Despite the uptick in Delta variant case numbers, with the efficacy of the vaccines, things are headed in the right direction overall. In many sectors, business is picking up at a rapid pace. Perhaps at your company, plans to expand facility operations and introduce new product lines are back in motion. A heightened focus on EHS concerns with a commitment from management to grow the business is always welcome news for an Environmental Health and Safety (EHS) Manager. But do you have the right wastewater systems and plans in place to handle expansion and comply with environmental regulations?
Wastewater treatment systems are all-too-frequently an afterthought in facility planning because they generally don’t make money for your business, but cost money to operate and maintain. Wastewater treatment systems also occupy valuable space and are often shoe-horned into a tight corner of the building with little to no room for future expansion or equipment replacement. As an EHS professional, you need to know if your wastewater systems are adequately equipped, and if your discharge permit is flexible enough to manage the additional demands that are coming your way. It’s time to take a good close look at all elements of your wastewater operations and plan for a scalable future.
Ask yourself these questions:
Can my pretreatment system handle additional loading?
Hopefully your pretreatment system was designed with adequate contingency and can handle any additional loadings that are planned. Regardless, it’s best to conduct a comprehensive review of your pretreatment systems to confirm this, or to identify any limitations that need to be addressed in advance. Can your chemical metering systems keep up with the new demand? Are your chemical storage tanks sufficiently sized so that delivery frequencies are still manageable? Are there adequate equipment and control redundancies in place, and spare parts stocked, such that a component failure will not shut down your operations?
Does my discharge permit allow for expansion or new product introduction?
If you are currently generating less wastewater than allowed in your permit, and the additional flow expected from expanded operations are within permit limits, perhaps you’re okay. But what about the wastewater chemistry? Are you planning to introduce new contaminants to the sewer that are not included in your current permit? If future discharges may exceed your current permit’s flow and effluent limits, it’s best to initiate planning discussions with your Industrial Pretreatment Coordinator right away to confirm if a permit revision may be necessary for an uninterrupted long-term outlook.
If required, how long will it take to work through the re-permitting process?
Assuming your municipality can handle the additional flow and contaminant loading, how long will the re-permitting process take? It could be several months. If the treatment works requires additional testing to confirm it can handle the new loadings, the permitting timeline may be extended significantly. If there is business pressure to expand operations right away, are you prepared to segregate the new wastewater stream(s) and haul this material off-site for disposal? What are the cost implications?
What if the treatment works cannot handle the new contaminants in my wastewater?
Perhaps the sewer system and the treatment works can handle the additional flow from your operations. But frequently, new constituents in your wastewater can be problematic to the treatment works? Are you prepared to manage the cost and logistics of new wastewater streams via off-site disposal indefinitely? Can you modify your pretreatment system to address problematic contaminants on-site before the materials are discharged to the sewer? Is there room to expand? How do you keep your existing system running while new operations are installed? And do you have the properly trained and certified operators on staff capable of operating and maintaining a more complex pretreatment system?
Whatever your answers may be to the questions that need to be asked, planning for facility growth can be both exciting and challenging. As an EHS professional, it’s appropriate and often necessary to ask the questions raised here along with a holistic review of your wastewater pretreatment operations. You need to make sure you are prepared to meet your compliance obligations with the systems and procedures you have in place and you must advocate for system improvements to be part of overall organizational growth planning.