Posted: March 24th, 2023

Environmental Improvement and Management Plan

Executive Summary

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Thames Water Utilities Ltd has faced controversies, including the leaks of untreated sewage to River Thames. The project aims at implementing an environmental improvement and management plan to protect the community and improve its image by ensuring better sewage treatment and reduction of pollution in the river. The scheme explores chemicals for CEPT and potential disinfection as the options to achieve its objectives. The discussion includes the risk and pollution sources using the Source, Pathways, and Receptors model, the actual effects of the pollution, including degrading water quality, Waste Management Implications using the Plan, Do, Check, Act model, policy instruments, environmental policies and legislation, and the environmental management system standards, including ISO 14001 and EMAS. The implementers will follow the above steps to achieve the objectives of the plan.




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Environmental Improvement and Management Plan for Thames Water Utilities Ltd


Thames Water Utilities Ltd is the company undertaking the project to prevent further pollution on River Thames, which results from the discharge of raw sewage. While the company plays a critical role in the management of water supply and sewage treatment, it has been accused of several issues, including the leaking of untreated sewage into the river. The firm was among the most heavily fined organizations in the United Kingdom between 2005 and 2013 for pollution incidents. The company continues to face accusations related to release of untreated sewage into the River Thames, which is a public safety concern. Thames Water is expected to comply with safety regulations. Therefore, the company should take the necessary precautions to ensure that the no waste contaminates the river. Thames Waters is expected to implement an environmental improvement and management plan to protect the community and improve its image. The initiative should be part of the ongoing effort in the U.K. to protect the environment.

Review of Chemicals for CEPT and Potential Disinfection

Three treatment options are considered to improve water quality and other environmental outcomes. The implementers will perform a batch test using an optimal chemical coagulant to establish the effectiveness of the method in chemical treatment of sewage. Biochemical oxygen demand (BOD) removal requirements and suspended solids (SS) at Thames Water are potentially about 50 percent and 70 percent respectively (Jouanneau et al. 2014, 63). Permitting an increase in wastewater strength will produce a typical sewage quality of <100 mg BOD/L and <55 mg SS/L. Past research shows that many chemicals have the potential to achieve the objective, including “polyaluminium chloride (PAC), polyaluminium ferric chloride (PAFC), poly ferric sulfate (PFS) (individual or couple with poly acrylamide [PAM])” (He et al. 2016, p. 209). In addition, the project will use the CEPT process as an effective approach for wastewater treatment.

Besides CEPT, other disinfection options can be used in the wastewater treatment process. UV irradiation and chlorination are some of the procedures that research have tested in terms of effectiveness in killing pathogenic microorganisms to prevent pollution. Ozonation and microfiltration can also be used, but the project will consider the first two due to the ease of access to the compounds. The feasibility of the selected options depends on their technicality relative to the project. UV irradiation is possibly the most technically practical option for the expansion of Thames Water Sewage works. One of the criteria used in selecting the alternative is the environmental impact (Wang et al. 2012, p. 1227). The proposed approach is revealed to have a minimal ecological impact and lacks dangerous by-products, which is influenced by the U.K. disinfection policy. The Environmental Agency policy dictates the use of UV solely as the long-term disinfectant. Chlorination is less feasible than UV irradiation because of the high cost involved in its use (Wang et al. 2012, p. 1227). While chemicals are not mostly favoured for the process because of THMs found in the compounds, research in the recent past has proven success and safety in their use in wastewater treatment (Simmons et al. 2002, p. 1013). Therefore, the project will use UV irradiation for disinfection of the sewage at Thames Water Sewage works.

                      Risk and Pollution Sources (Source, Pathways, and Receptors)         

            The project involves the efforts to control pollution risks. The team in charge of the scheme should consider the source, pathway, and receptor model to achieve the objective. The model plays a role in reducing the risk and mitigating any possible incident. The source is the origin of the pollution, and in the case of this project, it is the sewage and related wastes. The pollution emerges from the chemicals available in the water including “nanomaterials, pesticides, pharmaceuticals, industrial compounds, personal care products, fragrances, water treatment by-products, flame retardants and surfactants, as well as caffeine and nicotine” (Stuart et al. 2012, p. 1). Thames Water suffers the risk of leaking untreated sewage into the River Thames, causing water pollution. The pathway part of the model considers the way through which the contamination travels to the environment. Various trails are evident in the process of leaking untreated sewage into the river, including land and water. Micropollutants from the untreated water escaping from the treatment plant flow because of their persistency or/and the continuous introduction (Brankov, J, Milijašević, D and Milanović, A 2012, p. 50). The elements consider the aspects of the environment that the pollution is likely to affect. There are both human and environmental receptors of pollution (Naidu et al. 2016, p. 353). The leaked untreated sewage finds its way into the River Thames and potentially other water bodies. The emerging organic contaminants harm human health and aquatic ecosystems (Lapworth et al. 2012, p. 288). Humans and animals use the water, making them receptors of the pollution. The waste also flows through the land, possibly causing contamination, which affects plants and other life supported therein.

            The model is useful in the project to implement controls for the pollution. The most effective place to apply controls is before the source. The implementer should identify the cause and stop it before it moves on to the next level. The project is about considering the ways of reducing pollution from the source. It should find the means of preventing the emerging contaminants through effective treatment (Gavrilescu et al. 2015, p. 148). Even when the company cannot to stop pollution at the source, it will help to control it through effectively treating the wastewater. For instance, the firm can ensure that it treats all its waste products such that if there is any leakage, it does not cause any harm. The process would intercept the pollution before reaching the receptors. The model is useful in protecting the receptors from the adverse effects of the contamination (Naidu et al. 2016, p. 353). The approach is also crucial as a remediation plan if the problem of leakage occurs. For example, the company has in the past been accused of leaking untreated sewage into the river. As a remedy, the project will aim at minimizing the risk of pollution to the minimum level through successful treatment (Gavrilescu et al. 2015, p. 148). Also, since they know where the wastewater flows when it leaks, the sewage can be re-channeled to ensure that it does not reach the receptors.

Air Quality, Noise Quality, Water Quality, Land Contamination, Ecological Impact

Waste sewage affects the quality of water, land, and the environment in general. The effects on water depend on the nature of the water itself. Some water bodies are more prone to pollution than others. The characteristics and quantity of the contaminant also affect the process, explaining the importance of understanding the source of the pollutant (Owa, 2014, p. 1). Physical, chemical, and biological features of the water determine the level of pollution since they determine the capacity of the water to absorb and assimilate pollutants. River Thames is a large water body, which increases its ability to accommodate high amounts of the untreated sewage. Waste products alter the acidity level of the water and raise its temperature (Carmona, Andreu and Picó, 2014, p. 54). Experts can assess the actual impact through testing the water chemistry and the impacted system’s biota. Research reveals that when any form of pollutant flows into the river, it might change the chemical composition of the water completely, making it unfit for human consumption (Lapworth et al. 2012, p. 288). However, people depend on the same water for the survival since they use it for cooking, drinking, and washing among other uses. Therefore, companies and individuals should avoid leaking any waste into the waters.

Untreated sewage flows through the land, affecting its quality. The area through which the contaminants have permeated cannot successfully support life. Land management practices determine the level of pollution that flows through into the water body. The worst contamination is evident in lands that are used for agricultural activities because they cannot support crops Shen et al. 2012, p. 105). Untreated sewage also leaks into the environment, causing detrimental effects. Concentrations of fecal-coliform bacteria are high where sewage leaks through agricultural lands (Reder, Flörke and Alcamo, 2015, p. 252). The challenges make vast stretches of land unsuitable for agribusiness. Currently, the environmental damage of pollution has become a serious issue. Untreated sewage harms wildlife and other living organisms that depend on land and water. Marine ecological systems are affected negatively when any pollutant enters their environment. The pollution destroys animals and their food chain (Lapworth et al. 2012, p. 288). Whether on the ground or water, contamination is the cause of various serious diseases such as e-coli, diarrhea, and hepatitis A. People are struggling with critical water-borne diseases due to the increasing level of pollution in the water they consume. Therefore, the project has implications for protecting life and the environment.

Waste Management Implications (Plan, Do, Check, and Act)

There are waste management implications related to the improvement of the environment resulting from untreated sewage. The project will apply ISO 14001 standards, particularly the improvement cycle of Plan-Do-Check-Act (see illustration below).

The model plays a critical role in quality control and improvement. The company is implementing a change to develop the process of treating sewage and protecting the river and the environment. The model relates to the acceptable standards for environmental conservation (Ferreira, Santos, and Silva 2014, p. 144). The plan’s objective is to reduce the amount of untreated sewage flowing into the river. Therefore, successful implementation will increase the efficiency of the treatment procedure and reduce the leakage.


The plan begins with understanding the organization’s context, expectations, and needs of the stakeholders. The implementer should determine the scope of the project, and the roles and objectives of the involved parties. The project will involve all the affected stakeholders (Luyet et al. 2012, p. 213). Planning continues to the concept of understanding the opportunities and risks that the project will create.


Do is the implementation aspects of the activities that will decrease the amount of sewage leaking into River Thames. The project phase involves the acquisition of an improved sewage treatment system as part of environmental management projects (Ferreira, Santos, and Silva 2014, p. 144). Various processes are critical to establish and maintain an effective sewage waste reduction plan. The implementers should develop operational controls required for the company to continue operating in a way that it reduces the adverse effect of its activities on the environment. The plan includes the emergency preparedness and response strategies in case something goes wrong.


A check is the evaluation of the project to establish whether it is achieving the objective. The process entails a comparison of the actual reduction against the expected. The implementers will have reached the purpose when the aspect of “check,” after implementation, is lower than before. If the level is the same or higher, it means that the project is not achieving the objective. The evaluation methods include monitoring, measurement, analysis, and evaluation that relates to the organisation’s characteristics with the leading effect on the environment. The results are critical to inform the performance of the project (Hendren et al. 2013, 1192). Internal audits are also activities in the process as they review to validate the project. The team should perform a management review and maintain information effectively.


The Act phase involves decision-making. The project implementers are expected to decide the course of action. The activity requires nonconformity and corrective action to address possible problems as identified during the evaluation phase. The facilitators react to the information to make necessary adjustments (Hendren et al. 2013, 1192). They implement new targets once they meet the previous ones. The project team adjusts the scheme if it does not realize the objectives. The actions are a part of the continual improvement program (Ferreira, Santos, and Silva 2014, p. 145). The phase allows modification of the project such that the Plan-Do-Check-Act cycle begins again.

Policy Instruments

The project will use some policy instruments categorised into administrative, economic, and informative. The implementers will use them in isolation because each will serve a particular purpose. Various administrative tools are available, including “substance restriction; source separation; producers take-back of specific discarded products; collection, reuse/refill and recycling targets; minimum recycled material content standards; landfill restriction/diversion targets; and environmentally sound treatment standards” (Tojo, Neubauer and Bräuer 2008, p. 9). However, the project team will not use all the instruments because some do not apply to sewage treatment. Some of the devices are preventive, while others deal with the problem after its occurrence. Compulsory recycling is one example of an effective prevention process (Finnveden et al. 2013, p. 842). Preventive instruments are the most effective and less costly. Substance restriction; source separation, reuse/refill and recycling targets, and environmentally sound treatment standards are some of the instruments that the project team will utilise.

Economic instruments for waste management are the second category that the project implementers will use. Among the policy instruments under this category include “landfill tax, waste disposal tax, recycling credit scheme, subsidies for secondary products/taxation of quarry products, waste pricing: pay-as-you-throw approach, and deposit-refund systems” (Tojo, Neubauer, and Bräuer, 2008, p. 10). Applicability of the instruments will comprise organizational requirements and political acceptance/enforceability. Additionally, the project team will not use particulars apparatus because they do not apply to the project and some are costly to implement (Sterner and Coria 2013, p. 82). Waste pricing and deposit-refund systems are the only policy instruments that the team will include since they are within the scope of the project and can be implemented efficiently.

Informative instruments are the last category of the policies that apply to the project. The development team will choose from among the following tools: “eco-labeling scheme, green shopping guide, marking of products and components, information campaigns to residents, information provision to treatment facilities” (Tojo, Neubauer, and Bräuer 2008, p. 12). The informative instruments are critical to send a message to the affected parties about the nature of the project. Some of them will not apply to the project. Therefore, the implementers will only use the two, including the information campaigns to residents and information provision to treatment facilities. They will play a role of involving the stakeholders by communicating the project’s objective. For example, it will ensure increased community support for the waste sewage treatment plan.

Environmental Policies and legislation (Type of laws, Environmental legislation, Penalties, and Environmental Regulators)

Most of the conservational legislation in the U.K. emanate from the European Union law. The national code implements the statute. The ecological regimes that apply to the project are the Environmental Permitting Regime (EPR), waste, conservation of nature, environmental impact assessments, and wildlife, and habitats (Jörgens 2012, p. 91). The legislation specifies the liability of any perpetrator. However, there are different categories under which the regulator can charge an individual or company for violating environmental law.

Environmental liability, as relates to the project, can arise under criminal law, civil law, public or administrative law, and company law. The relevant regulator persecutes a person or company that violates the environmental laws (Jörgens 2012, p. 91).  About GB£50, 000 and/or six months imprisonment is the minimum penalty in lower courts. Unlimited fine and/or five years imprisonment apply in higher courts: unlimited fine and/or five years imprisonment (Coxall and Hardacre, 2018, para 11). The courts can prosecute individuals, company directors, and officers. The common law of nuisance or negligence is the civil regulation that people can file in cases relating to environmental matters. The public or administrative law also applies to the issue of an environmental law violation. A person who fails to comply with enforcement notices can be found guilty of committing a criminal offence. The most common penalty in the event is shutting down the operator’s activities. Directors must promote the success of the organization according to the company law (Coxall and Hardacre, 2018, para 15). They should ensure that the organization’s actions do not harm the community or environment.

The Environment Agency (EA) is the primary regulator of the environmental law in the U.K. It adopted an enforcement and prosecution policy to deal with the relevant cases. Enforcement is discretionary, but compulsory in some cases. For instance, the local authority or the EA must give a remediation notice in case of potential contamination, unless the process is voluntary. The Regulatory Enforcement and Sanctions Act 2008 is the source of civil sanctions by some regulators (Coxall and Hardacre, 2018, para 18). The penalties, unlike the criminal ones, include compliance notices, fixed or variable monetary penalties, stop notices, restoration notices, and enforcement undertakings. However, the sanctions depend on the regulatory regime.

Environmental Management System Standards: ISO 14001, EMAS Etc.

Various regulatory tools are available for effective environmental management. An environmental management system (EMS) is an international instrument that enhances conservation management aspects of organizations. The global regulatory authority expects all organizations to implement continuous improvement of environmental performance. The international standard ISO 14001 is one of the reference standards that relates to EMS. The International Organization for Standardization (ISO) is the private body that created the rule. The Eco-Management and Audit Scheme (EMAS) is the second reference standards related to the same. The European Regulation EC 1221/2009 controls the standards (Disterheft et al. 2012, p. 82). However, the organisation is free to establish its EMS, but following the codes. The freedom is as a result of the differences in the internal characteristics and structures. They also define the interior solutions that apply to their unique environmental challenges to improve their performance (Boiral and Henri 2012, p. 86). Thames Water will implement the EMS to strengthen its procedural aspects of environmental management, including sewage treatment and prevention of leakage into River Thames. The EMS will specify all the requirements for successful adoption of the project and related activities. The tool offers potential benefits to the company, the community, and in the reduction of pollution.

The EMS will have various features that make it useful in achieving the project’s objective. Those aspects include “recording and use of information, knowledge, and implementation of authorization requirements, plant maintenance, management and training, and process operation” (Testa et al., 2014, p. 164). It is the environmental toolbox that a policy-maker can utilise to achieve its environmental objectives. The project will integrate environmental protection and sustainable use of natural resources. The company is already involved in the treatment of sewage and wastewater, but it has not adequately prevented the leakage into the river. Therefore, the EMS, informed by ISO 14001 and EMAS, is likely to succeed since it will follow all the necessary guidelines. The decision to design the project founded on the Deming cycle (i.e., EMAS) concept is evidence of the importance of local and international standards in environmental management activities. The EMAS and ISO 14001 adoption are gaining support in the U.K. and forming a platform of effective conservational policies (Whitelaw, 2012, p. 18). Thames Water will use the standards to change its ecological narrative and avoid future violation of the environmental law.


Thames Water Utilities Ltd is currently facing challenges relating to its environmental policy. The company is the leading contaminator of River Thames due to the leakage of untreated sewage from the enterprise into the water. The firm plays a role in the treatment of wastewater, but the management should address the controversy to maintain a positive image and protect the community. The proposed project is aimed at increasing sewage treatment to reduce the level of water pollution associated with the company. The project includes an environmental improvement and management plan. Thames Water Sewage work to improve conservation performance on the eco-friendly management systems.

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