Sewage Pumping Stations
Sewage pumping stations form a major element of sewerage services and are required to lift sewage from a lower to higher level to assist normal gravity-flow towards the sewage treatment plant. In some Queensland communities, sewerage networks rely solely on gravity but this is rare and most towns rely on pumping stations. There are 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 the emergency release of sewage (e.g. during floods), avoiding overflows occurring on private property and inside houses. Overflows can occur in wet weather when sewage volumes are increased beyond the capacity of the network, or because of illegal connections to the sewer and through infiltration of pipes by stormwater. Building sewerage systems large enough to contain the entire potential wet weather flow in sub-tropical and tropical Queensland is prohibitively expensive so overflows are a necessary feature of some pumping stations after heavy rain.
The design of Sewage Pumping Stations as the safest overflow point within a sewerage system requires careful management because of the potential risks to human health and the environment. Service Providers seek to reduce or eliminate overflows when possible and when they do occur, to reduce the chances of human contact by warning people not to swim or play in waterways that may be affected by a sewage overflow. In fact, recreation in urban waterways is not recommended in general after heavy rains as even when there is no chance of sewage overflows, stormwater can be contaminated with germs and chemicals from catchment run-off.
Regulation to avoid environmental impacts from overflows at pumping stations has been in place since 2009 and the industry has been working with the Department of Environment and Heritage Protection (the Regulator) since then to design fit-for-purpose rules to mitigate risks from overflows and avoid environmental harm. Significant changes have been made to the rules over the past few years (see Previous Regulation below), and the industry is currently transitioning from rigid and often unachievable ‘standard conditions’ to a more outcome-focussed Industry Code of Practice. This transition was suggested by the Regulator itself and a qldwater expert panel has been working on the new Code with the department. This transition was suggested by the Regulator itself and a qldwater expert panel is working on the new Code with the department. Until the Code of Practice is completed (estimated early 2015) the current Standard Conditions remain in place noting agreement between the industry and the Regulator on their interpretation (see FAQ below).
What is an Industry Code of Practice
Under the Queensland Environmental Protection Act 1994, an Industry Code of Practice (CoP) is a guideline created by the industry itself, describing optimal operations, maintenance and planning in different situations. Following a CoP can be used as a defence against a charge of causing environmental nuisance or harm or other offences like releasing contaminants to waters. The CoP is expected to reflect the outcomes targeted under the previously renegotiated Standard Conditions, but it can be more flexible than a rigid list of requirements, allowing for risk-based management relevant to conditions of each system.
Adhering to the Code would be voluntary, but operators who had an overflow and did not comply would need other evidence to prove that they had complied with the General Environmental Duty to avoid enforcement action. The Department has an information sheet and suggested template for Codes of Practice.
There are serious considerations for each service provider. For example, a CoP applies 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 40 kl/hr would be deleted, and those pumping stations would no longer need an environmental authority using Standard Conditions. This allows industry members to determine the best way to meet the desired outcomes specified in the Code of Practice but means that the only protection from prosecution is under the General Environmental Duty.
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. The potential risks and benefits associated with moving to an Industry Code of Practice were detailed in a qldwater Position Paper sent to all members in March 2014.
In the first half of 2014 a Position Paper was circulated to urban water service providers describing the potential risks and benefits for the industry in transitioning to a Code of Practice. The response (see Previous Regulation below) was overwhelming support for the industry to transition to an Industry Code of Practice. In the second half of 2014, qldwater commenced a process to develop the Code and invited broad industry involvement. This included:
- Forming an sub-group of qldwater's ERA 63 expert panel to advise on and review drafts of the Code of Practice.
- Keeping in regular contact with the State Regulator to ensure the Code would receive Ministerial consent.
- Keeping the industry informed through updates (e-Flashes, web page, newsletters and letters to urban water service providers – see below for some of these communications).
- Provision of draft documents for industry input including the following: a. Table of Contents for Industry Pump Station Guidelines (developed by the industry expert panel and ratified by the Regulator in 2013 - prior to Development of the Code)
b. Initial Draft of the Code of Practice based on the above document using the regulator’s Code of Practice Template.
c. A final draft of the Code of Practice was completed incorporating feedback from the industry and the Department of Environment and Heritage. qldwater is working with the Department to raise this document to Parliament to have the part of ERA 63 dealing with pump stations deregulated.
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 applied to stations with a ‘design capacity’ exceeding 40 kL per hour (11 L/s) unless the pump is an integral part of a sewage treatment plant (i.e. used to maintain flows on the site of the STP). The threshold was an arbitrary figure chosen by the Regulator to define stations that deal with a ‘significant’ amount of sewage. However, there is little correlation between size and either (a) the likelihood of overflow, (b) the volume discharged or (c) the 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 an industry-developed template and guideline and an incident response manual for managing sewer overflows in early 2010 following the release of the Wet and Dry Well Maintenance Manual in late 2009. Continuing industry advocacy 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 more practical regulatory framework.
In 2013, ‘greentape-reduction’ saw the recently released Code of Environmental Compliance converted to ‘Standard Conditions.’ This had no effect on the actual conditions applying to pump stations, but altered the way in which compliance could be achieved. This resulted in a new wave of negotiation between the regulator and the industry to clarify issues arising from the change and led to agreement early in 2014 to several amendments to the Standard Conditions. This included a variation to Condition 10 which had created the impossible requirement that there should never be overflows at pump. This aim would be impossible in many areas and would result in any excess flows spilling within low-lying private residences. 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 (including the Code of Environmental Compliance.
Members of the qldwater expert panel for STP and pump station regulation were asked to provide a formal response from their organisations and all were in favour of transitioning to an Industry Code of Practice subject to broader agreement from the industry. e-Flash # 222 was distributed on 28 February 2014 describing the proposal by the regulator and a draft industry Position Paper was mailed to all local governments that provide sewerage services requesting feedback. This communication process was continued until June 2014 with numerous reminders to garner the broadest-possible industry response. A majority of the industry responded by the June deadline and all supported the transition to a Code of Practice that was fit-for-purpose for different sized providers and maintained proper protection for all industry members. Responses were provided by the following Service Providers:
- Blackall Tambo
- Charters Towers
- Gold Coast
- North Burnett
- Queensland Urban Utilities
- South Burnett
- Unity Water
- Western Downs
- Wide Bay Water
Informal responses were provided by several more councils. In the entire response, there were no objections to the Code of Practice but six councils commented on the risks of removing protection provided by the existing ERA 63 regulation and the need to have a fit-for-purpose and outcomes-driven approach relevant to all sizes of service provider.
- The General Environmental duty applies to all pumping stations regardless of size/age.
- 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.
- Condition 10 under the Standard Conditions requiring no release from sewage pump stations has been found to be unachievable in many situations resulting in a Practice Alert being issued by the environmental regulator.
- The Standard Conditions and previous Code of Environmental Compliance and the Guidelines before it applied 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.
qldwater Position Paper Pump Station Regulation - Release Date 01-Apr-2014: - The regulation of sewage pump stations has been problematic for Queensland service providers since its introduction in 2009. Continued negotiation with the Regulator has resulted in current Regulation becoming increasingly practical, but in early 2014 the Department proposed a dramatic change in the way that this issue is managed. The proposal is for an Industry Code of Practice which could have significant benefits for sewage service providers but also create new risks. (112KB)
eFlash #230 - 3 June 2014 - Release Date 03-Jun-2014: - 1. . qldwater NQ Conference & Taste Test Mackay 29 July - Call for Papers. | 2. New ERA63 Guidelines Released. | (16KB)
Environmental Services Practice Alert 2014 Sewage Pumping Stations - Release Date 01-May-2014: - Following on from Practice alert 5/2013 – Sewage pumping station overflows, condition 10 of the standard conditions in the code of environmental compliance does not permit sewage pumping stations to have a release to land or waters under any circumstances. This condition has been shown to be inflexible as it does not take into consideration pumping stations are often designed to release during heavy rainfall. Proponents may apply for an amendment to vary this condition on existing approvals, or (186KB)
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)
qldwater Contents for Industry Guidelines for Pump Stations - Release Date 16-Oct-2013: - Standard Conditions created for Sewage Pump Stations under ERA 63(2) require among other things: Condition 10 Release to land and waters: The operator must ensure that contaminants are not released to land or waters (including the bed and banks of any waters) as a result of the activity. As pump stations are designed intentionally with the ability to release under conditions where sewage would otherwise damage private property, this condition cannot be met. The Department of Environment and Heri (17KB)
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: - Sewer Overflow Policy and Supporting Technical Guidelines. This two part document expands on State Government Guidelines to provide steps Service Providers can follow to meet their General Environmental Duty to reduce overflows and resultant environmental impacts. (1641KB). | Also available for modification by members. | Companion document of the Sewerage Incident Emergency Response Manual | (423KB) (518KB)
Water incident management flowcharts (member example) - Release Date 29-Jan-2010: - High-level incident management flowcharts provided by Sunshine Coast Water, showing procedures followed in the event of a water incident. (952KB)
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. | (365KB)
Sewage Treatment Plant Operations and Maintenance Manual - Release Date 04-Sep-2008: - This manual forms part of a series covering water and wastewater infrastructure. This manual deals with treatment facilities at the sewage treatment plant (STP) The user of this manual will be those water service providers throughout NSW and Queensland responsible for the operation and maintenance of facilities at STPs. | Available to members only. | (9146KB)