Odour Code of Practice – An Update

Martin Key

Presentation to Scottish Noise and Nuisance Conference,

6 October 2006

The Odour Code of Practice

Life Before the Odour Code of Practice

• Difficulties enforcing Environmental Protection Act 1990 at WWTW throughout UK

• EC Directives on Water Quality driving enhanced treatment

• Volume of complaints increasing annually

• Parliamentary pressure for new legislation

Developing the Odour Code of Practice

• Formation of SOSG (Scottish Odour Steering Group) with representatives from: Scottish Water Local Authorities Water Industry Commission WaterWatch (formerly WCCP) SEPA REHIS Scottish Executive-Environment & Planning officials and an Independent Consultant

• Voluntary Code of Practice in April 2005 • Water Services etc (Scotland) Act 2005 power to make

statutory Sewerage Codes for assessing, controlling and minimising sewerage nuisance

• Sewerage Nuisance (Code of Practice)(Scotland) Order 2006 dealing with odour from WWTW

Principles of the Code of Practice

• Guidance on odour nuisance assessment - Odour Risk Assessment Matrix

• Hierarchy of controls Management and houskeeping Design, installation and maintenance Optimisation of WWTW operation Containment Extraction of odour and end-of-pipe treatment

• Implement on a stepwise basis to avoid ‘goldplating’

Sewerage Nuisance (Code of Practice)(Scotland) Order 2006

• Baseline management and housekeeping requirements

• Preparation of a phased Odour Management Plan (OMP) (>500pe)

• If odour nuisance still exists, prepare Odour Improvement Plan (OIP)

• Implement measures reflecting BPM from OIP within approved timescales - Balance capital and operating costs with odour significance and impact and avoid disproportionate escalation

• Specifies odour abatement equipment efficiency

OMP – Phase I

• Produced and adopted by 1 August 2006• Generic plan• Summary of WWTW location, receptors, sources

and process overview• Management responsibilities (faults, maintenance

etc)• Complaints reporting and response procedure• Inspection and maintenance procedures• Spillage management• Operator training • Record keeping (who, what, when, where)• Emergency breakdown response including liaison

with LA

OMP – Phase II/III

• Phase II - ‘standard’ operational and management procedures for the type of plant and equipment in use at a WWTW – 1 January 2007

• Phase III adapts the ‘standard’ to be specific for a particular WWTW – 1 April 2007

• In the absence of continuing odour nuisance, Phase III OMP defines BPM for the WWTW

• Will lead to revised operating methods and require a culture change – facilitated by management

• Format for ease of use and supported by training• Living document - updated regularly and reviewed

every 12-months

Odour Improvement Plans

• Systematic evaluation of the sources and causes of odour nuisance and a review of all available control options to develop a plan detailing the proposed measures to mitigate odour nuisance that reflect best practicable means’

• Phased programme for investigation and implementation Process optimisation Inlet works Sludge handling Storm tanks Primary sedimentation

• Phase 1 submitted by 1 April 2007• OIP content subject to LA approval

Implementing the Odour Code of Practice

• Scottish Water actively working on OMPs and OIPs

• Odour now as level of service indicator for Scottish Water – Q&SIII 35 sites

• Complaint Management• LA Inspection programme – based

on risk assessment• >2000 works in total ; ~400 require

regular inspection• LA Enforcement – able to serve

enforcement notices for breach of Code

Supporting Implementation – The Role of SOSG

• Oversee the production and implementation of the Code

• Identify and prioritise the 35 worst offending sites Q&SIII

• Act on behalf of and report to the Capital Monitoring Group on odour and oversee and sign-off the agreed abatement at the 35 sites

• Support LA enforcement through on-going training

• Facilitate a web-based ‘Odour Hub’ to act as a central clearing house for all complaints

Odour Code of Practice – An Update

Thank You