Is your Pollution Prevention Watertight?

By David Cole, Water Pollution Manager at Hydro Consultancy.

The only acceptable kind of pollution risk is one that a business can demonstrate it has taken adequate measures to protect against.  Flooding, pollution spills and fires are not far-fetched disasters that are unlikely ever to befall industrial or commercial premises.  They happen all the time. (Read More)

Providing evidence of how surface water is discharging to the environment should be on the agenda of any company that is keen to act sustainably.  As well as being environmentally unacceptable, inadequate water pollution containment could be very costly.  

Causing environmental water pollution is a risk that many companies may unwittingly be taking every day.  The risk of causing environmental pollution through fire-fighting water is often unforeseen, for example, as is failure to contain spills of pollutants including those carried in surface water flooding on site.

An unexpected pollution incident is likely to land an unprepared operator with significant fines and a substantial bill for environmental remediation.  Insurance cover may not be sufficient to pay for the clean-up costs, in all but the most exceptional circumstances.  In the worst cases, a pollution conviction can even include the option of custodial sentences for company directors.

Notwithstanding a company’s regulatory obligations and noting that in the vast majority of instances the “polluter pays”, the expectations of Corporate Social Responsibility alone (especially for larger companies) make it good practice to demonstrate exemplary environmental compliance.

Managing Flood Risks

Under current planning guidelines, the suitability of a new development is assessed using a system that compares flood risk vulnerability against its compatibility with a flood zone.  The National Planning Policy Framework states that for any “installations requiring hazardous substances consent” such as Control of Major Accident Hazards (COMAH) and Environmental Permitting Regulations (EPR) sites, their vulnerability classification would be “highly vulnerable”.

This would place planning restrictions on such development on the grounds of flood risk in two of the three “Flood Zone” classifications.  But this applies only to new developments and many existing sites are unlikely to have been built according to these guidelines.

So when considering existing “highly vulnerable” sites, it’s a fair assumption that a great many of them are located in a flood zone that is not appropriate to their vulnerability, with the residual flood risks largely not understood.

Flood Risk Assessment

A robust flood risk assessment provided by suitably-qualified experts will identify all sources of flood risk, along with potential flow paths into and out of a site.  A Hazard and Operability (HAZOP) study may also be an appropriate methodology to support an evidence-based understanding of the combined water pollution and flood risks, especially for COMAH or EPR sites.

As part of this process, using hydraulic modelling can be invaluable.  It can accurately map the surface water pathways on and off a site as well as assessing and validating the effectiveness of the drainage system design.

Hydro Consultancy has developed this 2D modelling technique, a pioneering approach that requires an uncommon mix of flood risk and pollution containment expertise.  It can provide an effective method to test the efficiency of containment systems – and provide reliable evidence for regulators and Environmental Management System documentation.

Even for those operators who are already fully familiar with their responsibilities, a comprehensive review could be both timely and highly advisable.

Hydro Consultancy is currently offering free on-site assessments to help companies check their current provision.  Contact This email address is being protected from spambots. You need JavaScript enabled to view it..
www.hydro-consultancy.com