Abbey Metal Finishing Case Study
We are sharing this case study because Abbey Metal Finishing’s challenges with water pollution started and were resolved prior to the development and introduction of the CIRIA c736 guidance in 2014. Now that we have CIRIA c736 I refer to it regularly and actively motivate people to read it and use it as this guidance is the cornerstone of effective water pollution prevention. It includes best practice and provides excellent examples of how to implement effective water pollution. Prior to CIRIA c736 we were kind of operating in the dark, making the best of what technology was available and innovating to produce the very best solutions.
Abbey Metal Finishing appears as a case study in the CIRIA c736 guidance, you will find it at 12.1. If you need a copy it is free to download here but you can ask me and I will forward you a version which is compressed so you can forward it on to anybody you know who may find it useful. The reason this case study is so important to us is Abbey Metal Finishing Case have been instrumental in challenging us to deliver and develop the very best solutions, they have been very proactive in addressing their water pollution challenges and the work we have done with them appears as a best practice in the CIRIA c736 Guidance.
Abbey Metal Finishing are a COMAH regulated site, in 2010 they suffered a fire. The fire was very similar, though smaller, to what happened at Buncefield. There was a major pollution incident event as a result of this fire, not from the fire itself or even the materials that they were handling on site – the environmental issue was caused happened by the water pollution that came from the firewater that was used to fight the fire. The outcome of this fire is that the factory was burnt to the ground and 27,000 fish were killed by Cyanide which had escaped from the site. The company were then prosecuted and fined around £166,000 in 2013, on top of the Environment Agency, legal and clean up costs were considerable.
In 2013 Abbey Metal Finishing were a business that was clearly in trouble.
In 2008 or 2009 I had approached this company and I asked if they wanted to look at firewater pollution containment. The answer was no, they were a low-tier COMAH site and felt that they had it covered with their environmental risk assessment and environmental management plan. The truth is that this was five years prior to CIRIA c736 so for all intents and purposes they were most likely conforming to the relevant guidance at the time which was, CIRIA c164, so their confidence in their systems and processes wasn’t necessarily mis-placed.
Unfortunately, 18 months after I had first approached them they suffered this significant fire due to an electrical fault, which caused the factory to burn down, and put the business under serious financial pressure due to the fines, legal and clean up costs. On top of this the regulator and local authorities were refusing to allow the busine
It was the firewater runoff that caused the environmental problem. The firewater runoff, which was supposed to be contained in the tertiary area by a Penstock Valve, which, as is almost universally the case, failed to seal, and failed to stop the flow. Indeed, it is likely that the Penstock Valve never sealed in the first place because nobody had inspected it to see if it ever actually worked. So the Penstock Valve failed to seal, allowing the flow from the drainage network, from the bunds in the ground and the tertiary bunds to escape directly in to the nearest river. You can look this whole incident up because it’s quite an easy one to find, there was a huge amount of fish killed and this represented a major water pollution incident.
So, the site is burned to the ground and they can’t now rebuild the business on that premises because the regulator and the local authority are refusing to allow them to rebuild on this site for this purpose or give them operating permits for a new site until they could evidence that they had systems to contain firewater.
The regulator said essentially that “enough is enough.” The business had been responsible for a major pollution event, in fact this was their second pollution event in ten years, although the two incidents were quite a distance apart. This is the impact of getting water pollution prevention wrong. This is a business that has a factory that’s burnt to the ground, who, even though they thought they’d got their water pollution containment right certainly hadn’t in an evolving regulatory environment and now had to find a new site and demonstrate that they ahed the necessary protections in place.
When they found themselves under prosecution they were unable to evidence what water pollution containment they had in place. Now they were in a situation where two hundred people had to be laid off, they have a factory to build and the regulator are refusing them operating permits.
To regain their operating permits they had to prove to the regulator that what they were going to design and implement would effectively contain firewater, which is when we were invited in to support them with this challenge. The big challenge at that time is that we didn’t have CIRIA c736 for guidance. Everything we were presenting to them about firewater containment at that time was assumption based. CIRIA c736 hadn’t been completed at this time, in fact it hadn’t really been started. We only really started on CIRIA c736 as we started this project so all we knew for certain is that we had to deliver an effective firewater containment solution.
Our proposal was that the firewater should be contained in the tertiary area. We were not so worried about the bunds, the real pollution risk is the area outside of the factory and we set about designing a solution to address that particular risk.
The major challenge here is how to protect Harrow Brook?
How do we start it?
What do we look at?
The first thing to understand is the drainage system. We do this by mapping the drainage pathways using a visual, we don’t do a CCTV unless it becomes apparent that the area where we are going to be containing the pollutant materials are not in good condition. We did a visual inspection using by lifting the chambers, measuring the depths and building up a topography of the site.
What we are looking for here is the water levels which dictate the required height of the retaining walls. What was really important in this case is that we block the pathways, especially considering that the drainage system was also used for foul waste drainage on this site. We had to inspect all of the manhole covers inside the tertiary catchment area where the retaining wall was proposed. In the event of a spill these manholes would be a pathway that would take the pollutant material, potentially including cyanide, into the foul sewer. All foul sewerage had to be separated with sealed manhole covers so that it wouldn’t mix with any materials that we may need to contain in the future.
We also proposed two ToggleBlok valves that would be automatically triggered in the event of a power cut or fire alarm and could be activated remotely from a control room. These pollution containment devices were positioned strategically at the point where the drainage systems filtered into the surrounding environment, and close immediately on activation and effectively contain any pollutant materials.
Below you will find a Google image of the site which was taken after we completed the job. You can see where we have placed the valves – Valve 1 and Valve 2. The new facility used to be a storage depot and wasn’t designed as a COMAH site. It wasn’t designed as a plate work, and the new sites primary function was as a plating facility. Because they were redeveloping this site there was the opportunity to include modern bunding and all the protection required of a COMAH site. Working with the client we designed this whole system to enable the complete isolation the drainage system which continues valve points with valves that close immediately on activation.
Penstock Solutions proposals, with some minor adjustments proposed by the customer, were implemented over three days. This enabled Abbey Metal Finishing to reapply for their operating permits and put the new site into production. The operating permits were issued successfully and the new site was up and running within two years of the incident. They have recently updated the containment devices to newer versions.
Abbey Metal Finishing is a really key site because it appears in the guidance. Graham Vaughan who was the Environmental Manager at the time, was the individual who was prosecuted and is still under caution for the pollution incident that happened in 2013. He became a great deal of support for me in the work that I did contributing to the writing of the CIRIA c736 guidance. He invited the whole CIRIA c736 team to visit the site and see what we had built together. It is also out of this close working relationship that we further developed our solutions to include Spill Mapping which is essentially an animation of worst case scenarios and takes even more guesswork out of the process.
Please remember that the work that I am sharing in this case study happened prior to CIRIA c736 being produced, presented and implemented. I am posting this because the work that we did with Abbey Metal Finishing and the system that we implemented was most likely the first ever CIRIA c736 compliant water pollution containment system.
Finishing project we were innovating, we looked at what everybody else was doing, leveraged the limited amount of technology and data that was available, developed some topography, inspected the drainage system and had to trust the assumptions that the walls were right from our drawings. We didn’t have a roadmap to follow and this for me is the best thing about the CIRIA c736 guidance, which is what we hope you are referring to. CIRIA c736 provides a starting point for all of our future work, we now refer to CIRIA c736 every time we undertake a new project to ensure that the work that we do is compliant. CIRIA c736 includes examples like Abbey Metal Finishing so that you can be assured that the systems that you implement will not only comply but give you failsafe protection against the risk of your business causing water pollution.
One last thing that you should note when it comes to considering your water pollution risk is that the regulatory landscape has moved on again with the Sentencing Guidelines that were introduced in 2015. The Sentencing Guidelines were changed to make the entire group of companies liable for the damage caused with the fines based on group company turnover rather than just the subsidiary. If Abbey Metal Finishing, as part of a big American investment group, were to be fined for a similar event now the fine would likely be ten times the amount they were fined in 2013. The regulator and the courts have worked together to ensure that water pollution is taken seriously and have acheived this in the approach they have taken to fines and sentencing since.
The technology has also moved on with our pollution containment devices evolving to be easier to instal and more connected to allow all manner of activation types. We have also developed our Spill Mapping service which animates the worst case scenario and empowers boards to make decisions about there water pollution prevention investments based on their actual risk rather than an unevidenced guesstimate of what could possibly happen.
David Cole MSEE
David is a pioneer of the spill containment and water pollution prevention industry with 30 years experience. He was instrumental in the development of CIRIA736 with The Environment Agency and is passionate about preventing water pollution.