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Evans38004  
#1 Posted : 25 February 2022 09:18:57(UTC)
Rank: Forum user
Evans38004

Hi all,

I'm new to a company that manufacture & place into containers various chemical products & have bee ISO14001 certified for nearly a decade (seems like a open checque book agreement!!) - we will become a COMAH site within 18 months or so due to increased productivity.

We have a standard 12 month SME contract with a national company - wherby we pay them to supply us with water and for them to deal with our sewerage services (metered sewage & highway drainage) 

Being a national supplier they deal with the regional suppliers (water / sewage)

Having read the T&Cs for the contract agreemen, they do not stipulate any restrictions on what we can / can't put into the drains.

Where can I find details of what we're allowed to tip down the drains?

HSSnail  
#2 Posted : 25 February 2022 09:42:47(UTC)
Rank: Super forum user
HSSnail

You should have a "consent" agreament which tells you what you can and cannot discharge.

Dont know where you are based but i found this useful leaflet from Anglia Water

https://www.anglianwater.co.uk/siteassets/business/services/led225-trade-effluent-explained.pdf

Your own are water company may have something similar

Evans38004  
#3 Posted : 25 February 2022 09:50:26(UTC)
Rank: Forum user
Evans38004

Thanks Bryan,

The problem is that the contract is now with a national water company (cost saving) - not a local water provider. 

Our contract with them does not mention any consents / limits of pollutants !

 

Kate  
#4 Posted : 25 February 2022 09:51:47(UTC)
Rank: Super forum user
Kate

Yes, you definitely need a "consent" with the sewerage company.  This sets out what types, concentrations and quantities of effluent you are allowed to discharge. It may be that this exists as a sheet of paper somewhere in the business archives and everyone has forgotten about it.  If you can't find it you will need to approach the sewerage company either to find it in their records or to issue you with one.

This is something that your COMAH inspectors are likely to be interested in.  That's a particular incentive to make sure this is in place.

Kate  
#5 Posted : 25 February 2022 09:55:18(UTC)
Rank: Super forum user
Kate

It won't be in the contract.  It will be a separate document.  And it's the sewerage provider, who may not be the water supplier, who issues it.  There could be something historical if you have changed providers and it would be worth finding it.

"You can't post in the next 0 seconds"

followed by

"You can't post in the next 34 seconds"

thanks 2 users thanked Kate for this useful post.
RVThompson on 25/02/2022(UTC), HSSnail on 25/02/2022(UTC)
Roundtuit  
#6 Posted : 25 February 2022 10:21:23(UTC)
Rank: Super forum user
Roundtuit

Agree with the above the sewage works accepting the discharge will specify the limits on what can go "down the drain" as it affects the performance of the treatment works (at one employment we hade to advise on any plant closure over 24 hours such was our impact) AND impacts upon their discharge performance as measured by the relevant environemnt agency.

At minimum there will be limits on pH, solids (suspended / total) along with Biological and or Chemical Oxygen Demand (BOD / COD) which are used in calculating the charging formula.

There is also a large list of "nasties" which has been around for a long time which should not be present to protect the body of water into which the ultimate discharge is made.

The invoice is a good starting point as this will show how the volumetric charge is calculated.

BEWARE as you are dealing with a national supplier they may be oblivious to your trade effluent.

If you have large volumes or factors that massivley increase the charging rate e.g. solids these are the areas the business would have or be looking to invest on controlling e.g. by recycling, filtering or on-site treatment

thanks 2 users thanked Roundtuit for this useful post.
HSSnail on 25/02/2022(UTC), HSSnail on 25/02/2022(UTC)
Roundtuit  
#7 Posted : 25 February 2022 10:21:23(UTC)
Rank: Super forum user
Roundtuit

Agree with the above the sewage works accepting the discharge will specify the limits on what can go "down the drain" as it affects the performance of the treatment works (at one employment we hade to advise on any plant closure over 24 hours such was our impact) AND impacts upon their discharge performance as measured by the relevant environemnt agency.

At minimum there will be limits on pH, solids (suspended / total) along with Biological and or Chemical Oxygen Demand (BOD / COD) which are used in calculating the charging formula.

There is also a large list of "nasties" which has been around for a long time which should not be present to protect the body of water into which the ultimate discharge is made.

The invoice is a good starting point as this will show how the volumetric charge is calculated.

BEWARE as you are dealing with a national supplier they may be oblivious to your trade effluent.

If you have large volumes or factors that massivley increase the charging rate e.g. solids these are the areas the business would have or be looking to invest on controlling e.g. by recycling, filtering or on-site treatment

thanks 2 users thanked Roundtuit for this useful post.
HSSnail on 25/02/2022(UTC), HSSnail on 25/02/2022(UTC)
Roundtuit  
#8 Posted : 25 February 2022 11:20:03(UTC)
Rank: Super forum user
Roundtuit

Been a long time since I looked at consents but it appears the suppliers keep registers in their local area so for mine under United Utilities: https://www.unitedutilities.com/trade-effluent-consent-register/

The actual consent conditions are in a numbered pdf attachement

Given charges by authority are set on a regulator apporoved scale what does this national provider bring to the table other than their invoice?

Roundtuit  
#9 Posted : 25 February 2022 11:20:03(UTC)
Rank: Super forum user
Roundtuit

Been a long time since I looked at consents but it appears the suppliers keep registers in their local area so for mine under United Utilities: https://www.unitedutilities.com/trade-effluent-consent-register/

The actual consent conditions are in a numbered pdf attachement

Given charges by authority are set on a regulator apporoved scale what does this national provider bring to the table other than their invoice?

Evans38004  
#10 Posted : 25 February 2022 13:03:08(UTC)
Rank: Forum user
Evans38004

Thanks to all thus far,

Roundtuit - we are in the UU catchment area & checked your link, our neighbour has a consent - we don't !!

We own the site, but a property management company take care of the drains for all the 10 units on the business park and the joint interceptor tank for all units (at least 2 of the other units manufacture chemicals!). The property management company do not have an UU consent either.

At last 8 smaller units (back street garages, etc.) at the corner of the estate / our site have drains that cross our boundary and feed into the joint drains.

I cnnot see any water treatment plants betwen us and the rather large river <80yards away

We are trying to do the right thing, I'm just concerned that other national water providers companies may be providing a contract / take money for removing foul & storm water without any inkling of these consents, other companies may not be seeking compliance. Seems like a msssive loop hole.

peter gotch  
#11 Posted : 25 February 2022 13:34:37(UTC)
Rank: Super forum user
peter gotch

Hi Evans - looks like time to read the small print in your contract with the property management company.

With every more public concern about pollution of watercourses, can't see the regulator only targeting that company rather than the sources of the pollution. 

Have to be careful what we say on this Forum.

P

ttxela  
#12 Posted : 25 February 2022 15:19:03(UTC)
Rank: Forum user
ttxela

Originally Posted by: Kate Go to Quoted Post

Yes, you definitely need a "consent" with the sewerage company.  This sets out what types, concentrations and quantities of effluent you are allowed to discharge. It may be that this exists as a sheet of paper somewhere in the business archives and everyone has forgotten about it.  If you can't find it you will need to approach the sewerage company either to find it in their records or to issue you with one.

This is something that your COMAH inspectors are likely to be interested in.  That's a particular incentive to make sure this is in place.

Your finance folk should know if you are paying trade effluent charges as they are calculated differently from ordinary sewage.

Usually a form is sent each quarter for you to complete with the number of staff on site, days worked, any overnight accomodation and nights used plus any water into the site that leaves as product rather than to drain. From this your TE charge is calculated.

You would also have nominated monitoring points and occasional visits for sampling.

thanks 1 user thanked ttxela for this useful post.
peter gotch on 25/02/2022(UTC)
Roundtuit  
#13 Posted : 25 February 2022 15:50:44(UTC)
Rank: Super forum user
Roundtuit

Consent could be small volume based upon incoming water volume

There will still be consented parameters such as temperature

Evans you have a PM

Roundtuit  
#14 Posted : 25 February 2022 15:50:44(UTC)
Rank: Super forum user
Roundtuit

Consent could be small volume based upon incoming water volume

There will still be consented parameters such as temperature

Evans you have a PM

ianm69  
#15 Posted : 10 March 2022 13:12:15(UTC)
Rank: Forum user
ianm69

Hi, I agree with  roundinit below, spot on.  I worked in waste water in scotland years ago.  Companies still needed a discharge consent from local water authoritys, even if water was removed (if it canot be piped into waste water system) as it usually goes into a separator tank for temporary storage.  We offered testing for BOD, COD and suspended solids, so how do you know if you ar enear/beyond/below its limits? 

BUT its expense to remove water by third parties (okay, profitable) as they use their wider consent to discharge.  It may be worthwhiel speaking with your water company to understand the ins/outs, and if you need a dischareg consent - but speak to your boss first to okay it.  

Dont waste, water, save it :-) 

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