Sewage Pumping Stations
Sewage pumping stations form a major element of sewerage systems and are required to mechanically lift sewage to a higher level to assist normal gravity-flow towards the sewage treatment plant. In some Queensland communities, sewerage networks can rely solely on gravity flow without needing pumping stations but this is rare and there are estimated to be more than 3500 sewage pumping stations of all sizes across the state.
Pumping stations are usually located in low points of the landscape and often are designed as a ‘safety valve’ for emergency release of sewage (e.g. during floods) to avoid overflows on private property and inside houses. Overflows can occur in wet weather when sewage volumes are increased beyond the capacity of the network because of illegal connections to the sewer and stormwater infiltration. Building systems large enough to cope with the entire potential wet weather flow in sub-tropical and tropical Queensland is prohibitively expensive so overflows are a necessary feature of many sewerage networks after heavy rain.
Pump stations were designated as an Environmentally Relevant Activity (ERA) in 2009 under the Environmental Protection Regulations 2008 (EP Regs) to mitigate potential environmental impacts of sewage overflows at pump stations. The ERA applies to stations with a ‘design capacity’ exceeding 40kL per hour (11L/s) unless the pump is an integral part of a sewage treatment plant (i.e. used to maintain flows on the STP site).
The threshold is an arbitrary figure chosen by the State to define stations that deal with a ‘significant’ amount of sewage. However, there is little correlation between size and the likelihood for overflow, volume discharged or potential for environmental harm. An estimated 1900 pump stations in Queensland exceed the 40kL/hr threshold.
After the release of initial Statutory Guidelines for the ERA by the Regulator in 2009 the industry sought further advice and support on meeting the new requirements. This resulted in qldwater releasing industry-developed templates, guidelines and an incident response manual in early 2010. Continuing industry advocacy also led to the Regulator reformulating their Guidelines in 2011 and then in late 2012 converting the document to a self-assessable Code of Environmental Compliance. These changes, which were undertaken in close consultation with the industry, resulted in a far more practical regulatory framework.
In 2013, ‘greentape-reduction’ saw the recently released Code converted to ‘Standard Conditions’, having no effect on the ‘standard conditions’, but altering the way in which compliance could be achieved. This resulted in a new wave of negotiation between the Regulator and the industry to clarify some issues arising from the change and led to agreement early in 2014 to several changes to the Standard Conditions. However, before these changes could be made, the Regulator came back to the industry with an alternative proposal, namely to remove the legislative requirement (ERA) completely and replace it with an Industry Code of Practice. This would be a sweeping change introducing a very different approach to all previous models.
Industry Code of Practice
Under the EP Act, an Industry Code of Practice (CoP) is a guideline created by the industry itself, describing 'best practice' operations, maintenance and planning. Following a CoP can be used as a defence against a charge of causing environmental nuisance or harm or certain other offences (like releasing contaminants to waters). The CoP would be expected to reflect the outcomes targeted under the previously re-negotiated standard conditions, but it can be more flexible than a rigid list of requirements, allowing for risk-based management relevant to conditions of each scheme. Adhering to the Code would be voluntary, but operators who had an overflow and did not comply with the Code would need to prove that they had complied with the General Environmental Duty (under the Act) to avoid enforcement action.
There are serious considerations for each service provider in transitioning to a CoP. For example, a CoP would apply to all pump stations and the entire sewage network regardless of size and age. It also puts the onus on the industry to maintain best practice standards but removes the direct legislative requirement/penalty reflecting this need. Under a CoP, the current ERA for pumping stations over 40kl/hr would be deleted, and those pumping stations would no longer need an environmental authority. The CoP must be created and maintained by the industry in negotiation with the Regulator but would then be in place for seven years before needing to be reviewed.
Current Status (First half 2014)
Members of the qldwater expert panel for STP and pump station regulation were asked to provide a formal response from their respective organisations on whether to proceed with a CoP. Of the eight responses received at the time of writing, all favoured a shift to an industry Code of Practice. e-Flash # 222 was sent to the broader industry on 28 February 2014 describing and requesting feedback on the proposal by the Regulator and a draft industry Position Paper has been circulated to seek feedback from all local governments.
If there is broad support for a move to a voluntary Code of Practice, the document will need to be developed by the industry before the end of 2014 with the aim of having it recognised under Environmental legislation in early 2015.
- The General Environmental duty applies to all pumping stations regardless of size/age and the guidelines outline examples of application to ERA 63.
- The 40 kL/hr figure for 'large' pumping stations is based on total design capacity and is an arbitrary threshold to denote pumping stations of a size sufficient to be recognised as a specific Environmentally Relevant Activity.
- The Guidelines and CoEC apply only to infrastructure on the premises subject to the ERA.
- The definition for 'major upgrades' in the Standard Conditions means upgrades which will involve expenditure in excess of $150,000. This figure is relevant as of 1 January 2012 and will increase by 3% as of 1 January thereafter.
- While all contaminant release must be recorded and reported, it has been clarified that this is to be undertaken at a high level (i.e. not with intensive environmental monitoring and assessment) for all but significant (e.g. notifiable) overflows.
- An Integrated Environmental Management System and three ‘Management Plans’ (namely a Contingency Plan, Emergency Response Plan and the Sewage Overflow Abatement Plan) were previously required for all large pumping stations but these conditions will be replaced with a single requirement for written documentation that can cover multiple stations.
- For notifiable overflows, the notification procedures require a phone call to the Department’s pollution hotline number as soon as practicable within 24 hours.
- General requirements for notifications are now included within the EP Act (sections 320-320G) regardless of the Guidelines or CoEC. The notification guidelines listed above provide additional guidance on expectation of notification for overflows from pumping stations regulated under ERA 63.
eFlash #225 - 16 April 2014 - Release Date 16-Apr-2014: - 1. Industry Code of Practice for Sewage Pumping Stations. | 2. qldwater SWQ Conference & Taste Test – Warwick 16 May 2014. | 3. See you at Ozwater 2014. | (26KB)
eFlash #184 - 13 November 2012 - Release Date 13-Nov-2012: - 1. New Publication - Overview of 2011 Australian Drinking Water Quality Guidelines (ADWG). | 2. New Code of Compliance for Sewage Pump Stations (ERA 63). | 3. 2013 Events and Promotional Video. | 4. Website Changes. | 5. International Water Centre Partial Scholarships. | (34KB)
eFlash #175 - 7 August 2012 - Release Date 08-Aug-2012: - 1. Queensland Water Newsletter #4. | 2. New Code for Building Over Public Water Infrastructure. | 3. Passing of the Greentape Reduction and Other Legislation Amendment Bill 2012. | 4. Pumping Stations Targeted for Greentape Reduction. | (36KB)
eFlash #174 - 1 August 2012 - Release Date 01-Aug-2012: - 1. Drinking Water Quality Management Plan Review and Audit Guideline. | 2. Reform of STP Licensing Guidelines. | 3. Interim SEQ Bulk Water Board Announcement. | (28KB)
e Flash #159 - 5 April 2012 - Release Date 05-Apr-2012: - 1. Post Election Announcements Affecting Water and Sewerage - Week 2. | Finalisation of DERM Requirements for Large Sewage Pump Stations - ERA 63 (3). | 3. qldwater Support During Disasters. | 4. National Drinking Water Operator Certification Framework. | (37KB)
ERA63 Code of Environmental Compliance - Release Date 05-Apr-2012: - (377KB)
Notification criteria for sewage releases to the environment - Release Date 05-Apr-2012: - Final (254KB)
Sewage pumping stations ERA 63(3) - Release Date 05-Apr-2012: - (397KB)
e Flash #150 - 23 December 2011 - Release Date 23-Dec-2011: - 1. Summary of Proposed New Regulation of Sewage Pumping Stations. | 2. Urban Water Security Alliance Fact Sheets. | 3. New IWC Graduate Certificate in Water Planning. | 4. qldwater New Telephone Numbers Reminder. | 5. And the Winner is..... | 6. Merry Christmas and Happy New Year. | (46KB)
e Flash # 137 - 3 October 2011 - Release Date 03-Oct-2011: - 1. DERM Draft Guidelines for Sewage Pump Stations - Industry Response. | (26KB)
Industry Comments on Draft Pumping Station Guidelines - Release Date 30-Sep-2011: - The water industry was asked by DERM to provide comments on draft amendments to the Guidelines for Sewage Pumping Stations ERA 63(3). | Free download. | (73KB)
DERM Pump Station Guideline - Sept 2011 - Release Date 02-Sep-2011: - (134KB)
e Flash #132 - 2 September 2011 - Release Date 02-Sep-2011: - 1. Short Term Staff Changes at qldwater. | 2. Regional Collaboration of Provision of Water Services. | 3. Industry Feedback Sought on Changing DERM Requirements for Sewage Pump Stations. | (43KB)
Sewage Incident Response Manual - Release Date 02-Apr-2010: - Industry template for a WSP-specific manual for responding to sewage overflow incidents and meet Queensland environmental legislation. Created by qldwater with input from members. | Available for modification by members. | (1122KB)
Sewer Overflows Policy Guidelines and Template - Release Date 02-Apr-2010: - Policy template and guidleines for use by members to create a WSP-specific policy to mitigate and manage potential sewage overflows. Created by qldwater with assistance from members and reference to Queensland environmental legislation. | Available for modification by members. | (423KB)
Wet and Dry Well Maintenance Manual - Release Date 04-Dec-2009: - Manual and template for best practice maintenance of wet and dry well pumping stations. Created by qldwater for use by members. | Available for update by members. | (344KB)