Pollution Prevention - Fact Sheets

Pollution Prevention
For Publicly Owned Treatment Works (POTWs)

Operators at POTWs face a number of challenges these days:

• How do I keep up with the ever increasing regulatory burden?
• How do I keep my plant at peak performance and stay within my budget?
• How do I manage my growing industrial base?
• How do I work with my current industries to avoid plant upsets or pass-through of pollutants?
• How can I reduce the amount of contaminants in my sludge?
• With homes sprouting up closer and closer to my plant, how do I work with the surrounding community to address their concerns and be a "good neighbor"?

Sound familiar? How can pollution prevention programs help?

Incorporating a pollution prevention (P2) program into your plant

operations can help with many of your concerns. It can:

• help you deal with the regulatory requirements by eliminating some of the pollutants before they have to be treated.
• save you money in your operating budget to use for more pressing needs or to save for future improvements.
• help you convince your governing board that the improvements made now will save on operating costs later.
• help you work with your industries to reduce sludge problems and influent loadings, instead of just assessing fines and penalties and creating tension with your industrial community.
• help you be a "good neighbor" to your surrounding community.

Even small facilities without a lot of industries can benefit from P2.

Household chemicals, dental offices, medical facilities, laboratories, photo-processing facilities, etc. can impact all community wastewater discharges.

Sources of contaminants in your sludge or wastewater discharges can be puzzling. P2 techniques and evaluations can help identify and reduce these sources.

Implementing P2 into your everyday routine doesn't have to take time away from your routine or take dedicated personnel. Meeting with industrial leaders occasionally for a breakfast meeting, making recommendations and/or referrals during routine industrial inspections, or just looking at your everyday activities with a P2 perspective is all that is needed to make a difference.

P2 as a means of achieving compliance can be used as an incentive to avoiding enforcement and improving public relations with both the industrial community and the residential community. Awards or certificates can be given to encourage the industrial and commercial sector to reduce their toxic discharges and be a "good citizen". Model industries and businesses can be promoted within the community to encourage patronage and enhance public relations.

There are many ways to approach P2. You can approach it with a particular goal in mind, such as reducing copper concentrations in your sludge. Or, you can approach it more generally, such as "How can we do our everyday tasks differently so that there is less handling of materials, fewer spill clean-ups, more efficiency and maybe even save a little money along the way?" P2 does not even require training to start, just a willingness to consider alternatives. As time goes on, or if you have a significant industrial base, there are resources and materials to help you and your employees. There are even groups that will take referrals at no or little cost to the industry to handle your more complicated P2 cases. A resource list is provided in this package.

So now its time for you to Think P2! To help you get started, we have provided a series of factsheets with ideas to consider, ranging from general plant operations to industrial sector recommendations. For example, you can pull out the maintenance factsheet before you start scheduling maintenance tasks with your staff. Start out small and add new items over time.

Remember: P2 is an ongoing effort. Even the simpler changes can make a difference. As time goes on, look through the different factsheets and incorporate some new ideas into your routine. Pass out copies of the industrial factsheets and the resource list to your industries. Remember also to discuss P2 with your fellow operators to see what they have tried!

Waste Treatment Facility Operations

Your day-to-day operations have plenty of pollution prevention opportunities just waiting to be discovered and put in place. Taking the time to look at your basic process and your everyday routine with some of the following ideas in mind will give you a fresh perspective of your plant and could ultimately save you precious time, money and maybe even a lot of headaches.

Treatment Process Flow Diagrams

Start by evaluating your basic process.

• Identify all process and waste streams and their disposition on a process flow diagram.
• Evaluate all process and waste streams to see if any can be reduced or eliminated.
• Evaluate maintenance waste streams (such as replacement of sand in sand filters, rock media in trickling filters, coolant and lubricant replacement, etc.) for recycling or reuse opportunities. For example, can the sand be used in a lagoon or polishing pond? Can the rocks or sand be cleaned and used for landscaping? Can coolant be filtered and reused?

Process Control Strategies

Put your process control techniques to use to optimize your plant performance and keep problems in check before they get out of control. Optimizing plant performance can reduce energy and chemical costs and help to avoid effluent violations.

• Implement secondary process control strategies and tests to optimize performance (examples are the Al West method, microscopic analyses, measuring dissolved oxygen levels in various areas of the tanks to check for uniformity, sludge settleability tests, daily observation logs, etc.) See the resource list for information on process control methods.
• Evaluate sludge handling, stabilization and disposal practices to see if they can be modified to be more efficient and/or effective.
• Use diurnal (investigative) sampling to evaluate and plan chemical and energy use. For example, a facility may be overaerating or over chlorinating/dechlorinating to correct a problem that may only occur during a small part of the day. [Note: diurnal sampling involves taking hourly grab samples and analyzing them separately as opposed to a 24 hour composite. This sampling protocol can provide information that is buffered or hidden by the composite sample.]
• Aerate the outfall or allow it to cascade down a tiered or rocky area (those old rock filter media rocks?) to increase effluent D.O. levels and strip volatiles from the disinfection process.
• Consider UV disinfection instead of chemical disinfection.
• Investigate alternatives for chemicals that are used in processes. Look for chemicals that are less toxic to both operators and the environment.

Preventative Maintenance Programs Whether daily, weekly, monthly or yearly, preventative maintenance programs help the plant run smoothly and limit costly and problematic downtime for equipment, as well as limiting potentially hazardous situations for plant personnel.

• Develop and implement a preventative maintenance program.
• Review existing maintenance programs to see where improvements can be made or where the most problems occur.
• Evaluate the spare parts inventory to see that it is being maintained and covers the most critical operations.
• Replace problematic equipment with new lower maintenance equipment.
• Use quality parts and service for repair of equipment to decrease equipment downtime and increase service life.

Laboratory Operations

Although analysis methods are dictated by regulations, there is still some flexibility in laboratory operations, as well as best management practices, that can lead to P2 in the laboratory.

• Establish and maintain a QA/QC program and include best management practices.
• Periodically inspect stored chemicals for signs of leakage, improper storage practices or past expiration dates and other problems.
• Use a first in/first out inventory practice to help avoid keeping chemicals past their expiration dates.
• Evaluate purchasing practices to better match supply with need.
• Consider purchasing chemicals with short shelf lives in smaller amounts to avoid waste through expired chemicals. Also look for coated containers that can increase shelf life.
• Increase use of instrumental analysis over wet chemistry (where allowed by approved methods).
• When solvent rinses are required, use spent/recovered solvents for an initial rinse and fresh solvents for the final rinse.
• Where practical, purchase reagents in plastic bottles to avoid breakage, and reuse or recycle bottles. Also consider plastic overcoat carriers for large solvent bottles to improve handling and avoid breakage.
• Install spill kits in each laboratory and train employees in spill cleanup and prevention.

General Plant Operations and Training

• Train personnel annually on P2 awareness. Consider an award program for P2 ideas.
• Consider appointing a P2 coordinator or team for coordinating and overseeing all P2 activities (especially helpful for larger districts).
• Promote beneficial reuse of biosolids as opposed to landfilling. Also, if biosolids can meet Class A requirements, consider establishing a public distribution program.

The Collection System

The first step in wastewater treatment is transporting the wastes to the treatment plant. This is also the first opportunity for P2. The following are some pollution prevention ideas to consider with regard to the sanitary sewer collection system:

Sewer System Evaluation Survey (SSES)

Information provided by your sewer system evaluation survey can allow for immediate response to problems in the system, thereby minimizing pollution if a problem occurs.

• Catalog SSES reports and sewer maps for quick and easy reference.
• Locate and assure accessibility of all manholes, cleanouts, valve vaults, etc.
• Periodically update sewer maps to include new sewer connections.

Inflow/Infiltration Control

Inflow/infiltration (I/I) contributes to loading and can cause sewer back-ups and manhole surcharges during rain events. Most communities already have programs in place to address their current I/I problems, but the programs don?t address new potential sources of I/I. By keeping new sources of I/I out of your system, you can save from having to provide treatment for it later and will preserve future hydraulic capacity at the plant.

• Develop and implement an on-site Inspection Mandate for all new service connections.
• Develop and implement a periodic drainage basin inspection program to assess current storm flow and flooding patterns.

CSO Operational Plan Review

If your town still has combined sewers, there are ways to minimize pollution concerns associated with overflow use.

Review and implement the elements in your approved CSO Operational Plan, including:

• proper operation & maintenance of sewers and CSO outfalls
• maximizing use of collection system for storage
• working with industries to reduce discharges, especially during wet weather
• maximizing flows to the POTW
• eliminating CSOs where possible, especially any dry weather discharges
• controlling solids and floatable material discharges
• monitoring discharges to effectively characterize CSO impacts and the efficacy of CSO controls

General System Inspection and Maintenance Program

Taking some proactive steps with your sewer maintenance program lets you act on potential (and possibly preventable) problems instead of just reacting to actual problems, especially the ones that involve weekend labor and overtime charges and/or hazardous material responses.

• Develop and implement a preventative maintenance program instead of a reactive maintenance program.
• Establish a routine sewer cleaning program for all sewers on a 3 to 5 year basis and more frequently for problem areas.
• Establish a budget to immediately address repairs identified by cleaning and inspection programs.

Materials and Inventory

Materials handling is perhaps one of the easiest and most cost effective ways of implementing pollution prevention in your operations.

Materials Handling and Storage

• Keep all containers and chemical tanks labeled and all process piping labeled and/or color coded.
• Store containers to allow for visual inspection of corrosion and leaks.
• Set up stations for dispensing chemicals and collecting wastes.
• Dispense and transfer materials using spigots, pumps and funnels.
• Designate responsibility for coolant and lubricant maintenance and replacement.
• Stack containers in a way that minimizes the chance for tipping, puncturing or breaking.
• Segregate non-hazardous materials from special and hazardous wastes to reduce the possibility of cross-contamination.
• Reduce generation of corrugated waste by working with suppliers to provide returnable and reusable containers.
• Empty containers completely before cleaning or disposal.
• Keep storage and work areas clean and well organized.
• Minimize interim storage and chemical handling, wherever possible.
• Restrict traffic through storage areas to reduce the likelihood of contamination or spillage of stored material.

Inventory Control

• Employ a "first in, first out" policy for expendable materials to keep them from becoming too old to use.
• Practice "just in time" inventory control for expendable materials and materials that risk contamination (such as sterile filters and laboratory media).
• Substitute non-hazardous materials for currently used hazardous materials where possible. (Contact the IL EPA Office of Pollution Prevention for recommendations).
• Purchase materials in reusable containers, tote bins or bulk shipments, but avoid buying too much of a product that might spoil or has a short expiration date. Limit bulk purchases to items that you use in large quantities.
• Inspect deliveries immediately and return unacceptable materials to the suppliers.
• Store expendable materials in locations that will preserve their shelf life.
• Check that all purchases have dated, legible labels.
• Stock spare parts for equipment repairs to minimize downtime.

Spills and Leak Control

Spill and leak prevention can have an initial cost factor, but when weighed against the cost of clean-up and disposal, the initial costs can be well worth the time and expense.

• Address spills as they occur to limit runoff contamination.
• Document all spillage to identify problem areas.
• Use temporary diking when pumping liquid sludge and dry clean-up methods for dried sludge spills to avoid contaminated run-off.
• Cover waste disposal areas and recycling bins to avoid rainwater contamination.
• Regularly inspect dumpsters and compactors for spills and stains.
• Routinely inspect and maintain valves, pipe joints, pumps, tanks, etc.
• Use drip pans under vehicles and lubricate equipment.
• Use pans, trays or wringable pads for capturing and retrieving spilled liquids instead of granular absorbent, where applicable.
• Install catch basins and dikes in storage areas.
• Store oil cans, paint cans and other liquid materials with like substances in drip pans or trays to catch leaks and spills.
• Install overflow alarms in tanks that have the potential to overflow.

Solid Waste Prevention

• Ask vendors to minimize unnecessary packaging or packing materials and to use recyclable materials for the remainder.
• Isolate liquid wastes form solid wastes.
• Substitute non-toxic products for products that require special handling, ventilation or have warning labels. (Examples would be cleaning with soap and water or high pressure water sprays instead of solvents, substituting potassium sulfite for sodium bisulfite for dechlorination, or better yet, switching to UV disinfection).
• Purchase products made with recycled materials, such as printing and writing paper, shipping containers, outdoor benches and tables, carpeting, note and log books, parking stops, fences, sign posts, antifreeze, wall panels, road building materials, retread tires, garbage bags and speed bumps.
• Recycle scrap metals, flourescent lamps, used oil and lead-acid batteries. (For recyclers and information on other recyclable materials, contact the IL EPA-OPP.)
• Reduce the use of solvents for cleaning by putting a small amount on a rag and wiping the component rather than soaking it.
• Distill solvents for reuse.
• Save and reuse boxes for shipping and other uses.
• Use cloth towels and rags which can be laundered for reuse.
• Use rechargeable batteries for pagers and other electronic devices.

Office and Groundskeeping

Office

Everyday office procedures generate a lot of paper and material waste, much of which can be avoided with only a slight change in habits and procedures.

• Encourage office practices that reduce wastepaper, such as copying on two sides, using electronic mail, posting information on announcement boards, sharing and circulating documents, storing files on computer disks and reusing scrap paper for note pads. Recycle what can't be eliminated.
• Donate office equipment, supplies or goods that are no longer needed to non-profit organizations.
• Give employees the opportunity to purchase old office equipment, computers and supplies, or consider a sale or auction to local residents.
• Purchase a plain paper fax machine ( if needed) so faxes are recyclable. As an option, have faxes sent to the office computer, if equipped with a fax/modem, and only print out faxes as needed.
• Use rebuilt or recharged toner cartridges for copiers and laser printers.
• Purchase reusable coffee mugs for employees or encourage employees to bring their own.

Water Use and Conservation

Water use throughout the plant, especially with cleaning and landscaping irrigation, is a good area to evaluate for potential savings.

• Use wastewater effluent whenever possible for non-potable water systems and landscape watering.
• When washing, use high-pressure, low volume washing equipment with minimal or no detergents.
• Encourage employees to shut off hoses and sinks when not in use.
• Clean equipment and areas using dry methods whenever possible, including scraping, sweeping and shoveling.
• Fix water leaks right away.
• Water landscaping during the cooler parts of the day (before 10AM and after 5 PM) to minimize evaporation. Consider automatic sprinkler systems with timers and rain delays.
• Install water-efficient shower heads.

Pest Control and Groundskeeping

Landscaping practices and procedures offer plenty of opportunities for pollution prevention.

• Use a mulching lawn mower or retrofit your mower to leave grass clippings on the lawn.
• Landscape with slow growing, drought tolerant native plants or groundcovers (other than grass) that require less fertilizer and pest control measures (see resource list).
• Convert difficult to mow and/or maintain areas from "grass lawn" to "Illinois Acres for Wildlife Program" (see resource list).
• Apply pesticides only according to manufacturer's direction and only as necessary. Apply only at a time when wind drift and runoff losses are unlikely.
• Save water used to rinse pesticide containers and use it with the next application.
• Select the most species-specific, least damaging treatment for pest and weed control.
• Practice spot application where a problem exists instead of spraying over an entire area.
• Leave unsprayed buffer zones to protect sensitive areas or wildlife habitats.
• Use evergreen trees and/or bushes and berms near populated areas to aid in odor control and reduce the amount of chemical usage/energy use needed for odor control systems.
• Use shoreline buffer strips around lagoons or physical barriers around or over large clarifiers to control geese and duck populations (added nutrient loading). Access areas to lagoons can be kept to allow maintenance.
• Xeriscape (dry landscape) with rocks, sand and other non-plant landscaping materials.
• Investigate non-toxic pest control methods, such as live trapping and destruction of pest breeding and refuge areas.
• Erect Purple Martin and/or Bat Houses for insect control instead of using pesticides. Bat house plans can be obtained from the IDNR website (see resource list).

Industrial Monitoring and Evaluation

Industrial User Evaluation/Pretreatment Programs

Working closely with your industries creates an awareness on both sides of potential problems and the cause and effect of industrial discharges on the treatment plant. A good relationship with your industries also fosters communication which can help reduce the impact of problems that do occur. It also gives you the opportunity to promote pollution prevention within your community.

• Regularly update your industrial user survey to determine what industries are tributary to the POTW (and/or CSOs).
• Identify the pollutants of most concern and the industries most likely to be a source of those pollutants.
• Target one or more industrial groups per year for pollution prevention (fact sheets and guidance are available through the Illinois EPA Office of Pollution Prevention).
• Schedule a workshop/training/brainstorming session with one or more industries (speakers/facilitators are available - contact the Illinois EPA Office of Pollution Prevention for recommendations).
• Incorporate voluntary P2 conditions into permits and renewals, as well as into compliance agreements and corrective action plans.
• Train industrial inspectors in basic pollution prevention, particularly in the types of industries that operate in your municipality. This can also include other Village inspectors, including fire department personnel and city code inspectors.
• Incorporate pollution prevention advice into routine pretreatment inspections (e.g. less hazardous parts cleaning methods, equipment cleaning and maintenance practices, reuse of materials, etc.)
• Encourage hazardous waste generators to participate in pollution prevention training programs.
• Promote material exchange between industries for usable waste materials (pallets, packaging materials, still usable chemicals and byproducts of production are examples). Material exchange opportunities can be posted at the local Village Hall or business association. Industrial Material Exchange Service (IMES) material can be obtained through the IL EPA/OPP (see resource list).

(Note: although not technically considered pollution prevention, sponsoring a hazardous waste pick-up day in your community for either businesses or local residents can help to reduce the introduction of hazardous wastes into the sanitary sewer system. Information can also be provided to both businesses and residents on alternatives to hazardous chemicals and proper disposal methods. Contact the IL EPA for more information.)

Resource List

• Illinois EPA - Office of Pollution Prevention (OPP)
  (217) 782-8700
  General P2 Information
  P2 Facility Assessments
  Internship Program
• Illinois Waste Management and Research Center (WMRC)
  (217) 333-8940
  P2 Information
  P2 Facility Assessments
  Technology Evaluation Testing
  Research Funding
  Laboratory Analysis
• Illinois Department of Natural Resources (IDNR)
  Publications for landscaping and conservation practices
  Illinois Acres for Wildlife information

Information Websites

• U.S. EPA Pollution Prevention
  General P2 Information
  Links to P2 Research and Information
• U.S. EPA P2 Database (Envirosense)
• Research Triangle Institute
  Solvent Alternatives Guide
• University of Missouri - Office of Waste Management
  Waste Reduction Assistance for Business
• Texas Water Utilities Association
  Potential Pollutant Sources and Pollution Prevention Tips Listed by Pollutant
• Chicago Botanic Garden
  Information on Native Plants for Illinois

U.S. EPA Publications

• Guides to Pollution Prevention - Municipal Pretreatment Programs
  Publication No. EPA/625/R-93/006
  October 1993