The Scottish Environmental Protection Agency (SEPA) has listed three Argyll businesses in its 2009 ‘naming and shaming’ of the worst polluters in Scotland, those who do not comply with their specific licence conditions and who have been found to be in breach of regulations.
SEPA’s Compliance Assessment Scheme
Each year now, SEPA, under its Compliance Assessment Scheme, uses a continuous assessment process to evaluate an operator’s level of compliance with their licence.
The level of compliance is assessed after each inspection, data assessment or environmental event (such as an oil spillage) at a site. This assessment is shown as a compliance level. The compliance levels are; excellent, good, broadly compliant, at risk, poor and very poor.
The three named and shamed
The three Argyll operations named are all in the second worst category: Poor.
The criteria for a classification as ‘Poor’ include an operator not being compliant with licence conditions and or responsible for at least one significant breach.
- Furnace Quarry: Ennstone Thistle
- Ledaig Fish Processing Plant: Scottish Sea Farms
- Lighthouse Caledonia Fish Processing Plant Ardkinglas, Cairndow: Scottish Salmon Company
SEPA report on Ennstone Thistle’s operation at Furnace Quarry
The SEPA note on its classification of Ennstone Thistle’s e Upper Loch Fyne Furnace Quarry operation as ‘Poor’ says:
‘SEPA investigated environmental events (ELC breaches) resulting from operations at Furnace Quarry on two occasions during 2009 and in both instances enforcement action was taken in accordance with SEPA’s enforcement policy.’
ELCs are Environmental Limit Conditions – meaning that the operating licence for Furnace Quarry imposes environmental limits which have been breached twice in 2009, each of which required enforcement action by SEPA.
Quarries are assessed under ‘Regime B’ by SEPA – meaning that the chief consideration is air pollution. This indicates that the environment;a limits exceed in this case related to air pollution, which, in the case of quarry dust, is a serious threat to health.
It will be interesting to see the 2010 ’naming and shaming’ list when it emerges, given the volumes this quarry has been producing on a virtual 24 hour operation for some time, fuelling Scotland Transerv’s need for road stone in repairs.
SEPA report on Scottish Sea Farms operations at Ledaig fish processing plant
The SEPA note on the classification of the Scottish Salmon Company’s fish processing operation at Ledaig as ‘Poor’ says:
‘Investigations have indicated temperature issues affecting the operation of the biological treatment plant. This is being worked on. Operator has applied for variation to relax the Ammonia limits as modelling has demonstrated that there is suitable dilution to mitigate any environmental impact’
SEPA report on Scottish Salmon Company operations at Lighthouse Caledonia fish processing plant at Ardkinglas, Cairndow
The SEPA note on the classification of the Scottish Salmon Company’s fish processing operation at the Lighthouse Caledionia plant in Cairndow as ‘Poor’ says:
‘The Cairndow plant continued to have water discharge lower tier numeric breaches during 2009, despite the addition of a new unit to the treatment chain. Improved efficiency of treatment process has yet to be realised, and review of operations is on-going’.
Ammonia in fish processing
The references to biological treatment plants in the cases of the two fish processing plants named and shamed relates to the management of waste water from such plants.
Specifically, it relates to the effective treatment of ammonia levels in such waste water.
Salmon urinate ammonia and biological treatment plants are normally used to neutralise the ammonia in the effluents before discharge.
It is clear that in these two cases, this treatment process is inadequate to meet licence conditions.
- In the case of Ledaig, the operator’s response is to apply to change the levels of ammonia allowed – obviously upwards.
- In the case of the Lighthouse Caledonia plant, no improvement to performance has yet been achieved.
Why are ammonia levels important?
Ammonia is toxic and may be fatal if inhaled, ingested or absorbed through the skin.
Exposure to ammonia – with its irritative and corrosive properties - can lead to irritation, frostbite and serious chemical burns on the skin, in the mouth, throat, lungs and eyes. Other common symptoms include headaches, shortness of breath, nausea, and vomiting.
Some people suffering from asthma or other pulmonary conditions may be more sensitive than others to the effects of ammonia.
Most of us can smell ammonia in concentrations of less than 20 parts per million (ppm) of air – but repeated exposure to its presence rduces our ability to smell it.
Naming and shaming SEPA’s public information performance
As an organisation fundamentally responsible to the Scottish people for environmental protection, SEPA’s online public information system leaves almost everything to be desired.
It is the worst of culprits in information managed by bureaucrats for bureaucrats and it is technically incompetent.
You search the site in vain for everyday words like ‘pollution’ or ‘polluters’. The words. Compliance Assessment Scheme’ do not at all suggest to the concerned site visitor that this relates to pollution.
And indeed in some case it need not even do so.
Some operators whose environmental performance is classified as ‘very poor’ or ‘poor’ may be guilty of nothing other than failure to submit paperwork, although as SEPA’s stance asserts, others may delay to submit paperwork in order to disguise breach of regulations.
When you are guided, as we wee through phone queries, to click on Compliance Assessment Scheme, you it another blank wall – but, again at the bottom of a narrow column on the right hand side of the screen, there is ‘Compliance Scheme 2009 Assessments’.
However, this does not take you to a list. It takes you to a search system, which appeals to require you to enter or select information in each of four search boxes.
Neither we nor SEPA’s own Communications Department could get any results out of this – and we were looking for these three specific companies whose presence on the list was known.
Eventually, the very helpful member of SEPA Communications’ staff discovered, by trial and error that if he ignored all but the first search box and then entered only very basic information in it, a result was possible.
So: enter ‘furnace’, ‘ssf’ or ‘lighthouse’ in the first - ‘Site Name’ – search box -, then click ‘Filter’ below and you should see the broef notes on each we have republished above.
However – this is an all but utterly opaque system. It requires:
- serious and immediate attention from knowledgeable information and communications personnel - who understand and will test for usability
- the attention of competent IT personnel capable of creating a simple search engine that works.
Nobody would defend the release of polluting agents into waters that we like to believe are clear and pure but I suspect that the really major candidates here are the larger agencies like Scottish Water and the UKEA -Windscale! So good they renamed it Sellafield – that you feature in another part of your site. The advocates of the extension of nuclear power stations seldom pray in aid the appalling example for example of Dounreay who regularly manage to lose radioactive material into the environment at Sandside Bay and doubtless at other less obvious points or SW who appear to have regularly occurring crises in sewage treatment and waste water plant in Campbeltown, Oban and elsewhere. If SEPA ever throw the book at these offenders they must be doing it behind tightly closed doors
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