup the costs from the company.

Sampling Techniques The first task in monitoring is to collect the sample, e.g. air, water, gas, so that it may be analysed. There are a number of considerations here, with the decision of the approach to be used depending on the risk level of the contaminant being assessed.

• Location of the Sample

Samples may be taken in the general working atmosphere, or at a position close to the contaminant generation.

• Method of Analysis

The procedure may involve sampling and analysis in the same instrument, or taking the sample collected and analysing it using different equipment, perhaps in a laboratory away from the point of collection.

• Duration of the Sampling

There are three approaches to this:

− A spot or grab sample, which is a single sample collected instantaneously at a particular location or in a limited area, and is representative only of that location or area at that point in time. Such samples may be analysed on the spot by the same instrument or be taken away for subsequent laboratory analysis. To obtain time-averaged levels, a series of spot samples may be taken over the period in question, but this is not necessarily accurate.

− A better method of obtaining a time-weighted average is by collecting a sample over a period and then analysing it.



− A continuous monitored sample – where a sample is collected continuously over a period of time. In this case, the sample will be analysed during the monitoring, either by the sampling instrument itself or by direct connection to another instrument which carries out the analysis continuously.

• Frequency of the Sampling

The frequency with which spot samples are collected will depend on the type of contaminant and/or the results of the last sample. So, for example, if an initial sample was borderline, further samples may be taken very frequently until a satisfactory reading is obtained. On the other hand, if the initial sample showed that the atmosphere was safe, no further readings would be necessary for a considerable period.

To obtain time-averaged levels, either a series of spot samples may be taken over the period in question or spot readings may be taken from a continuous sample.

Monitoring of Waste Management Sites for Leachate and Landfill Gas A programme for monitoring of landfill sites must be established. Monitoring should be continued until the concentration of landfill gas is less than 1% by volume or there is a 95% confidence level that all the biodegradable matter has been used up.

Several methods are available and may be used at different times and in different circumstances; e.g. surface monitoring, subsurface monitoring (gas probes), excavated pits, gas monitoring boreholes or gas wells, and leachate wells.

Other monitoring should also take place including groundwater and the integrity of the liner (where appropriate), and records kept. In general, this will be a condition of the landfill licence.

Monitoring Equipment All measurements should be made by trained operators.

• Catalytic Oxidation Detectors

These detect low concentrations of flammable gases as a percentage of the Lower Explosive Limit (LEL) of the gas.

• Thermal Conductivity Detectors

These measure the total concentration of all flammable gases and carbon dioxide by comparing the thermal conductivity of the sample against an internal electronic standard representing normal atmospheric air. They may be combined in a single instrument.

• Infra-Red Analysers

These can also be used to measure specific gases in the mixture.

• Gas Chromatography

This is probably the most reliable method for analysing landfill gas, and is often installed permanently. It is often used in field laboratories.

• Flame Ionisation Detectors

These can detect any flammable gas. They should not be used where flammable gas is in excess of 1% by volume (20% of the LEL).



• Gas Indicator Tubes

These may be useful to indicate the components in a gas mixture. The gas is drawn through a tube containing a reagent which reacts, giving a colour change, with the amount of colour change depending on the concentration of the gas.

• Carbon Dioxide Monitors

Carbon dioxide may be monitored by a number of methods − infra-red analysers, thermal conductivity meters and gas indicator tubes.

Similar techniques are used for waste water and stack emissions but measured against different standard.

Monitoring Standards General monitoring and reporting provisions for emissions to all environmental media are provided, for example: monitoring methodologies, frequency of monitoring, compliance assessment criteria and environmental monitoring. The Environment Agency is a useful source of further information. (See: www.environment-agency.gov.uk)

A Monitoring Certification Scheme (MCERTS) to improve the quality of monitoring data, and to ensure that the instrumentation and methodologies employed for monitoring are fit for purpose has been introduced by the Environment Agency. The list of such MCERTS equipment is available.

The analytical methods given should normally be used. However, if other substances need to be monitored, standards should normally be used in an order of priority: e.g. Comité Européen de Normalisation (CEN), International Standardisation Organisation (ISO), British Standards Institution (BSI), etc.

Additional guidance on standards for monitoring gaseous releases relevant to PPC (see later) is given in the ‘M’ series of Technical Guidance Notes; available from the Environment Agency. It specifies manual methods of sampling and analysis, which will also be suitable for calibration of continuous emission monitoring instruments.

Need to Keep the Regulatory and Local Authorities Informed of Environmental Performance Development and Scope of Public Registers The necessity for the information to be provided to the public authorities and for the public authorities to provide information is written into several statutes. The requirement was part of the EPA 1990, IPC and LAAPC (Local Authority Air Pollution Control) requirements (Sections 20-22) and is now part of the Environmental Permitting (England and Wales) Regulations 2007.

The Regulations state that the following information shall be put on the register:

• Documentation relating to the applications.

• Copy of the advertisement relating to the applications.

• Permits and conditions.

• Documentation relating to any notices.

• Any appeals.

• Any convictions.



• Monitoring data.

• Landfill closure notices

• Reports from the regulator about the consequences of the process in the particular locality.

• Directions from the Secretary of State.

Removing information from the Register covers:

• Withdrawal of an application.

• If process ceases to be prescribed due to a change in the regulations.

• Monitoring information after four years.

• Information relating to a process which has been superseded.

Applicants may request that certain information be excluded on the grounds of commercial confidentiality, and the regulator has 28 days in which to determine the request. If he fails to do so in that period, it is deemed not to be commercially confidential, but will not be entered on the public register for 21 days following notification to the applicant, who has a right of appeal during that period. Any requests for exclusion on the grounds of national security are determined by the Secretary of State.

Other Public Registers There are also public registers of registered waste carriers and brokers, waste management licences, public registers of notifications made under the Genetically Modified Organisms (Contained Use) Regulations 2000, registers of consented discharges to watercourses and trade effluent, registers of actions to be taken in the case of an accident at a COMAH site, and registers of works in relation to contaminated land.

Development of the Pollution Inventory A number of legislative provisions, in particular the European Pollutant Release and Transfer Register Regulation, require reporting of emissions to the Environment agency pollution inventory. All permits contain a condition requiring operators of processes to provide annual reports to the Environment Agency of releases of 183 specified substances. The reporting date is 31st January each year and covers the preceding year. The data thus collected forms the basis of the Agency’s pollution database. This replaces the Chemical Release Inventory which was established under the former HMIP. Data is also collected by the local authorities on processes which they control.

As releases of substances included in the inventory must be reported to the Agency on an annual basis, the latest data will refer to the last reported year. The Environment Agency site has been enhanced with detailed information on all pollutants emitted to air, water and land. Entries may be found on the “Pollution Inventory” pages of the EA website (www.environment-agency.gov.uk). There are 183 potentially hazardous substances listed and each has an associated fact sheet giving contextual information about the substances. Fact sheets have been available since 1st April 2003.

Reporting to the Pollution Inventory

Companies can provide information to the Pollution Inventory electronically or by completion of a set of forms. Very detailed information is required.



Environment and Safety Information Act 1988 This Act requires safety and environmental authorities (such as Fire Authorities, Environment Agency, HSE, Local Authority) to set up public registers of the enforcement notices they serve on factories, shops and other premises where public hazards or breaches of safety or environmental laws have happened.

It requires authorities to:

• Maintain a register of relevant notices served.

• Convey the substance of the notice in each entry to which it relates.

• Ensure that the register is adequately indexed.

• Ensure that both the register and index are open to inspection by the public free of charge at all reasonable hours.

• On request, and on payment of a reasonable fee, supply a copy to any person inspecting the register.

Separate registers may be kept to cover different areas.

Environmental Information Regulations 2004 These Regulations implement Council Directive 2003/4/EC on public access to information on the environment. They require a public authority who holds any information to which these Regulations apply to make that information available to every person who requests it and to give advice and assistance. Information must progressively be made available by electronic means. There is provision for a reasonable charge to be made to cover the costs of providing the information.

The Regulations apply where the information requested is not the subject of other statutory disclosure obligations. Specific details:

• Regulations apply to:

− All Ministers of the Crown, government departments, local authorities and other national, regional or local public administration bodies that have responsibilities in relation to the environment.

− Anybody with public responsibilities for the environment not covered by the previous paragraph but under the control of a person falling within that paragraph.

• Information includes anything contained in any records.

• Records include registers, reports and returns, as well as computer records and any other records.

• Statutory provision means any provision made by or under any enactment.

There are a number of significant exemptions including: security and defence, commercial confidentiality, intellectual property.

Freedom of Information Act 2000 (Scotland 2002) Full implementation of this Act took place on 1st January 2005. It extends the right to official information at Central and Local Government levels and covers many areas besides environment.

Appeals are heard by an Information Commissioner, although decisions about whether it is in the public interest are taken by Government Ministers.



Schedule 1 to the Regulations lists the bodies to which the Act applies, including the House of Lords, House of Commons, National Assembly of Wales, Scottish public authorities, conservation and regulatory bodies, etc. Bodies to which the Act applies have to set out a “Publications Scheme”, setting out what they will make publicly available.

Definitions Integrated Pollution Prevention and Control (IPPC) Background to IPPC The European Council adopted directive 96/61 on Integrated Pollution Prevention and Control (“the IPPC Directive”) in September 1996. The Directive is derived in a large measure from Integrated Pollution Control (IPC) established under Part I of the Environment Protection Act 1990, although there are some important differences. In the UK, the directive was implemented through regulations known as the Pollution Prevention and Control Regulations 2000. These regulations have now, however, been replaced in England and Wales by the Environmental Permitting (England and Wales) Regulations 2007. These new regulations do not alter the regime or impose any new standards they purely serve to consolidate many permitting requirements under one set of regulations. In Scotland the Pollution Prevention and Control Regulations continue to apply. The regime, however, continues to be referred to as the ‘PPC regime’.

The PPC regime:

• Applies PPC concepts such as “Best Available Techniques” (information on BAT follows) to all installations covered by the regime.

The Environmental Permitting (England and Wales) Regulations 2007 and Pollution Prevention and Control (Scotland) Regulations 2000 (The PPC Regime) The PPC Regime requires industry to prevent or, where that is not possible, to reduce pollution from a range of industrial and other installations, by means of an integrated permitting process based on the application of “best available techniques”. The new permit process takes a wide range of environmental impacts into account:

• Emissions of pollutants to air, water and land.

• Energy efficiency; waste management.

• Consumption of raw materials.

• Noise and vibration.

• Site restoration and decommissioning.

In order to satisfy this condition, a Site Condition Report has to be prepared, giving the condition of the site at the time the Permit was issued. Site must be returned to this condition after the plant has closed.

Permits must take into account local environmental conditions at the site concerned, its technical characteristics and its geographical location. Conditions must be included to address any transboundary pollution from an installation.



New Installations The original Directive’s requirements applied to new installations immediately, and to parts of existing installations which undergo a “substantial change”. Existing installations, insofar as they were not substantially changed, enjoyed a grace period of up to seven years following transposition, during which they must be upgraded to meet the new requirements. All installations are however now permitted and, in England and Wales, are undergoing transition from being permitted under the Pollution Prevention and Control Regulations to the Environmental Permitting Regulations. Once issued, a permit will be reviewed periodically, and will be upgraded if there are significant technological or other developments. The timetable for each process application is published in Schedule 3 to the regulations.

PPC is More Than Pollution Control PPC seeks to regulate almost all of the environmental impact of the operation of an installation, for example:

• Contaminated land.

• Energy efficiency.

• Noise, vibration and raw materials consumption.

• Accident prevention (COMAH and PPC data can be used to satisfy both requirements).

• Environmental Impact Assessment (a number of the installations require an environmental impact assessment before consent for development is given. It is suggested that under certain circumstances there may be benefit in running the two procedures together).

• Waste.

Best Practicable Environmental Option (BPEO) Under the Environmental Protection Act 1990 (EPA), Part 1, Section 6, certain processes required Authorisation in order that they could operate or continue to operate (in the case of existing processes). The EPA introduced two parallel regulatory control regimes. Details of the processes concerned were set out in the Environmental Protection (Prescribed Processes and Substances) Regulations 1991, as amended. Processes were designated Part A and Part B. Guidance (actually to the enforcing authorities) gave details of the performance requirements expected of each process in terms of emissions and other factors. Certain risk control strategies were incorporated within this legislation. These are respectively BPEO (Best Practicable Environmental Option) and BATNEEC (Best Available Techniques Not Entailing Excessive Cost). The more complex processes involved with potential releases to more than one environmental medium (designated Part A) required both a BPEO assessment and were required to work to BATNEEC, whereas all other processes were required to work to BATNEEC only. Where there are releases to more than one environmental medium in the process, the test of BPEO applied. Under the Pollution Prevention and Control Act 1999 and Regulations 2000, and the Environmental Permitting (England and Wales) Regulations the concept of BATNEEC and BPEO has been extended to purely BAT (Best Available Techniques).

Best Available Techniques (BAT) Best means the most effective and advanced stage in the development of activities and their methods of operation which indicates the practical suitability of particular techniques for providing in principle the basis for emission limit values designed to prevent and, where this is



not practicable, generally to reduce emissions and the impact upon the environment as a whole.

Available techniques means techniques which have been developed on a scale which allows them to be used in the relevant industrial sector, under economically and technically viable conditions, taking into account the costs and advantages, whether or not the techniques are used or produced inside the member state in question, as long as they are reasonably accessible to the operator.

Techniques include both the technology and the way the installation is designed, operated and decommissioned.

Role of the Environment Agency/Scottish Environment Protection Agency The Environment Agency (EA) and Scottish Environment Protection Agency (SEPA) are the principal enforcement agencies.

The Environment Act 1995 brought into being the Environment Agency and Scottish Environment Protection Agency (SEPA) in April 1996.

The Environment Agency operates in England and Wales and brings together the former National Rivers Authority (NRA), Her Majesty’s Inspectorate of Pollution (HMIP) and the Waste Regulation Authorities (WRA). SEPA is the Scottish equivalent.

Environment Agency The Environment Agency (EA) is charged with protecting and enhancing the environment and contributing towards attaining the objective of achieving sustainable development. It mainly aims to:

• Achieve major and continuous improvements in the quality of air, land and water.

• Encourage the conservation of natural resources, animals and plants.

• Make the most of pollution control and river-basin management.

• Provide effective defence and warning systems to protect people and property against flooding from rivers and the sea.

• Reduce the amount of waste by encouraging people to reuse and recycle their waste.

• Improve standards of waste disposal.

• Manage water resources to achieve the proper balance between the country’s needs and the environment.

• Work with other organisations to reclaim contaminated land.

• Improve and develop salmon and freshwater fisheries.

• Conserve and improve river navigation.

• Tell people about environmental issues by educating and informing.

• Set priorities and work out solutions that society can afford.

To achieve these aims, it must adopt an integrated approach and work with relevant bodies and the public at large. Section 4 of the Environment Act 1995 details how this should be



done. It must also further the conservation and enhancement of natural beauty, flora and fauna. According to its own literature:

“By combining the regulation of land, air and water, the Agency offers a comprehensive approach to environmental protection and improvement (in England and Wales). This is achieved with an emphasis on prevention and education and on vigorous enforcement where necessary.”

More specifically the EA has pollution control responsibilities as follows:

• Authorising emissions, discharges and disposals to the various media by licensing, monitoring compliance and taking enforcement action.

• Waste management licensing and regulation, including special and radioactive wastes and also import/export of waste. It must assess waste disposal needs and offer technical guidance on waste management.

• Regulating and reporting on contaminated land.

• Advising government in setting environmental quality objectives (EQOs).

• Advising industry and others on best environmental practice.

The Agency also has an administrative and consultative role. It must set up and consult:

• Regional Environment Protection Advisory Committees.

• Regional and Local Fisheries Advisory Committees.

• Regional Flood Defence Committees.

It must also set up registration and exemption schemes for producer responsibility (e.g. packaging).

It must consult with the Joint Nature Conservation Committee about SSSIs (Sites of Special Scientific Interest) and other relevant bodies in respect of issuing discharge consents and other relevant decisions.

The Chief Executive and Directors are based in the head office in Bristol with supporting offices in London. They manage the overall business and put new laws into practice to make sure the environment benefits. They make decisions and manage the areas to make sure the needs of the local community are met.

The Agency has seven regional offices, over 20 area offices and one in Cardiff representing Environment Agency Wales. This allows a quick response to incidents and emergencies across England and Wales and provides a local service.

The duties of the agencies may be summarised as:

• To enforce relevant legislation, i.e. to be responsible for authorisations, licences and consents, and for monitoring compliance. An enforcing officer will be responsible only for enforcing specific legislation, not all legislation.

• To monitor environmental conditions and publish statistics.

• To advise government in setting environmental quality standards and for proposals for pollution prevention measures.

• To provide advice and guidance on best environmental practice.

• To respond to complaints from the public concerning environmental pollution and nuisance.



Scottish Environment Protection Agency The main aim of SEPA is to improve the environment and contribute towards the achievement of sustainable development. Other important aims include:

• Providing an excellent environmental service for Scotland.

• Improving sustainable use of natural resources.

• Maintaining and restoring good quality environments for: water, air and land.

• Promoting respect for the environment.

SEPA regulates:

• Activities that may pollute water and air.

• Waste issues.

• Disposal and retention of radioactive materials.

For further information on SEPA, see the website: www.sepa.org.uk.




Revision Questions

1. Explain BAT.

2. Define ‘environmental impacts’.

3. What pollution control responsibilities do the environmental agencies have?

4. What types of pollution can be prevalent in drinking water?

5. Explain the difference between spot or grab and continuous sampling.

6. What standards are used in monitoring environmental performance?

7. What information is required to be put on public registers by the Environmental Permitting (England and Wales) Regulations 2007.

(Suggested Answers are at the end of Unit C.)

?


CLASSIFICATION OF WASTES Definitions Solids, Liquids and Gases There are many types of solid, liquid and gaseous waste, such as:

• Solids

Residues from incineration and from household waste.

• Liquids

Effluent from chemical processes activities and from water treatment works.

• Gases

Sulphur dioxide and nitrogen oxides.

Hazardous and Non-Hazardous Wastes are defined as hazardous if, for example, they are highly flammable, harmful, toxic, carcinogenic or corrosive. The definition includes many household products such as: fridges, freezers and televisions, fluorescent light tubes and computer screens, and printer toner cartridges. Hazardous wastes include those from:

• Industrial chemical processes.

• Oil refining.

• Metals processes.

• Nuclear industry.

They also include:

• Solvents.

• Waste oils.

• Some clinical waste.

• Asbestos.

Non-hazardous waste means waste that is not covered by the above, including: household waste, paper, wood and other degradable waste.

Difficult Waste Difficult waste is a term frequently encountered when discussing waste management options, but it has no legal status. It is taken to mean waste which is difficult to handle, usually in the context of a waste treatment or management facility. It includes: wet sludges, liquids or dusty materials.

Flammable Waste Annex 111 of the EC Directive 91/689 on Hazardous Waste describes flammable waste as: liquid substances and preparations having a flash point equal to or greater than 21° C and less than or equal to 55° C.



Clinical Waste Clinical waste is defined in the Controlled Waste Regulations 1992, as amended, as:

“any waste which consists wholly or partially of human or animal tissue, blood or other bodily fluids, excretions, drugs, pharmaceutical products, swabs, dressings, or syringes, needles or other sharp instruments which, unless rendered safe, may prove hazardous to any person coming into contact with it”

and

“any other waste arising from medical, nursing, dental, veterinary, pharmaceutical, or similar practice, investigation, treatment, care, teaching or research, or the collection of blood for transfusion, being waste which may cause infection to any person coming into contact with it.”

There are specific joint HSC (“Health and Safety Commission”, merged with the HSE in 2008)/Environment Agency Guidelines published on the Safe Disposal of Clinical Waste, which is a Code of Practice for all those managing and working with clinical waste. Requirements include hygiene, training and waste segregation, including a colour coding for the different categories of clinical waste, some of which demand incineration.

Clinical waste is subdivided into groups reflecting the means of disposal:

• Group A:

− Soiled surgical dressings, etc.

− Material other than linen from infectious disease cases.

− Human and animal tissues and carcasses and dressings, etc.

• Group B: sharps.

• Group C: laboratory and post-mortem waste.

• Group D: pharmaceutical and chemical waste.

• Group E: used disposable bedpan liners, incontinence sheets, etc.

Clinical waste should be segregated from general waste in order to reduce the amount as far as possible. Separate bins, signage and training should be provided to encourage this.

• Group A waste should be put into heavy-duty yellow bags (⅔ full) and securely fastened.

• Sharps should go into properly designed sharps containers.

• Group C waste should be separately labelled, stored and transported with due respect for the nature of the contents. Laboratory material where risk of pathogens is high should be autoclaved before being included with other clinical waste.

All the above will need to be stored and should either be kept refrigerated or the storage time kept to one-week maximum; ultimately to be incinerated in an approved facility.

• Group D waste will need to be handled separately because it must be incinerated under conditions to ensure complete and rapid destruction in such a way that vapours are not released.

• Group E is of large bulk and low hazard and may be sent to landfill.



Biodegradable Waste Biodegradable waste is that which can undergo bacterial decomposition. Under the Landfill Directive biodegradable waste is “waste from households or other similar waste which is capable of undergoing anaerobic or aerobic decomposition”.

Radioactive Waste A radioactive substance is defined as “any substance which contains one or more radionuclides whose activity cannot be disregarded for the purposes of radiation protection".

Radioactive waste requires authorisation from the Environment Agency before such materials are accumulated or disposed of.

Wastes can, of course, be covered by more than one definition; some definitions are concerned with the point of arising or with physical properties.

Waste According to the Environmental Permitting (England and Wales) Regulations 2007 waste is called ‘Directive Waste’ (from the EU Waste Framework Directive) and is defined in terms of any substance or object in the categories set out in the schedules thereto and also Schedule 22 of the Environment Act 1995.

The Waste Management Duty of Care Code of Practice describes it as being defined from the point of view of the person discarding it. Waste is defined as any substance or object which the producer or the person in possession of it discards, or intends or is required to discard (Council Directive 75.442 EEC, as amended by Directives 91/156/EEC and 91/689/EEC). In this definition, the “producer" is anyone whose activities produce waste or who carries out reprocessing, mixing or other operations resulting in a change in its nature or composition. Anything discarded or dealt with as waste must be presumed to be waste unless proved otherwise. A ‘yes’ answer to any of the following questions should clarify any doubts about the matter:

• Would it normally be described as waste?

• Is it a scrap material?

• Is it an effluent or other unwanted substance?

• Is it broken, worn out, contaminated or spoiled?

• Is it being discarded as if it were waste?

Whilst waste may be a commonly understood term, its definition in law is far from straightforward, and the waste management controls which have been evolving since the Control of Pollution Act 1974 and the Environmental Protection Act 1990 have profound implications for industry and commerce.

Controlled Waste The Control of Pollution Act 1974 addresses all aspects of pollution including wastes and introduces the concept of controlled waste, and later special waste (now hazardous waste). Controlled waste was effectively any waste covered by the Control of Pollution Act and meant all waste, including wastes from households, industry and commerce but not from agriculture, mines and quarries, or explosives or radioactives (which have their own special regulatory framework). It was incorporated into the Environmental Protection Act 1990, Section 75, and the Controlled Waste Regulations 1992.



Most of the provisions of the EPA apply only to controlled waste: household, commercial and industrial waste. Section 75 of the EPA further defines household waste as “waste from a domestic dwelling, caravan, residential home, hospital or nursing home”; commercial waste is waste from premises used for trade, business, sport, recreation or entertainment; and industrial waste is waste from a factory or any premises used in connection with public transport, public supply of gas, water, sewerage services and electricity, telecommunications and postal services.

Although this definition is set out in the EPA, it is clarified by the Controlled Waste Regulations 1992, and modified by Section 90 of the EPA, which states that the following are not to be treated as household waste: “asbestos, mineral, synthetic oil or grease or clinical waste”, so the definition and interpretation of the definition of waste becomes more complex.

Note that hazardous waste and clinical wastes are also controlled waste, but due to their nature they require special provisions for handling.

Hazardous Waste Directive 91/689/EEC on hazardous waste was initially implemented in the UK through the Special Waste Regulations 1996 (1998 in N. Ireland). However the UK list of special wastes varied from Europe and the Directive has now been fully implemented, to bring it in line with Europe, by the Hazardous Waste (England and Wales) Regulations 2005, with similar regulations for Scotland and N. Ireland. The Hazardous Waste Regulations 2005 repeal the Special Waste Regulations and wastes that are included in the definition are now referred to as Hazardous Wastes rather than Special Wastes.

The European Waste Catalogue contains a list of hazardous and non-hazardous wastes meeting the requirements of the Hazardous Waste Directive and the Framework Directive. The European Waste Catalogue, 2002, has been implemented into the UK through the List of Wastes Regulations 2005.

These Hazardous Waste Regulations came into force in two phases, on 16th April 2005 and 16th July 2005. The regulations did not apply to Agricultural and Mines and Quarries Waste until 1st September 2006.

The main provisions of the Hazardous Waste Regulations are:

• Definition of hazardous waste.

• Restriction of the mixing of wastes.

• Notification of premises producing hazardous waste.

• Consignment Note arrangements.

• Returns and records.

Definition of Hazardous Waste A waste is hazardous if it is listed as a hazardous waste in the List of Waste Regulations 2005. The Environment Agency Technical Guidance Note WM2 – Hazardous Waste gives guidance on the methodology for assessing wastes based on the European Waste Catalogue (EWC) 2002.

The EWC lists the following wastes:

• Non-hazardous waste those entries that are given in ‘black’ and have no *



• Absolute entries those entries that are given in ‘red’ and have an * - these are always hazardous waste.

• Mirror Entries those entries that are given in ‘blue’ and have an * - these are only hazardous waste if dangerous substances are present above threshold concentrations, specified in Article 2 of the EWC. (In the UK - the List of Wastes Regulations 2005).

Note that the term 'dangerous substance' is as defined in the Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP). From the above definitions it is clear that 'Mirror Entry' wastes may or may not be hazardous, depending on whether certain criteria are fulfilled. Waste holders are required to determine whether their 'Mirror Entry' waste is indeed hazardous and, if so, assign it to one or more of the Hazardous Property Categories (H1 - H14, listed in the technical guidance note, WM2, referred to earlier). These hazardous property categories, for the most part, follow the categories of danger used in the CHIP Regulations, e.g. H1= Explosive; H2 = Oxidising; H6 = Toxic; H7=Carcinogenic, etc. There are several ways to determine the assignment:

• If the chemical composition of the waste can be determined (e.g. from knowledge of which raw materials went into it and how it was produced) then it should be assessed to determine whether it contains components which are 'dangerous substances'. Many common 'dangerous substances' are listed in the Approved Supply List (ASL), which accompanies the CHIP Regulations. If a component is listed in the ASL, then the hazard classification of that component will be given for you, along with its associated 'risk phrases'.

If a component is not listed in the ASL, then you must determine whether that component is 'dangerous' or not by recourse to either safety data sheets or by using the approved classification methods described in the approved classification and labelling guide (which also accompanies the CHIP Regulations). If any of these identified 'dangerous substances' are present in the waste above prescribed threshold concentrations, then the waste as a whole is hazardous. The threshold concentrations are listed in the technical guidance note for each hazard category.

• If it is not possible to determine the composition or there is insufficient information available, then either you must test the waste as a whole or assume that it is indeed hazardous (but the assumption should normally be based on at least some crude tests, such as pH determination, and information on the likely nature of the waste)."

Note:

• Where a waste is not listed in the European Waste Catalogue – it is not a hazardous waste.

• To be a Hazardous Waste a waste must first meet the definition of Controlled Waste.

The determination of Mirror Entry Hazardous Wastes can be complex; reference should be made to Technical Guidance WM2 and the Consolidated European Waste Catalogue, also available through the Environment Agency website.

Restriction of the Mixing of Wastes It is an offence to mix hazardous wastes unless it is permitted as part of a disposal or recovery operation. Mixing of hazardous waste includes:

• Mixing different categories of hazardous waste.



• Mixing with a non-hazardous waste.

• Mixing with any other substance or material.

There is an additional requirement that where such mixing has occurred the holder of the waste must separate the wastes where it is technically and economically feasible. The duty to separate may not necessarily be on the person who initially mixed the waste but on who now holds the waste.

Disposal Arrangements Notification of Premises Producing Hazardous Waste Where hazardous waste is produced at or removed from premises, the premises must notify the Environment Agency. Once the Environment Agency has been duly notified the premises become ‘notified premises’ for the period of twelve months.

Note: It is an offence to remove hazardous waste from premises which have not been notified to the Environment Agency, unless they are exempt premises or the waste has been flytipped. All premises at which hazardous waste is produced or removed must be notified by the producer of the waste or the consignor (the person who arranges for the removal of the waste). A fee is payable to the Environment Agency on notification of premises. (This requirement replaces the pre-notification of movement requirements in the repealed Special Waste Regulations.)

Certain types of premises are exempt from the requirement to notify if less than 200kg of hazardous waste is produced in any twelve month period. Premises that may be exempt under this regulation include:

• Offices.

• Shops.

• Agricultural premises.

• A residential home.

• Caravan.

• Premises forming part of a university, school or other education establishment, hospital or nursing home.

• Premises at which waste electrical and electronic equipment is collected.

• Dental, veterinary or medical practice or a ship (no quantity limit applies in the case of a ship).

Consignment Notes The movement of hazardous waste requires consignment notes, to be completed whenever hazardous waste is removed from premises (which includes removal from ships and removal by pipeline). The various types of form are set out in Schedules 4 to 7.

Producers, holders, carriers, consignors and consignees are all required to complete various parts of the forms. If the consignee rejects the waste, suitable alternative arrangements must be made.

Where more than one carrier transports the consignment a schedule of carriers must also be completed.



Where a single carrier collects more than one consignment of waste in the course of a journey and each consignment is collected from different premises, if all consignments are being transported to the same consignee promptly, ‘multiple collection’ provisions are available.

An example of a consignment note follows.



Example of a Consignment Note



Records and Returns Producers, holders, carriers, consignors and consignees are required to keep records. These must be kept for a minimum of 3 years except in the case of carriers where the period is 12 months. Consignees are required to provide the Environment Agency with a quarterly return setting out the consignments they have received during that period. Consignees may be required to pay a fee to the Environment Agency but are given a right to recover the payment from consignors who sent the waste to them. They are also required to send a return to producers or holders who sent waste to them.

Disposal of hazardous wastes is managed by specialist companies (e.g. Rechem) who have acquired expertise and operate dedicated chemical plant. Recovery of waste oils, solvents, etc. is usually followed by incineration of the residues, which must be carefully controlled to minimise production of environmentally nasty substances such as dioxins and furans. The latter involves careful control of incinerator temperatures and cleaning of effluent gases. The problems caused by the inadequate combustion of difficult substances such as PCBs underline the need for effective high-temperature incinerators for treating hazardous wastes.

There are two merchant hazardous waste incinerators in England and Wales which receive waste from other waste producers: i.e. Cleanaway, Ellesmere Port and Shanks, Southampton. Hazardous waste is also incinerated at a number of chemical plants, drum reconditioning facilities and cement or lime kilns that incinerate hazardous waste with other fuels.

Such a plant is subject to IPPC so that contaminant levels of prescribed substances must meet defined limits at all times. These would include stack emissions of nitrogen and sulphur oxides (which can form acid rain) and particulates; chemical composition, temperature and turbidity of outfall passed to water; and content of dioxins, furans and other halogenated compounds passed to all three media - land, air and water.

From July 2004 hazardous waste has had to be treated prior to landfill disposal due to the ban on co-disposal with non-hazardous waste. The treatment must:

• Be a physical/thermal/chemical or biological process including sorting.

• Change the characteristics of the waste in order to:

− Reduce its volume, or hazardous nature; or

− Facilitate its handling; or

− Enhance its recovery.

Methods of Categorising Waste and Different Techniques Required for Each Waste Category Waste definitions and categorisation are represented in the diagram that follows. These waste categories are generally dealt with by following the waste hierarchy already mentioned. Eliminating or reducing waste, or changing to a waste disposal arrangement higher up this hierarchy should both improve the environmental outcome and make economic sense in each case.

Controlled Waste Controlled waste can be split into the following categories:



• Household

Applies broadly to households, places of worship, charity premises, private garages, campsites, prisons, public meeting venues, royal palaces, residential homes, educational establishments and hospitals.

• Industrial

Applies broadly to waste arising from factories, public transport premises, premises used to supply services (water, gas, electricity, telecommunications, etc.), commercial garages, laboratories, workshops and excavation works. Also applies to certain categories of sewage and clinical waste.

• Commercial

Defined broadly as waste from premises used wholly or mainly for the purposes of trade, business, sport or recreation. It includes waste from offices, showrooms, hotels, large private garages, clubs, societies, etc., and waste classified as ‘industrial’ or ‘household’ from courts, government departments, local authorities, corporate bodies, markets, fairs and tents not pitched on a campsite.

Controlled Waste Non-controlled Waste

Commercial Industrial Household Agricultural Mines, quarries

Inert Non-hazardous Non-special

Hazardous Special

WASTE

Waste Categorisation

We have discussed hazardous waste in the previous section.




Revision Questions

8. Define the following wastes:

− Biodegradable.

− Flammable.

9. Explain what is meant by clinical waste, and what groups are used for its disposal.

10. Define hazardous waste.

11. Define controlled waste and give examples.


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PRACTICAL WASTE MANAGEMENT Minimisation The emphasis should be on not generating waste in the first place. So, although waste may be unavoidable in many cases, minimisation can be achieved by process change and optimising efficiency.

Storage Waste must be properly stored and protected. If it is not, it may escape to the environment and cause harm. Practically this means covering skips, storage in bunded areas (to protect against leakage) and security.

Labelling Waste should be labelled where appropriate and in accordance with the CHIP Regulations. If the waste is hazardous for transportation, it should also be correctly labelled in accordance with transportation regulations.

Carriage Anyone who holds waste may transfer it to a waste carrier who must be registered with the Environment Agency. However, it is part of the waste holder’s duty to ensure that carriers are suitable to handle and dispose of the waste. The holder should remain alert to any sign that the waste may not be legally dealt with by a carrier.

The duty holder therefore ultimately remains responsible for the fate of the waste so that if, for example, it is taken by a carrier and fly-tipped, it will be the duty holder’s (perhaps difficult) task to persuade a court of law that he acted in accordance with the Code of Practice, which explicitly has legal standing. It is for the waste holder to ensure the bona fides of any waste carrier, who must be a registered carrier of controlled waste.

The Duty of Care An important provision of Part II of the Environmental Protection Act 1990 was the introduction of a new duty for all persons involved in the generation, importation, handling, transporting and disposal of ‘directive waste’. Any such person automatically becomes a waste holder. The duty identifies the responsibility for waste management from the generation of the waste to its final disposal as lying with the company or organisation which generates or imports the waste. The duty does not, however, extend to householders or occupiers of domestic properties. The concept is dealt with later under legal regimes.

The Duty of Care Code specifies prevention of:

• Corrosion or wear of containers.

• Accidental spills or leakages.

• Breach of containment by weather.

• Blowing away or falling from vehicles or storage.



• Scavenging by vandals, thieves, children, trespassers or animals.

So leakage from waste into the ground may contaminate it, and the contamination may then pollute ground-water. Waste holders’ duties are designed to prevent such abuses, which it was anticipated would increase following the introduction in 1996 of the Landfill Tax at set amounts per tonne for inactive waste (builders’ rubble) and for active (general) waste. The waste holder must:

• Protect the waste while they have it (cover skips, store liquids in bunded enclosures, etc.).

• Ensure that it reaches the next holder intact (if the next stage is a waste transfer station, it should be sorted and mixed so that excessive packaging is not needed).

• Segregate incompatible wastes (preventing cross-contamination of waste).

• Ensure security (secure against waste attractive to scavengers, e.g. building materials).

Waste left for collection should be adequately secured and left for a minimum of time.




Revision Questions

12. The Environmental Protection Act 1990 introduced a duty of care for all persons involved in the generation, importation, handling, transportation and disposal of ‘directive waste’. What does that duty specify prevention of?

13. Which legislation should be considered when labelling hazardous waste?


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WASTE DISPOSAL Types of Waste Treatment Physical and Chemical Treatment Physical treatment of waste includes reducing its bulk, e.g. by the use of presses to remove water from sludges. Physical treatment may also include heating to kill pathogens. Chemical treatment may be necessary to reduce the hazardous nature of a chemical, e.g. neutralisation of acids with bases, and treatment of sludges.

Newer technologies in this area are:

• Pyrolysis: in this treatment, organic waste is heated in the absence of air to produce a mixture of gaseous and liquid fuels and a solid inert residue (mainly carbon).

• Fermentation: this particular treatment is confined mainly to agricultural wastes, but can in theory also be extended to pre-treated municipal solid waste, to produce liquid fuel (ethanol, and some methanol).

• Anaerobic digestion: this is the biological degradation of organics in the absence of oxygen, producing methane gas and a residue suitable for use as a soil improver. It is used to treat sewage sludges. The methane gas is used to meet on site power and process heat requirements and the residue is cattle slurry.

• Gasification: where carbon based wastes are heated in the presence of air or steam to produce fuel-rich gases. Northumbrian Water has proposed gasification for the treatment of sewage sludge in its area.

• Feedstock recycling: it is possible to react mixed plastic waste in a polymer cracking process which produces products similar to naphtha feedstock.

• Feedstock substitution: in this process mixed plastic waste is used as a feedstock in blast furnaces producing pig iron. Mixed plastic waste can be used as a substitute source of carbon.

• Substitute fuels: these include scrap tyres and solvent wastes which substitute coal and petcoke (petroleum coke) in cement and lime kilns, and can also include packaging waste paper, biofuels and plastics.

• Plasma arc: an alternative heat combustion system for mixed wastes, such as municipal solid waste. It uses plasma arc heating (the energy released by an electrical discharge in an inert atmosphere) to raise the temperature of the waste to anything between 3,000 and 10,000°C, converting organic material to a hydrogen rich gas and non-combustibles to an inert glassy residue. The gas (which is relatively uncontaminated) is suitable for generating electricity to support the process. The volume of gases discharged from these processes is generally less than 10% of that generated by incinerators with the same waste processing capacity.

• Biomechanical waste treatment (BWT): this commonly comprises a number of standard waste separation operations to remove recycled materials such as glass, metals and plastics, followed by composting of the remaining organic materials.

• Anaerobic digestion instead of composting: a variant of the BWT process that uses biomechanical waste treatment. It is claimed that the potential of the residue for landfill



gas production and residual waste is reduced, but leads to an increase in levels of VOCs (volatile organic compounds) to the atmosphere.

Landfill Landfill Sites Landfill sites are the most commonly used form of waste disposal. They have been used extensively in the UK due to an abundance of disused mineral extraction sites. Every site is different and use is subject to conditions set by the Environment Agency and the Local Planning Authority. The conditions imposed on a landfill site will depend on the geology, hydrogeology, topography and the general environment, i.e. proximity to houses, roads, etc.

The conditions on each landfill site will therefore be unique to that site. From a practical viewpoint, waste producers must check (see Duty of Care as discussed later in this element) that the particular site proposed for the waste is permitted by the Waste Management Licence. There may be problems with heavy vehicle movements.

Landfill sites were originally small, informal or non-engineered sites used by local councils and industry. Landfill was first defined in 1971 as “the deposit and compacting of waste in shallow layers, and covering the exposed surfaces with inert materials to form a seal”.

Prior to the 1970s, there was little engineering control beyond that provided by local topography and geology. Since then, the trend has been towards larger sites (5 × 106m3) sited away from urban centres. Legislation to license landfills did not begin until the late 1970s, with further tightening in 1994. Permitting will continue under the Environmental Permitting (England and Wales) Regulations 2007.

A landfill site must be geologically suitable. Ideally it should be impervious, e.g. underlain by clay, but if not a membrane can be laid to make it so. The design should minimise ingress of ground-water which could arise due to changes in the local water table, flood conditions or the existence of springs or streams. The site should be finished with an impervious clay dome to shed rain-water. Modern landfill sites are highly engineered. Works commence with detailed engineering surveys and studies of the geology, hydrogeology, soils, water, ground-water and many other parameters. Today, sites are expected to avoid pollution, so sites are usually lined with a plastic or asphaltic liner, followed by the development of a complex of leachate and gas collection wells and pipes. Monitoring of all these systems is required and incorporated. The waste inputs are carefully monitored and checked and tipping takes place in ‘cells’, each of which will be virtually self-contained, giving a complex ‘honeycomb’ of cells in the completed site, which is then capped with a carefully engineered series of different sealants (such as clay and subsoil), before being finished with topsoil and planted.

Certain kinds of hazardous waste are not considered suitable for disposal by landfill, however sophisticated the site; these include some clinical wastes, pesticides, industrial gases under pressure in degradable containers, highly flammable concentrates, and certain heavy metals such as lead and cadmium. The Landfill Directive introduced new regulations restricting certain wastes which may be disposed of by landfill.

Potential Problems with Landfill Sites The major potential problems concerned with landfill sites are:

• Landfill gas.

• Leachate.

• Nuisance.



Landraising Landraising, or above ground landfills have increased in the last few years and may become more widely used in order to combat the decreasing number of landfill sites. Planning Policy Statement 10: Planning for Sustainable Waste Management (PPS10), is the principal source of national planning advice on waste management and it distinguishes between landfill and landraising. The disposal of wastes by landraising can provide more effective control over the migration of landfill gas and leachate. These schemes are much less common than landfill sites but have the same environmental disbenefits, e.g. incompatibility with the local topography, visual intrusion, noise from vehicles on site and odour from landfill gas. Such schemes require careful management and site choice throughout their life from conception and planning to the final restoration stage.

Landraising might also be used for agricultural improvement, e.g. by improving drainage and/or land productivity or for the restoration of degraded, contaminated or derelict land and former mineral workings.

Landraising does however offer some benefits to the environment, for example:

• Greater distance from ground-water.

• Leakages may be easier to identify and control.

• Engineering aspects of design and construction are less complex.

Where landraising is proposed, operators will need to obtain a waste management licence from the Environment Agency, as well as getting planning permission.

Incineration Application Incinerators are used for a variety of purposes. Applications include destruction of:

• Domestic waste, commercial waste and certain industrial wastes.

• Liquid industrial waste, e.g. oils, solvents.

• Sewage sludge.

• Clinical waste.

• Animal carcasses, etc.

Advantages Incinerators are used in a number of applications and have many advantages over other disposal methods, for example:

• Reduction in volume.

• Destruction of hazardous components.

• Creation of an easily disposed of ash.

• Small size of plant.

• Immediate and measurable effects.

• Can be used to raise energy by utilising calorific value of waste.


http://www.communities.gov.uk/planningandbuilding/planning/planningpolicyguidance/mineralsandwaste/wastemanagement/pps10/

http://www.communities.gov.uk/planningandbuilding/planning/planningpolicyguidance/mineralsandwaste/wastemanagement/pps10/


Disadvantages These include:

• High capital cost and monitoring requirements.

• High fuel costs on start up.

• Need to carefully control inputs.

• Incinerators are not suitable for aqueous wastes, wastes containing heavy metals, chlorinated materials (unless special controls are in place), and non-combustible solids.

The Waste Electrical and Electronic Equipment (WEEE) Regulations 2006 These Regulations have come into force since the introduction of the present syllabus and you should have some knowledge of their impact. It is appropriate to include them here.

They finally came into full force in the UK on 1st July 2007.

Derived from the WEEE Directive, the Regulations aim to minimise the impact of electrical and electronic goods on the environment, by increasing reuse and recycling to reduce the amount of electrical and electronic equipment disposed of at landfill sites. They seek to achieve this by making producers financially responsible for collection, treatment and recovery of waste electrical equipment. The Regulations also oblige distributors to allow consumers to return their waste equipment free of charge.

The WEEE Directive requires EU member states to collect and recycle the equivalent of 4kg of "e-waste" for every person living in the country.

In the UK, DEFRA is responsible for ensuring the permitting of Authorised Treatment Facilities for the WEEE Regulations. The enforcement agency responsible is the Environment Agency in England and Wales, the SEPA in Scotland and the Environment and Heritage Service (EHS) in Northern Ireland.

Manufacturers and importers in the UK have to join one of 37 authorised "producer compliance schemes". The schemes, which are funded by manufacturers, are responsible for ensuring the correct collection, recovery and disposal of e-waste. The schemes report to the appropriate authority (e.g. the Environment Agency), which ensures enforcement of the measures.

Retailers must either offer a free in-store "take-back" service; take the customer's old equipment when they buy a new one; or help fund improvements to local authority recycling facilities.

Households are under no obligation to recycle their e-waste as far as the WEEE Regulations are concerned, but they will be discouraged from throwing away items potentially containing harmful substances.

They will be encouraged instead to use the recycling facilities being offered to them through the authorised producer compliance schemes.

Products that have been on the market since August 2005 have been marked with a crossed-out wheelie bin. The symbol is to help user identification of electrical and electronic equipment (EEE).

The ten WEEE categories are listed below:

1. Large household appliances.

2. Small household appliances.



3. IT and telecommunications equipment.

4. Consumer equipment.

5. Lighting equipment.

6. Electrical and electronic tools.

7. Toys, leisure and sports equipment.

8. Medical devices.

9. Monitoring and control instruments.

10. Automatic dispensers.

The e-waste problem is the fastest growing category of waste in the European Union. In the UK alone, an estimated 1.2 million tonnes of e-waste are produced each year. While the WEEE Directive requires about 20% of the nation's electronic waste to be diverted away from landfill, it is hoped that the new law will result in much more EEE being recycled.

When the WEEE Directive was first agreed in February 2003, it was criticised for being far too complex and costly to implement. While a number of nations, such as Austria and the Netherlands, were able to implement the measures on time, others struggled. The UK delayed adoption of the legislation a number of times, but following the announcement of further postponement in July 2006, the Opposition parties criticised the Government for taking "the longest WEEE in history". Officials blamed the delays on "major difficulties".

Major figures in industry said the setbacks were due to the UK attempting to establish a system that would be successful once it was up and running. A number of other nations decided to adopt the Directive quickly and sort out resultant problems later.

According to the Department for Business, Enterprise and Regulatory Reform (formerly the Department of Trade and Industry), full implementation of the WEEE Regulations in the UK is estimated to cost between £111m and £133m, rising to £331m-£434m by 2017.




Revision Questions

14. What environmental benefits are gained by using a landraising method of waste disposal?

15. Highlight the advantages and disadvantages of using incineration as a method of disposal.

16. Which hazardous wastes would not be considered suitable for disposal in landfill sites?


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LEGAL REGIMES APPLICABLE Concept of Duty of Care Environmental Protection Act 1990 In disposing of a Directive Waste, there is a statutory duty of care defined by the Environmental Protection (Duty of Care) Regulations 1991. The duty imposed by these Regulations includes hazardous wastes. The Duty of Care regulations were enacted under Section 34 of the Environmental Protection Act 1990 and implement a broad framework Directive (75/442/EEC) on the control of both household and toxic wastes. Regulations and a Code of Practice have been introduced to add detail to the Duty of Care introduced at Section 34 of the Environmental Protection Act 1990. The Environmental Protection (Duty of Care) Regulations 1991 define the documentation required to exercise the duty of care. The Code of Practice provides practical guidance on how the duty of care should be exercised.

Particular emphasis is placed upon preventing any other person contravening the law as to unauthorised deposits, treatment or disposal of the waste. This requirement places a duty on producers of waste to ensure that their wastes are transported and disposed of in accordance with the provisions of the duty of care.

This duty of care extends from those producing waste through transporters of waste to final disposal. An important feature of the duty of care is that whilst persons responsible for transporting and disposing of the waste have duties to do so safely and effectively, that does not remove from the organisation generating the waste the duty to ensure that the waste is properly transported and disposed of. The Duty of Care and Code of Practice recommends that producers should require to see the actual licences held by the transporters and disposers of the waste. Licences to transport waste last for three years, so regular checking should be part of the waste producer’s duties.

Similarly, some industrial waste producers arrange to follow the trucks of the waste transporters to the disposal site once a year. The waste producer must ensure the proper and safe disposal of waste, even after it has been passed on to another party such as a waste contractor, scrap merchant, recycler, local council or skip hire company.

There are specific duties on producers of waste to ensure that wastes are only transferred to persons who are licensed to accept or transport the particular types and quantities of waste involved. To fulfil this duty it is not sufficient simply to ask the transporter if he is licensed to transport and dispose of that type and quantity of waste.

The duty of care has no time limit and extends until the waste has either been disposed of or fully recovered.

All employees and contractors working on a business’ premises should be given specific instructions relating to how each and every type of waste that might arise is to be handled and disposed of, and frequent checks should be conducted to ensure that they are followed. We therefore see that this imposed a new responsibility not only on generators of waste. One example of this is the duty of care related to the disposal of hazardous waste, for example, to ensure that any waste consignment has the correct documentation, with an accurate description.



Category Of Persons On Whom Duty Is Placed As we have seen, the duty of care applies to all persons involved in waste generation, importation, handling, transporting and disposal of directive waste, e.g. waste carriers, waste brokers. The company or organisation which generates or imports waste is responsible until its final disposal, although this does not apply to householders or occupiers of domestic properties.

Typically authorised persons are:

• A waste collection authority.

• Any person who is the holder of a waste management licence under section 35 of the EPA, or of a disposal licence under section 5 of the Control of Pollution Act 1974.

• Any person registered as a carrier of controlled waste under section 2 of the Control of Pollution (Amendment) Act 1989.

• A waste disposal authority in Scotland.

Authorised transport involves:

• The transport of controlled waste within the same premises between different places in those premises.

• The transport to a place in Great Britain of controlled waste which has been brought from a country or territory outside Great Britain not having been landed in Great Britain until it arrives at that place.

• The transport by air or sea of controlled waste from a place in Great Britain to a place outside Great Britain.

This information was obtained from the HMSO (Stationery Office), “Waste management, The Duty of Care, A Code of Practice”, ISBN 0 11 753210 X. It is available from their bookshop or by telephoning 0870 600 5522, or see www.tsoshop.co.uk.




Revision Question

17. Explain the concept of duty of care in dealing with waste.

(Suggested Answer is at the end of Unit C.)

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EMERGENCY PROCEDURES Need for Emergency Response Measures in the Event of an Uncontrolled Release Whilst emergency planning is a requirement of an Environmental Management System, it is also a necessity under certain legislation, such as a Permit under the Environmental Permitting (England and Wales) Regulations 2007, where certain conditions require preparations to be made in the case of emergency conditions arising. Pollution prevention guidelines (PPG 11, 18, 21) are available from the Environment Agency and SEPA.

The Civil Contingencies Act 2004 defines an environmental emergency as: “an event or situation which threatens serious damage to …the environment of a place in the United Kingdom” if it involves, causes or may cause:

“(a) contamination of land, water or air with biological, chemical or radio-active matter, or

(b) disruption or destruction of plant life or animal life.”

There is also a common law duty of care on local authorities for such eventualities. Following a flood in December 1979, Cardiff City Council and South Glamorgan County Council were found negligent in their preparation and implementation of a flood emergency plan at Cardiff Crown Court on 16 October 1987.

You will remember that your studies for Unit A of the National Diploma covered Emergency Planning in some detail (Element A4). You may find it useful to look back at the appropriate study material.

Emergency Situations Emergency situations may arise from a variety of different circumstances.

Natural Events Natural events such as high winds, storms or excessive rainfall can cause emergency conditions to arise at a factory, e.g.:

• Winds may cause wind-blown dust.

• Rain can cause flooding or prevent discharges flowing away easily.

• Storm sewers may overflow.

Spillages and Containment Failure Spillages can be caused by a variety of circumstances, e.g.:

• Road traffic accidents.

• Failure of pipes, hoses or other equipment.

Once again, an analysis of the risks should be carried out. A source, pathway, target analysis should identify the pathways and targets. Appropriate emergency procedures and equipment should then be put in place to reduce the risk to a condition which is as low as practicable. The amount (and cost) of risk reduction measures will depend on the potential damage which could be done if the substances escaped, and the sensitivity of the receptor.



Emergency plans can vary from complex off and on site emergency plans involving the local authority and emergency services, evacuation procedures and closure of roads and railways, to a small number of local procedures and spillage kits, to cover the spillage of a low risk chemical in a low risk situation. The former scenario would be a requirement of the COMAH Regulations 1999. Such sites will have an emergency officer, with a dedicated control room, meteorological information, drain plans, road plans etc., and usually a media communication officer. It is always prudent to practise emergency procedures, and most companies will have invited the emergency services (particularly the Fire and Rescue services) to the site to reconnoitre as part of the planning process. Having an inventory of the chemicals in use on the site, and information concerning services (electricity, gas, water, etc.) is essential.

Disposal of Fire Water Fire water can pose particular pollution problems. It has the potential to be contaminated with a cocktail of combustion products, chemicals and possibly fire-fighting foams, all of which can do harm to surface waters or sewage systems. Polluting a watercourse or the sewage system may be an offence, even if there was an emergency situation prevailing. It is therefore preferable to consider the disposal of fire water prior to the emergency situation. Possible solutions include sacrificial areas, retention tanks and containment bunds. The Environment Agency issues a number of advisory leaflets to explain best practice in this and other related subjects. Known as Pollution Prevention guidelines, they are available from the Environment Agency (EA) and are also on the EA website www.environment-agency.gov.uk. The subject of fire water is discussed in PPG18, “Managing Fire Water and Major Spillages”.

Emergency Contacts As part of any emergency plan, there need to be emergency contact numbers for the Environment Agency, and the sewerage undertaker. Many companies also have arrangements with emergency contractors who undertake to arrive within a specified timescale.

Emergency preparedness and response plans for such events may include the following elements:

• On-site emergency response teams and equipment.

• Key personnel duties and responsibilities and contact details.

• Interrelationship with, and contact details for, off-site emergency services.

• Internal and external communication plans.

• Training arrangements and practice drills.

• Detailed response measures for each type of emergency incident − including personnel response and equipment needs.

• Supportive data on inventories, locations, method of storage and potential effects on the environment of the full range of chemicals held on the site.

All such plans should be practised and tested periodically and feedback given to promote continual improvement.

Environmental Aspects of the Control of Major Accident Hazards Regulations The Control of Major Accident Hazards Regulations 1999 (COMAH) implement EC Directive 96/82/EC (known as the Seveso II Directive) except for the land use planning



aspects which have been implemented through amendments to existing planning legislation. COMAH replaced the Control of Industrial Major Accident Hazards Regulations 1984 (CIMAH) which implemented the original Seveso Directive (82/501/EEC). COMAH gives equal importance to safety and environmental risks and, where practical, they must be treated in an integrated way.

COMAH aims to prevent and limit the effects on people and the environment of those major incidents involving dangerous substances, e.g. liquefied petroleum gas, chlorine, arsenic pentoxide. COMAH has a number of important requirements, including:

• Identifying major accidents.

• Limit consequences for persons and the environment.

• Implement accident prevention measures.

The Seveso Directives take their name from an accident at a chemical plant at Seveso, Italy, in 1976, in which a safety disk in a reaction vessel ruptured and a plume of chemicals containing trichloro-phenol blew 30 to 50m above the factory. The resulting fallout led to dioxin contamination of a 3-4km2 area down-wind from the factory with significant adverse health effects in the local population.

The Regulations are enforceable by a joint Competent Authority comprising the Health and Safety Executive (HSE) (who provide Guidance notes on certain aspects, e.g. HSG190 and HSG191) and the Environment Agency in England and Wales and the HSE and the Scottish Environment Protection Agency (SEPA) in Scotland. The Environment Agency or SEPA is concerned principally with the assessment of the environmental aspects of COMAH. In addition, local authorities have an important role to play in relation to emergency planning. A Memorandum of Understanding (MOU), which sets out the responsibilities of the joint competent authority, has been signed.

COMAH Regulations The COMAH Regulations apply to companies which manufacture, store or transport dangerous chemicals (including petrochemicals, pharmaceuticals and agro-chemicals) and explosives, i.e. flammable, explosive, toxic or which are dangerous to the environment in quantities in excess of threshold quantities specified in Schedule 1. Approximately 1,200 establishments in the UK have the potential to suffer major accidents because they use or store significant quantities of dangerous substances, such as oil products, natural gas, chemicals or explosives.

The Regulations apply at two thresholds, known as lower-tier and top-tier, depending upon the quantity of dangerous substances stored or used. If the lower-tier threshold is equalled or exceeded, operators must notify the Competent Authority.

The regulations legislate that:

• All sites should be able to demonstrate that they can operate safely.

• The competent authority should be notified of major accidents.

• Companies with large inventories should prepare safety reports and an on-site emergency plan, co-operate with local authorities in preparing an off-site emergency plan, and provide information to the public.

The competent authority must be notified so that it can plan its assessment and inspection programmes and ensure that operators comply with their duties under the Regulations. Essentially, what is needed is information about the operator, site, processes and inventory.



Schedule 1 lists the substances to which the regulations apply.

Schedule 2 describes the principles to be taken into account when preparing the operators’ major accident prevention policy document (aims and principles of action relating to major accidents) and safety management systems (organisation, personnel, identification and evaluation of major hazards, operational control, management of change, planning for emergencies, monitoring performance, audit and review).

Schedule 3 requires that companies inform the competent authority of:

• The name and address of the operator.

• The address of the establishment concerned.

• The name or position of the person in charge of the establishment.

• Information sufficient to identify the dangerous substances or category of dangerous substances present.

• The quantity and physical form of the dangerous substances present (or likely to be present).

• A (brief) description of the activity or proposed activity of the installation concerned.

• The immediate environment liable to cause a major accident or to aggravate the consequences thereof.

Schedule 4 details the purpose and contents of safety reports, e.g. description of installation, identification of major accidents and accidental risk analysis and prevention methods, protection measures, etc.

Under Schedule 5 of the Regulations, the operator must prepare a Major Accident Prevention Plan (MAPP) which should demonstrate that there is an adequate safety management system in place.

If the top-tier threshold is equalled or exceeded, operators must comply with additional requirements to provide a Safety Report to the authority for approval, including details of the types and quantities of hazardous substances (Section 7).

Under COMAH there is a requirement that a Site Safety Report is written which has the function of identifying major accident hazards on the site and, inter alia, provides for an estimation of the likely risks associated with the site and potential for major accidents which could affect the environment. Where such risks are identified an assessment must be undertaken to establish the consequence of the event in terms of the environment. In this context ‘environment’ includes the air, the land and controlled waters. Should any sites have a designated protected status or sensitive receptors in the vicinity then this has to be taken into consideration. (DEFRA: Guidance on the Interpretation of Major Accident to the Environment for the Purposes of the COMAH Regulations, 1999). The site safety report will cover:

• Major hazards arising from the consequences of potential accidents, especially the possible extent and severity of an accident.

• Maps showing land use and the location of sensitive parts of the environment.

• Description of the environment and surroundings of the establishment.

• The ecotoxicology of substances that might be released in an accident.

• Protection and intervention methods designed to limit the consequences of accidents.



• Provisions made to mitigate post-accident impacts and aid the recovery of the environment.

• A review when circumstances, including environmental ones, change in important ways.

The site safety report must include remediation (i.e. remedying environmental damage) and clean up following an accident.

In assessing the environmental aspects of the installation for the purposes of the report, attention focuses on the potential for harm to the environment (land, flora and fauna, etc.). It has also focussed on any indirect effects on humans (such as the potential to contaminate drinking water, food crops or water used for recreational purposes). The Health and Safety aspects with specific consideration of potential harm to humans are contained in the main body of the Site Safety Report. The Safety Report must be reviewed and revised at least every five years.

A further requirement is to have an on-site emergency plan which covers features within the boundary of the establishment, e.g. designated land, controlled waters (Section 9, schedule 5). Under Section 10, Local Authorities must also prepare an off-site emergency plan for each top-tier site (Further guidance HSG191). In the case of top-tier sites, the report must deal with Major Accidents to the Environment (MATTEs).

COMAH places duties on the Competent Authority to inspect activities subject to COMAH and prohibit the operation of an establishment if there is evidence that measures taken for prevention and mitigation of major accidents are seriously deficient. It also has to examine safety reports and inform operators about the conclusions of its examinations within a reasonable time period.

The Environment Agency places information on COMAH establishments upon its Public Registers which can be viewed at local Agency offices (Regulation 14, schedule 6).

As you will remember from your studies of Unit A, site operators have particular duties depending on whether they operate on a lower-tier or higher-tier site. To remind you, the requirements are as follows.

Lower-Tier Sites Operators must notify the Competent Authority before operations with dangerous substances begin. They must also take all measures necessary to prevent major accidents and limit their consequences to people and the environment. Prevention should be based on the principle of reducing risk to a level that is as low as is reasonably practicable (ALARP) for human risks and using the best available technology not entailing excessive cost (BATNEEC) for environmental tasks. The aim is always to avoid the hazard altogether where possible.

The key documentation that needs to be prepared is the major accident prevention policy. This basically demonstrates how the safety management systems will prevent major accidents and consequently covers areas such as:

• Organisation and personnel.

• Identification and evaluation of major hazards.

• Operational control.

• Planning for emergencies.

• Monitoring, audit and review.



Top-Tier Sites Operators must comply with the above, and rather than prepare a major accident prevention policy, they must compile a more comprehensive safety report. The safety report provides information to demonstrate to the Competent Authority that all measures for the prevention and mitigation of major accidents have been taken. The safety report must include:

• A policy on how to prevent and mitigate major accidents.

• A management system for implementing that policy.

• An effective method for identifying any major accidents that might occur.

• Details of plant and operating systems to prevent any major accidents.

• Information on safety precautions built into plant and equipment.

• Information on measures to limit consequences of any major accident that might occur.

• Information about the emergency plan for the site.

The safety report needs to be kept up-to-date and reviewed every five years or after significant changes. Top-tier operators also need to prepare and test an on-site emergency plan and provide local authorities with information to enable them to prepare off-site emergency plans. Members of the public who could be affected by an accident at a COMAH establishment must also be provided with information.

Additional Legislation In addition, some sites are subject both to COMAH and to the PPC Regime which establishes a permitting process by the competent authority which covers accidental pollution. In recognition of the potential overlap, it is proposed that operators be given flexibility in how they present information required under both regimes. They can keep applications for PPC permits and safety reports separate or they can combine them so that information which serves both purposes is not duplicated.

The requirements for safe storage, handling and use, and the notification of any releases will be part of the permit.

Major Accidents A major accident is described in COMAH as an occurrence (including a major emission, fire or explosion) resulting from uncontrolled developments in the course of the operation of any establishment and leading to serious danger to human health or to the environment, immediate or delayed, inside or outside the establishment, and involving one or more dangerous substances. All parts of this definition are necessary for an occurrence to be defined as a major accident.

Major Accident Evaluation depends on the event type, the event scale, the size and location of the affected area, the evaluation of event progression, and the potential harm to the population and the environment.

Major Accidents to the Environment (MATTEs) The more extensive the areas and quantities of natural and semi-natural resources damaged, the longer the effects are likely to last; and the more intense or severe these effects, the more likely it is that the event will be regarded as a major accident to the environment.

MATTEs can be caused by a number of factors, e.g. fires, land contamination, contamination from a spill, release of material to an aquifer, explosion leading to the release of noxious gases,



affecting a Site of Special Scientific Interest (SSSI), trees, wildfowl roosts, soil characteristics, loss of habitat, loss of species, or loss of amenity, or spills to bodies of water leading to the death of wildfowl, etc.

The damage which could occur as a result of a major event at a COMAH site from an environmental viewpoint is detailed in Tables 1-12 of the DEFRA, Guidance on the Interpretation of a Major Accident to the Environment for the Purposes of the COMAH Regulations, June 1999.

This includes damage to: National Nature Reserves, Sites of Special Scientific Interest, Marine Nature Reserves (land/water), Natura 2000 and RAMSAR Sites (land/water), designated land, scarce and widespread habitats (land/water), aquifers or ground-water, soil or sediment, built heritage (land/man-made), water, particular species (land/water/air), marine and freshwater and estuarine habitats.

Judgment of the scale of events which would be classed as a MATTE is important. The key parameters are a combination of recovery time, spatial extent of the damage and severity of damage.

The COMAH Competent Authority issues Guidance to assist companies in the preparation of the reports and the risk assessments: Guidance on the Environmental Risk Assessment Aspects of COMAH Safety Reports, COMAH Competent Authority 1999.

The following methodology for carrying out the Risk Assessment is proposed: in order to carry out a risk assessment, there must be an understanding of the nature of hazardous situations, their outcome and likelihood. This must be followed by a reduction of the risks to a level as low as reasonably practical (ALARP).

This process is shown in the following figure, which is taken from Guidance on the Environmental Risk Assessment Aspects of COMAH Safety Reports, Version 2, December 1999, produced by the Environment Agency.



Gather data, select team


No

Identify Hazard

Can hazard be

screened out?

MATTE Risk Assessment Process

Identify how harm could occur

How likely is it?

Make changes to make it so

Maintain controls Record assessment

No

Can hazard be screened

out?

Can hazard be screened

out?

Is it a MATTE

Are risks as low as reasonably practicable?

Justify Maintain records

Yes

Yes

Yes

No

Yes No

B

A

No

C

Yes



Revision Question

18. What is contained in the site safety report of the COMAH Regulations?

(Suggested Answer is at the end of Unit C.)

?


SUMMARY Environmental Pollution Various different industries affect the environment, such as: agriculture, construction, food production, brick manufacture, metal finishing, timber and offices.

Releases that can affect both people and the environment include:

• Intended releases, for example, from chemical plants.

• Abnormal conditions that result in releases.

• Major releases following plant failure, as happened at Bhopal, Chernobyl and Seveso.

Toxic substances produce injury in some way to a human or animal body, for example, gases such as hydrogen sulphide and hydrogen cyanide. Similarly, work with flammable substances, including gases, is hazardous because of the risk of fire and explosion.

The release of toxic substances can result in pollution:

• The Environmental Permitting (England and Wales) Regulations 2007 control the release of substances to land.

• The dispersion of pollutants to water is often caused by oils and fuel, or sewage; waterways can both spread and dilute these pollutants.

• The National Air Quality Strategy sets air quality standards and objectives for eight priority pollutants that affect health.

An environmental impact is: “any change to the environment… resulting from an organisation’s environmental aspect”. Environmental aspects are: “an element of an organisation’s activities or products or services that can interact with the environment”. This could include polluting both water and land. The impact could be global, regional or local.

Pollution control strategies include:

• Prevention of waste.

• Minimisation of waste, including the 4R rule: Reduce, Re-use, Recycle and Responsibly dispose.

• Rendering harmless certain substances.

Monitoring is carried out to check conformance (to the law) by the regulatory bodies, and to monitor environmental quality. It is a means of demonstrating control and of enabling failures to be recognised. Techniques include:

• Routine visual inspection.

• Instrumental monitoring.

Three approaches to sampling:

• A spot or grab sample.

• Collecting a sample over a period and then analysing it.

• A continuous monitored sample.

Two basic methods of sampling:

• Diffusion or passive sampling



• Mechanical or active sampling.

The necessity for the information to be provided to the public authorities and for the public authorities to provide information is controlled by law, in particular the Environmental Permtting (England and Wales) Regulaitons 2007.

Pollution Prevention and Control (PPC) seeks both to achieve pollution control and to regulate almost all of the environmental impact of the operation of an installation.

BAT is the Best Available Techniques to prevent and reduce emissions and the impact upon the environment.

The Environment Agency (EA) operates in England and Wales and is charged with protecting and enhancing the environment and contributing towards attaining the objective of achieving sustainable development. SEPA (Scottish Environmental Protection Agency) is the Scottish equivalent.

Classification of Wastes Wastes are classified as:

• Solids, liquids or gases.

• Hazardous or non-hazardous.

• Difficult.

• Flammable.

• Clinical.

• Biodegradable.

• Radioactive.

Directive waste is defined in terms of any substance or object in the categories set out in the schedules to the Environmental Permitting (England and Wales) Regulations 2007 and Schedule 22 of the Environment Act 1995.

Waste can be categorised as:

• Controlled, such as: household, industrial, commercial.

• Non-controlled, such as: agricultural, mines and quarries.

Practical Waste Management In terms of waste management, matters requiring attention include: minimisation, storage, labelling, carriage and the Duty of Care.

Waste Disposal Types of waste disposal include:

• Physical and chemical treatments of various types, including: pyrolysis, fermentation, gasification, etc.

• Landfill, usually on large sites outside urban areas.

• Landraising, or above ground landfills.




• Incineration, which is used for the destruction of various types of waste, including: domestic, liquid industrial and clinical wastes, sewage sludge and animal carcasses.

Disposal of waste electrical and electronic equipment is now governed by the WEEE Regulations 2006.

Legal Regimes Applicable The Environmental Protection (Duty of Care) Regulations 1991 define a statutory duty of care when disposing of a Directive Waste. The duty of care applies to all persons involved in waste generation, importation, handling, transporting and disposal of directive waste, e.g. waste carriers, waste brokers.

Emergency Procedures An environmental emergency, as defined by the Civil Contingencies Act 2004, is: “an event or situation which threatens serious damage to …the environment of a place in the United Kingdom”.

Emergency situations may arise from a variety of situations, such as:

• Natural events.

• Spillages and containment failure.

• Disposal of fire water.

Emergency contact numbers for the Environment Agency and the sewerage undertaker must be provided as part of any emergency plan.

COMAH aims to prevent and limit the effects on people and the environment of those major incidents involving dangerous substances. The Regulations apply to companies which manufacture, store or transport dangerous chemicals and explosives. They also apply at two levels, lower-tier and top-tier, depending on the quantity of dangerous substances stored or used.

COMAH requires a Site Safety Report and an on-site emergency plan. Top-tier sites must include provision for MATTEs (Major Accidents To The Environment) in their report.

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