Environment Agency UK Issues Guidance on Environmental Permitting for "Orphan" Leachate Treatment Plants

Earlier this month (July 2009) the EA's Modernising Waste Regulation Panel issued a Regulatory Position Statement about Environmental Permits for Waste Treatment Plants.

This has updated a previous pair of statements on this subject which we found hard to interpret, and which were issued a least a year ago.

Under the original EU Directive based PPC Regs. and UK permitting rules it appeared that in due course all leachate treatment plants greater than 50 tonnes per day (50 cubic metres per day) capacity would have to be officially issued with a permit by the Agency. This would be the case even if the plant had been in existence for many years and was clearly complying with its watercourse (or sewer) discharge consent and not causing any environmental problems at all.

From the start this seemed absurd, and an enormous cost and bureaucratic burden on the operators of these plants, without anyone really being clear what benefit would result.

As time progressed and the Environment Agency concentrated on prioritising the most important treatment processes and all new landfills, we all wondered when they would catch up with this and start contacting the operators of these so called "orphan" sites.

Now, finally it seems that most if not all leachate treatment plant owners and operators that do not already have an Environmental Permit, or have been required to submit for one, for their leachate treatment plant can relax about this.

The position statement says:

The Environment Agency’s position:

We will not pursue an environmental permit application for an IPPC directive waste treatment activity where all the following conditions are met:

• the treatment plant is subject to a consent issued under the Water Industry Act or the Water Resources Act;

• the plant only treats waste/waste water produced on-site and does not import it from other sites;

• management of the activity ensures that the risk of pollution incidents from the site, including nuisance, remains low;

• relevant operational records are kept for a period of four years and made available to Environment Agency officers when requested.

However, if you do own or operate a leachate treatment plant on what would usually be a closed landfill, you should not rely on this posting alone, and you really should visit the EA's web site and read it for yourself at the WTP Orphan page/pdf.

However, here is a thought to end this post. How many closed landfill leachate treatment plant operators have a full 4 years of data properly archived and ready for inspection, if requested. I wonder!?