Compliance in a change-heavy environment

June 14, 2016

Being proactive to ensure permit compliance requires that the discharge permit limits are unbendable and predictable at all times.

This column is another in a series that identifies procedures used to troubleshoot wastewater treatment processes. With more than 20 years of experience working as an operator of record at wastewater treatment plants, I have seen that proactivity is a vital prerequisite for setting up and maintaining operating precision. Being proactive to ensure permit compliance requires that the discharge permit limits are unbendable and predictable at all times.

To establish permit consistency, operators can include testing knowledge of how untreated wastewater conditions respond to changes and establish versatility in the treatment plant operations. This situation requires proactivity with wastewater treatment techniques because the discharge permit is resolute, and wastewater treatment conditions change.

I often see conditions and circumstances that require flexibility. A wastewater treatment plant’s frequent attribute variations include:

  • Changes in waste stream flow rates
  • Changes in pH value
  • Different types of contaminants
  • Varied contaminant concentrations

Design for compliance

Designing a wastewater facility based on the wastewater discharge permit prerequisites is a primary concern for a facility to ensure that it operates reliably. Paramount among these requirements is ensuring that information gathering during design does not downplay or exaggerate real conditions. Minimizing or ignoring stream controls and regulations may prevent the facility from satisfactorily treating its influent wastewater.

On the other hand, overstating real conditions can increase the contact time, which may be an operational overabundance or have a negative effect on the quality of wastewater treatment.

Design flexibility

If the untreated wastewater or discharge requirements change during operations, having the capacity to react to those differences is required. Some examples include:

  • If greater than normal flow occurs, additional treatment capacity would be required.
  • If the pH of the untreated wastewater fluctuates, then the ability to immediately react to those variations is vital.
  • Changes in the types of contaminants vary the types of wastewater treatment units required to remove or deactivate those contaminants.
  • Contaminant concentration fluctuations alter the amount of the treatments needed.

For discharge requirement changes (which could include stream flow, pH, contaminants and contaminant concentrations), the facility’s design may need to be altered to ensure that it can meet the end goal of compliance.

Facility changes

In many cases, an existing installation cannot treat the wastewater to comply with discharge requirements. In this situation, examining the limit of the capacity versus the treatment prerequisites is imperative. Planning for and rolling out fundamental facility improvements is required.

Management changes

Wastewater management changes require a comprehensive survey of the release allowed, the treatment plan limit, the actual treatment results and the correlation of those outcomes with the discharge permit. When another management group is responsible, shortcomings in any of these areas must be recognized and amended.

Personnel changes

Staff changes require broad examination and comprehension of working methods. New team members must get comfortable with the facility, the wastewater treatment strategy and the requirements of the discharge permit. An inability to become familiar with and execute the plan could result in permit infringement.

Ambient weather changes

Changes in weather can influence wastewater discharge permit uniformity. Temperature fluctuations, increased or decreased precipitation, and/or flooding can impact permit limits. Establishing a management plan and having flexibility to respond to any alterations is critical for the well-being of the systems and the assurance of compliance.

Discharge permit changes

Changes to a discharge permit require broad investigation of all the elements in the revised document. Changes may include working methods, laboratory sampling analysis, reporting requirements and facility upgrades.


Compliance is not a "do it once and be done" task. Remaining in compliance requires constant monitoring and adapting to changes as they occur. Forethought in the design phase and executing these proactive measures will help keep a facility in compliance with discharge permits from the beginning and will define plans for any changes or disruptions that may occur.    

Known in the industry as "Wastewater Dan," Dan Theobold, proprietor of Environmental Services, is a professional wastewater and safety consultant/trainer. He has more than 24 years of hands-on industry experience operating many variants of wastewater treatment processing units and is anxious to share his knowledge with others.