Table of Contents
- Wwtrackopt
- Wwtrackopt Verification And Scoring
- Wwmonitorbod5
- Wwmonitorbod5 Verification And Scoring
- Wwstormwatermixing
- Wwstormwatermixing Verification And Scoring
- Wwoffsitetreatplantcontract
- Wwoffsitetreatplantcontract Verification And Scoring
- Wwfunction
- Wwfunction Verification And Scoring
- Wwemergplan
- Wwemergplan Verification And Scoring
- Wwleaking
- Wwleaking Verification And Scoring
- Wwsludgesources
- Wwsludgesources Verification And Scoring
- Wwsludgereporting
- Wwsludgereporting Verification And Scoring
- Wwsludgedomesticreporting
- Wwsludgedomesticreporting Verification And Scoring
- Wwsludgestorage
- Wwsludgestorage Verification And Scoring
- Wwhsludgedisposal
- Wwhsludgedisposal Verification And Scoring
- Does your facility track its wastewater volume? (Ref ID: wwtrackopt)
Answer Yes If: Your facility tracked the volume of wastewater discharged from all sources (e.g., domestic, industrial and/or combined) in the FEM reporting year.
Answer Partial Yes If: Your facility tracked the volume of wastewater discharged from one (1) or more, but not all sources (e.g., domestic, industrial and/or combined) in the FEM reporting year.
If you answer Yes or Partial Yes to this question, you will be asked to complete a table with the following questions to provide details on your facility’s wastewater discharge for each applicable wastewater type.
- Does your facility track its wastewater volume for this wastewater type?
- What was the total quantity of wastewater discharged from your facility during this reporting year? (in cubic meters - m3)
- Which method was used to track wastewater volume?
- Note: If your facility does not track wastewater via metering or metered invoices and calculates your annual wastewater discharge volume using an estimation methodology, then you must select “Estimates” for this question.
- What was the frequency of measurement?
- How many wastewater discharge points do you have?
- Have you labelled all wastewater discharge points?
- Do you monitor all identified wastewater discharge points?
- What was the final discharge point for your facility’s wastewater?
- Note: This should be where the wastewater is discharged to after it leaves the facility.
- Provide any additional comments.
- Please upload documentation.
Suggested Uploads:
- Documentation that demonstrates the facility tracked the volume of wastewater discharged from applicable sources. (e.g., tracking records for wastewater discharge, metering records/logs, wastewater treatment invoices, etc.)
Note: Uploading of all metering records/logs or bills is not required, however they should be available for review at the time of verification.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they are tracking the volume of wastewater discharged from the facility.
Technical Guidance:
Wastewater tracking allows visibility into daily operations and which operations impact wastewater volume. Knowing your wastewater volume is also linked to potential environmental impact and operational costs.
Wastewater tracking should include all wastewater generated from all manufacturing and/or commercial activities at the facility (domestic and industrial). Tracking should also include wastewater that is reused/recycled at the facility.
When establishing your water tracking and reporting program, start by doing the following:
- Mapping out facility areas and processes to identify where wastewater is generated and discharged.
- Establish procedures to collect and track wastewater data:
- Install on-site meters or use metered invoices from off-site treatment facilities.
- If estimation techniques are used to determine the amount of wastewater generated, the calculation methodology should be clearly defined and be supported by verifiable data.
- Record tracking data (e.g., daily, weekly, monthly records) in a format that is easy to review (e.g., Microsoft Excel or similar data analytics program that allows export of data in a human readable format) and maintain relevant supporting evidence for review during verification.
Tracking Wastewater Volume
The most accurate way to track wastewater volume is using a metering system. Mechanical meters and ultrasonic meters are widely used to track wastewater volume. Facilities should install meters at all wastewater discharge points before wastewater is discharged to the environment. If the facility has its own effluent treatment plant (ETP), the meter should be installed at the outlet of the wastewater treatment facility. Facilities should collect data from the meters regularly in order to track accurate wastewater discharge volumes. This method applies to both domestic and industrial wastewater.
If a facility does not have meters to track its wastewater discharge volume, an estimation method can be used which may include any of the following estimation techniques listed below.
Note: If your facility does not track wastewater via outlet metering or metered invoices and calculates your annual wastewater discharge volume using an estimation methodology, then you must select “Estimates” for the question “Which method was used to track wastewater volume?”
- If the facility has accurate data (meters or invoices) on incoming water volume for production process and domestic use, the facility may estimate wastewater discharge volume using the incoming water volume. The facility may need to account for water use or loss for things like cooling tower evaporation loss or irrigation when estimating wastewater volume.
- Use of any official environmental reports that contain data on wastewater discharge volume (e.g., Environmental Impact Assessment reports, Environmental permit applications, Government’s compliance report or offsite wastewater treatment invoices).
- Note: In some cases, wastewater treatment invoices from offsite wastewater treatment facilities may not provide the treated wastewater volume. Instead, the invoice would indicate the total treatment fee (e.g., 100 USD) with unit treatment cost ($1 USD/m3). In this case, a facility may need to manually calculate and record wastewater volume with the total treatment fee and unit cost (e.g., total treatment fee ÷ unit treatment cost = wastewater volume).
- If the facility has no documentation which indicates the amount of incoming water, then they can estimate industrial wastewater volume based on different production processes and equipment specific consumption.
- For example, in a dyeing mill, the dyeing recipe may have water needed for each dyeing batch, or the dyeing machine may also have specifications on how much water is required for each batch. Facility would need to collect the production volume of each dyeing recipe and production volume of each dyeing machine. Then the facility would be able to manually calculate using production water use of each recipe per machine and water needed of each recipe/machine, multiply by respective production volume. Lastly, sum up all production water use. This estimated production water volume could be considered as the estimated amount of industrial wastewater discharged. Facilities may also need to account for any loss due to evaporation during production processes.
A tool available to help calculate water use from different sources can be found here: http://waterplanner.gemi.org/calc-waterbalance.asp.
Domestic Wastewater Tracking (including Septic Systems):
Tracking the flow rate and discharge volume of domestic wastewater with on-site meters is not a common practice but it is highly encouraged to accurately track the volume and quantity of domestic wastewater discharged.
If domestic wastewater discharge metering data or actual discharge data is not available, the facility could consider estimating wastewater discharge based on the site's total water use, the estimated amount used for domestic purposes and then minus an estimated amount due to losses (e.g., evaporation).
- For example, a site with domestic only wastewater who used 150m3 of municipal water per month estimates that 10% of the water is lost due to evaporation and leaks would report 135m3 of wastewater discharged (150m3 – 10%).
Water use in a facility can also be estimated by the number of persons, number and types of facilities, taps, toilets, shower, irrigation etc. based on any available local/regional data or manufacturer’s specifications (e.g., rated litres per flush for toilet fixtures).
Note: If an estimation technique is used, this should be fully documented, applied consistently and based on reasonable estimation factors that are derived from relevant sources (e.g., manufacturer’s specifications, regional data on sewerage volume per person/day, etc.)
Reporting wastewater data in the FEM:
Before reporting wastewater data in the FEM, data quality checks should be performed to ensure that the data AND the processes used to collect and record the data are effective at producing accurate data.
Do:
- Review source data (e.g., meter logs, invoices, etc) against aggregated totals to ensure it is accurate.
- Compare the current year with historical data. Any significant changes (e.g., an increase or decrease of over 10%) should be attributable to known changes. If not, further investigation may be warranted.
- Ensure the most recent and updated versions of data tracking spreadsheets are being used and that all automated calculations/formulas are correct.
- Ensure the proper units are reported and verify any unit conversions from source data to reported data. Note: The FEM requires that wastewater data be entered in cubic meters (m3).
- Report the data source (e.g., meters, invoice, estimates) and frequency of measurement (e.g., daily, monthly, etc).
- Report the final discharge point (e.g., Offsite Wastewater Treatment Plant). Note: This should be where the wastewater is discharged to after it leaves the facility.
- Review any assumption or estimation methodology/calculations to ensure accuracy.
- Add notes in the “Provide any additional comments” field to describe any data assumptions, estimation methodology, or other relevant comments on the reported quantity.
Do Not:
- Report data that is not accurate (e.g., the data source is unknown or has not been verified).
- Report estimated data if it is not supported by verifiable and reasonably accurate estimation methodology and data (e.g., engineering calculations).
Wwtrackopt Verification And Scoring
How This Will Be Verified:
When verifying a facility’s wastewater data, Verifiers must review all aspects of the facility’s wastewater tracking program that could produce inaccuracies including:
- The initial data collection processes and data sources (e.g., invoices, on-site meters, metering logs, etc.); and
- The process and tools used to aggregate the data (e.g., spreadsheet calculations, unit conversions, etc.)
If any inconsistencies or errors are noted, the reported information must be corrected where possible and detailed comments should be included in the Verification Data field.
Full Points:
Full points will be awarded for facilities that have tracked the volume of wastewater discharged from all sources (e.g., domestic, industrial and/or combined) in the FEM reporting year.
Documentation Required:
- Documentation that demonstrates the facility tracked the volume of wastewater discharged from applicable sources. This may include:
- Wastewater discharge records (e.g., monthly bills and annual discharge records, metering records/logs, etc.)
- Note: Annual discharge records compiled in a spreadsheet (e.g., Excel) are ok as long as detailed discharge tracking data is available for review.
- Wastewater discharge records (e.g., monthly bills and annual discharge records, metering records/logs, etc.)
- Meter calibration records where applicable (e.g., as per manufacturer’s specifications).
- Estimation methodology documented where applicable.
- All wastewater sources at the facility are tracked in full. This means that all sources listed in the Level 1 table have complete answers in all columns that are accurate.
Interview Questions to Ask:
- Staff responsible for managing wastewater can explain the facility’s wastewater tracking program (e.g., how wastewater sources are identified, and discharge quantities are tracked).
- Key staff should understand:
- The procedures in place for tracking wastewater quantity.
- How data quality of the wastewater tracking program is maintained.
- Any estimation methodologies used to calculate annual wastewater discharge volume.
Inspection - Things to Physically Look For:
- All wastewater sources observed are properly identified and tracked.
- Appropriate equipment for wastewater measurement is present (e.g., meters) if applicable.
Partial Points:
- Partial points will be awarded for facilities that have tracked the volume of wastewater discharged from one (1) or more, but not all sources (e.g., domestic, industrial and/or combined) in the FEM reporting year.
- Does your facility monitor the BOD5 Level of your wastewater?
(Ref ID: wwmonitorBOD5)
Answer Yes if: If your facility tests wastewater for Biochemical Oxygen Demand 5-days concentration (BOD5) and at least one test has been conducted in the FEM reporting year.
If you answer Yes to this question, you will be asked the following sub question(s):
- How does your facility monitor the BOD5 Level of your wastewater?
- Before Treatment only.
- After Treatment only.
- Before and After Treatment.
- All processes including sub process level.
- How many biological treatment subprocesses does your treatment plant(s) consist of?
- Note: This question only applies to facilities that monitor BOD5 in all processes and sub processes of wastewater treatment.
Based on where your facility monitors BOD5, you will be asked to complete a table with the following questions to provide details on your wastewater treatment processes/subprocesses and BOD5 monitoring practices:
| If BOD5 is Monitored Before and After Treatment | If BOD5 is Monitored in All Processes and Subprocesses |
| Wastewater Type (responses will be pre-populated based on wastewater sources) | Biological Treatment Sub Process (responses will be pre-populated based on number of sub processes reported) |
| Indicate whether each subprocess is Aerobic, Anaerobic or Facultative. | Wastewater Type |
| What is your BOD5 level prior to treatment? (mg/L) | Indicate whether each subprocess is Aerobic, Anaerobic or Facultative. |
| What is your BOD5 level after treatment? (mg/L) | What is your BOD5 level immediately prior to the biological treatment sub process? (mg/L) |
| How was the BOD5 value obtained? | What is your BOD5 level immediately after the biological treatment sub process? (mg/L) |
| How was the BOD5 value obtained? |
Suggested Uploads:
- Documentation that shows the facility monitors BOD5 in wastewater (e.g., sampling and analysis reports, onsite monitoring records/logs, sampling plan/schedule that shows BOD5 sampling practices).
This question is not scored in the 2024 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that the concentration of BOD5 in wastewater is being monitored. Note: In the FEM, BOD5 is used to calculate the biogenic GHG emissions from Wastewater Treatment.
Technical Guidance
Biochemical oxygen demand (BOD) is a characteristic of wastewater that represents the amount of oxygen required by bacteria and other microorganisms to remove waste organic matter from water under aerobic conditions (where oxygen is present) at a specified temperature. High levels of BOD can impact water quality by depleting the amount of dissolved oxygen to levels that are harmful to aquatic life. BOD is commonly reported as BOD5, which is the amount of oxygen consumed over a 5-day period of incubation during testing.
In most cases limits for the BOD concentration in discharged wastewater are regulated by local laws or other requirements (e.g., brand or industry standards). At minimum, facilities should ensure that processes are in place to monitor BOD and ensure compliance as required, however additional monitoring of BOD throughout a facility’s treatment processes (and sub processes) can provide valuable information on BOD loading into the treatment systems processes and the effectiveness of treatment.
It is also important to ensure that testing is performed in accordance with recognized testing methods that comply with any applicable legal requirements (e.g. ISO 5815-1, USEPA 405.1, SM 5210-B, HJ 505, IS 3025 (Part 44)).
Resources:
- ZDHC Wastewater Guidelines https://www.roadmaptozero.com/output#guidelines
- ZDHC Wastewater and Sludge Sampling and Analysis Plan https://www.roadmaptozero.com/output#Sampling
- ZDHC Wastewater Treatment Technologies https://www.roadmaptozero.com/output#Wastewater-Treatment-Technologies
Wwmonitorbod5 Verification And Scoring
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that demonstrates the facility has tested/monitored BOD5 in wastewater. This may include:
- Sampling and analysis reports or onsite monitoring records/logs from the FEM reporting year.
- Wastewater sampling procedures (e.g., sampling plan/schedule that shows BOD5 sampling practices).
Interview Questions to Ask:
- Staff responsible for wastewater management/treatment can explain how the facility monitors BOD5 in wastewater.
Inspection - Things to Physically Look For:
- Observations on site are consistent with the facility’s reported practices for monitoring BOD5 in wastewater (e.g., wastewater sampling locations, presence of onsite sampling and analysis equipment if applicable).
3. Does your facility have a mechanism to prevent stormwater from being contaminated before it is discharged into the environment? (Ref ID: wwstormwatermixing)
Answer Yes If: Your facility has a mechanism to ensure stormwater is not being contaminated before being discharged to the environment from the facility.
Note: For this question the term “mechanism” refers to procedures, practices and/or protections that are in place to prevent stormwater contamination.
Answer Not Applicable If: Your facility is located in a multi-storey building and stormwater runoff does not accumulate in the areas owned or controlled by your facility.
If you answer Yes to this question, you will be asked the following sub question(s):
- How do you prevent stormwater pollution at your facility?
- Please upload documentation, if available.
If you answer No to this question, you will be asked the following sub question(s):
- Can you please confirm that contaminated stormwater is not directly discharged into the environment?
- How do you manage contaminated stormwater if it occurs at your facility?
- Please upload documentation, if available
Suggested Uploads:
- Documentation that demonstrates the facility has mechanisms in place to prevent the contamination of stormwater (e.g., facility diagram showing stormwater flow/drainage network and storage, photos of any protection devices such as drain covers, berms, stormwater management or monitoring procedures, etc.)
What is the intent of the question?
The intent of this question is to ensure that mechanisms are in place to prevent the contamination of stormwater through appropriate stormwater collection and drainage and ensure that any contaminated stormwater is properly treated before being discharged to the environment.
Technical Guidance:
It is considered a good practice to separate stormwater collection and drainage systems from wastewater or other sources of potential contamination. This provides greater control over waste volume surges and pollutant loading on wastewater treatment systems as well as prevention of overflows that release sewage and/or untreated industrial wastewaters to the environment. Facilities should ensure that stormwater and industrial/domestic wastewater collection and drainage systems are separated throughout the facility, however facilities are expected to adhere to any applicable legal requirements related to stormwater management.
Good practices to prevent contamination of stormwater may include:
- Coding and labelling of all the stormwater and wastewater collection points, drains, and drainage systems to prevent unintended contamination.
- Develop a stormwater and wastewater drainage network map with the information of location, uses, code and responsible person.
- Post the drainage map in a location where it is accessible for most of the employees. Note: The facility’s wastewater collection and stormwater drainage system may be included on facility structural engineering/utility drawings.
- Ensuring there is sufficient collection and storage capacity for surges in stormwater (e.g., precipitation) to avoid overflow.
- Install and maintain protections (e.g., drain covers, berms) in areas where there is a risk of contamination.
- Ensure staff are aware of the facility’s stormwater protection and management practices.
- Ensure procedures are in place for the proper storage of hazardous materials and effective spills response procedures are in place to prevent contamination of stormwater drains.
- Regularly check (e.g., daily, monthly, etc) all stormwater and wastewater collection points and drainage systems to ensure there is no mixing or damage to the systems.
Note: If there are no mechanisms in place to prevent stormwater from being contaminated, procedures should be in place to ensure that if contamination occurs that the stormwater is collected and appropriately treated (to levels that comply with legal or other applicable requirements) before being discharged to the environment.
Resources:
Note: The resources below are provided for reference only and include links to external service provider websites. Cascale does not endorse the products or services offered or provided.
- Examples of stormwater protection equipment
Wwstormwatermixing Verification And Scoring
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have mechanism(s) in place to prevent the contamination of stormwater.
Documentation Required:
- Documentation that demonstrates the facility has mechanisms in place to prevent the contamination of stormwater. This may include:
- Stormwater management procedures.
- Facility diagram showing stormwater flow/drainage network and storage.
- Stormwater drainage system inspection and maintenance records.
- If applicable, documentation that shows contaminated stormwater is treated before being discharged to the environment.
- If applicable, any required permit or discharge requirements related to stormwater or combined stormwater/wastewater discharge.
Interview Questions to Ask:
- Staff responsible for stormwater management can explain the facility’s procedures to prevent the contamination of stormwater and maintain the stormwater collection and drainage system at the facility.
- Staff responsible for inspection and maintenance of the stormwater collection and drainage system understand the facility’s procedures to prevent contamination and maintain the stormwater system.
Inspection - Things to Physically Look For:
- Observations indicate that appropriate infrastructure (e.g., collection, storage, and drainage systems) and protections are in place to prevent the contamination of stormwater.
- Observations do not indicate the presence of stormwater contamination (e.g., untreated wastewater flowing to stormwater drainage).
Partial Points:
- Partial points will be awarded to facilities that do not have mechanisms in place to prevent the contamination of stormwater but can demonstrate that an effective process is in place to manage and treat contaminated stormwater if needed.
4. Does your facility maintain a copy of the current contract, permit, agreement or invoices regarding regulatory compliance requirements for your facility's wastewater discharge to the offsite wastewater treatment plant? (Ref Id : wwoffsitetreatplantcontract)
Answer Yes If: Your facility has a current/valid copy of the current contract, permit, agreement, or invoices that demonstrate compliance with applicable requirements for wastewater discharge to the offsite wastewater treatment plant.
If you answer Yes to this question, you will be asked the following sub question(s):
- Please upload documentation, if available.
- If you cannot upload the documents, please describe here.
- Please provide the name and contact information of the offsite wastewater treatment plant
- Name
- Address
- Ownership
Suggested Uploads:
- A copy of the permit, contract, agreements, invoices, or other supporting documentation (e.g., payment terms, wastewater quality standards, volume / flow rate thresholds, etc.) that demonstrates compliance with applicable requirements for discharge to an offsite wastewater treatment facility.
What is the intent of the question?
The intent of this question is for facilities to demonstrate that they maintain the required documentation to demonstrate compliance with applicable requirements for discharge to the offsite wastewater treatment plant.
Technical Guidance
It is important that facilities understand the requirements related to discharging wastewater to an offsite treatment plant. Requirements may be outlined in contractual agreements, permits relating to the quantity and quality of wastewater that can be discharged, or established fee structures for accepting wastewater discharges.
These requirements allow facilities to establish the required procedures, monitoring, and reporting practices to ensure wastewater discharged complies with applicable requirements and does not negatively impact the operations of the offsite treatment facility.
Wwoffsitetreatplantcontract Verification And Scoring
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates the facility is in compliance with applicable requirements for discharge to the offsite wastewater treatment facility. This may include:
- A current/valid copy of the permit, contract, agreements, invoices, or other supporting documentation (e.g., payment terms, wastewater quality standards, volume / flow rate thresholds, etc).
Interview Questions to Ask:
- Staff responsible for wastewater management can explain any contractual or permit requirements related to wastewater discharge to the offsite plant and how the facility ensures compliance.
Inspection - Things to Physically Look For:
- Observations onsite indicate that the facility’s wastewater management and discharge practices align with the applicable requirements for discharge to the offsite treatment plant.
Partial Points: N/A
5. Does your facility have a mechanism or process to monitor whether your wastewater treatment plant is functioning as per the design parameters (Volume, Flow Rate, Input /Output Quality)? (Ref ID: wwfunction)
Answer Yes If: If your facility has established procedures to ensure your water treatment plant is operating as per the design parameters and the documented procedures or processes must cover all of the following aspects:
- Standard Operating Procedures
- Training
- Communication
- Continuous monitoring
- Continuous Sampling & Testing
- Ongoing Maintenance
Answer Partial Yes If: If your facility has established procedures to ensure your water treatment plant is operating as per the design parameters and your documented procedures or processes, at minimum, cover the following aspects:
- Standard Operating Procedures
- Continuous monitoring
- Ongoing Maintenance
If you answer Yes or Partial Yes to this question, you will be asked the following sub question(s):
- If yes, which of the following activities do you have and are being conducted?
- Standard Operating Procedures
- Training
- Communication
- Continuous monitoring
- Continuous Sampling & Testing
- Ongoing Maintenance
- What is the design capacity of your onsite wastewater treatment plant (m3/h)?
- What is the average volume of wastewater treated by your wastewater treatment plant per day (m3/day)?
- Do you monitor all process control parameters of your wastewater treatment plant as per the design parameters and operating procedures of the system?
- Select Yes If: Your facility monitors all of the control parameters as specified by the design parameters and operating procedures of your treatment system.
-
Select Partial Yes If: Your facility monitors some, but not all of the control parameters as specified by the design parameters and operating procedures of your treatment system.
- If yes or partial yes, how frequently do you monitor them?
- Please upload documentation.
Suggested Uploads:
- Documentation that demonstrates the facility’s wastewater treatment plant is being operated as per the design parameters (e.g., treatment plant design specifications, drawings, or manufacturers operating specifications, wastewater treatment plant operating procedures, records of process monitoring, testing).
What is the intent of the question?
The intent of this question is for facilities to demonstrate that the wastewater treatment plant is being operated and maintained as per the design specification/parameters.
Technical Guidance:
Wastewater treatment systems are highly engineered systems that are specifically designed based on the wastewater characteristics they are intended to treat (e.g., the types and concentrations of pollutants, volume of wastewater, level of treatment required, etc). It is crucial that the wastewater treatment system is operated within its design specifications and operating parameters to ensure the effective treatment of wastewater.
Facilities should have established procedures to ensure that the system is operated, monitored, and maintained in accordance with the design specifications and manufacturer’s specifications for all system equipment and components (e.g., pumps and valves, flowmeters, motoring/sampling equipment, etc.)
It is also important that staff who operate and maintain the treatment system are appropriately trained to understand the operating/monitoring requirements, limitations, and troubleshooting of the system to ensure its continuous and effective operation.
Resources:
- ZDHC Wastewater Treatment System Operator Minimum Qualifications Guidelines https://www.roadmaptozero.com/output#Qualification
- ZDHC Wastewater Treatment Technologies https://www.roadmaptozero.com/output#Wastewater-Treatment-Technologies
Wwfunction Verification And Scoring
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have established procedures to ensure the water treatment plant is operating as per the design parameters and the documented procedures or processes cover all of the following aspects:
- Standard Operating Procedures
- Training
- Communication
- Continuous monitoring
- Continuous Sampling & Testing
- Ongoing Maintenance
Documentation Required:
- Documentation that demonstrates the facility’s wastewater treatment plant is being operated and maintained per the design parameters. This may include:
- Treatment plant design specifications, drawings, or manufacturers operating specifications
- The facility’s wastewater treatment plant operating procedures
- Process monitoring/testing records to ensure plant is operating within the designed operating parameters (e.g., flow rates, temperature, pH, suspended solids and/or heavy metals concentrations, etc)
- Training records for operators.
- Maintenance records that show equipment and components are maintained and calibrated per the design and manufacturer’s specifications.
Interview Questions to Ask:
- Staff responsible for wastewater management can explain the facility’s procedures for ensuring the wastewater treatment system is operated and maintained as per the design specifications and operating parameters.
- Operators and staff responsible treatment system maintenance understand the facility’s procedures as well as the design/operating parameters and troubleshooting/maintenance procedures.
Inspection - Things to Physically Look For:
- Observations indicate that the treatment system is being operated and maintained in accordance with the facility’s procedures and the systems design parameters (e.g., equipment is observed to be in good working order, proper process monitoring/testing activities are being conducted, etc.)
Partial Points:
- Partial points will be awarded for facilities that have established procedures to ensure the water treatment plant is operating as per the design parameters and the documented procedures or processes, at minimum, cover the following aspects:
- Standard Operating Procedures
- Continuous monitoring
- Ongoing Maintenance
- Does your facility have a back-up plan if there is an emergency related to wastewater? (Ref ID: wwemergplan)
Answer Yes If: Your Facility has a back-up plan, process, and/or onsite and/or offsite facilities to respond to emergencies related to wastewater that is capable of handling the average daily volume of wastewater discharged by the facility.
If you answer Yes to this question, you will be asked the following sub question(s):
- Does your facility have a process to contact appropriate government authorities or agencies as legally required in case of accidental discharge?
- Please upload documentation, if available
- If you cannot upload the documents, please describe here.
Note: If your facility is not legally required to notify relevant government authorities or agencies of any accidental discharge, you should select “Not Legally Required” for this question.
- Select all strategies included in your facility's back-up plan for wastewater:
- Emergency Production Shutdown
- Note: This action must be backed up by additional emergency response actions or processes rather than stating simply that the facility will stop production.
- Holding Tank
- What is the size of your facility's holding tank (in m3)?
- Availability of additional pumps, blowers, dosing pumps and critical equipment for the specific treatment plant, that are not used for day to day running of the plant.
- Discharge to Offsite Water Treatment Plant
- Note: Discharge of untreated wastewater that cannot be treated onsite due to an emergency must be directed authorized offsite wastewater treatment service provider (public or private) with prior consent.
- Other Backup Process
- If other, please describe.
- Emergency Production Shutdown
- Please upload your backup plan
- What is your facility’s wastewater treatment plant maximum holding capacity (in m3) if the treatment plant is shut down in an emergency?
- Does your facility provide training to all relevant employees regarding the backup plan?
- If yes, how many employees were trained?
- If yes, how frequently do you train your employees?
- Do you evaluate your employees after the training?
- How do you evaluate the knowledge of your employees after the training?
- Please upload documentation.
Suggested Uploads:
- Documentation that shows emergency backup processes are in place that are sufficient to treat the average daily volume of wastewater discharged by the facility site (e.g., wastewater treatment flow diagram, documented back-up plan, back -up equipment inventory, agreement with offsite treatment plant to receive wastewater in an emergency, etc.).
What is the intent of the question?
The intent of this question is to confirm that facilities have a contingency plan in the event the treatment process fails to prevent untreated effluent from being discharged.
Technical Guidance:
It is crucial that facilities evaluate the risk of wastewater treatment system failures (e.g., failures in treatment processes or equipment, natural disasters, power outages). Facilities should establish a documented contingency plan to respond to potential emergencies. It is important to know the wastewater treatment systems handling capacity (per day) and compare this information with the quantity of wastewater generated to determine what actions or onsite facilities are required to effectively manage any treatment system failures.
It is also important that facilities ensure the relevant staff members and teams are trained and understand the facility’s back-up plan to ensure that emergency response actions are effective.
Some examples of actions that can be taken in the event of an emergency include, but are not limited to:
- Emergency shutdown of production or treatment system until the situation is rectified.
- Note: This action must be backed up by additional emergency response actions or processes rather than stating simply that the facility will stop production.
- Back-up holding tank capacity which temporarily stores the quantity of wastewater equal to one day’s production.
- Note: Holding tanks should not be considered as an exclusive backup measure.
- Maintaining a sufficient amount of back up equipment to ensure broken/damaged equipment can be timely replaced.
- Establish agreement and procedures for alternative offsite treatment with a licensed third-party wastewater treatment plant or service provider.
Resources:
Note: The resources provided below are for reference only and may contain reference to legal requirements that do not apply to your facility. It is expected that facilities comply with all applicable legal requirements related to wastewater emergency planning and procedures.
- New Hampshire Department of Environmental Services - Emergency Response Planning Guide Developed for Insertion into Wastewater Treatment Facility O&M Manuals https://www.des.nh.gov/sites/g/files/ehbemt341/files/documents/2020-01/ww-emergency-response-guide.pdf
- ICS Effluent Treatment Plant (ETP) – Emergency response plan Fact Sheet https://ics-asso.org/wp-content/uploads/2018/04/Chap-4_Wastewater_Effluent-treatment-plant-emergency-response-plan_factsheet.pdf
Wwemergplan Verification And Scoring
How This Will Be Verified:
Full Points:
Full points will be awarded for facilities that have a back-up plan, process, and/or onsite and/or offsite facilities to respond to emergencies related to wastewater that is capable of handling the average daily volume of wastewater discharged by the facility and have a process to notify relevant government authorities or agencies of any accidental discharge, if it is legally required.
Documentation Required:
- Documentation that shows emergency backup processes are in place that are sufficient to treat the average daily volume of wastewater discharged by the facility site. This may include:
- Wastewater treatment flow diagram showing additional emergency holding or treatment capacity if applicable.
- Documented back-up plan and/or procedures (e.g., emergency shutdown procedures).
- Back -up equipment inventory
- Agreement with an offsite treatment plant to receive wastewater in an emergency.
- List of emergency contacts/responsible parties (internal and external).
Interview Questions to Ask:
- Staff responsible for wastewater management can explain the facilities back-up plan and/or procedures to respond to any type of wastewater emergency.
- Responsible staff (treatment plant operators, maintenance staff) understand the facility’s emergency response procedures.
Inspection - Things to Physically Look For:
- Observations indicate the appropriate equipment and facilities are in place as per the facility’s back up plan.
Partial Points:
- Partial points will be awarded for facilities that have a back-up plan, process, and/or onsite and/or facilities to respond to emergencies related to wastewater that is capable of handling the average daily volume of wastewater discharged by the facility, but do not have a process to notify relevant government authorities or agencies of any accidental discharge, if it is legally required.
7. Can you please confirm that, wastewater generated by the facility is not discharged to the environment through leaking and/or bypassing? (Ref ID : wwleaking)
Answer Yes If: There are no leaks of untreated wastewater or bypassing of the wastewater treatment system AND your facility has processes in place to ensure that untreated wastewater is not discharged to the environment from leaks or bypassing of the wastewater treatment system.
Answer Partial Yes If: There are no leaks of untreated wastewater or bypassing of the wastewater treatment system at your facility, but you do not have a formal process to regularly monitor this.
Select No If: Leaks of untreated wastewater or bypassing of the wastewater treatment system are observed to be discharged to the environment.
If you answer Yes to this question, you will be asked the following sub question(s):
- If yes, please describe how you monitor.
- Please upload documentation.
Suggested Uploads:
- Documentation that shows no wastewater is discharged through leaks or bypassing the facility’s treatment system (e.g., wastewater flow/piping diagram, records of effluent volume monitoring against the volume of wastewater generated, leak inspection records)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that untreated wastewater is not being discharged to the environment from leaks or bypassing of the wastewater treatment system.
Technical Guidance
Ensuring that the facility’s wastewater collection and treatment system network (e.g., collection and transfer piping, and storage) is properly designed and capable of appropriately directing wastewater to treatment is crucial to ensure that no untreated wastewater is able to bypass treatment. It is also important to ensure that this network is inspected and maintained to prevent unintended discharge from leaks or overflow.
Factories should have an established process to monitor the volume of wastewater generated from production or other operations in relation to the volume of water that is treated and discharged. Any significant or unknown difference should be investigated to determine the cause.
Examples of actions that can be taken to prevent this include, but are not limited to:
- Review the facility’s wastewater collection and treatment system network (e.g., construction or utility drawings) to ensure all wastewater is being properly collected and directed to treatment.
- Identify and characterize all wastewater streams to ensure they are directed to treatment before being discharged to the environment.
- Install and maintain appropriately sized wastewater treatment systems that account for the expected volume of wastewater generated on site.
- Conduct regular inspections of wastewater piping systems and tanks to monitor for leaks.
- Prepare for emergencies and implement emergency response actions in case the on-site wastewater treatment plant exceeds its capacity or if it malfunctions.
Wwleaking Verification And Scoring
How This Will Be Verified:
Full points:
Full points will be awarded if your facility has processes in place to ensure that untreated wastewater is not discharged to the environment from leaks or bypassing of the wastewater treatment system
Documentation Required:
- Documentation that demonstrates the facility has processes in place to ensure that untreated wastewater is not discharged to the environment from leaks or bypassing of the wastewater treatment system. This may include:
- Wastewater flow/piping diagram.
- Wastewater volume monitoring records that show the difference between volume of wastewater generated and discharged is acceptable.
- Records of inspections for of wastewater piping systems and tanks that the facility uses to monitor for leaks (e.g., inspection schedule, and completed checklists)
Interview Questions to Ask:
- Staff responsible for wastewater management can describe how the facility ensures that all wastewater is directed to appropriate treatment and the system is monitored for leaks.
- Staff responsible for inspecting and monitoring the system for leaks understand the facility’s inspection procedures and how to effectively identify leaks.
Inspection – Things to Physically Look For:
- Observations indicate that all wastewater is appropriately directed to treatment (e.g., no observed bypassing of wastewater collection or treatment) and the wastewater piping network and tanks are maintained in good condition (e.g., there are no observed leaks).
Partial Points:
Partial Points will be awarded if there are no leaks of untreated wastewater or bypassing of the wastewater treatment system at your facility, but you do not have a formal process to regularly monitor this.
8. How many separate and distinct sources of wastewater sludge are managed and disposed of? (Ref ID : wwsludgesources)
If you indicate that your facility has one (1) or more sources of sludge, you will be asked the following sub question(s):
- Please describe the source of each type of wastewater sludge generated at your facility.
- Do you know the % solids of your wastewater sludge you generated?
- What are the % solids of this wastewater sludge you have generated?
Notes:
- The % solids of sludge should be reported as the average % solids value for that sludge type if multiple samples were analysed.
- The formula for determining the % solids is:
- weight of dry sludge / weight of wet sludge x 100
- If you have not conducted % solids analysis in accordance with a recognized test method (e.g., EPA 160.3 or SM 2540G), you should answer No to the Question. Do you know the % solids of your wastewater sludge you generated?
Suggested Uploads:
- Documentation that shows your facility has identified all sources of sludge and conducted an analysis to determine the % solids of the sludge (e.g., a list/inventory of the types of sludge, internal or external sludge analysis results/reports).
This question is not scored in the 2024 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to identify the different sources of sludge generated at the facility and understand the % solids content of each sludge type.
Technical Guidance:
It is important for facilities to know the different sources (e.g., types) of sludge and the general composition of sludge to ensure the most effective treatment and disposal options are used. The compositions of can vary depending on the composition of wastewater and the processes used for its treatment. In general, sludge contains water, organic and inorganic materials, and solids.
A key basic sludge quality parameter that is important to understand is the % of dry solids content. The % solids indicate the moisture content or sludge after its generated at the facility and can impact the cost and type of disposal that is available. In general, reducing sludge moisture content (e.g., drying, dewatering) as much as possible can help reduce sludge volume and the associated transportation/disposal costs.
Resources:
- ZDHC Sludge Reference Document. Note: This guidance is not applicable for domestic only sludge. https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
- ZDHC Wastewater and Sludge Laboratory Sampling and Analysis Plan https://downloads.roadmaptozero.com/output/Sampling-and-Analysis-Plan
Wwsludgesources Verification And Scoring
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that shows your facility has identified all sources of sludge and conducted an analysis to determine the % solids of the sludge. This may include:
- A list/inventory of the types of sludge.
- Internal or external sludge analysis results/reports.
- Supporting data and calculations to that shows the average % solids content for sludge (where multiple analyses have been performed).
Interview Questions to Ask:
- Staff responsible for wastewater and sludge management can explain how the facility identified its sludge sources and the methodology used for determining the % solids content of sludge.
Inspection - Things to Physically Look For:
- Observations indicate that sources of sludge reported are consistent with sludge generation at the facility.
9. Does your facility track its industrial wastewater sludge generated in the reporting year? (Ref Id: wwsludgereporting)
Answer Yes if: Your facility tracked the annual quantity of industrial wastewater sludge generated at the facility in the FEM reporting year.
If you answer Yes to this question, you will be asked the following sub question(s):
- If yes, how much industrial wastewater sludge (in Metric Tons) did you generate in the reporting year?
- Note: If domestic sludge is combined with industrial sludge, it should be reported here.
Suggested Uploads
- Sludge quantity/disposal tracking records that show the quantity of sludge generated of in the reporting year (e.g., waste manifests, internal tracking records)
This question is not scored in the 2024 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to demonstrate the annual quantity of industrial wastewater sludge was tracked in the reporting year.
Technical Guidance:
Tracking the quantity of sludge provides important information that can be used to identify opportunities to reduce sludge and quantify these reductions.
Procedures to track the annual quantity of sludge generated generally align with the practices used to track the quantity any waste stream and include the following:
- Determine what types of waste are generated.
- Determine where (location and processes) where sludge is being generated.
- Establish procedures to collect and track waste data:
- Examples include on-site scales, waste invoices/manifests.
- If estimation techniques are used to calculate the quantity of sludge, the methodology should be clearly defined and be supported by verifiable data.
- Record the data (e.g., daily, weekly, monthly sludge quantities) in a format that is easy to use and review such as Microsoft Excel or another data analytics program.
Estimating Sludge Quantity Data
In some cases, calculating annual sludge quantities may require estimation. Any estimation methodology used should include documented and verifiable processes that include details on the calculation methodology and any data or assumptions used.
Note: If an estimation technique is used, the methodology should be applied consistently and based on reasonable estimation factors that are derived from relevant data (e.g., actual weights of a representative sample of the sludge).
An example of how waste quantity data can be estimated is provided below:
- A facility generates a specific quantity of sludge every time the filter press is unloaded. Weighing the sludge every time is not practical. Therefore, the average weight of each filter press load can be determined by weighing a representative sample of sludge from multiple loads and then multiplying this average weight by the number of filter press loads each week or month as shown below:
- Average weight of a load = 50kg (based on representative weights of loads from different days, months, production scenarios, etc.)
- Number of loads in 1 month = 45
- Total estimated sludge quantity for the month = 2,250kg (50kg x 45 loads)
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
Wwsludgereporting Verification And Scoring
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that supports the reported sludge quantity. This may include:
- Tracking records for annual sludge quantities (e.g., invoices from waste contractors, weighing records, etc.).
- Scale calibration records if applicable (e.g., as per manufacturer’s specifications)
- Documented estimation methodologies if applicable.
Interview Questions to Ask:
- Staff responsible for managing sludge and/or wastes can explain how sludge quantity is tracked.
- Key staff should understand:
- How data quality of the sludge tracking program is maintained.
- Any estimation methodologies used to calculate annual sludge quantity.
Inspection - Things to Physically Look For:
- Observations are consistent with the facility reported procedures to track and measure sludge quantity (e.g., appropriate equipment is available for sludge quantity measurement if applicable).
10. Does your facility track its domestic wastewater sludge generated in the reporting year? (Ref Id: wwsludgedomesticreporting)
Answer Yes if: Your facility tracked the annual quantity of domestic wastewater sludge generated at the facility in the FEM reporting year.
If you answer Yes to this question, you will be asked the following sub question(s):
- If yes, how much domestic wastewater sludge (in Metric Tons) did you generate in the reporting year?
Suggested Uploads
- Sludge quantity/disposal tracking records that show the quantity of sludge generated of in the reporting year (e.g., waste manifests, internal tracking records)
This question is not scored in the 2024 Higg FEM reporting year. Scoring may be applied in future reporting years.
What is the intent of the question?
The intent of this question is for facilities to demonstrate the annual quantity of domestic wastewater sludge was tracked in the reporting year.
Technical Guidance:
Tracking the quantity of sludge provides important information that can be used to identify opportunities to reduce sludge and quantify these reductions.
Procedures to track the annual quantity of sludge generated generally align with the practices used to track the quantity any waste stream and include the following:
- Determine what types of waste are generated.
- Determine where (location and processes) where sludge is being generated.
- Establish procedures to collect and track waste data:
- Examples include on-site scales, waste invoices/manifests.
- If estimation techniques are used to calculate the quantity of sludge, the methodology should be clearly defined and be supported by verifiable data.
- Record the data (e.g., daily, weekly, monthly sludge quantities) in a format that is easy to use and review such as Microsoft Excel or another data analytics program.
Estimating Sludge Quantity Data
In some cases, calculating annual sludge quantities may require estimation. Any estimation methodology used should include documented and verifiable processes that include details on the calculation methodology and any data or assumptions used.
Note: If an estimation technique is used, the methodology should be applied consistently and based on reasonable estimation factors that are derived from relevant data (e.g., actual weights of a representative sample of the sludge).
An example of how waste quantity data can be estimated is provided below:
- A facility generates a specific quantity of sludge every time the filter press is unloaded. Weighing the sludge every time is not practical. Therefore, the average weight of each filter press load can be determined by weighing a representative sample of sludge from multiple loads and then multiplying this average weight by the number of filter press loads each week or month as shown below:
- Average weight of a load = 50kg (based on representative weights of loads from different days, months, production scenarios, etc.)
- Number of loads in 1 month = 45
- Total estimated sludge quantity for the month = 2,250kg (50kg x 45 loads)
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
Wwsludgedomesticreporting Verification And Scoring
How This Will Be Verified:
Note: This question is unscored.
Documentation Required:
- Documentation that supports the reported sludge quantity. This may include:
- Tracking records for annual sludge quantities (e.g., invoices from waste contractors, weighing records, etc.).
- Scale calibration records if applicable (e.g., as per manufacturer’s specifications)
- Documented estimation methodologies if applicable.
Interview Questions to Ask:
- Staff responsible for managing sludge and/or wastes can explain how sludge quantity is tracked.
- Key staff should understand:
- How data quality of the sludge tracking program is maintained.
- Any estimation methodologies used to calculate annual sludge quantity.
Inspection - Things to Physically Look For:
- Observations are consistent with the facility reported procedures to track and measure sludge quantity (e.g., appropriate equipment is available for sludge quantity measurement if applicable).
11. Does your facility have well-marked, designated wastewater sludge storage areas? (Ref Id : wwsludgestorage)
Answer Yes if: Your facility has designated wastewater sludge storage areas.
If you answer Yes to this question, you will be asked a set of sub questions to indicate which of the following practices your facility has in place for sludge storage areas:
- Does your facility have the following practices in place in the wastewater sludge storage area?
- The surface of the wastewater sludge storage area prevents permeability into the ground and is inert in nature.
- The wastewater sludge storage area is protected from exposure to precipitation and stormwater runoff.
- The industrial and domestic wastewater sludge are kept and stored separately.
- If only Domestic wastewater sludge is generated, Not Applicable should be selected for this question.
- The industrial wastewater sludge storage area is protected from unauthorized employees.
Suggested Upload:
- Photos of sludge storage areas.
What is the intent of the question?
The intent of this question is to ensure that sludge is stored in a way that is safe for employees, the environment, and the local community.
Technical Guidance:
The proper storage of sludge is important to prevent unintended contamination of other wastes, the surrounding environment and to reduce exposure risks to employees. Facilities should have dedicated storage areas for sludge and implement appropriate controls practices based on the hazardous characteristics of the sludge such as those listed in the sub questions.
Information on the hazardous characteristics of sludge should be evaluated using analysis data from sludge samples or in the Safety Data Sheets (SDS) of the hazardous raw materials used in the processes that generate the sludge. For example, if heavy metals are used in any process chemistry, these contaminants will likely be present in sludge generated.
Sludge storage areas should also be inspected regularly to ensure good storage and housekeeping practices are continuously implemented.
Resources:
ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
Wwsludgestorage Verification And Scoring
How This Will Be Verified:
Full Points:
Facilities will receive full points for having dedicated sludge storage areas, and have implemented all the applicable control measures listed in the sub question.
Documentation Required:
- Documentation to support the facilities procedures to ensure that sludge is stored appropriately. This may include:
- Procedures or work instructions for sludge/waste storage areas
- Hazardous waste area inspection records
Interview Questions to Ask:
- Staff responsible for sludge/waste management handling and storage understand risks associated with sludge stored and how to properly store sludge (e.g., which containers to use, required segregation, etc.)
Inspection - Things to Physically Look For:
- Observations indicate that sludge is being stored in designated areas with appropriate controls.
Partial Points:
- Partial Points will be awarded to facilities that have dedicated sludge storage areas and have implemented some, but not all, the applicable control measures listed in the sub questions.
12. Is industrial wastewater sludge disposed of properly? (Ref ID: wwhsludgedisposal)
Answer Yes if: Your facility is disposing of industrial wastewater sludge in accordance with all legal requirements based on the hazardous characteristic of the sludge.
Note: This question refers to the final treatment/disposal method of the sludge. This can be onsite or offsite depending on the final treatment/disposal location.
If you answer Yes to this question, you will be asked the following sub question(s):
- Which disposal pathway(s) does your facility dispose of your industrial wastewater sludge?
- Hazardous Waste Treatment
- Open burning
- Note: The use of open burning of sludge is strongly discouraged unless specific regulatory approval is obtained and complied with.
- Onsite Incineration at ≥1000 °C
- Onsite Incineration at <1000 °C
- Offsite Incineration at ≥1000 °C
- Landfill with Significant Control Measures
- Building Products Processed at ≥1000 °C
- Landfill with Limited Control Measures
- Offsite Incineration and Building Products Processed at <1000 °C
- Landfills with No Control Measures
- Land Application
- E.g., Compost, fertilizer.
- Non-disclose method by authorized third party (final disposal method not disclosed)
- Please upload documentation.
Note: In the Higg FEM, the definition of landfills (e.g., with significant, limited, or no control measures) and disposal pathways aligns with the ZDHC Disposal Pathway definitions listed in the ZDHC Sludge Management Document available at the link below. FEM users should reference this document to ensure proper selection of their sludge disposal pathway. https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
Suggested Uploads:
- Documentation that demonstrates industrial wastewater sludge is being disposed of properly (sludge analysis/test showing hazardous properties, sludge disposal manifests, permit/license of waste vendor accepting and treating the sludge, evidence of the final treatment/disposal method being used, etc.)
What is the intent of the question?
The intent of this question is for facilities to demonstrate that industrial wastewater sludge is being disposed of responsibly to minimize environmental impacts.
Technical Guidance:
The hazardous properties and proper disposal method of sludge depend on the specific hazardous properties of the sludge (e.g., the type and concentration of hazardous chemicals). Facilities should ensure that sludge is properly characterized (e.g., via laboratory testing) to identify its hazardous properties and any specific disposal requirements or limitations.
At minimum, sludge should be disposed of in accordance with all applicable legal requirements related to sludge and waste disposal. This includes the use of qualified waste disposal vendors who are licensed/permitted to treat the sludge based on its hazardous characteristics as required.
As part of a facilities waste management program, it is important for facilities to understand how wastes (including sludge) are treated and/or disposed of after leaving the facility. Facilities should have processes in place to communicate with waste vendors and verify the final treatment disposal methods for sludge.
If sludge is treated and/or disposed of onsite, this should be done with proper permission (e.g., approvals/permits) from government authorities when required.
Resources:
- ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document
ZDHC Wastewater and Sludge Laboratory Sampling and Analysis Plan https://downloads.roadmaptozero.com/output/Sampling-and-Analysis-Plan
Wwhsludgedisposal Verification And Scoring
How This Will Be Verified:
Full Points:
Documentation Required:
- Documentation that demonstrates industrial wastewater sludge is being disposed of in accordance with all legal requirements based on the hazardous characteristic of the sludge. This may include:
- Sludge analysis/test showing hazardous properties.
- Sludge disposal manifests
- Where applicable, permit/license of waste vendor accepting and treating the sludge.
- Evidence of the final treatment/disposal method being used by the waste vendor.
- Legal approvals/permits for any onsite treatment/disposal of sludge if applicable.
Interview Questions to Ask:
- Staff responsible for wastewater/waste management understand the hazardous composition of the facility’s sludge and the final disposal method used to treat/dispose of the sludge.
Inspection - Things to Physically Look For:
- Observations indicate that sludge is being collected and treated per the methods reported by the facility (e.g., onsite treatment/disposal conditions, sludge storage conditions, etc.)
Partial Points: N/A