Guidance

Paper, pulp and textiles: examples for your adapting to climate change risk assessment

Updated 17 May 2023

Applies to England

Possible impacts and mitigation measures to consider when preparing your climate change risk assessment.

Summer daily maximum temperature

This may be around 7°C higher compared to average summer temperatures now, with the potential to reach extreme temperatures as high as over 40°C with increasing frequency based on today’s values.

Impact 1

Possibility of increased fire risk within a waste paper storage yard.

The mitigation for this could include:

  • storage under cover wherever possible
  • making sure a fire prevention plan considers increased risk over time

Impact 2

Increase in potential for odour generation and amenity issues such as fly infestations associated with effluent treatment plant.

The mitigation for this would include:

  • reviewing the odour management plan to make sure it maintains adequate protection
  • consideration of covering tanks and storage facilities
  • reviewing the need for a pest management plan

Impact 3

Higher ambient process water temperatures leading to higher thermal loading at effluent treatment plant (ETP).

The mitigation for this could be influent cooling by cooling tower and recovery of low grade heat.

Impact 4

Potential impact on floc formation and nitrification at ETP.

The mitigation would include increased monitoring of ETP.

Impact 5

Thermal loading of effluent on watercourse, increasing stress to aquatic life.

The mitigation for this could be to consider installation of heat recovery within ETP.

Impact 6

Increased risk of Legionella.

The mitigation for this could be to increase biocide dosing, referring to sector-specific guidance from the Health and Safety Executive.

Winter daily temperatures

This could be 4°C more than the current average with the potential for more extreme temperatures, both warmer and colder than present.

Impact 1

Reduced performance at ETP due to extreme low temperatures.

The mitigation for this could include:

  • increasing monitoring to make sure nitrification levels are adequate
  • making sure contingency plans are in place for periods of reduced removal or treatment efficiency, including buffer storage and measures to reduce influent loading

Impact 2

Increased risk of pipework freezing.

The mitigation for this could be to insulate or provide trace heating for exposed pipework.

Impact 3

Land bank inaccessible due to prolonged periods of frozen fields.

The mitigation for this would be to make sure a contingency plan is in place for landspreading of wastes, including:

  • reduction in waste production at source
  • dewatering to reduced waste quantities
  • added storage options
  • alternative waste treatment outlets such as anaerobic digestion

Daily extreme rainfall

Daily rainfall intensity could increase by up to 20% on today’s values.

Impact 1

Flash floods could result. Effluent treatment plants may require more capacity or be overwhelmed.

The mitigation for this could include:

  • managing drains and ETP
  • considering surface falls at the design stage

Impact 2

Discharge point capacity may be overwhelmed.

The mitigation for this could be to take increases into consideration in the surface water management plan.

Impact 3

Increased shock flows to ETP and upset to primary clarification, resulting in risk of breaching suspended solids limits.

The mitigation for this could be:

  • installing buffer storage
  • increased separation of clean uncontaminated surface water

Impact 4

Risk to design capacity of interceptors and silt traps.

The mitigation for this could be to increase frequency of interceptor maintenance whilst conducting a review of their design capacity.

Impact 5

Loss of hydrocarbons and silt to ETP.

The mitigation for this could be to replace the surface water or oil interceptor if it’s inadequately sized.

Impact 6

Potential for increased site surface water and flooding.

The mitigation for this would be to prepare flood plan with reference to the guidance Preparing for flooding: A guide for sites regulated under EPR and COMAH.

This should include:

  • identification and risk assessment of process equipment and services at greatest risk from flooding
  • provision of emergency pumps to remove floodwater and identification of lowest risk location for discharge of floodwaters
  • protection of control and electrical systems
  • identification and protection of flat bottom tanks at risk of floating in floodwater

Average winter rainfall

Average winter rainfall may increase by over 40% on today’s averages.

Impact 1

Potential for increased site surface water and flooding.

The mitigation for this would be to prepare flood plan with reference to the guidance Preparing for flooding: A guide for sites regulated under EPR and COMAH.

This should include:

  • identification and risk assessment of process equipment and services at greatest risk from flooding
  • provision of emergency pumps to remove floodwater and identification of lowest risk location for discharge of floodwaters
  • protection of control and electrical systems
  • identification and protection of flat bottom tanks at risk of floating in floodwater

Impact 2

Weaker organic load and increased pressure on balancing tanks or clarifiers during winter.

The mitigation for this could be to divert increasing amounts of clean surface water to increase influent strength.

Impact 3

Land bank inaccessible due to prolonged periods of heavy rain, leading to fields being at or above field capacity.

The mitigation for this would be to make sure a contingency plan is in place for landspreading of wastes, including:

  • a reduction in waste production at source
  • dewatering to reduced waste quantities
  • added storage options
  • alternative waste treatment outlets such as anaerobic digestion

Sea level rise

Sea level rise which could be as much as 0.6m higher compared to today’s level.

Impact 1

If a site is located near the coast there is potential increased risk of flooding.

The mitigation for this would be to review flood defences around coastal landfill sites and to produce a flood plan with reference to the guidance Preparing for flooding: A guide for sites regulated under EPR and COMAH.

This should include:

  • identification and risk assessment of process equipment and services at greatest risk from flooding
  • provision of emergency pumps to remove floodwater and identification of lowest risk location for discharge of floodwaters
  • protection of control and electrical systems
  • identification and protection of flat bottom tanks at risk of floating in floodwater

Impact 2

Outfall can no longer be maintained.

The mitigation for this would be to consider relocation of outfall.

Impact 3

Flooding to site leads to increased risk to transformers for ETP and paper machine hall.

The mitigation for this could include relocating or raising all vulnerable transformers in line with the site risk assessment.

Drier summers

Summers could see potentially up to 40% less rain than now.

Impact 1

Stress on groundwater supply.

The mitigation for this could be to carefully manage water consumption and internal water loops.

Impact 2

Availability of water for surface water abstraction.

The mitigation for this would be to:

  • maintain progress on water consumption
  • consider contingency supplies during prolonged periods of dry weather
  • consider rainwater harvesting in winter months

Impact 3

Increased risk of spread of fire in stockyard.

The mitigation for this would be to keep the fire prevention plan under review at a suitable frequency.

Impact 4

Increase risk of dust accumulation.

The mitigation for this could be to increase housekeeping in vulnerable areas.

Impact 5

Increased dust and impact on combined heat and power air intake.

The mitigation for this would be to increase maintenance of air intake filters.

River flow

The flow in watercourses could be 50% more than now at its peak, and 80% less than now at its lowest.

Impact 1

At low flow, increased stress on the river if the plant is discharging into it.

The mitigation for this could be to manage the discharge flow rate and temperature to avoid impacts in the watercourse.

Impact 2

Availability of water for surface water abstraction at certain times of the year.

The mitigation for this would include:

  • reviewing the water reduction programme
  • investigating alternative sources of water to reduce reliance on abstraction, such as rainwater harvesting and effluent treatment for reuse

Impact 3

Reduced dilution available for effluent discharge.

The mitigation for this would be to maximise re-use opportunities and ETP performance to minimise load of pollutants discharge.

Storms

Storms could see a change in frequency and intensity. The unique combination of increased wind speeds, increased rainfall, and lightning during these events provides the potential for more extreme storm impacts

Impact 1

Storms and high winds could damage buildings and other structures, such as tall chimneys, with the potential to increase fugitive dust and wastepaper emissions.

The mitigation for this could include:

  • reviewing the design of vulnerable structures and buildings
  • reviewing wind loading calculations, providing reinforcement if necessary
  • maintaining building integrity