THE POLLUTER MUST PAY

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THE POLLUTERMUST PAY
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the polluter pays......

• who is the polluter..?
• industry must improve practices....
• governments
• may regulate prices so they are not passed on to
  the consumer
• may pass increased costs to taxpayer in
  recognition of social benefit of environmental
  protection

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True costs of resources

• system boundaries
• life cycle costs
• energy
• materials
• opportunity loss
• Industrial pollution -
  dereliction of society in imposition of
  constraints

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(No Transcript)
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What is pollution?

• EU 1996 IPPC Directive
• ..shall mean the direct or indirect introduction
  as a result of human activity, of substances,
  vibration, heat or noise into the air, water or
  land which may be harmful to human health or the
  quality of the environment, result in damage to
  material or property, or impair or interfere with
  amenities and other legitimate uses of the
  environment.
• Generally pollutants have a threshold for damage

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Substances without impact (known)

• Contaminate
• strictly means not harmful
• Language means that different cultures see
  pollution differently -
• in Germany word for pollution means dirt

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Societys changing view of pollution

• Pollution is a sign of healthy industry
• limited scientific knowledge
• or deliberate ignorance
• Systems must now be assessed holistically - and
  must be sustainable, but
• ...the polluter must pay...

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Sustainable wastewater?

• Agenda 21 - equal access to worlds resources for
  all
• Developed world sanitation?
• Unsustainable
• energy
• nutrient cycles

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POLLUTION IS.................
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....often natural
evolution relied on pollution......
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Sources of industrial pollution

• Emissions - too much or in the wrong place
• The acceptable may become the unacceptable as
  knowledge develops

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Examples
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Primary water pollutants

• Soluble organics - deplete oxygen
• Suspended solids -
• adhering pollutants
• blanket the bed of watercourses
• heavy metals, cyanide toxic organics
• priority pollutants - new complex synthetic
  compounds

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primary pollutants

• colour turbidity - aesthetic and light
  penetration problems
• nutrients - eutrophication
• oil and other floating material
• other volatiles - e.g. H2S and VOCs

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Air pollutants

• Limitless in range
• particulate
• oxides
• Health effects - acute or chronic
• Impacts - diverse
• New problems arise as soon as old ones are solved

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Sources - water

• direct emissions
• urban drainage
• poor storage practices
• materials in transit
• leakages due to decay of containment systems
• diffuse sources

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On-site treatment/sewered discharge?

• with or without resource recovery
• residual effluent and sludge
• discharge to municipal sewerage
• direct discharge to watercourses

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Sludge

• On-site treatment generates sludge
• landfill ?
• incineration?
• agriculture?

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Co-treatment with municipal sewage

• In sewers?
• volatility
• hazard to health
• corrosive
• odourous

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Co-treatment

• At WTP?
• treatability?
• toxicity?
• sludge disposal route?

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Co-treatment

• In aquatic system?
• toxicity?
• degradability?
• persistence?

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E
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Integrated perspectives

• re-use
• recycling
• recovery of substances
• some treatment techniques may not be best for
  this - oxidation?

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To treat on-site or not?

• Complex decisions
• best available technology
• charging structure
• waste management licenses?
• Trade effluent charging
• England Wales - Mogden formula
• increases K factor inflation

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Mogden formula

• CR(VVB)B(Ot/Os)S(St/Ss)
• or VM or V
• C total charge for trade effluent treatment
• R Reception and conveyance charge
• V volumetric and primary treatment cost/cu.m
• VB additional charge where there is biological
  treatment
• VM treatment and disposal cost for sea outfalls
• M treatment and disposal costs for designated
  long sea outfalls
• Ot COD of effluent after 1hr settlement at pH
  7
• Os COD of crude sewage after 1hr settlement
• B biological oxidation cost/cu.m of settled
  sewage
• St total suspended solids (mg/l) of trade
  effluent
• Ss total suspended solids (mg/l) of crude
  sewage
• S treatment and disposal cost of primary
  sludges/cu.m of sewage

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Problems with formula approach

• Regional strength of sewage apparently changes
  annually/around country
• Does not include heavy metals or toxic organics -
  likely to be introduced 2/3 yrs
• No benefit for easy to treat wastes - may provide
  e.g. nutrients
• Differences in application -

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STRENGTH OF SEWAGE COD (mg/l) 1995/6
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TRADE EFFLUENT CHARGES for 1 tonne COD/day 200
cu.m/d, 5000mg/l COD, 1000mg/l SS (1995/6)
Nil
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TRADE EFFLUENT CHARGES for 1 tonne COD/day 200
cu.m/d, 5000mg/l COD, 1000mg/l SS (1995/6)
Pick your area to set up in Business
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TRADE EFFLUENT CHARGES for 1 tonne COD/day 200
cu.m/d, 5000mg/l COD, 1000mg/l SS (1995/6)
Trade effluent charges risen more than other
charges since privatisation
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Standards

• Often set to protect a sub set of the environment
• Thresholds
• e.g. NOEL - No effect level in toxicology
• Where no threshold level - requires risk
  assessment (minimal/managed effects)
• Carrying capacity precautionary principle

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IPC

• Regulates most polluting/complex processes - SEPA
  (Formerly HMIPI)
• Application of BATNEEC to ensure BPEO
• EU Directive on Integrated Pollution Prevention
  and control (IPPC) - also requires energy
  auditing (unlike UKs IPC)

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UK INDUSTRIES TO WHICH IPC APPLIES
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PRESCRIBED SUBSTANCES FOR RELEASE TO WATER FOR IPC
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Air pollution

• 1990 Environmental Protection Act
• administered by bodies created in 1995
  Environment act
• IPC baseline - consider all media together
• Derived from BPEO (1976 Royal Commission on Env,
  Pollution)
• Covered most polluting emissions - BATNEEC

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Air pollution

• UK National Air Quality Strategy 1997
• Or EU legislation
• Primarily protect health (not environment)
• Important international control problem
• Little effective attempt to control agriculture

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Solid wastes

• New regulations now very complex (not understood
  by SEPA!)
• UK national waste strategy - 3 years in the
  making (June 1998, consultation paper). Still not
  out.
• Waste hierarchy (EU perspective) is naïve
  (ignores transferability).
• Packaging Directive to be revised

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Future

• Producer responsibility
• In France/Germany obligations on producers
• Environmental liability - polluter pays
• More moves toward consumer responsibility
• design of products to minimise both waste and
  packaging

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Smaller discharges

• Local Authority Air Pollution Control (LAAPC)
• standards set nationally, monitored locally
  (SEPA)
• Some discharges not covered
• AmmN from agriculture
• Sewage sludge or sewage effluent

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IPPC Directive 1996

• Regulates - industries
• energy
• metals
• minerals
• chemicals
• certain others
• Regs to be in place by Oct 1999

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IPPC principles - BPEO

• One step further than IPC
• Preventative measures in place
• no significant pollution caused
• waste minimised
• energy efficiency
• follow-up measures once production ceased to
  prevent subsequent pollution
• New Directive for small industries

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UWWTD

• Expensive for Scotland
• With a lot of new sludge
• Typical TE consents in England Wales for
  discharge to municipal system
• 3000-5000mg/l COD
• where lt500mg/l on-site treatment essential
• Reductions required in any case of 50 in
  suspended solids and 20 in BOD in sewage

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UWWTD compliance

• For domestic sewage - achievable with primary
  settlement
• Without suspended solids (but with a higher
  strength TE) may be more difficult and requires
  biological or chemical treatment
• UWWTD also targets 11 specified industries
  producing biodegradable wastes

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Dangerous substances

• toxic
• persistent
• bioaccumulative
• Specified in EU Directive (1976)
• List I (black list) - controlled by UESs
• List II (grey list) - controlled by EQOs
• North Sea
• Red list - minimise discharges via BATNEEC
  (Reduce by 50 by 1995)

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REDUCTIONS IN TOTAL LOADS OF SOME RED
LIST SUBSTANCES UP TO 1993 - TAYSIDE REGION
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Site and Urban Drainage problems

• definition of trade effluent
• may include surface water
• separate storm drainage may be highly polluting
• storage yards
• highways
• construction sites

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Scale of problem

• FRPB - 24 (1994) of poor quality rivers resulted
  from industrial estate runoff
• fuel oils most industries
• gas oil
• diesel
• lubricating cutting oils light/heavy
  engineering/motors
• cadmium other metals cable manufacture
• yeast, beer, Fobb brewing
• fermenting grain animal f eeds, granaries
• caustic alkali, acids chemical industries
• sodium bisulphide
• detergent, grease oil , silt and grit industrial
  premises with vehicles
• flour, sugar, other degradable materials food
  processing

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Industrial estates

• Contamination from
• intermittent incidents (diffuse)
• gross spills from inadequate storage and handling
• wrong connections
• current planning and design system -
• ...little option but to cause pollution...
• ....problem is extensive, chronic, severe and
  unresolved...

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Highways

• Diffuse or point sources
• Designed or accidental
• e.g. 120 spillages per annum in London area
  (1993)
• 200-300 chemical spillages p.a.
• oil, petrol, chemicals, dyes, pesticides,
  fungicides, beer, paint, adhesives, sludge,
  offal, milk

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Contaminated land

• 100 million tonnes p.a. controlled waste
• 90 to landfill
• 3.8million tonnes hazardous
• 2.9 million tonnes sewage sludge included in
  total going to 4700 landfill sites
• Gross pollution of industrial sites - land,
  groundwater

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US nuclear industry

• 17 facilities (1951-)
• clean up costs 300bn - land water
• Uncontrolled until 1986
• Rocky Flats site (Denver)
• raided in 1989
• 8000 chemicals in use
• releases 1975 - 1000x greater than Chernobyl
• No guilt - (1992) but Rockwell fined

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Contaminated land/sediments

• Poor records
• Some coordinated clean-ups
• Netherlands - 10-15 mill cu.m sediments p.a.
• Develops new world-leading technology
• Costs for riparian landowners usually prohibitive
  
• New Scottish Office Guidelines in draft form 1996
  (re-introducing register)

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Groundwater

• Protection zones pioneered by NRA
• nature of water bearing strata
• presence/nature of drift deposits overlying
  strata
• presence/nature of overlying soil
• depth of unsaturated zone
• Use requirements
• aquifers
• minor aquifers
• major aquifers

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EU Directives

• Groundwater Landfill
• prohibit list I substances
• prescribed substances
• monitoring
• will end practice of lagooning substances

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CHANGING PERSPECTIVES

• Uniformity in Scotland
• Levelling UP of TE charges
• -equitable cost distribution
• Difficult cost-benefit equations for on-site
  treatment

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New Scottish water industry

• Scottish WAs at least still public!
• is this good?
• encouraging information exchange
• honest brokers
• greater flexibility
• efficiency investment opportunities
• NO CHANGES to TE charging!

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New constraints

• More than 300 Directives
• environmental law now one of the biggest
  headaches for industry - confusing, but more
  integrated
• Scotland with vast assimilative capacity of water
  courses doesnt need them
• When is wastewater actually liquid waste?
• UWWTD militates against cost-effectiveness and
  sustainability

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Regulators

• New SEPA one stop shop - an integrated approach?
• decisions now not made at a local level
• IPC but not ICP
• Can renege on existing agreements/consents
• but...point sources largely under control
• Supposedly wish to work with encouragement NOT
  prosecutions

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ADVICE TO INDUSTRY

• find another sewer?
• utilise new technologies (bio-)
• diversity and flexibility ensure sustainability
  (i.e. room for expansion)
• housekeeping - recycling, re-use, waste
  minimisation
• Special industries IPC substances - hard luck!

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Law of diminishing returns

• You get less and less for more expense
• Philadelphia
• 464 mill gall/day in 3 WTPs - cost 36,000b.oil
• achieves BOD reduction of 80, SS 85
• New standards
• 90 BOD, 95 SS 2x quality, 7x energy
  239,000b.oil
• 98 BOD, 98 SS further 2x quality plus nutrient
  removal 3x this amount of energy
• HOLISTIC APPROACH?

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True costs?

• Risk, life-cycle multi-criteria analysis
• Question the viability of some (industrial)
  activities
• e.g. Mining - true costs include
• extraction
• clean-ups
• continuing protection
• Who is the polluter?

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CONCLUSIONS

• Local or global sustainability?
• Recycle/recover
• energy
• materials
• Technical solutions are subordinate to political,
  social, cultural and economic criteria!

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The polluters are the people in Society..... who
demand ever increasing standards of living...
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The polluters are the people in Society..... who
demand ever increasing standards of living...
......arent you?