5 Steps to Properly Managing Your Industrial Wastewater System
Wastewater system operation and maintenance (O&M) is a complex process; one that is pivotal to facility compliance and the successful treatment of wastewater before it is discharged into the environment. Industrial wastewater is a product or byproduct of industrial and commercial processes, and is separate from domestic sources of wastewater.
This type of wastewater includes runoff and leachate from areas that receive pollutants associated with industrial or commercial storage, handling, or processing facilities. If your company discharges industrial wastewater, you must ensure that you treat it as needed before it enters the sewer system or otherwise leaves the facility.
Properly operating a wastewater management system in accordance with federal, state, and local regulations includes many requirements. Below, we've simplified the complex world of managing wastewater systems into five areas that you should pay particular attention to so that your system operates within compliance and to its full potential.
1. Permits and Regulatory Obligations
Are your permits, plans, and compliance obligations submitted, up-to-date, and in order?
The first step to compliance is communicating with your local sewer and/or environmental authority about your plans to discharge industrial wastewater. When you call, ask specifically for the industrial pretreatment program coordinator. This person’s responsibilities are to oversee compliance with the EPA's National Pollutant Discharge Elimination System (NPDES) pretreatment program. The local authority may require that you submit a permit application or notice of intent (NOI) that typically describes the sources, characteristics, and volumetric flow of your industrial wastewater discharge. The NOI also identifies other chemicals in use at your facility.
For any wastewater treatment processes that you operate (for example, pH adjustment, ion exchange, flocculation/coagulation, or settling tanks), you will need to create and regularly update an operations and maintenance (O&M) manual that describes your equipment and how it is designed to work.
O&M manuals contain: guidelines for start-up of the system, standard operating procedures (SOPs), directions for emergency situations, a staffing plan for the operators in charge of your system, and a record of the operation of the system. Properly maintaining manuals, plans, and logs shows the permitting authority that you keep your facility in good-running condition, and that compliance with your permit is important to you. These records can also serve as supporting data for proper operation and validation for replacement or upgrading the system.
If you are issued a permit, read it carefully upon receipt. Often you will have the opportunity to respond to the authority with comments, questions, and disputes of the requirements. Your permit may require periodic compliance sampling and laboratory analysis along with submitting reports to your state environmental department and/or local wastewater authority. You may also be required to submit other deliverables, such as pH and flow record logs, and other parameters monitored day-to-day.
2. Characteristics of Incoming Wastewater
You need to determine pH, temperature, and pollutants, to name a few.
Fortunately, this step is also part of many permit application processes and the wastewater system design, so the information you develop here will work two-fold. As a waste generator, you know the processes that produce your waste streams. You will need to review your chemical hygiene/management plan and other procedures to verify the chemicals that you keep on-site, and how those chemicals are handled. Interview other personnel at your facility to ensure that the plans are followed, and make adjustments if you discover discrepancies. Left uncorrected, those discrepancies could cause major problems in the future.
Review your procedures for how products and reagents are combined to produce wastewater streams. Once you have a handle on the character and variability of the wastewater, you can design your treatment system and/or develop protocols to ensure continuous and compliant operation. If you have the opportunity to run a scaled-down treatability study (aka “bench test”), do it. Even if performed on a small scale, it can head off pitfalls that could lead to substantial rework of your plans.
3. Quantity and Origin
How much wastewater does your facility generate for treatment and where is it generated?
If your facility has received wastewater discharge violations, whether related to volume, certain pollutants, or color, you are responsible for returning to compliance. You may wish to divert target pollutants from entering your wastewater stream in the first place, but if you don’t know their precise source, you’ll need to investigate further and possibly perform sampling at various points in the waste drainage system to determine where the pollutant originates. When a waste stream has the potential to cause discharge compliance violations, collecting the offending waste in a carboy instead of sending it down the drain can represent a significant cost savings over adding wastewater treatment processes or continuing to receive violations (and the “bad press” that goes with them).
Similarly, when a new process is brought online, you must be involved in the early planning stages to determine what waste, if any, will contribute to your wastewater discharge. You should review the material data sheets for any products used in the new process and even run some sample analyses on the waste to confirm whether it poses any discharge compliance concerns. When in doubt, check with your contact at the regulatory authority. Adding new sources to an existing wastewater discharge may require submitting further documentation.
4. Flow Measurement
Does the wastewater flow balance with known facility operations or are you treating more than is necessary?
As a wastewater operator and/or compliance manager, you must be familiar with the balance of how much water flows into your facility, and how much leaves. If the input does not equal the output, you must start tracking down discrepancies. For example, did you factor in cooling tower evaporation or irrigation uses?
Accurate flow measurement is important for several reasons. Flow rate is arguably the most critical factor when calculating the capacity of your wastewater treatment system. You’ll be in a perpetual battle trying to ensure that your wastewater is fully treated, and any upset could mean you'll have a major clean-up or compliance problem on your hands. Flow measurement is needed to determine treatment and thus how much of the chemical additives to keep on-hand. And strictly from a regulatory perspective, almost all discharge permits will require you to measure wastewater flow.
Flow can be measured by many different methods and types of equipment. Some meters such as magnetic, paddlewheel, and turbine require full-pipe (closed channel) flow, and often have a minimum flow rate that they can register accurately, so they don’t work well for very low flow applications. Flumes and weirs are suited for partially filled pipes (open-channel) and can read accurately across large ranges, including at zero to just above. Choosing the correct equipment to measure your flow is critical to collecting accurate and useful data.
5. Responsibilities of Operators
What are the daily, weekly, and monthly tasks of your wastewater operators?
Again, this depends on your system, but there are some common tasks that apply to most operators.
In terms of equipment maintenance, operators are responsible for managing pumps, probes, filtration equipment, software and firmware updates to automated systems, general housekeeping, testing alarms, and any other tasks to keep a safe and orderly facility.
Operators must also report any spills and/or abnormal operation. If any plans exist to: change operations, significantly modify and/or replace equipment, or change flow, operators must initiate the proper notification chain, which may also include the regulatory authority. As a good practice for notification, when in doubt, check your permit requirements and call the regulatory authority. If you outsource wastewater system maintenance, your vendor can facilitate notification.
Wastewater operators must also maintain their own licensure in good standing and be sure that they receive necessary training credit hours. These credits may go by names such as CEUs, ECHs, TCHs, CECs, PDHs, etc., depending on the terms your state licensing or certification board uses. No matter the name of your credits, don't wait until the last minute to attend training right before your license renewal is due.
Where to Get Started
If your facility discharges industrial wastewater, it is imperative that you're maintaining compliance with the various local, state, and federal regulations. Click below to learn more about how Triumvirate Environmental can help you.