Up to scratch on the EA’s Regulatory Policy Statement?

Dr Richard Coulton, CEO at Siltbuster, talks to FC&A about what the Environment Agency’s new Regulatory Policy Statement means for those working within the construction industry.

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he Environment Agency’s new Regulatory Policy Statement (RPS) sets out the circumstances under which water can be discharged off site without the need for a Bespoke Discharge Permit. It also states that contractors need a permit if they want to discharge off site into the surrounding environment anything other than clean water. This comes in the context of the Environment Agency recently prosecuting a Leeds-based house-building company £120,000 for illegally polluting a watercourse, by not controlling silty run-off.

It should be noted that the new sentencing guidelines remove any economic benefit derived by committing the offence, always making it cheaper to prevent the pollution incident. “It should not be cheaper to offend than to take appropriate precautions,” Judge Francis Sheridan said at the trial of Thames Water, fining them £20m for polluting the river.

Before work starts

Given that most UK soils contain silts or clays, almost all construction projects will potentially generate unclean wastewater. Therefore, any construction work that companies predict will not meet the criteria outlined in the RPS must have a Bespoke Discharge Permit.

This means that contractors need to be better prepared than ever, forcing them to be more proactive in their planning around the management of excess waters on-site. They will need to implement accurate and clear plans to either treat the wastewater on-site, or find an alternative, and often more expensive, disposal route, either by tinkering off site or discharge to a sewer which requires prior approval of the local utility company.

As a collective, the construction industry will have to be more aware of the issues surrounding wastewater and, in turn, become more educated on the appropriate water treatment solutions available prior to carrying out any pumping. In fact, those in charge of sites will need to be able to distinguish between clean excess water due to rainfall and contaminated/dirty water created by construction processes and silt-polluted site run-off in order to minimise volumes requiring treatment.

Planning is paramount

The RPS effectively makes the preparation of a Site Water Management Plan prior to commencing work mandatory, no matter if a Bespoke Discharge Permit is required or not. For those sites that require a permit, a clear and well-thought-out plan is essential, not only to guarantee a permit is granted but also to ensure the smooth running of the project.

The plan must:

  • Endeavour to minimise risk and the amount of contaminated water generated by isolating clear surface and groundwater as far as possible from construction activities.
  • Isolate concrete wash water and any potentially oil-contaminated water from the rest of the site.
  • Estimate the amount of contaminated water that will be generated and put in place suitable treatment methods.
  • Include contingency plans to cover the scenarios that are unlikely, but still possible.
  • Demonstrate adequate site operator training and awareness of the environmental issues associated with the risk of waterborne contamination.
  • Document the procedures put in place and provide evidence of compliance.

Act now

Complying with these requirements clearly represents planning and a major increase in workload for engineering and environmental departments. It requires specialist knowledge of not only the proposed construction works but also hydrology and appropriate methods of water treatment.

To help companies prepare, Siltbuster provides technical support, CPD-accredited courses plus bespoke and tailored technical training days.

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