What is Environmental Permitting? Transcript.
Speaker: Hi, my name is David Cole and I’m Technical Director of Sandfield Penstock Solutions, and I’m going to talk to you a little bit about Environmental Permitting.
What is Environmental Permitting?
Speaker: So, an Environmental Permit is something that you may need in your business to allow you to actually trade, like discharge consent permits for example, to allow you to get water or liquids off your site into local brooks and streams.
When is an Environmental Permit required?
Speaker: Various Environmental Permits may be required, which are particular to different types of businesses. There is an assessment that you’ll need to carry out using the Environmental Agencies tools that you can find on their website to see which permits may be required for your sites. A lot of companies will use outside consultants to decide where they sit if a an Environemental Permit is required. So, if you’re a waste management site, or if you’re a food processing plant, you will need to go through those applications. From those applications, you’ll follow a process, which will involve the ENvironemnt Agency or Local Authority to look at where you want to discharge your water, what your consent levels are, and what that impact is, and what protection your business has in place if things go wrong.
So, if you start a new business and you fall under the permitting regulations then you’re going to have to have a permit. Often there are businesses where they might install an Effluent Treatment Plant, for instance, which will mean that they’ve got a deviation on their permit and it will have to be reviewed or a new permit applied for. If you chang the way your business takes operates; a factory that expands and builds another production line, for example, these ttpes of changes will require a review of a permit that might be in place. Once that happens, obviously, that’s an opportunity for the regulator to say, well, there are some changes, the permit that you’ve had for the last 10 years, things have changed and it needs reviewing. They may also take the opportunity to look at other areas, we’d like to look at what is your impact on the environment should your production line fail, where that might not have happened on the previous permit, but the new permit might get more focused, and certainly the regualtions and guidances have changed in that time.
What do businesses need to do to acquire an Environmental Permit?
Speaker: To get an Environmental Permit, you’re going to need a Environmental Permitting Consultant or you’re going to need somebody within your business and who meets the permitting requirements and able to complete all of the documentation and evidence is what you’re doing, then you’ll need that to be signed off by The Environmental Agency or the Local Authority. That involves acceptance that what you’re doing has been deemed as controllable and meets the requirements of that permit.
What do Environmental Permits have to do with water pollution prevention?
Speaker: As a business, we’ve been involved in several Effluent Treatment Plant projects recently, where sites have put in a new process to clean up their water discharge, so they’ve got more control. They’ve invested in Effluent Treatment Plants, because a lot of water companies are now saying to sites, “We can’t just take this uncontrolled effluent anymore,” just pimp, maybe pH balance. We actually want you to put an Effluent Plant in place. This involves the regulator by looking at the sites and the regulator is looking at these huge buildings that are going up that contain lots of effluent, lots of chemicals, lots of daf plans, lots of equipment, that if that ever failed, where does it go? Because there is a chance then if that equipment fails, or those bulk storage tankers fail, then instead of a pollution release going down the foul drain, it could enter storm drains – staright into the surrounding environment.
So, there’s a need to look at how that would impact the environment in the event of a failure.
So, we get quite involved now when The Environment Agency are asking our customers; “Well, you have put this new piece of equipment in and that’s great, it’s going to improve your discharge consent for your foul permit, and it’s going to reduce your costs. But if that equipment failed, it could impact the environment greatly. We want to look at your permit and how you would manage an event where if that were to fail, could you contain that pollutant on site?.”
How involved are the Environmental Agency in issuing permits?
Speaker: So, its The Environmental Agency that controls the permit system, and you’re going to need their OK and their support and involvement in any permit application. What you’ll find is, the environmental agency will want to know unless it’s a very, very simple permit. If it isn’t so complicated it won’t require them to turn up. Certainly with our customers’ sites, where they put new Effluent Treatment plants in, that involves several meetings and, and our involvement in that has meant that the Environment Agency has swung around to our customers and reffered to CIRIA c736 asking questions like What is your firewater risk? What is your pollution risk? What is your water pollution containment policy? How would you react if one of your 80,000 liter bulk storage tanks failed? How would you stop that release getting into the storm drain?
Really, the way you should look at it is if you’re putting in for an Environemental Permit, you’re highlighting what your business is doing to the Environment Agency. It’s their job to make sure that when people apply for Environemental Permits, that they do things right and in serious applications there is a good chance that they’re going to get involved with your site.
What is your recommendation for anyone about to apply for an Environmental Permit?
Speaker: I think when you go for an Environemntal Permit you should be looking at what is your potential to cause harm if the worst happens? It’s a difficult subject because nobody likes to talk about catastrophic failure, or a major fire but these things happen every day; they’re always happening. They can happen at any time and nobody knows when. Equipment can fail, and you can have a disaster. Why add to a disaster with something that’s actually an uninsured loss? because by then you’ve actually committed a criminal offence. No matter what you’ve done, or what you’ve tried to do, if you pollute offsite, you’ve committed a criminal offense, and it could result in a huge fine as well the major costs because you’ve got to clean it up.
So, I think when you’re going to do a permit, why don’t you follow our six-point checklist: understand the regulation; understand how the regulation applies to your site; complete a risk assessment; design the system that’s going to contain that firewater or pollution runoff for your site; build that system, install it, get it up and running; monitor, maintain, and document the system that you put in place and be prepared to change it as guidance moves along. If you need to find out more, get in touch with us. Go to www.penstocksolutions.co.uk
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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.