The purpose of a Liquid Pollution Risk Assessment is to establish any activities on site which pose a risk of polluting the environment and identify proportionate control measures to reduce your risk to a reasonable level. Ensuring you have adequate control measures for your risks on site will help to achieve legal compliance and reduce the likelihood of causing pollution (and the subsequent prosecutions and damage to reputation which follows).
Our Liquid pollution risk assessments (LRPAs) are built using the source – pathway – receptor model and comprise 2 components; a desktop survey and a site risk assessment.
The desktop survey and the on-site risk assessment are then combined into a report to give a comprehensive list of risks on site. Each risk is given a significance score to allow easy identification of your highest risks, integrating with the aspects register of your management system, e.g. ISO14001. Where unacceptable risks scores are identified additional control measures will be recommended to bring your risk score down to an acceptable level.
A desktop review is carried out prior to conducting the on-site risk assessment in order to highlight any environmental risks in the area around your site. The review includes:
A basic outline of current site layout.
Most sites will be governed largely by the same pieces of legislation e.g. Water Resources Act 1991, The Groundwater (England and Wales) Regulations 2009 and The Control of Pollution (Oil Storage) Regulations. However certain sites will also be governed by additional legislation e.g. COMAH sites must also comply with CIRIA (C736). All relevant legislation will be compiled in order to assess site activities in line with legal requirements.
We will use environmental data to make an assessment of the site geology (including artificial, superficial and solid bedrock), hydrology (surface water bodies) and hydrogeology (ground water properties). This is required in order to determine the possible pathways through soils, bedrock and water courses. These pathways can take pollutants off site, but also have the potential to bring them on site from external sources.
This may identify pollution sources in close proximity to the site such as petrol stations, industrial workshops etc.
The environmental setting will identify receptors such as protected environmental features and groundwater vulnerability. Many industrial sites are located on the border of or will discharge into areas with special environmental designations such as SSSIs, SACs and RAMSAR sites; where such environmental designations are present in the adjacent area risk scores are increase to reflect this. Groundwater is designated into zones of vulnerability, local groundwater abstractions and discharge consents are also documented where relevant.
The second phase is to conduct an on-site risk assessment looking at the site activities, liquid storage, potential pathways and the existing control measures.
Individual storage areas and potentially polluting activities are zoned and subjected to a local risk assessment based upon hazard and likelihood.
Existing drain plans will be studied in order to establish the catchment areas and discharge points from site to identify the receptors any spillages would be released into. If drain plans are unavailable we are able to undertake drain surveys to ascertain this information.
Existing controls such as bunds, interceptors, spill kits, emergency shut-off valves etc. are collated and scored against the level of risk of the source.
Each risk is given a significance score which is RAG (Red-Amber-Green) colour coded. Where there is an unacceptable risk of pollutant linkage then mitigating measures / corrective action will be recommended. The significance scoring allows you to prioritise fixing non-conformities based on the level of risk they pose, and to distribute resources as effectively as possible so that you can maximise environmental performance within your budget.
Following the report we recommend you to install a robust monitoring and servicing system to ensure critical environmental controls remain legally compliant and are appropriately maintained. Click here for more information on our environmental auditing service.
Accident prevention and management plan
You need a plan for dealing with any incidents or events that could result in pollution.
The plan must identify potential accidents, e.g. equipment breakdowns, enforced shutdowns, fires, vandalism, flooding, or any other incident which causes an unexpected change to normal operations, e.g. bad weather.
For each potential incident, it must also state the:
Environment Agency guidance - Develop a management system: environmental permits
"If you pollute, you could get an unlimited fine, go to prison for up to 5 years, or both. You may also have to pay for the whole cost of the clean-up."
Environment Agency guidance - Pollution prevention for businesses