Guidance

Water and sewerage company OSM and UWWTR sampling affected by COVID-19: RPS C3

Updated 22 June 2020

This guidance was withdrawn on

This document has been withdrawn because it has expired.

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You need a permit to discharge sewage and trade effluent into inland freshwaters, coastal waters and groundwater. This COVID-19 regulatory position statement (RPS) applies to regulatory sampling carried out in accordance with your permit in relation to Operator Self-Monitoring (OSM) and Urban Waste Water Treatment Regulations 1994 (UWWTR) monitoring.

Water and sewerage companies that monitor discharges from wastewater treatment works (WwTW) and water treatment works (WTW) must check that discharges comply with numeric quality limits in environmental permits.

If you follow the conditions in this COVID-19 RPS you can reduce how often you self-monitor discharges of:

  • treated sewage effluent from WwTW
  • trade effluent from WTW

You must get written agreement from your Environment Agency water company account manager before you use this COVID-19 RPS.

1. When this COVID-19 RPS applies

This COVID-19 RPS only applies if you have missed any sample collections or analysis because of:

  • staff shortages due to COVID-19
  • restricted access caused by people or places being infected or potentially infected with COVID-19 – for example, if a WwTW, WTW or laboratory is in a zone of restricted access

In those circumstances, and provided you meet the conditions in this COVID-19 RPS, we will not expect you to:

  • reschedule missed OSM and UWWTR sample(s)
  • collect and report the number of OSM and UWWTR samples required by your permit in 2020

You must demonstrate that you have taken all reasonable steps to continue sampling and analysis. Reasonable steps include:

  • contingency planning to avoid or minimise disruption to your business because of COVID-19
  • COVID-19 response planning to minimise the impact and duration of not being able to comply with your permit

2. Conditions you must comply with

You must comply with all the other requirements of your environmental permit.

You must minimise the number of OSM and UWWTR samples you miss and cannot reschedule and maintain a record of those missed.

You must prioritise collecting and analysing OSM samples of discharges from WwTW and WTW which have the greatest potential to cause environmental damage.

You must give highest priority to OSM sampling of discharges upstream of drinking water abstractions. This includes groundwater discharges into a groundwater source protection zone 1.

You must also give highest priority to discharges which fall into the following permit condition or performance categories:

  • numeric limits that protect Natura 2000 sites, Ramsar sites or sites of special scientific interest
  • numeric limits for ammoniacal nitrogen of 5 mg/l or less
  • numeric limits for phosphorus of 1mg/l or less
  • UV disinfection for shellfish and/or bathing waters
  • increased sample frequency due to previous numeric limit failures

You must update your relevant quality management systems to reflect changes to your monitoring programmes after you have prioritised.

You must keep records that show why you needed to use this COVID-19 RPS. For example, records of:

  • staff absences
  • contractors being unavailable
  • supply chain failures

You must keep these records for 24 months after this COVID-19 RPS has expired, including any extensions to it. You must make them available to the Environment Agency on request.

You must make sure your activities do not endanger human health or the environment.

You must not:

  • cause a risk to water, air, soil, plants or animals
  • adversely affect the countryside or places of special interest

Places of Special Interest include but are not limited to:

  • European sites (Special Areas of Conservation and Special Protection Areas)
  • Ramsar sites
  • Sites of Special Scientific Interest
  • national and local nature reserves
  • Areas of Outstanding Natural Beauty
  • Marine Conservation Zones
  • National Parks

You must continue to tell the Environment Agency about any performance issues or pollution incidents, following normal reporting routes and processes. This is required by permit condition 4.3.1 and operational instruction 16_02.

3. Enforcement

A COVID-19 RPS means that the Environment Agency will not normally take enforcement action against you provided:

  • your activity meets the description set out in this COVID-19 RPS
  • you comply with the conditions set out in this COVID-19 RPS
  • your activity does not, and is not likely to, cause environmental pollution or harm human health
  • you have taken all reasonable steps to comply with your permits

If a WwTW does not have the required number of UWWTR samples taken and reported in 2020, we will not record them in the 2020 Environmental Performance Assessment as failing for not having enough samples. This is provided they meet all of the conditions in this COVID-19 RPS.

If you operate under this COVID-19 RPS but think you may no longer be able to comply with its conditions, you must tell the Environment Agency immediately.

The Environment Agency will monitor how operators use and comply with this COVID-19 RPS through its proportionate, risk-based inspection and monitoring activity.

4. When to check back

This COVID-19 RPS will be withdrawn on 30 September 2020 unless the Environment Agency extends it. After this date you must comply with your permits.

5. Contact the Environment Agency

Contact your water company account manager to get written agreement to use this COVID-19 RPS.

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