If you are applying to the Environment Agency for an ELV permit you will notice in the guidance that there is a requirement for a sealed drainage system.
The Environment Agency’s view of a sealed drainage system is “sealed drainage system” in relation to an impermeable surface, means a drainage system with impermeable components which does not leak and which will ensure that:
(a) no liquid will run off the surface otherwise than via the system;
(b) except where they may lawfully be discharged to a foul sewer, all liquids entering the system are collected in a sealed sump.
In many of the standard rules permits there is also an introductory section that says;
These rules do not allow any point source emission into surface waters or groundwater. However, under the emissions of substances not controlled by emission limits rule:
ï Liquids may be discharged into a sewer subject to a consent issued by the local water company.
ï Liquids may be taken off-site in a tanker for disposal or recovery.
ï Clean surface water from roofs, or from areas of the site that are not being used in connection with storing and treating waste, may be discharged directly to surface waters, or to groundwater by seepage through the soil via a soakaway.
ï Clean surface water from the un-depolluted vehicle storage area may only be discharged directly to surface waters, or to groundwater via a drainage system designed and constructed so surface water discharged does not adversely impact the water quality of receiving water bodies, both during construction and when operational.
In essence as an ATF and to be regulated by the EA, you have 3 choices:
- Divert all surface water from waste areas to a foul sewer with the consent of the local water authority.
- Install a blind sump to collect all contaminated surface water and have this tankered away.
- Ensure that all surface water discharged to a surface water ditch or stream does not come into contact with any waste by segregating waste from this area.
If any rainwater falls on a “waste” storage area in your ELV yard and then runs into a surface water system you will be in non-compliance with your environmental permit.
Installation of a concrete plinth, impermeable surface area, interceptors or connection to the foul sewer can be a very costly element of compliance with your environmental permit running into 10’s of thousands of pounds for some operators and in many cases, can make the business unviable if you are forced into this upgrade by an unexpected visit by the Environment Agency.
Compliance with the permit conditions can be difficult on many levels but for a number of businesses who are now being asked to become compliant after many years of operation under the old waste management licences that were issued many years ago, the cost can be the final blow.
The reasons for the sealed drainage systems are obvious and no-one can deny that protection of subsurface soil and groundwater from oils and chemicals is important, however, if you haven’t factored this cost into your compliance budget then you may be in for a nasty shock.
For more advice on Environmental Permits for ELV sites and ATFs please contact Paul for an informal discussion on 07790147084. You can also visit www.pauldowningltd.co.uk