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| Pretreatment Manual |
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For more
information, contact David Eppstein by email at
deppstein@masco.harvard.edu,
or by calling 617-632-2860.
12.0 PRETREATMENT SYSTEM IMPLEMENTATION AND OPERATION
Bench-scale
feasibility and treatability testing and onsite pilot testing
may vary in the time required to get the desired results. Good
records need to be maintained during this phase because the
records may be needed at times when referencing regulatory
authorities, waste disposal vendors, or using the information
for full-scale system selection, design, installation, and
operation. Some items that need to be addressed during
full-scale pretreatment system implementation and operation are:
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Purchase
orders and contracts must be developed for the selected
pretreatment system, supporting equipment and systems,
piping, valves, instruments, controls, electrical power and
lighting systems, and installation materials. The consulting
engineering firm, an architectural-engineering firm, and a
general contractor may be used during this phase.
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The
project manager must be sure that all the proper permits and
licenses have been addressed and granted before the
installation and operation can take place (please review the
section in this Manual about licenses).
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The
equipment, once in place, should be thoroughly tested for
proper performance. Performance testing requirements should
be detailed in construction contracts. The contracts should
also include provisions for training of licensed operator(s)
in the functions and maintenance requirements of the
equipment and controls.
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Log
books (including wastewater discharge volumes and times),
standard operating procedures, licenses, and sampling
results must be maintained onsite for regulatory inspections
and for your own information and comparisons.
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Equipment
repair and parts lists and service and inspection logs
should be kept on hand in case of a breakdown. These
documents usually include lists of parts known to fail after
extended use, or have a known service life. The list would
also feature parts that would be changed periodically as
part of normal maintenance (filters, screens, membranes,
chemicals, gaskets, etc.). Often, pretreatment system
vendors supply spare parts for a one year period as part of
a purchase order. If the spare parts are not properly used,
the service contract and warranty can be negated and, more
important, could cause the system to malfunction.
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The
company must take compliance samples of the treated
effluent, according to the discharge permit requirements
established by the regulatory agency or with the
requirements of any noncompliance enforcement order.
Usually, the required frequency of effluent sampling is
specified in the permit or enforcement order. For the MWRA,
the sampling must be done by trained and certified
individuals and analytical testing must be done by a
Department of Environmental Protection (DEP) approved
testing laboratory using approved methods. Equipment and
process warranties and various liability issues should be
thoroughly considered to help reduce risks if the
pretreatment system does not function as promised.
-
If
there are pretreatment system performance problems or
discharge violations, the steps taken to address the
discharge problem should be reviewed and verified.
Corrective actions can include additional source reduction
considerations, wastestream segregations, and pretreatment
system additions or operating procedure modifications.
Sometimes, an iterative process of source reduction and
changes in pretreatment may be needed before compliance can
be achieved. All pretreatment system additions should be
approved by the licensing authority before installation and
operation, and the status of the facility may be reviewed
for possible site and operator upgrading.
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To
avoid notices of noncompliance, fines, or other enforcement
actions (including public listing as being in
"significant noncompliance"), submit all required
monitoring reports and pay all annual permit and user fees
to appropriate agencies. Failures in this area may
"flag" your facility and bring unnecessary
attention to your operation.
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Inspections
by MWRA inspectors may be possible anytime. The MWRA
monitoring staff also may make periodic unannounced visits
to take compliance monitoring samples of the wastewater
discharge. MWRA discharge permits require facilities to
provide proper effluent sampling locations and safe access
to those locations.
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The
type of pretreatment system may impose additional concerns
for facility owners/operators concerning employee health and
safety for workers at or near the wastewater pretreatment
equipment and systems.
-
Considerations
should be given to the development of an employee hazard
notification program, health and safety manual, spill
containment plan, evacuation plan, and Best Management
Practices (BMP's).
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Provide
for implementation of "Right-to-Know" policies at
your facility in accord with local and Federal employee
training requirements. Any wastestreams determined to be
hazardous will require the development and posting of
instructions on proper handling and disposal techniques.
These
are merely some basic issues to be considered when operating a
wastewater pretreatment system. Remember that every operation is
different and no single pretreatment system can be universally
effective.
Wastewater
characterization; pretreatment system feasibility, treatability,
and pilot testing; and the design, installation, and operation
of a full-scale pretreatment system can all involve considerable
financial expenditures. Since there are many possible
definitions of a problem and many possible approaches toward its
solution, it is important for all involved parties to have a
good understanding of the issues.
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