F R E S m A T E R POLLUTION AND INDUSTRIAL PROCESSES: THE REPORT OF THE UK ROYAL COMMlssIoN ON ENVTRONIMENTAL POLLUTION

David Ingham, Drainage Engineering Services, Salford and Ray Baker, University of Salford, UK

The Royal Commission on Environmental Pollution has recently published a report documenting declining freshwater quality in England and Wales. David Ingham and Ray Baker discuss the implications of the report for industrial polluters, particularly the recommendations made to encourage wider adoption of incentive schemes to control water pollution. Reference is made to the Dutch ABC water and soil pollution control framework, applied in several countries in Europe, which may form the basis of innovatory charging schemes at Community level,

Introduction

The background to the 16th Report of the Royal Commission on Environmental Pollution' is the 1990 National Rivers Authority (NRA) survey of the quality of rivers, canals and estuaries in England and Wales. The 1990 NRA survey found a net deterioration of 3.6% in the quality of waters between 1985 and 1990. This reversed an earlier trend of long-run improvement between 1958 and 1980. In its survey of 1990, the NRA gave some reasons for the decline in river quality. It cited three factors in particular. agricultural pollution, sewage works effluents and industrial (or trade) effluents.

The Report emphasises the following features of freshwater pollution arising out of industrial processes:

+ Estuarial pollution associated with heavy industry. In the past such industries have been deliberately located on estuaries and major rivers in the UK (such as the Mersey, Yorkshire Don and Rother and the West Midlands Tame) because of the assumed high assimilative capacities of the waters.

+ Industrial activities. deliberate or othenvise, which contaminate the soil overlaying aquifers. Contamination may be associated with landfill sites, disused industrial complexes, waste disposal points, abandoned mines etc.

4 A significant number of industrial pollution incidents. In 1990 there were 2.800 incidents of industrial pollution reported to the NRA.

+ Pollution which stems from major difficulties in monitoring the complex discharges associated with modem industrial processes. Many components of trade effluent are dificult to identify, hence the environmental impact of the discharges is difficult to assess, and problems arise in seuing consents at levels which provide adequate control. Moreover. effluents from sewage treatment works frequently fail to comply with consent conditions.

4 Problems with surface water sewers. In new developments. and in the upgrading of old systems, combined sewers have been rejected in favour of separate sewers which provide for separate foul and surface water run-off, the latter being discharged to the nearest suitable watercourse. Experience shows that industrial waste is often wrongly connected to surface water sewers.

Following on from the NRA Report, the Royal Commission Recornmendations on Environmental Pollution has looked again in detail at the on Industrial Processes problems of freshwater pollution, and has considered both surface waters and groundwaters. Problems of drinking water The Royal Commision has made Over 100 recommendations are not iddressed directly, except h ~ f a r as Pollution of for controlling inputs of polluting substances to freshwater. surface and groundwaters may make them unsuitable for Three recommendations are especially relevant to industrial abstraction. processes.

The Report has identified four major sources of freshwater Recommendation 14 calls for resources to be made available pollution. These are: to clean contaminated land, in order to protect groundwater.

+ waste. water production and treatment 4 contaminated land 4 transport

Recommendation 40 calls for a radical reappraisal of the polluting effects of untreated surface water discharges from separate sewerage systems.

+ farming, in particular farm waste, high nitrate pollution Recommendation 43 is that leachate should be monitored to determine whether or not a pollution threat exists. levels, and pesticides.

Section 7.9 of the Royal Commission Report deals with industrial processes as sources of pollution. Specifically In addition to specific recommendations, Chapter 10 argues identified are the large volumes of liquid wastes which are the case for broader measures to protect water quality. A produced. Unless appropriately treated and disposed of indus- number of these have implications for industrial processes. trial waste may have a deleterious effect on freshwater life. Among the most important are policies which would support:

12 European Environment

David Ingham and Ray Baker Freshwater Pollution and Industrial Processes

4 recycling and treatment of waste within each industrial plant, as a means of minimising waste and reducing its environmental impact (Para. 10.25).

+ regular monitoring of effluents in order to draw attention to unrecognised pollutants and unsuspected effects (para.10.25).

+ revision of trade effluent consents and stronger enforcement procedures to reduce non-compliance of sewage treatment works caused by industrial discharges to sewer (Para.10.27).

Pollution Charges

The Report of the Royal Commission also makes a number of recommendations for pollution charging schemes which would affect industry.

As far as point discharges into freshwater are concerned, the Commission comes down against economic instruments alone. Traditional regulation must remain in place. But an incentive charging scheme is recommended in order to reinforce the regulatory system. Thus, in addition to the existing system of discharge consents, the charging scheme should also reflect the volume and content of effluent as specified in the discharge consent (Recommendation 76). Higher charges should be made if monitoring yields samples which exceed consent levels. Reductions in charges should be made where discharges are reduced below consent levels. In addition it is recommended that possibilities are explored for innovative charging schemes which would reduce pollution from diffuse soucces @kcommendation 78). There is a further recommendation, (Recommendation 79), that the income from the new pollution charges should fund a scheme to provide grants to industry for investment in pollution abatement.

Road Drainage Systems

The Report of the Royal Commission deals a t length with the problems associated with road drainage systems. Particular stress is placed on pollutants such as heavy metals, oil and fuel which are washed, directly to watercourses. off roads and from large paved areas such as car-parks or to ground- water via soakaways. Additionally, sediments may build up in gully-pots to be discharged in the first flush of water after heavy rain, directly into watercourses or indirectly into watercoums via storm overflows in the sewerage system.

Surface water drains on industrial sites cany a potential pollution load. Much that is in the Report on road drainage systems is clearly relevant to drainage systems on industrial s i t s . On industrial sites surface water drains (also referred to as clean water drains or storm water drains) cany rainwater run-off from roofs, roads and large paved areas. There is always the possibility of contamination from vehicles, from accidental spillages, or from washdown of plant operations.

Pollution from Pipelines

As an adjunct to the main Report of the Royal Commission, consultants were inviwl to prepare reports on specific aspects

of freshwater pollution and its controls. These are available in a separate publication. An Addendum to the consultant's Report on Transport Pollution covers pollution from pipelines. The main objective i s to provide an account of the mechanisms and processes which give rise to pollution from pipelines. Foremost in the mind of the Commission was the loss of crude oil in the Mersey Estuary in 1989, following the rupture of the supply pipeline between the Oil Refinery and Oil Terminal on the Mersey Estuary.

Consultants reported that failures in European pipelines could be ca tegor id into five areas: pipe defects. pipe corrosion, external impact, environmental factors, and operational factors. Corrosion and external impact together constituted the largest single cause of failure. The consultants recommended frequent monitoring of pressur id supply pipelines using:

+ pressure drop detection methods for leak, + "intelligent pigs" for internal inspections, and; + pipeline protection measures such as concrete slabs at

likely impact points.

The Royal Commission endorsed the consultants' conclusions, adding that as age may also contribute to pipeline failure, the failure rate of oil, gas and chemical supply pipes is likely to increase with time. Continued vigilance is therefore necessary. The Report concludes that '...frequent monitoring of the condition of pipelines and the use of additional pipe protection measures would help to reduce the risk of pollution' (Para 1034).

An aspect of pipeline failure which might perhaps have been given greater attention in the Report concerns the distinction between major accidental discharge from pressure supply pipes and longer run undetected leakage. The Report is concerned primarily with pollution to freshwater from major incidents. But small discharges of hazardous or toxic substances from pressure supply pipes can cause significant pollution through time. There is no such thing as a small or harmless loss of fluid from a pipeline carrying a toxic or hazardous product Undetected, there will be major problems of pollution in the long-run. One or two drops per second from a leaking joint adds up to hundreds of gallons in a year.

The Royal Commission was also concerned with pipeline construction as a major pollution risk to freshwater. Q u e ~ t i 0 ~ a i 1 - 1 ~ submitted to all regions of the NRA. and to the Scottish River Purification Boards by the consultants, suggested that this was a major concern. Pollution risk was associated with the diversion of river routes, disturbance of river beds, and spillages of materials from construction sites. The Commission concluded that pollution risks originating in pipeline construction could be reduced by better site management procedures during pipelaying.

Diffuse Sources of Pollution on Industrial Sites

Much of the research work which has been carried out on pipeline failure in the UK has concentrated on pressure pipes i.e. major incidents or leakages in water distribution systems,

European Environment 13

Freshwater Pollution and Industrial Processes David Ingham and Ray Baker

and in supply pipes for hazardous and toxic substances. Little attention has been paid to gravity pipes in the drainage system. This lack of emphasis is reflected in the Report of the Royal Commission. On industrial sites, however, drains may be carrying toxic or hazardous substances. Small discharges, even in low concentrations, may have detrimental effects on soil and groundwater if they remain undetected over a significant period of time.

As in the case of supply pipes, corrosion and external impact are likely to constitute important causes of failure. Corrosion may be exacerbated if drains are. conveying c o m i v e or abrasive fluids. Concrete pipes in particular are susceptible to Ph levels, sulphate and nitrate attack. Clayware pipes are brittle when subjected to ground movement They may present considerable problems in mining areas where there is subsidence, or in clay where there is soil shrinkage. Third party damage is a perennial problem, especially from mechanical diggers excavating or operating near buried effluent pipelines.

There are two additional probAems which are of special relevance to drainage systems on industrial sites:

+ drains on industrial sites may be run at high temperatures leading to failure especially if the drain is already subject to corrosion. Drains may also be used for a variety of fluids which may render operations outside of design limits.

+ many drains on industrial sites are permanently surcharged (often to prevent explosions). Surcharged drains leak considerably more than unsurcharged drains, even when operated within design limits.

Cross-Media Transfers of Pollution

A concern of the Royal Commission in this and in previous Reports, has been to avoid crossmedia distortions. The principle that the "polluter pays" underlies the call in the Report for an incentive charging scheme, in addition to the existing system of discharge consents. The problem is that if incentive charges are imposed for water pollution, dischargers may be encouraged to disperse waste using other environmental media, i.e. the air and the land. The outcome may be that the discharger will not select the best environmental option for disposal of waste.

To avoid cross-media transfers of pollution the Royal Commission recommends that the Government should examine the scope for the introduction of appropriate market mechanisms for the disposal of pollutants to air and land (Para. 8.60). (e.g. The market could be used to prevent a reduction in water pollution at the expense say of an increase in the volume of sewage sludge disposed in landfill sites, through a rise in the relative price of sludge disposal.)

Cross-Media Distortions from Diffuse Sources

The discussion on cross-media distortions in the Report refers to point sources of pollution i.e. identifiable discharges from

industrial processes, covered by a form of consent which sets limits for the substances that can be discharged in effluent But the discussion should alert us to a more general problem which can arise in relation borh to point and to diffuse sources of pollution.

Diffuse sources of pollution from industrial processes are difficult to identify, but tend to be dispersed through the drainage systems on industrial sites, or to be found as run-off from roads, buildings and paved ~re8s, or as leachate from disposal sites. Regulations and incentive charging which relate only to point sources of pollution may, by default, discourage interest in, and incentives for, the abatement of pollution from diffuse sources on industrial sites.

The Royal Commission recommended that the Government encourage the EC Commission to explore the possibilities for innovative charging schemes as a means of reducing water pollution from diffuse sources. The Commission concluded that some of the most serious problems of freshwater quality in the UK are the result of pollution originating from diffise sources (Para 1057). Specifically mentioned are storm overflows, surface water run-off, accidental discharges and activities that risk pollution.

As far as industrial processes are concerned, drainage systems for example represent a largely unrecognised and unresolved aspect of pollution from diffuse sources. Regulation and/or market incentives are likely to be complicated by the following special considerations:

drainage systems are gravity operated. Pipeline modelling appropriate to pressure pipes cannot be used to detect leakage. inputs and outputs are difficult to measure. Connections may be numerous and unrecorded. There may be a high level of infiltration of defective pipes which complicates flow measurement leakage detection methods which operate from within drains may be adversely affected by aggressive chemical environments.

The Dutch ABC System

Innovative methods of measuring (and possibly charging for) diffuse sources of pollution from industrial processes are likely to be based on some variant of the Dutch ABC system. This has the advantage of offering a simultaneous considera- tion of the effects of pollutants on both groundwater and soil.

In the Netherlands, Germany, Canada and the USA there has been much greater concern expressed than in the UK over the possibility of long-term contamination of groundwater from industrial sources. including leakages or spillages from pipes or tanks. In these countries the aim is to clean up contaminated sites such that they cannot affect groundwater. Groundwater must also reach drinking water standards. The effect has been that technologies are being developed to remove pollutants from soil down to background levels. The approach is to set standards for concentrations of contaminants in both soil and groundwater.

~~~ ~~ ~~

14 European Environment

David Ingham and Ray Baker Freshwater Pollution and Industrial Processes

ystem

Groundwater (mgfl)

A B C

1 2.5 10 20 50 200 20 50 200 2o *O0 ~

100 500 2000 10 100 300

1 30 100

0.01 0.2 1

The Dutch ABC system (set out in the Dutch environmental improvements in regulatory controls and monitoring. The programme, 1987) adopted for both soil and groundwater: recommendation that the Government should consider

introducing a scheme for grants to industry for pollution 4 an "A" Value, a reference Value below which there n0

demonstrable pollution. commended. 4 a "B" value, an assessment value, above which a pollutant

should be investigated more closely a "C" value at which the pollutant requires treatment

abatement, funded by income from the is ah to be

The Royal Cornmission is also aware that the principle that the polluter should pay for discharges into water only. could

1. Royal Commission on Environmental Pollution, (1992). Freshwater eal i ty . Sixteenth Report, Cm 1966. June.

2. UK Department of Environment, (1989) Agreed 'Red List' of Dangerous Substances, April.

3. Royal Commission on Environmental Pollution, (1992) Freshwater Quality, Additional Report Undertaken for the Royal Commission on Environmental Pollution, London mso.

4. Institution of Water and Environmental Management, Symposium on the Development of Contaminated Land, 2nd October 1990

5. Keuzencamp, K., (1990). 'Dutch Policy on Clean-up of Contaminated Soil', Chemistty and Industry, February 1990.

6. Mull, R., Harig. F. and Pielke, M., (1992) 'Groundwater Management in the Urban Area of Hanover, Germany', Journal of the Institution of Wafer and Environmental Management, V01.20, N0.2, April.

7. official Journal of the European Communities, No.C176/3,

Table 1 below illustrates the operation of the system for certain contaminants. The Dutch ABC system is used in many countries including Norway, Denmark, Germany and Canada. Threshold levels are set low in comparison with the UK's existing regulations. and a wider range of potential pollutants is covered. For example, the threshold level (level A) for soil concentration (mglkg dry matter) in the

Inorganics 0r S

lead to distortions as polluters switch to other environmental media, air or land, to dispose of waste. Wonies on this score are enhanced rather than mitigated by the proposals for a new independent environmental agency in the UK, which according to some critics is largely water-orientated with very little in the way of information on proposals for reducing air pollution for instance.

20 50 300 2 20 200

Netherlands, for Cadmium (Cd), is 1. In the UK it is 3, i.e. the concentration permitted for certain planned uses. For the action level (level C) the Netherlands figure for PAH is 70 industrial processes, for example the mglkg dry matter. In the UK the comparable action level is 500 mglkg dry matter.

has been unable to make much progress in pollution from diffuse sources deriving from

of the drainage system on industrial sites. Leaking Sewers and drains have received little attention in the UK where the emphasis has

The simultaneous coverage of the effects of pollutants on been on infiltration rather than exfiltration. Studies elsewhere groundwater and on soil in the Dutch BC and dmilm in Europe indicate that leaking drains and %wets can systems, my indicate a first stage in the development of a contaminate groundwater. at's. nitrate and sulphur in the

media transfers of pollution. It may also provide the basis for drains and the innovatory charging schemes for diffuse sources of

noted, however, that such charging schemes are likely to be establish precise link between environmental and diffuse sources of pollution. It is likely that the innovative

framework as demonstrated by the lower threshold a d action charging s&emes called for by the Royal Commission as a means of reducing water pollution from diffuse sources will levels of the Dutch system. take some time to develop. Use may well be made of

Conclusion environmental standards based on the Dutch ABC system which are wider and more consistent than the current UK and

Pollution from industrial processes does feature in the Royal EC standards, and have the advantage of simultaneous Commission R e p a on Freshwater Quality and there are a consideration of groundwater and soil pollution effects. number of worthwhile proposals based on the principle that the polluter pays, as well as recommendations for

regulatory and/or market framework to discourage cros- aquifers have been shown to be associated with leaking located above the groundwater mface-

pollution called for by the Royal Co&on. It is to be A bowledge of Particular Site conditions is b d e d

a much more stringent

References Table 1: Examples of the Dutch ABC

Soil (mg/kg dry) Pollutant

Metals Cd Cr c o Ni

- 1 5 20

100 250 800 20 50 300 50 100 500

Chlorinated Hydrocarbons

Mineral Oil

0.05 1 10

100 1000 5000 Communication from the Commission to the Council on Dangerous Substances in List I , July 1982. 2o 2oo 600 1

European Environment 15

BUSINESS STRATEGY and the ENVIRONMENT

CONFERENCE Leicester Business School September 1st-2nd 1992

KEYNOTE SPEAKERS Carol Chnrlton. Landbank Envtronmental Research and Consulting

Edwln Datschdski. Manager, Business and Environment Programme. The Environment Council Andrew Lees. Campaigns Director, Friends of the Earth

David Wheeler. General Manager, Environmental Affairs, The Body Shop International plc Giles Wybnrd. Special Adviser. International Chamber of Commerce. Paris

OTHER PAPERS WILL INCLUDE:

Sustalnable Development: A Challenge for Dutch Industrp? ErlcJan Tuininga and Peter Groenewegen. VrtJe Unlversitelt. The Netherlands.

M- Environmental Factors in Product Development Nlgel Roome. Manchester Bushess School and Mark Hinnells. Manchester Polytechnic.

Ecology and Senior Management. A Stikker. Ecological Management Foundation. The Netherlands.

Qualitative Growth: An Alternative to Conventional Growth Objectives? Dr David Fleming. The Strategy Workshop.

Managing the Green Message: Ecological Brand Positioning. Ralph Mehna, Lund University. Germany.

Ranking Industrial Environmental Performance. Walter Wehrmeyer, University of Kent.

E n v i m ~ ~ ~ i e ~ ~ t a l Policy Formdation in The Netherlands T Wolters. TNO Centre for Technology and Policy Studies.

Environmental Risk Management and Insurance Stephen J Cook. AIG Consultants. Green Markets: Myth or Reality?

John Moxen & Allstair McCulloch. The Robert Gordon Institute of Technology. Aberdeen Competitive Podtion and Environmental Performance:

Recycling and the Canadian Paper Industry Vincent di Norela. Barry Cotton, John Dodge, University of Sudbury. Canada

Environmental Pressure and Strategic Response: An Analysis of the Chemicals Industry

Dr Suzanne Pollack. Henley Management College The Greening of Business: State of the Art or Paradigmatic Straightjacket?

Denis Smlth. Liverpool Business School and Paul Shrlvastava. Bucknell University

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16 European Environment