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Highlands Islands Airports Limited (Form)

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Highlands Islands Airports Limited (Form) Enforcement Undertaking Section 1 Details of person making this offer Full name of person making offer: Highlands & Islands Airports Ltd Are you: An individual A partnership A limited company A limited liability partnership Public Body Other If ' Other', please specify: Non -Departmental Public Body Address and full Postcode: Highlands and Islands Airports Limited Inverness Airport IV2 7. 113 Registered office Address ( if different from above): As above Registration Number ( if a company or an LLP): SC097647 Contact Telephone Number: 01667 464000 Email Address: info@hial. co. uk If the Offer is made by a partnership, a limited company, a limited liability partnership, a public body or another entity, please give us the contact details of a person we can contact about the offer ( e. g. this could be a managing partner, a company director or a Head of Service). Full Name: Graeme Bell Address ( if different from above): Contact Telephone Number: 01667464020 Email address: gbell@hial. co. uk Page 1 Section 2 Tell us about the act or omission that has led you to make this offer. Please give the location of the offending behaviour, include a National Grid Reference ( NGR) if you can. What happened or failed to happen? How did it happen? When did it happen? 2nd 2. 1 On December 2015 a SEPA Sampling Officer reported an unidentified discharge occurring at NGR NH 7835 5274 into an un - named tributary to the Ardersier Burn. A sample of the discharge was taken by the SEPA Officer and analysis indicated a Biochemical Oxygen Demand in excess of 120mg/ I, exceeding the 3 mg/ I BOD limit allowed under the CAR licence. The discharge occurred when the capacity of the swales and reed -beds had not been exceeded and as such was considered to breach CAR/ L/ 1009176 ( Schedules as stated in Section 8). 22nd 2. 2 On December 2015 an Information Notice ( IN) was served on HIAL ( Inverness Airport) by SEPA. Following the issue of the IN, extensive investigations were carried out by HIAL ( Inverness Airport) through the use of term contractors. As a result of the initial 7th investigations on January 2016, a representative from HIAL ( Inverness Airport) confirmed to SEPA by letter that the ( unauthorised) discharge occurred due to the failure of a riser pump. It was believed that the operation of the riser pump had been affected by the breakage of a support chain which had failed due to corrosion. However, the existence of the riser pump was queried as it did not appear on any as -built system plans and was found to have been misidentified. The pump in question was actually the recirculation pump for the northern reed -bed and was inoperative. 22nd 2. 3 On January 2016 an Enforcement Notice ( EN) was served on HIAL ( Inverness Airport) by SEPA. The EN required the immediate installation of a temporary pump to 22nd replace the one which had failed and the rectification of the system by February 27th 2016. A temporary pump was delivered to site and installed on January 2016 and a 19th letter confirming completion of the rectification works was issued to SEPA on February 2016. 2. 4 Following the installation of the existing system HIAL ( Inverness Airport) had been working on environmental improvement at the site for several years, this included drain realignment, new drain construction, drain reconfiguration and various other investigative works. However these works were reactive and lacked focus. As a consequence it proved difficult to view the local issues in the wider context of environmental management at Inverness. As a result corrective actions focussed on outcomes and not the root cause of the environmental system failings. The investigations carried out as a result of the IN/ EN also found that: pipework associated with the environmental system was clogged and blocked in various locations; valves and switching mechanisms were poorly maintained and had suffered failures in several locations; wells were silted and flow restricted; a pipe running from the north- eastern threshold of the main runway by- passed Page 2 the environmental system allowing untreated surface run- off to discharge to the burn; insufficient warning and alerting systems were incorporated in the environmental system meaning discharges could occur without the knowledge of the airport; the as -built diagrams were incorrect and misidentified the location for the point where the unauthorised discharge occurred. 2. 5 The incident and subsequent investigation identified a requirement for further improvements in HIAL ( Inverness Airport)' s approach to Environmental Management. These included: More clearly defined responsibilities for Environmental Management and Compliance; Greater understanding of installed systems and their correct operation; Improved maintenance of systems to ensure operation as designed; Greater compliance with monitoring and management systems as required by licence conditions. Section 3 If the act or omission was a breach of an environmental authorisation, please provide the authorisation number and tell us what condition or conditions were breached. Controlled Activities Regulations ( CAR) Licence reference no CAR/ L/ 1009176 Condition numbers; 2. 71 and 7. 41 of water use licence were breached. Section 4 If you know the legislation that has been breached, please refer to it here, giving the name of the Act and section number or the name of the Regulations and regulation number. Water Environment ( Controlled Activities) (Scotian d) Regulations 2011 Section 5 What, if any, environmental impact was caused by the offending behaviour ( e. g. any impact on water, air, land, human health or amenity)? 5. 1 A trade effluent with a Biochemical Oxygen Demand level greater than 120 mg/ I BOD was measured entering an unnamed tributary of the Ardersier Burn, and the fault identified was deemed rectified 79 days later. 5. 2 HIAL ( Inverness Airport) also identified sewage fungus at the outfall of the culvert Page 3 during winter periods. 5. 3 SEPA informed Inverness Airport of complaints from local residents who notified them of unpleasant odour from the airport drainage system in the winter. 5. 4 In accordance with the European Water Framework Directive SEPA have classified the un - named tributary to the Ardersier Burn status as " Good" upstream of the culvert and " Bad" downstream of the culvert. 5. 5 A Habitat and Ecology survey has now been carried out as detailed in Section 8. Section 6 What, if any, costs did you avoid, or financial benefit did you make from the offending behaviour? 6. 1 HIAL ( Inverness Airport) estimates that the following costs were avoided leading up to, and as a result of, the offending behaviour. The estimate is based on the omission of planned maintenance since system commissioning in 2006, omission of environmental management oversight and tankering away over a period of 79 days: Tankering away of trade effluent during pump failure: 27 362 Mechanical and Electrical planned maintenance since system installation: 101 700 Civils planned maintenance since system installation: 58 500 Environmental Management Oversight since system installation: f28 600 Total 216 162 6. 2 Although the above costs were not incurred due to omissions in maintenance, other areas were routinely maintained and emergent work carried out as necessary ( as referenced in section 2, paragraph 4). These costs were for the replacement and subsequent maintenance of the TOC analyser: Replacement of the TOC analysers with upgraded system: 31 000 TOC analyser maintenance and repair: 44 200 Additional investigation and repair costs since system installation have amounted to: Drainage survey ( 2011) f16 559 South apron drainage CCTV survey ( 2011) f2f2 690690 Main runway drainage investigation ( 2011) 8 500 Main runway drainage clearing and testing ( 2011) 90 846 Sealing of main runway disused pipework (2011) 25 000 Civils investigation and repair following IN/ EN ( 2015/ 16) f40 309 Total 259, 104 6. 3 HIAL will remove the £ 27, 362 financial advantage identified in 6. 1. above Page 4 carrying out the following: A Habitat and Ecology Survey along the tributary to the Ardersier Burn £ 2637 An Ecology Survey at the proposed new outfall in the Moray Firth £ 1750 Employment of a local biodiversity specialist at the airport £ 5200pa This will ensure the sum is repaid over a 4 year period. 6. 4 Since the completion of the initial investigation and rectification works HIAL have committed significant funding to a project to upgrade the existing water treatment system. The initial funds allocated, phased over the next two financial years, stand at 268, 526. This does not include construction costs. Section 7 How are you going to ensure the offence does not continue or recur and what date/ dates will you have achieved that/ those action( s) by? Please specify what will be done and the date which it will be done by. 1St 7. 1 HIAL will have in place an Environment Strategy ( ES) by the October 2017 which will present how environmental benefits will be delivered during the next five years and beyond. This will include: 7. 1. 1. The implementation of an Environmental Management System ( EMS) to deliver the Environment Strategy. 7. 1. 2 HIAL operate under strictly regulated policies and procedures for both security and safety. These are delivered through a robust Safety Management System ( SMS) which is subject to regular audit and oversight by regulatory bodies such as EASA and the CAA. The SMS is fundamental to the Company' s business and is the core of the Safety Culture applied to everything the Company does. 7. 1. 3 The same robust approach will be applied to environmental management and this will be addressed through the implementation of the EMS. The EMS will sit under the Company' s SMS and the policies and procedures will be commonly applied to both wherever possible. 7. 1. 4 A draft EMS has been produced and an Environmental Working Group is in place to manage its development and implementation.
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