Regulations could increase costs and carbon emissions
20 Nov 2007
The UK process industries have an important role to play in implementing the Water Framework Directive (WFD), which is set make the sourcing of water and the disposal of wastewater much more complex than today.
The UK process industries have an important role to play in implementing the Water Framework Directive (WFD), which is set make the sourcing of water and the disposal of wastewater much more complex than today, writes Dr Arthur Thornton of Atkins Group:
The WFD, which has been described by Defra as "the most substantial piece of EC water legislation to date", requires a fully integrated approach to meeting its key target; that all inland and coastal waters reach "good status" by 2015.
The directive is being implemented through a cross-sectoral, stakeholder-led approach based on a river-basin district structure within which demanding environmental objectives will be set. This will start with a planning phase up until December 2009 to identify the programmes of measures to be enacted through 2009-2012 — a cycle subsequently to be repeated for the following three years.
Process industry operators should engage during the first planning cycle to ensure they fully understand the increased costs that they are likely to face. More importantly, perhaps, they will have the opportunity to influence the outcome of the regulation.
In particular, operators will need to assess the impact of water abstraction and of their wastewater discharges. Significantly, the water industry will also have to to review its policy on trade-effluent control and charging to ensure that its policy is fit for the purpose of future compliance.
Defra is currently assessing the overall impact of the WFD requirements for tighter treatment of wastewater, monitoring and stopping the discharge of priority hazardous substances, across the UK and including industry.
Substances of concern include anthracene, cadmium, chromium, cypermethrin, DEHP, lead and its compounds, mercury, nickel, tributyltin, trichloromethane, pentaBDE and phenols. Some of these substances are already subject to controls, however it remains to be seen if the current controls will drive the required reductions. Furthermore, where the existing controls do not exist then there will be the need to introduce new measures.
The direct discharge of chemicals, or the indirect discharge through sewage treatment works, is clearly a concern for manufacturers using priority hazardous substances and priority substances in their processes. The need to control these substances will drive site-specific costs.
Another increasing concern is the recognition that the use of materials in domestic applications is also resulting in elevating concentrations of substances in the sewage received at sewage treatment works. Manufacturers might, therefore, have to consider the use to which their products are being put and consider the potential for the loss or leaching of substances to the environment.
There is the very real risk that the tighter Environmental Quality Standards (EQS) for some chemicals will lead to tighter discharge controls at sewage treatment works. The problem is that the cost of end-of-pipe treatment to remove very small concentrations of substances is often extremely expensive.
Control in manufacturing processes may be of the order of hundreds of millions of pounds, but control at the sewage treatment works may significantly outweigh these costs. The issue then would be how these costs are charged to customers. Should the domestic charges increase to meet the treatment requirements and, if so, how will the social aspects of affordability be assessed and managed?
Working for the water industry in a UK Water Industry Research-led initiative, Atkins Group has demonstrated how these tighter controls may lead to the need for infrastructure upgrade at sewage treatment works across the country — including tertiary technologies, which have yet to be proven in this application.
The Atkins approach included the creation of a UK model of sewage treatment works and their potential impact at their discharge points to assess the treatment processes required to meet the tighter discharge controls.
These additional processes could involve oxidation techniques, adsorption or filtration systems that tend to involve high energy consumption and have the potential of generating additional waste streams, as well as greenhouse gas emissions.
With a tertiary treatment sand filter, for example, carbon emissions can be in the region of tens of kilogrammes per megalitre treated. Scaling this up to a national level could mean carbon emissions in the hundreds of kilotonnes per year, increasing the water industry's annual greenhouse gas emissions by about 25%.
The Atkins/UKWIR research highlights how some of the EQS have been set at a precautionary tight level due to uncertainty in the data on which the standards were being based. Whilst the precautionary approach does not necessarily provide any benefit to the flora and fauna found in the receiving water, the tighter standards lead to the need for potentially more treatment and, therefore, an increase in carbon emissions or tighter controls on industry.
An example of a substance of particular concern is the plasticiser DEHP. Having been found in sewage and in final effluents from sewage treatment works, it is important that its sources and potential control options are fully understood. It is currently envisaged that the control measures at sewage treatment works could cost over £6 billion.
The technologies needed to deliver the required treatment efficiencies at sewage treatment works have yet to be proven, so there seems to be no simple solution. Furthermore, it is anticipated that the types of technologies that may be required would be both energy-intensive and have themselves the potential to generate wastes.
DEHP is not currently controlled in its use, but there is mounting presssure to understand how it is released from the plastic materials in which it is used as a plasticiser and its fate during sewage treatment. Clearly, such specific cases require more detailed investigations prior to any commitment to build end-of-pipe treatment at sewage treatment works.
Defra and the Environment Agency understand such issues, especially in the cases where control measures are in place, and it is highly likley that the substance will die away naturally, as, for example, in the case of the flame retardent pentaBDE. It is also likely that any treatment investment would be seen as a disproportionate cost in such cases.
Imports are another source of substances over which industry may have little control, but may need to consider. Chemicals may be used outside of Europe and imported as an impurity or contamination. This issue has been recognised for many years in the textile industry, but is a potentially a bigger issue in the future, particularly as the control of chemicals through REACH may not influence import risk. site-specific level and within specific river basin management plans. It also challenges society to balance the benefits that we derive from the substances that we use with the potential costs of controlling them, through whichever mechanism.
There is a need to understand the science behind the behaviour of chemicals within manufactured products and the means by which they enter the environment. This requirement resides partially with the Environment Agency, but also with the process and product manufacturing industries.
The science on which the standards are set needs to be robust and, where uncertainty drives a precautionary approach, it is important to understand the potential downstream impacts that this can cause.
The phased implementation of the WFD provides the opportunity to derive and perform the appropriate investigations so as to thoroughly appreciate and develop the required areas of understanding. However, industry at large will need to be part of the solution, and must realise that there will be costs involved.
Water Framework Directive
The overall objective of the WFD is to protect water quality and to restore ecology of the water environment, so compliance with the directive will lead to an improved water environment.
The directive requires EC member states to put in place River Basin Management Plans (RBMPs), which must each apply to a "river basin district". The river basin planning (RBP) process involves setting environmental objectives for all groundwaters and surface waters within the river basin district, and devising programmes to meet those objectives.
WFD objectives include physical aspects, the morphology of rivers such as its impact on the banks and beds of the river, good ecological status and chemical aspects such as cessation of emissions of priority hazardous substances and the control of priority substances.
The WFD also requires that other environmental priorities, economic considerations and social issues are taken into account when setting water management objectives. These requirements are important as they set the balance between the social, environmental and economic impacts of the directive.
Industrial sectors that will need to consider the direct implications of the WFD include:
l Water industry (phosphates, ammonia, water resources, chemicals)
l Agriculture (phosphates)
l Industry (chemicals)
l Urban & Transport, excluding navigation (chemicals, phosphates, ammonia, morphology)
l Ports & Navigation (morphology, chemicals)
The WFD, which has been described by Defra as "the most substantial piece of EC water legislation to date", requires a fully integrated approach to meeting its key target; that all inland and coastal waters reach "good status" by 2015.
The directive is being implemented through a cross-sectoral, stakeholder-led approach based on a river-basin district structure within which demanding environmental objectives will be set. This will start with a planning phase up until December 2009 to identify the programmes of measures to be enacted through 2009-2012 — a cycle subsequently to be repeated for the following three years.
Process industry operators should engage during the first planning cycle to ensure they fully understand the increased costs that they are likely to face. More importantly, perhaps, they will have the opportunity to influence the outcome of the regulation.
In particular, operators will need to assess the impact of water abstraction and of their wastewater discharges. Significantly, the water industry will also have to to review its policy on trade-effluent control and charging to ensure that its policy is fit for the purpose of future compliance.
Defra is currently assessing the overall impact of the WFD requirements for tighter treatment of wastewater, monitoring and stopping the discharge of priority hazardous substances, across the UK and including industry.
Substances of concern include anthracene, cadmium, chromium, cypermethrin, DEHP, lead and its compounds, mercury, nickel, tributyltin, trichloromethane, pentaBDE and phenols. Some of these substances are already subject to controls, however it remains to be seen if the current controls will drive the required reductions. Furthermore, where the existing controls do not exist then there will be the need to introduce new measures.
The direct discharge of chemicals, or the indirect discharge through sewage treatment works, is clearly a concern for manufacturers using priority hazardous substances and priority substances in their processes. The need to control these substances will drive site-specific costs.
Another increasing concern is the recognition that the use of materials in domestic applications is also resulting in elevating concentrations of substances in the sewage received at sewage treatment works. Manufacturers might, therefore, have to consider the use to which their products are being put and consider the potential for the loss or leaching of substances to the environment.
There is the very real risk that the tighter Environmental Quality Standards (EQS) for some chemicals will lead to tighter discharge controls at sewage treatment works. The problem is that the cost of end-of-pipe treatment to remove very small concentrations of substances is often extremely expensive.
Control in manufacturing processes may be of the order of hundreds of millions of pounds, but control at the sewage treatment works may significantly outweigh these costs. The issue then would be how these costs are charged to customers. Should the domestic charges increase to meet the treatment requirements and, if so, how will the social aspects of affordability be assessed and managed?
Working for the water industry in a UK Water Industry Research-led initiative, Atkins Group has demonstrated how these tighter controls may lead to the need for infrastructure upgrade at sewage treatment works across the country — including tertiary technologies, which have yet to be proven in this application.
The Atkins approach included the creation of a UK model of sewage treatment works and their potential impact at their discharge points to assess the treatment processes required to meet the tighter discharge controls.
These additional processes could involve oxidation techniques, adsorption or filtration systems that tend to involve high energy consumption and have the potential of generating additional waste streams, as well as greenhouse gas emissions.
With a tertiary treatment sand filter, for example, carbon emissions can be in the region of tens of kilogrammes per megalitre treated. Scaling this up to a national level could mean carbon emissions in the hundreds of kilotonnes per year, increasing the water industry's annual greenhouse gas emissions by about 25%.
The Atkins/UKWIR research highlights how some of the EQS have been set at a precautionary tight level due to uncertainty in the data on which the standards were being based. Whilst the precautionary approach does not necessarily provide any benefit to the flora and fauna found in the receiving water, the tighter standards lead to the need for potentially more treatment and, therefore, an increase in carbon emissions or tighter controls on industry.
An example of a substance of particular concern is the plasticiser DEHP. Having been found in sewage and in final effluents from sewage treatment works, it is important that its sources and potential control options are fully understood. It is currently envisaged that the control measures at sewage treatment works could cost over £6 billion.
The technologies needed to deliver the required treatment efficiencies at sewage treatment works have yet to be proven, so there seems to be no simple solution. Furthermore, it is anticipated that the types of technologies that may be required would be both energy-intensive and have themselves the potential to generate wastes.
DEHP is not currently controlled in its use, but there is mounting presssure to understand how it is released from the plastic materials in which it is used as a plasticiser and its fate during sewage treatment. Clearly, such specific cases require more detailed investigations prior to any commitment to build end-of-pipe treatment at sewage treatment works.
Defra and the Environment Agency understand such issues, especially in the cases where control measures are in place, and it is highly likley that the substance will die away naturally, as, for example, in the case of the flame retardent pentaBDE. It is also likely that any treatment investment would be seen as a disproportionate cost in such cases.
Imports are another source of substances over which industry may have little control, but may need to consider. Chemicals may be used outside of Europe and imported as an impurity or contamination. This issue has been recognised for many years in the textile industry, but is a potentially a bigger issue in the future, particularly as the control of chemicals through REACH may not influence import risk. site-specific level and within specific river basin management plans. It also challenges society to balance the benefits that we derive from the substances that we use with the potential costs of controlling them, through whichever mechanism.
There is a need to understand the science behind the behaviour of chemicals within manufactured products and the means by which they enter the environment. This requirement resides partially with the Environment Agency, but also with the process and product manufacturing industries.
The science on which the standards are set needs to be robust and, where uncertainty drives a precautionary approach, it is important to understand the potential downstream impacts that this can cause.
The phased implementation of the WFD provides the opportunity to derive and perform the appropriate investigations so as to thoroughly appreciate and develop the required areas of understanding. However, industry at large will need to be part of the solution, and must realise that there will be costs involved.
Water Framework Directive
The overall objective of the WFD is to protect water quality and to restore ecology of the water environment, so compliance with the directive will lead to an improved water environment.
The directive requires EC member states to put in place River Basin Management Plans (RBMPs), which must each apply to a "river basin district". The river basin planning (RBP) process involves setting environmental objectives for all groundwaters and surface waters within the river basin district, and devising programmes to meet those objectives.
WFD objectives include physical aspects, the morphology of rivers such as its impact on the banks and beds of the river, good ecological status and chemical aspects such as cessation of emissions of priority hazardous substances and the control of priority substances.
The WFD also requires that other environmental priorities, economic considerations and social issues are taken into account when setting water management objectives. These requirements are important as they set the balance between the social, environmental and economic impacts of the directive.
Industrial sectors that will need to consider the direct implications of the WFD include:
l Water industry (phosphates, ammonia, water resources, chemicals)
l Agriculture (phosphates)
l Industry (chemicals)
l Urban & Transport, excluding navigation (chemicals, phosphates, ammonia, morphology)
l Ports & Navigation (morphology, chemicals)
