Sewage Discharge Consents - Proving within Limits

[claireyvb]

Afternoon all,

We currently have a discharge consent in place at our premises and have been graded 'low risk' by the water companies, but as part of our ISO 14001 assessment we have been asked to prove how we knew that we were within the tolerances. For the information we do not use water in any manufacturing processes and the only discharge is from cleaning.

I was wondering what others do?

Many thanks in advance for your advice.

 

[somashekar]

Re: Discharge consents - proving within limits

Hi Claire.
Does your consent also state certain conditions / limits for your discharge water. You have to study that and see what monitoring steps you must take periodically. BOD (Biochemical Oxygen Demand) for one.
As you mention, you may not be having a ETP (Effluent Treatment Plant), but at least you must be operating a STP (Sewage Treatment Plant) for your cleaning discharge and other sewage discharge.

 

[Randy]

Did the water agencies clearly state "low risk" and exclude you from some mandated effluent monitoring?

If the answer is yes, your auditor is exceeding what is required of you and you have no obligation to do anything other than what the exclusion says you are required to do.

Your "monitoring" is based on the decision of the government authority....You have a right to question the auditors experience and competency in matters such as this because you may have some "quality" person who transitioned into environmental and has no real hands on experience...Very common

 

[claireyvb]

Thanks Somasheker and Randy.

The water company has set limits within the discharge consent. In an email exchange with the water company they stated that we were low risk and that they would not be monitoring our discharge because of that.

The cleaning activity happens approximately once per week for a couple of hours or several times a week for a shorter period of time.

We monitor the amount of chemical used, water discharge over time, but not the composition of the water nor temperature as it heads towards the drains into the sewer. I agree that this does not mean that we cannot dissolve ourselves of responsibility, but we are unsure of what frequency of monitoring for effluent composition is acceptable (with no guidance from Water company or Auditor).

Can you provide any suggestions - we got a Major NC for this

 

[somashekar]

Thanks Somasheker and Randy.

The water company has set limits within the discharge consent. In an email exchange with the water company they stated that we were low risk and that they would not be monitoring our discharge because of that.

The cleaning activity happens approximately once per week for a couple of hours or several times a week for a shorter period of time.

We monitor the amount of chemical used, water discharge over time, but not the composition of the water nor temperature as it heads towards the drains into the sewer. I agree that this does not mean that we cannot dissolve ourselves of responsibility, but we are unsure of what frequency of monitoring for effluent composition is acceptable (with no guidance from Water company or Auditor).

Can you provide any suggestions - we got a Major NC for this

The water company has set limits within the discharge consent.

Is your discharge water within the set limit ?
YES - If you have tested.
If not, then get the test done.
Is it within the set limit ?
YES - test #1 is done
NO - You need to initiate a corrective action
When you will perform the test #2 depends upon your monitoring and measurement plan, which is your risk based decision.
Lets say you do the test #2 and test #3 annually.
You also do not change your process that generate the waste water
The test #1,2 and 3 show consistent results and are far less than the set limit. You then adopt bi-annual testing and continue monitoring against set limit. (Just a suggestion)

 

[claireyvb]

Re: Discharge Consents - Proving within Limits

Thanks for your advice Somashekar - really helpful
We'll get the discharge tested and go from there..

 

[lbug7575]

You mention, you may not be having a ETP (Effluent Treatment Plant), but at least you must be operating a STP (Sewage Treatment Plant) for your cleaning discharge and other sewage discharge.
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[MichaelMPerez]

It should be within 5 and 20 cubic metres of domestic treated sewage surface water . Make a trade effluent consent or groundwater permit enquiry. It will be issued with a permit. Take permission before any effluent discharge to public foul sewer