Evidence of illegal sewage dumping revealed by 'Dry Spills'

Evidence of illegal sewage dumping revealed

 in SAS 2022 Water Quality Report

24 November 2022

We found water companies have committed 146 ‘dry spills’ in the last year. For the first time, we’ve used rainfall data to investigate potentially illegal ‘dry spills’. Sewage outflows are only permitted in ‘unusually heavy rainfall’, but our analysis shows water companies have been dumping untreated sewage into our waterways even when there hasn’t been any rain. We would love to hear from water companies on why they’re releasing highly concentrated swathes of raw sewage into our parched waterways during one of the hottest summers on record?

The SAS Water Quality Report 2022 reveals 146 ‘dry spills’ in the last year, using rainfall data to show potentially illegal spills from CSO overflows.

SAS looked only at the most popular surf and swim spots, so not at Barry and Penarth

 

“Dry spills” are evident also for Lower Penarth’s Brockhill Rise CSO which spilled 114 times in 2020 and 67 times last year, averaging near 3 hours a time.  Other CSOs in Penarth discharge many fewer times, most 10-20 times nearer to storm frequencies.  In Barry, The Knap long outfall and Barry Dock storm CSO are worse (Welsh Water data).

 

Brockhill Rise CSO, goes from the pumping and storage plant on the
Railway Path (left) to the discharge point just below the low tide mark

 

NRW’s licence for the Brockhill Rise CSO specifies discharges are permitted solely of “storm sewage”.  Welsh Water built a huge underground storage tank on the railway path in the noughties. The CSO was modernised and discharges just below the low tide mark.  Welsh Water have to store peak flow there until there’s capacity to pump it through to Cog Moors works for treatment.  Instead, they appear to discharge it frequently to sea, evidently during many non-storm times.  

Extract of discharge consent from Brockhill Rise CSO
The discharge pipe is high capacity 1050mm

Welsh Water should report the licence breach to NRW but don’t.  And NRW make no check of the clearly over-frequent use of the CSO.  Welsh Water save on the treatment costs at Cog Moors and on the pumping cost to get the sewage there and pump the treated effluent to the Lavernock Point long outfall.

FOE briefed the regional MS on the 23 Dec.2020 flooding 

Barry&Vale FoE met with Heledd Fychan MS for the Cardiff region early November, briefing her on flooding due to sewer overload relating to the 23 Dec’2020 rainstorm, and unlawful discharges of untreated sewage. Flooding in Dinas Powys happened when the surface water sewers were unable to discharge into the river at high flows and the ‘attenuation’ tanks at Llandough hospital discharged quickly to the Eastbrook which itself overflowed and fed the Cadoxton river. The VoG Section 19 statutory report ducked these issues while the Section 19 report for Penarth is still delayed.  

 

Heledd agreed to take up the issues, alongside her findings on flooding in the Rhondda.  The last Senedd report in March disregarded sewage impacts on sea recreation, as does the Welsh Government. Heledd agreed this needs to change - the special Senedd committee on the floods could take up the evidence on NRW failing to regulate sewage spills during both floods and dry spells.

Welsh Minister Julie James taken in by "carbon-negative" nonsense

Incredibly, the Minister Julie James has been persuaded that the Barry Biomass incinerator would be “carbon negative” so help “build a stronger greener economy... towards decarbonisation”.

These words are in the Minister's letter of 29 July 2021 to DIAG, when she announced that she would assist the company's to overcome the EIA failure. So one would expect this assessment to be firmly based. But it isn't. She repeated numbers from the company, numbers that NRW repeated without scrutiny, apparently lacking any capability among her officials.

Here are Some Numbers, taken from the company 

Burns annually 86 000 tonnes wood wastes - gives direct emissions of 129 000 tonnes CO2. 

Uses over 5000 tonnes for process chemicals and start-up diesel (company figures in 2017), 

Another 20-30 000 tonnes CO2 is due to transport and chipping (the company ignores)

The company say they'd produce 80 000 MWh electricity a year, displacing electrical power otherwise coming from the Grid.

Figures for the average CO2 per MWh from the Grid are published each year - about 0.2 tonnes now with projected decrease to 0.1 tonnes per MWh in 2028 and lower in the 2030s. 

 So their electrical output will save a puny 8000 tonnes CO2 annually coming from Grid electricity - much less than the 25-35 000 tonnes above just for transport, chipping and chemicals+start-up diesel.

Julie James should have smelt a rat when the company claimed the 129 000 tonnes emitted CO2 doesn't count because it's “biomass”. Yet waste wood

# contains composites like MDF (10% level of glue etc.), as well as coatings and preservatives

# much is chipboard, whose coating can be stripped and the chips recycled into new board.

CO2 from glues and coatings is largely fossil; CO2 from burning recyclable woodchip has to be counted even on the bio-CO2 excuse.

Europe has ended subsidy to incineration, as they've realised it impedes the transition towards a carbon-neutral and circular economy. Julie James is responsible in Wales, but incredibly none of her civil servants are able to manage the numbers.

Av. CO2 from UK electricity.  Drops below 100 (kg/MWh or g/kWh) in the 2030s, while Julie James believed Biomass's quote of levels from 2013-14 in claiming CO2 "offset" makes it "carbon negative".

----  References to the Circular Economy ----

The EU in 2021 ended subsidies to Waste-to-Energy incineration, recognizing that WtE opposes the transition towards a carbon-neutral and circular economy

 Waste incineration is a carbon-intensive process [1] undermining the efforts to decrease carbon emissions and, thus, to reach carbon neutrality on time. Additionally, it .harms rather than supports the transition to a circular economy [2] Since both non-recyclable and recyclable waste can be used as a feedstock to a waste incinerator, waste prevention and recycling are discouraged [3],

[1] https://zerowasteeurope.eu/wp-content/uploads/edd/2019/09/ZWE_Policy-briefing_The-impact-of-Waste-to-Energy-incineration-on-Climate.pdf

[2] https://zerowasteeurope.eu/2019/09/waste-to-energy-is-not-sustainable/

[3] https://zerowasteeurope.eu/2017/10/deliver-pay-waste-incineration-causes-recycling-slow/

Sewage dumped into sea at Barry for hundreds of hours

 The Cardiffian reported in February:   Swimmers and surfers may not be aware of how much has been released

VAST amounts of untreated sewage are being released into the sea at the Old Harbour, despite council ambitions to turn it into “an area for nature”.

Wetland Birds looking for food in the Old Harbour with a sewer overflow in the background (from Cardiffian)

Sewage is also being released into Barry docks where a new marina and waterfront developments are planned.  Untreated waste is released from combined sewer overflows, pictured above, after heavy rain when sewer capacity is exceeded says the Cardiffian report 

Combined sewer overflows, also known as sewer storm overflows regularly release raw sewage into the sea

There's one CSO discharge into the Harbour.  Last year, 2021, the second "Barry Town" CSO spilled over 4 times more frequently than as in the picture for 2020:  65 times for a total 71 hours,.

"Barry Town CSO" is thought to be the short outfall from the Knap (not as depicted).  There's a second main long outfall from the Knap, built about 1990.  Discharges were supposed to end when the Cog Moors works came in 1997. DCWW have been concealing continuing use until the 2021 data came out:

Barry Town SPS - Long Sea Outfall   205 times   2236 Hours

This shows far more use than the Town and Harbour Rd CSOs, and for 10 hours a time. FoE suspects 

DCWW are using it unlawfully to relieve pressure on the overloaded Cog Moors sewage works and NRW are turning a blind eye.

Marine conservation group Surfers Against Sewage say on their website they are: “increasingly concerned that CSOs are being used to regularly dispose of untreated sewage, even during times of low rainfall or none at all.” 

 The Cardiffian received a response from Welsh Water:  sewage overflows

 “do not have an impact on the excellent bathing water quality at Barry”

This is false.  First the monthly water monitoring at both Whitmore Bay and Jackson's Bay in recent years has shown failures of the Blue Flag standard (exceed the virus and/or bacteria standard in more than one of the 20 weekly samples, summer season only).  

Second, NRW required use of UV disinfection on sewage overflows from Cog Moors sewage works to reduce bacteria and virus levels, in order to meet standards during the summer bathing season.  Welsh Water discharges untreated sewage at peak times at even greater volumes than the sewage it treats in  the Cog Moors works, with the UV equipment turned off from October to April.  

NRW inspections report visible evidence of sewage debris on both Whitmore Bay and Jackson Bay beaches. NRW do not monitor the water quality for viruses and bacteria outside the 20 summer weeks.  

And NRW are complicit with Welsh Water's nonsense claims that sewage 'spills' are

“highly regulated and closely monitored by our regulator Natural Resources Wales.”

Key objections to the Voluntary Retrospective travesty of the law for Barry Biomass Incinerator

 This Voluntary Retrospective EIA deserves ridicule and should be dumped.

responses to documents on barrybiomassconsultation.online were due by 17 January, but it's now blocked.  FoE's full response can be downloaded from Facebook

The “scope” was limited in cosy discussions between the WGovt and Barry Biomass outside EIA rules. Welsh policy supports community Health Impact Assessments, but this was ignored. The Welsh Government supports the rights of children to be consulted, but ignored it here.

They limited the site to the original area, yet operating the plant depends on using the northern extension and using Berth 31. They've been caught out by the VoG's enforcement action including the northern extension.

By basing the EIA on 2016, they tried to avoid Welsh 2017 policy on air pollution which adopted the WHO findings of harm at pollution levels below the legal limits and greater harm to vulnerable people.

What are the Critical Objections that should cause the downfall of this Incinerator?

#  Tight air pollution standards issued by the WHO in September over-rule the old limits used in the EIA. This arises as the legal criterion in waste management is no-harm-to-health; the new WHO Guidelines implement this. Barry already comes above the WHO standards.

# Ignoring the law requiring use of the waste heat, refusing to assess opportunities for it

# Ignoring the EIA requirement to assess major accidents and disasters, with their off-site impacts on the local community. There is no assurance the plant can be operated without harm to health and the environment.

# Failure to conduct a community Health Impact Assessment and involve children it it, despite their vulnerability to pollutants, contrary to Welsh policy. Ignoring the health hazard from ultrafine particulates.

# Using the wrong stack diameter: that constructed is 2.75m, but they've calculated the fumes from a 1.6m stack, claiming little difference. In fact it means the smoke plume emerges too slowly, is caught in stack eddies and easily descends onto housing.  Plume calculations are poor in Barry's basin and the 43m height is too short to clear Barry's hills

# Refusal to provide data on the composition of the wood-waste, with its chemicals in coatings etc., likewise no data from comparable working plants abroad.

# Failure to consider noise and pollution at the nearest housing, currently being built at East Quay site. The excuse there was no housing there in 2016 won't wash. Suppressing the issue equals lying.

# Carbon emissions higher than the UK power supply. They falsely claim a huge carbon allowance from replacing other electricity generators (670 instead of the 200 in 2020 and under 100 gCO2/kWh in the 2030s). They claim the few % plastics in the waste is 'biogenic' and fail to exclude the fraction that's recyclable. The emissions from their inefficient wood burning come to 1600 gCO2/kWh, a complete embarrassment to Wales.

# Discharge of the industrial effluent to sewer cannot be allowed, as it frequently discharges (via the Barry Storm CSO, 120 times a year) into the Dock. Nothing is said on the environmental sensitivity and watersport activities that would be impacted by the effluent.

# Tidal surge flooding required the raising of the nearby East Quay site to 8.9m AOD (Q100 level: 8.76m). The David Davies road entrance is 7.6m AOD.

THE FINAL BLOW; The public has a right to expect government to follow the rule of law, not choose bit and make arbitrary changes to help BUK. This ECHR right is called Article 8: the Welsh Government collusion with BUK is in flagrant breach of it.