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Pollution incidents costs and impacts Phil Gibbon Waste Regulatory Specialist GMMC Environment Agency
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Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

May 26, 2018

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Page 1: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Pollution incidents costs and impacts

Phil Gibbon

Waste Regulatory Specialist – GMMC

Environment Agency

Page 2: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Flood risk management

Water management

Fisheries, Conservation,

Recreation

Environmental protection

What we do

Page 3: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Our environmental protection role

Regulating large industries, e.g.

COMAH

Waste regulation, e.g.

Recycling/treatment, disposal

Protecting and improving water,

land and air quality

Preventing and mitigating impact

of pollution incidents is an

important part of this work

Page 4: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

EA incident response Category 1 responder

Assess all incident reports (22000pa) from public/FRS/others

Attend within 2-4hrs potential Category 1-2 and some high profile Category 3 incidents

Priority to prevent or mitigate damage

Use pollution control hierarchy – i.e. as close to source as possible

Other aims, e.g. collect evidence/recover costs

Page 5: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Pollution incidents overview

14287 Cat 1-3 pollution incidents in 2013

Wide range of types, e.g. oil/chemical spills, fires, fly

tipping, sewage treatment failure, flooding, etc

Sources, e.g. industry, agriculture, water industry,

transport ,construction, domestic etc

Page 6: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Serious pollution incidents

Serious/persistent /extensive impacts or effects on people & the environment

688 Cat 1-2 Incidents in 2013. 323 (47%) from sites we permit

Increase in 2012 reversed downward trend

Other includes. Transport, Domestic, Natural/Not identified

Page 7: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Many types/causes

Spillages

Containment and control/structural failure

Equipment/plant failure

Poor maintenance/practice

Road traffic collision/Other transport incidents

Deliberate, e.g. vandalism/fly tipping

Natural, e.g. high temperatures/flooding

Fires

Page 8: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Confirmed fire pollution incidents 2013 1587 Cat 1-3 incidents caused by fire

Approx 11% of total pollution incidents

Approx 16% of the fires linked to waste activities

30 fires had serious impact.18 (60%) of these from waste activities

2014 figures still not complete, but number likely to be similar

overall, but slight increase in waste fires

Page 9: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Impacts of pollution incidents -

people and the environment Water pollution:

Drinking water supplies

Water used by industry/agriculture

Fisheries/recreation use

Wild life

Air pollution:

Public health risk

Nuisance

Land:

Soil contamination

Page 10: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Impacts on operator/business

Disruption to business/Loss of permit to operate

Increased insurance premiums

Clean up costs/compensation claims

Fines and potentially imprisonment

Damage to business reputation

Page 11: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Cost of pollution incidents Marine spills well documented

Deepwater Horizon -$14 billion response/clean up costs

Sea Empress - £60 million, response/clean up costs

Less info on inland spills. Buncefield best known £70 million and rising.

EA project, to develop methodology to calculate all cost of an incident

Page 12: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Cost of incidents project Direct Financial Costs

Property damage

Recharge costs

Penal damages

Reputational Costs

Impact on Environment

Damage to aquatic environment

Damage to fish

Air quality damage

Impact on Society

Recreation

Human health

Restrictions on events

Page 13: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Diesel spill at water treatment site

Type of Cost Cost

Polluter’s Recharge Cost £2k

Polluter’s Cleanup Costs £1.2m

Penal Damages £15k

Awarded Legal Costs £1.5k

Total £1.22m

Page 14: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Type of Cost Cost

Polluter’s Recharge Cost £192k

Fire & Rescue Incident Response £107k

Penal Damages £40k

Awarded Legal Costs £15k

Local Authority Incident Response £8k

Public Health England Incident Response £2k

Damage to Recreational Angling £310k

Impact on Golf Club £13k

Fish Kill £47k

Loss of Spend on Angling Equipment £27k

Impact on Recreation £9k

Impact of Exposure to Smoke £112k

Loss of production at neighbouring site £500k

Total £1.4m

Large waste wood fire

Page 15: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Cost of pollution incident matrix

Page 16: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

EA role - Prevention a priority

Range of powers and initiatives in place. Some examples:

Regulation, e.g. COMAH, EPR, APPW notices/regulatory

guidance

Targeting illegal sites/activity. Defra consultation to extend

EA Powers, e.g. Financial Provision

Advice and Guidance – Effort reducing

Influencing/partnership working, e.g. Fire and Rescue

Service

Incidents will still happen. We will work with polluter

/partners/others to minimise their impact

Page 17: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Pollution response strategies Contain, e.g. booming, use of on site containment facilities

Aeration including peroxide

Dilution

Chemical treatment /Diversion to foul sewer

Fish rescue

Influencing others response, e.g. controlled burn or extinguish or both

Page 18: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Influences on strategy Speed of response, equipment available, access, drainage

Pollutant/Incident type, e.g. oil/chemical spill, fire

Environmental sensitivity, e.g. GW SPZ/ bathing water

Best environmental option , e.g. controlled burn, extinguish

Other priorities, e.g. life threat, threat to health, economy

We want polluter (Insurer) to lead, but will act ourselves if necessary,

e.g. polluter unknown, or response too slow

Page 19: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Other EA priorities during an incident

Regulate advice on waste disposal

Warn the public/abstractors, other partners

Monitor environmental impact

Seek remediation/clean up

Investigate cause/collect evidence

Record our costs for later recovery

Page 20: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

EA legal powers/Others

Various Acts/Regulations, allow us to:

Serve notice to get polluter to take action to

prevent/clean up, e.g. Anti Pollution Works Notice

Recover our response costs

Take legal action – Include civil sanctions, revoke

permits and prosecute in Magistrates/High Court

Cost recovery powers principally water focussed. Defra

consulting on extending to cover deposits to land

Civil claims, e.g. Angling Trust

Page 21: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Our partnership with the FRS

We work closely with FRS, sharing a common interest in preventing/mitigating impacts of fire on people, property & environment

FRS carry EA supplied pollution equipment e.g. pipe blockers, drain mats, land/water booms

We estimate the partnership reduces the number of Category 1-2 incidents by 20-25%. In case of recent large waste fires nearly 50%

Page 22: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Our partnership with the FRS

FRS Risk information plans. Main aim to protect fire fighters. But many now include environmental element too, e.g. firefighting /firewater management strategy

Sharing resources

Working closer together as regulators, ie links between EPR and RRO. Fire Prevention = Pollution Prevention

Page 23: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Summary Pollution Incidents can impact on people, the environment

business and can be costly. More work needed on costs

Most are preventable through good design, housekeeping,

maintenance and/or appropriate response

We won’t hesitate to take appropriate action to minimise impact,

recover costs, and if necessary take enforcement action

We want to work with business/partners/others to prevent them

Page 24: Pollution incidents costs and impacts - the FPA · Pollution incidents costs and impacts ... Awarded Legal Costs £15k Local Authority Incident Response £8k ... Prevention a priority

Thank you/Questions