Develop an Environment Management System for the discharge of up to 20 cubic metres per day of sewage effluent
If you have a permit for the discharge of up to 20 cubic metres per day of sewage effluent to groundwater or to surface water, you can use the following structure for your management system. It’s designed to help you meet the requirements of your permit conditions.
It will need to be modified to suit your site as some parts won’t be relevant to your operation and you may need to make some additions.
If the treatment plant is shared with others (for example multiple houses), you are all jointly responsible for the proper operation of the plant, but you only need one management system.
Your management system needs to be proportionate - a householder with a small plant serving their own house may not need specific training but must be aware of their responsibilities and the requirements of the permit.
An owner and/or staff of a sewage treatment plant serving a hotel, pub or campsite need to be adequately trained and competent to run the plant.
Type of treatment plant
Your management system should record the following information about the treatment plant
- type – for example a package treatment plant or a septic tank
- make
- model
- installation date
- who installed it?
- capacity
Prepare your site infrastructure plan
Your management system must include a plan of your site, drawn to scale. It must show:
- your wastewater treatment plant
- monitoring points - the locations from which you will take samples to check for contaminants or pollutant substances as required by your permit
- the location of emergency equipment
- the location of any mitigation measures referred to in your management system
- the outlet to surface water (standalone water discharges only)
- the infiltration system (standalone groundwater activity only)
Maintenance plans and records
You need a plan for how you will maintain the infrastructure of your sewage treatment system.
You must maintain any machinery according to the manufacturer’s or supplier’s recommendations (for example, following the instructions and guidelines of any manuals that came with your equipment).
You will need to record each time you carry out maintenance. If you have a service and maintenance contract in place the contractor must be trained and competent to maintain and service your particular sewage treatment system.
If you have a contract in place a copy of it must be kept with the Environmental management System along with a record of any work carried out by them
Monitoring plans and records
You should routinely monitor he sewage treatment system and discharge points. For sewage discharges we recommend:
- check to see if the treatment plant appears to be operating effectively, for example no unusual noises, odours and so on. If it is not operating correctly you must contact an appropriately qualified contractor to investigate and remediate the cause.
- ensure that the sample point is accessible at all times. If it’s not accessible, ensure access is reinstated.
- desludging should take place at least once a year or at a frequency specified by the manufacturer
- if your discharge goes to ground check the area through which the infiltration systems runs for any adverse effects e.g. sewage effluent breaking out of the ground.
- if your discharge goes to a watercourse check the discharge point for any adverse effects on the receiving water, the bed of the watercourse, or any plants or animals within the watercourse. Adverse visible effect means dead or distressed fish, other animals or plants in the vicinity of the discharge point, noticeable deposit of solid material; growth of sewage fungus (a grey growth covering rocks or other objects in the receiving water body); or noticeable discolouration of the water flow by the discharge.
If you observe any adverse effects you must contact an appropriately qualified contractor to investigate and correct the fault.
Training requirements
Your management system needs to explain who is responsible for what procedures and who is technically competent.
You need to understand what your treatment plant is designed to do, what its limitations are and the restrictions on its use (for example, chemicals which may prevent it from working properly).
Anyone that inspects, maintains or repairs the system must be adequately trained and competent to do so.
If you are a group of domestic residential properties with a permit to discharge sewage effluent via an infiltration system to groundwater, then you should designate one person from the group to have the appropriate knowledge.
If you have a contract with a manufacturer or service company to maintain your treatment plant then you need to record this. We would not expect you to undertake formal training but you should be aware of your responsibilities and how to do the necessary checks
If you run a larger establishment then you and/or your staff will need to demonstrate you are trained to an adequate level in the necessary skills although you may also employ a contractor to undertake many tasks.
Complaints record
You need a procedure that records:
- any complaints you receive in relation to activities covered by your permit (for example complaints from neighbours about noise, odour or dust from your site)
- how you investigate those complaints
- any actions taken as a result of complaints
It can be used as evidence that you’ve taken appropriate action to rectify any issues if Natural Resources Wales receives complaints about your site.
Accident management plan
You need a plan for dealing with any incidents or events that could result in pollution.
The plan must identify potential accidents, for example equipment breakdowns, enforced shutdowns, fires, vandalism, flooding, or any other incident which causes an unexpected change to normal operations, such as bad weather.
For each potential incident, it must also state the:
- likelihood of the accident happening
- consequences of the accident happening
- measures you’ll take to avoid the accident happening
- measures you’ll take to minimise the impact if the accident does happen
Your accident plan must also set out how you will record, investigate and respond to accidents or breaches of your permit.
Your accident plan must also include:
- the date it was reviewed
- when it will next be reviewed
- a list of emergency contacts and how to reach them
- forms to record accidents on
Consider taking the following actions, if you think they are relevant to the operations you carry out at your site:
- make emergency services aware of your activities
- take out insurance to cover the cost of clean up following an accident
- check whether you’re in a flood risk area and sign up for flood warnings
- develop a system to allow access to important information away from your site
Finally make sure that everyone on site knows about the plan, where to find it, and what it contains. It’s important that they know how to prevent accidents and what to do if there is one
Preventing accidents and what to do if they happen
The examples below set out some things that could go wrong and harm the environment and what to do if they happen.
You should check if you can identify anything else particular to your site that could cause a problem. If you can then add it to the list.
Overloading of treatment works/septic tank due to inadequate sized works/tank being installed
Prevention:
- If any changes are to take place to the property then ensure the treatment works/septic tank is still large enough.
Remedial action:
- Follow your spill response procedure. It describes what to do in the event of a spill and where the kit is kept.
Spillages during desludging of the facility
Prevention:
- Ensure pipe integrity has been tested prior to use and operator observes desludging process
Remedial action:
- Follow your spill response procedure. It describes what to do in the event of a spill and where the kit is kept.
Slow seepage of liquids from the treatment works/septic tank.
Prevention:
- Slow seepage can be less noticeable than spills. Integrity of the treatment works/septic tank will be tested. Treatment works/septic tank will be maintained in line with manufacturer’s instructions.
Remedial action:
- Follow your spill response procedure. It describes what to do in the event of a spill and where the kit is kept.
Releases of untreated sewage; due to faulty pipe work, valves, overpressure, blockages, pump failure, bad weather etc.
Prevention:
- Visual inspection and completion of weekly inspection checklist record. Preventative maintenance regime. Any underground pipes and tanks will be tested for integrity.
Remedial action:
- Follow your spill response procedure. It describes what to do in the event of a spill and where the kit is kept.
Sewage system stops working due to ingress of watercourse floodwater, water from blocked drains or burst mains, due to rising groundwater
Prevention:
- Ensure that no surface water/floodwaters can enter the treatment works.
Remedial action:
- Flood procedure describing what to do in the event of a flood warning such as installation of barge boards, use of sand bags.
Treatment system stops working due to failure of electricity supply
Prevention:
- Provision of alarm on the treatment works to warn operators of power failure.
- Provision of back-up generator should the works require constant electricity to ensure adequate treatment.
Remedial action:
- Utility supply failure procedure describing what to do in the event of services supply failure such as, start up of emergency generator.
Sewage systems leaks raw sewage due to containment failure caused by land movement, impact, corrosion etc
Prevention:
- Provision of secondary containment for hazardous liquids.
- Inspection of primary and secondary containment facilities.
Remedial action:
- Follow your spill response procedure.
Unauthorised entry and tampering or malicious damage to the sewage treatment system and equipment
Prevention:
- Secure treatment works /septic tank.
Remedial action:
- Follow your spill response procedure.