Your EA or environmental “licence” is the critical document for meeting your businesses environmental obligations. If the business entity responsible and accountable for meeting these obligations is not the entity listed on the EA then you should contact the environmental regulator in your state to have your EA updated.
Keeping water and sewerage assets operational and available day in day out can be challenging in itself. Ensuring your Operators have clear and accessible EA information is a great way of ensuring the environmental obligations do not get missed. This can be as simple as a laminated A4 plant information sheet in a convenient and accessible location that clearly outlines sampling frequency and quality obligations (water, land, air, etc.).
This includes disposal area requirements and effluent discharge requirements listed, such as final effluent (treated wastewater) BOD, TSS, TN, TP and/or free chlorine. You may also be obliged to show records of regular and accurate instrument calibration so having good management systems that ensure this will save potential issues if there is an incident onsite.
For instance, does your STP have a “winter feeding program” that will need to transition to a regular operational program, or does your STP need to be “fed” or “built-up” prior to the busy season to handle the higher loads the plant will experience?
An audit of the disposal areas should ideally be conducted when irrigation/disposal is taking place or has just recently finished, but ensure that this is conducted safely, i.e. do not expose you or your staff to unnecessary risks, but do look for evidence of:
Maintaining good records is not just critical to reporting to regulators annually, but also allows you to track and identify issues that are likely to become “an emergency” if not planned for. While you have the time make a point of reviewing your previous annual returns and look for feedback on what could be done better. Update your daily operational log sheets and other key internal reporting mechanisms to make future annual returns more comprehensive but easier to complete.
This document is critical to demonstrating to a public health regulatory body that you understand the public health risks facing your business and have adequate provisions in place to appropriately manage those risks.
Understand your businesses obligations and appropriately plan for them.
Not having a plan for incidents and emergencies exposes your business to risk and does not allow you to demonstrate to regulators that you are serious about protecting public health and safety. A typical response plan for a public health related water quality incident or detection could include, but should not be limited to:
Some examples could be as follows:
Plan to upgrade, replace or repair your assets based on the relative risk to your business. There is no sense having excellently serviced/maintained pumps, only for your level transmitters in storage tanks to fail and not be able to tell these pumps when and how to operate.
If you haven’t already, consider implementing regular monitoring of network flows and pressures, storage levels, and any other locations that will help track water consumption (including water treatment plant production).
Pipework branches and network zones that have been stagnant should be flushed to allow any biological growth (biogrowth) to be completely flushed and replaced with properly chlorinated water prior to bringing back online.
Maintaining your critical assets such as distribution pumps is necessary for continuous uninterrupted supply, but the instrumentation that controls these pumps is just as critical to this goal and assets have a habit of picking the most inopportune moment to fail. If you can, consider performing some “critical function” testing of key equipment, for instance switching off power to a duty pump and seeing that the standby pump automatically starts, or lifting a level sensor (if a float type) to see that it stops (or starts) a pump at high level. In all instances, keep safety front of mind. If it can’t be done safely then have a licenced plumber or electrician (depending on the test) carry these tests out on your behalf and provide you with a report that details what is working and what needs work.
Sodium hypochlorite will degrade to water and salt with drastically reduced disinfection properties. Chlorate is also a by-product of this degradation so rather than just topping up the same day tank, make a point of emptying the old residual chemical prior to the busy season, give the day tank a good clean (as appropriate and safely), and provide fresh chemical to your water treatment plant or disinfection system.
Prepare you and your Operators for more challenging raw water quality conditions, if these apply to the busy season, by reviewing previous operational history (e.g. last season’s raw water quality and chemical dose rates), updating your procedures and work instructions, and having contingency plans in place if historical experience highlights this risk (e.g. tanker potable water supply in if the raw water quality becomes too challenging and the WTPs “safe operating envelope” is breached).
Consider lifting and checking pumps prior to the busy season? If the pumps cannot be rapidly and safely removed in controlled conditions, then consider and plan for how this can be done in emergency conditions (e.g. design solutions or specialist contractors if necessary)
Check your pumping stations for excess flow from areas that shouldn’t have any. You can also check your flowmeters and see if they match with pump run times. Any discrepancies should be investigated and addressed if this is impacting the ability to provide sewerage services and a safe customer experience.
This includes pumps, blowers, mixers and the automatic control systems e.g. level, pressure and flow transmitters and water quality instruments. Make plans to have a regular inspection by licenced professional trades-people or process/mechanical engineers, so you can identify assets and equipment that are at most risk of failure and plan to replace these, or keep critical spares as most appropriate.
Does the plant operate according to this description? If not, does the manual need updating to match changes in the process, or do process upgrades or retrofits need to be conducted to improve plant operation?
This will require an experienced process engineer to help you determine but there are things you can do to assist with them calculate the amount of food required to get your plant ready for the higher loads of the busy season. Gather any data you have on daily flows to the STP and if possible, the population figures to match these periods e.g. daily flow to STP 20 m3 with resort population of 100 people. If you have raw water quality data for the STP then gather this and include this with your request to S&B to provide you with a feeding program to get your sewage treatment “bugs” up to peak physical condition and match-fit ahead of the busy season.
Regularly test your equipment in a safe manner so that you can be assured that it will operate as designed, at the right moment. If you have a local isolator switch (power supply) this could be as simple as switching off the power to the duty pump while it is running, and ensuring that the standby pump starts and supply is maintained. If you do not have local isolator switch, use a licenced electrician or suitably experienced engineer to assist in the testing and help resolve any issues.
Assets and equipment have a funny habit of waiting till the early hours of the morning or peak demand times to finally decide to pack it in (i.e. fail). If your equipment has not been tested in the last 12 months, then use this time to ensure that all assets are in a operable and serviceable state before the busy season kicks off.
Your Operators will be a valuable source of information on what general items are needed when emergency corrective maintenance is required. Use their experience to build a list of parts that may be required for those emergencies and arm your support staff with the tools and equipment to reduce the down-time if something does fail at the worst possible time.
Suppliers will generally have a reasonably well-developed list of critical spares, but if not your Operators will be the next best source of information.
This is particularly important for items that a “special” and likely to have long lead times. If you know you have duty (only) pump that presents a single point of failure for your system then holding a spare on the shelf may be the best way to cover the risk of this pump failing and suppliers telling you they cannot get a replacement to you for 8-10 weeks. In that case you may want to also consider having a dedicated online standby pump, but the cost of this upgrade may be too high in the short term, and a “cold” standby pump may only result in a short downtime (e.g. changed within 1 hour) and this may be more acceptable for the immediate future.
