FEM 2024 - Wastewater Level 2

Table of Contents

1. Wwcompliancetable
2. Wwcompliancetable Verification And Scoring
3. Wwcompliancehtml
4. Wwcompliancehtml Verification And Scoring
5. Wwzdhcguideline
6. Wwzdhcguideline Verification And Scoring
7. Wwzdhcfoundational
8. Wwzdhcfoundational Verification And Scoring
9. Wwtestmrsl
10. Wwtestmrsl Verification And Scoring
11. Wwsludgegenerated
12. Wwsludgegenerated Verification And Scoring
13. Wwsludgeaccount
14. Wwsludgeaccount Verification And Scoring
15. Wwseptictankupgrade
16. Wwseptictankupgrade Verification And Scoring
17. Wwqualitytest
18. Wwqualitytest Verification And Scoring

Wwcompliancetable

19. Are you reporting against any wastewater standard (additional to the legal requirement)? (Ref ID: wwcompliancetable)

Note:  The response to this Level 2 question will be pre-populated based on the response to the wastewater standard question in Level 1. The Level 1 question is unscored, and scoring will be applied in Level 2 as follows:

• Full Points: will be awarded for a Yes response.
• No Points: will be awarded for a No response.
• Unscored: This question will be unscored if the response is Not Applicable.

Wwcompliancetable Verification And Scoring

How This Will Be Verified:

This question will be verified in accordance with the criteria set forth in the Level 1 question.

Wwcompliancehtml

20. Are you in compliance/conformance with the reported wastewater standard? (Ref ID: wwcompliancehtml)

Note:  This question will only be applicable to facilities that have a Yes response to the question: Are you reporting against any wastewater standard (additional to the legal requirement)?

In this question, you will be asked to complete a table with the following questions to provide details on your facility’s compliance/conformance status with the wastewater standard(s) your facility reports against. 

• Reported Wastewater standard (this will be pre-populated with the applicable standard(s) the facility is reporting against).
• Frequency of Sampling
• Are you in compliance with this wastewater standard?
  • If not, please provide additional information of why you are not compliant with this wastewater standard.
• Are your parameter results available on the standard's platform?
  • Please provide a direct link to the standard's platform to access results.
• Please upload documentation to demonstrate you are compliant with the standard.

Note: The question “Are you in compliance with this wastewater standard?” Should be answered based on the guidance below:

• Answer Yes, all parameters are compliant if: Testing is conducted at the frequency required by the standard and the most recent testing results from the FEM reporting year meet the requirements of the standard for all parameters.
• Answer Partial Yes, at least one or more parameters are not compliant if: Testing is not conducted at the frequency required by the standards and/or the most recent testing results from the FEM reporting year show one (1) or more parameters did not meet the requirements of the standard. 
• Answer No, I did not test, or all parameters are not compliant if: Testing was not conducted in the FEM reporting year, or all parameters did not meet the requirements of the standard.

Suggested Uploads

• Copies of wastewater testing results and data reporting that demonstrates the facility is meeting the requirements of the standard.

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they are meeting all of the requirements of the wastewater standard that goes beyond basic legal compliance monitoring and reporting.

Technical Guidance:

Different standards or tools may have different requirements for monitoring and reporting of wastewater data (e.g., the type and frequency of reporting, types of pollutants that must be monitored/reported, or testing methodologies, etc.) When adopting an industry standard, facilities should review the guideline to determine the monitoring and reporting requirements that apply to their operations and put in place procedures to meet the required monitoring and reporting requirements. 

Supporting documentation that shows the facility is meeting these requirements such as wastewater monitoring data, testing results, etc. should be maintained.  

Examples of industry guidance/tools for wastewater include:

• The ZDHC suite of guidelines which can be downloaded here:  https://www.roadmaptozero.com/output 
  • ZDHC Wastewater Guidelines for Leather & Textile
  • ZDHC Man-Made Cellulosic Fibres (MMCF) Guidelines
  • ZDHC Sludge Reference Document
• bluesign® CRITERIA for production sites (and its Annexes) which can be downloaded here: https://www.bluesign.com/en/downloads 

Wwcompliancehtml Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded if testing is conducted at the frequency required by the standard and testing results of all the most recent testing results from the FEM reporting year meet the requirements of the standard for all parameters.

Documentation Required:

• Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the applicable standard(s) selected. This may include:
  • Wastewater test report showing the parameters tracked by the facility. 
    • Note: Testing should be conducted in accordance with the applicable standard (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.)
  • External links to the facility’s wastewater data on the standard's platform 
  • If applicable, internal procedures used to ensure the requirements of the standard are being met.
  • If applicable supporting documentation of investigations to identify the cause of any non-conformances. 

Note: Required documentation may vary by standard being reported against. All wastewater reporting documentation required by the standard to demonstrate compliance should be available for verification. 

Interview Questions to Ask:

• Staff responsible for managing wastewater understand and can describe the monitoring and reporting requirements of the standard the facility is reporting against.

Inspection - Things to Physically Look For: 

• The relevant wastewater sources observed at the facility are included in the facility’s monitoring/reporting procedures as required by the standard used to report wastewater data.

Partial Points:

• Partial points will be awarded if testing is not conducted at the frequency required by the standards and/or the most recent testing results from the FEM reporting year show one (1) or more parameters did not meet the requirements of the standard. 

Wwzdhcguideline

21. If you reported against ZDHC wastewater guidelines, did your facility test your wastewater and meet foundational level conventional parameters and Anion in the reporting year?   (Ref ID:wwzdhcguideline)

Note:  This question will only be applicable to facilities that are reporting against ZDHC Wastewater Guidelines.

Answer Yes, I tested and meet foundational level if: The most recent ZDHC testing results from the FEM reporting year show all conventional parameters and Anions met the foundational level of the standard.

Answer Partial Yes, I have tested and did not meet foundational level if: The most recent ZDHC testing results from the FEM reporting year show one (1) or more conventional parameters or anions did not meet the foundational level of the standard.

Answer Not Applicable if: Conventional parameters and anions are not required to be tested per the ZDHC Wastewater Guidelines based on your facility’s wastewater volume and/or the location or type of wastewater treatment.

If you answer Partial Yes to this question, you will be asked to complete a table with the following questions for ZDHC conventional parameters and anions :

• Did this parameter exceed the foundational limit?
  • Note: If you answer Yes to the above question, you will be asked to complete the following questions in the table:
• Quantity Detected
• Unit of measure
• What is the limit quantity?
• Unit of measure
• How long have you had this problem?
• Upload your action plan for the substance detected.
• If you don't have a document to upload, describe your plan.

Technical Guidance:

For detailed information on the ZDHC wastewater guidelines (e.g., sampling and analysis requirements, parameter limits, etc.) FEM users should refer to the most recent versions of the ZDHC Wastewater Guidelines and related supporting documentation available on the ZDHC website here: https://www.roadmaptozero.com/output 

Wwzdhcguideline Verification And Scoring

How This Will Be Verified:

Documentation Required:

• Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the ZDHC Wastewater Guidelines. This may include:
  • Wastewater test report showing the parameters tracked by the facility. 
    • Note: Testing should be conducted in accordance with the ZDHC program requirements (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.)
  • External links to the facility’s wastewater data on the standard's platform 
  • If applicable, supporting documentation of planned actions to address any non-conformances. 

Interview Questions to Ask:

• Staff responsible for managing wastewater understand and can describe the facility’s procedures to test wastewater in accordance with the ZDHC Wastewater Guidelines.

Inspection - Things to Physically Look For: 

• The relevant wastewater sources observed at the facility are included in the facility’s ZDHC testing/reporting procedures.

Wwzdhcfoundational

22. If you reported against ZDHC wastewater guidelines, did your facility test your wastewater and meet foundational level heavy metal limits in the reporting year?  (Ref ID: wwzdhcfoundational)

Note:  This question will only be applicable to facilities that are reporting against ZDHC Wastewater Guidelines.

Answer Yes, I tested and meet foundational level if: The most recent ZDHC testing results from the FEM reporting year show all heavy metals met the foundational level of the standard.

Answer Partial Yes, I have tested and did not meet foundational level if: The most recent ZDHC testing results from the FEM reporting year show one (1) or more heavy metals did not meet the foundational level of the standard.

Answer Not Applicable if: Heavy metals are not required to be tested per the ZDHC Wastewater Guidelines based on your facility’s wastewater volume and/or the location or type of wastewater treatment.

If you answer Partial Yes to this question, you will be asked to complete a table with the following questions for ZDHC heavy metals parameters :

• Did this parameter exceed the foundational limit?
  • Note: If you answer Yes to the above question, you will be asked to complete the following questions in the table:
• Quantity Detected
• Unit of measure
• What is the limit quantity?
• Unit of measure
• How long have you had this problem?
• Upload your action plan for the substance detected.
• If you don't have a document to upload, describe your plan.

Technical Guidance:

For detailed information on the ZDHC Wastewater Guidelines (e.g., sampling and analysis requirements, parameter limits, etc.) FEM users should refer to the most recent versions of the ZDHC Wastewater Guidelines and related supporting documentation available on the ZDHC website here: https://www.roadmaptozero.com/output 

Wwzdhcfoundational Verification And Scoring

How This Will Be Verified:

Documentation Required:

• Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the ZDHC Wastewater Guidelines. This may include:
  • Wastewater test report showing the parameters tracked by the facility. 
    • Note: Testing should be conducted in accordance with the ZDHC program requirements (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.)
  • External links to the facility’s wastewater data on the standard's platform 
  • If applicable, supporting documentation of planned actions to address any non-conformances. 

Interview Questions to Ask:

• Staff responsible for managing wastewater understand and can describe the facility’s procedures to test wastewater in accordance with the ZDHC Wastewater Guidelines.

Inspection - Things to Physically Look For: 

• The relevant wastewater sources observed at the facility are included in the facility’s ZDHC testing/reporting procedures.

Wwtestmrsl

23. If you reported against ZDHC wastewater guidelines, did your facility test your wastewater and meet MRSL parameter requirements in the reporting year? (Ref ID: wwtestmrsl)

Note:  This question will only be applicable to facilities that are reporting against ZDHC Wastewater Guidelines.

Answer Yes, I tested and meet parameter limits if: The most recent ZDHC testing results from the FEM reporting year show no MRSL parameters were detected including raw wastewater samples.

Answer Partial Yes, I have tested and did not meet all parameter limits if: The most recent ZDHC testing results from the FEM reporting year show one (1) or more MRSL parameters was detected including raw wastewater samples.

Answer Not Applicable if: MRSL parameters are not required to be tested per the ZDHC Wastewater Guidelines based on your facility’s wastewater volume and/or the location or type of wastewater treatment.

Note: No detection means that the parameter was not detected above the specified reporting limit listed in the ZDHC Wastewater Guideline. 

If you answer Partial Yes to this question, you will be asked to complete a table with the following questions for ZDHC MRSL parameters :

• Was a chemical in this MRSL Parameter Category Detected?
  • Note: If you answer Yes to the above question, you will be asked to complete the following questions in the table:
• Quantity Detected
• Unit of measure
• What is the limit quantity?
• Unit of measure
• How long have you had this problem?
• Upload your action plan for the substance detected.
• If you don't have a document to upload, describe your plan.

Technical Guidance:

For detailed information on the ZDHC Wastewater Guidelines (e.g., sampling and analysis requirements, parameter limits, etc.) FEM users should refer to the most recent versions of the ZDHC Wastewater Guidelines and related supporting documentation available on the ZDHC website here: https://www.roadmaptozero.com/output 

Wwtestmrsl Verification And Scoring

How This Will Be Verified:

Documentation Required:

• Documentation that demonstrates the facility is monitoring and reporting wastewater in accordance with the ZDHC Wastewater Guidelines. This may include:
  • Wastewater test report showing the parameters tracked by the facility. 
    • Note: Testing should be conducted in accordance with the ZDHC program requirements (e.g., frequency or testing, test parameters, sampling and analysis methods, etc.) 
  • External links to the facility’s wastewater data on the standard's platform 
  • If applicable, supporting documentation of planned actions to address any non-conformances. 

Interview Questions to Ask:

• Staff responsible for managing wastewater understand and can describe the facility’s procedures to test wastewater in accordance with the ZDHC wastewater guidelines.

Inspection - Things to Physically Look For: 

• The relevant wastewater sources observed at the facility are included in the facility’s ZDHC testing/reporting procedures.

Wwsludgegenerated

24. Does your facility track wastewater sludge by each source which includes all sludge generated onsite and its disposition in your sludge inventory?  (Ref ID: wwsludgegenerated)

Answer Yes if: Your facility tracks wastewater sludge and the disposal method for at least one (1) source of sludge generated at the facility.

If you answer Yes to this question, you will be asked to complete a table with the following questions to provide details on your wastewater sludge generated by each source during this reporting year.

• Source of Wastewater Sludge (This will be pre-populated based on the facility’s reported sources of sludge)
• How is this wastewater sludge generated classified for this source?
  • Domestic
  • Industrial 
  • Combined Domestic and Industrial
• Does your facility track how much wastewater sludge it generates from this source in the reporting year?
• How much wastewater sludge (in Metric Ton) do you generate from this source in the reporting year (after any drying process is conducted, if any)?
• How does your facility dispose of this wastewater sludge?
  • How does your facility dispose of ash generated from onsite incineration? (Applies if onsite incineration is selected)
  • If Other, please describe your disposal pathway.
• Did you test the wastewater sludge of this source?
  • Were MRSLs detected in the sludge?
    • If MRSLs is detected, please select which one (Select all that apply)
  • Were Heavy Metal (Total Metal) and conventional parameters tested?
    • If Heavy Metal (Total Metal) and conventional parameters were above allowable limits, please select which one (Select all that apply)
• Provide any additional comments.
• 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 wastewater sludge quantity, composition, and disposal method(s) are being tracked (e.g., sludge inventory/tracking, sludge analysis/test showing hazardous properties, sludge disposal manifests, 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 wastewater sludge generated at the facility is being tracked (e.g., sludge quantity, composition, and disposal method).

Technical Guidance:

It is important for facilities to know and track 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. Tracking the properties and volume of sludge generated at the facility can also provide insight into the effectiveness of wastewater treatment processes, the presence of undesired chemicals (e.g., MRSL compounds) as well as disposal costs. 

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.

Additionally, 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 

Wwsludgegenerated Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

• Documentation that demonstrates wastewater sludge is being tracked. This may include:
  • Sludge inventory showing the quantity, composition, and disposal method(s) for sludge generated at the facility.
  •  Sludge analysis/test showing hazardous properties.
  • Sludge disposal manifests
  • Evidence of the final treatment/disposal method being used onsite or by the waste vendor.

Interview Questions to Ask:

• Staff responsible for wastewater/waste management can explain how sludge is tracked at the facility including tracking of sludge volume, composition, and the final disposal method used to treat/dispose of sludge.

Inspection - Things to Physically Look For: 

• Observations indicate that sludge is being tracked in accordance with the facility’s reported procedures for tracking sludge.

Partial Points: N/A

Wwsludgeaccount

25. Does your facility maintain manifests or similar documentation of the handling, transportation, processing, and disposal of sludge, accounting for all domestic wastewater sludge generated at the facility?  (Ref ID: wwsludgeaccount)

Answer Yes if: Your facility has a process to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge and all of the following conditions are met:

• Documentation has been obtained that accounts for all sludge disposals.
• The documentation contains all of the information noted below:
  • Shipper (the facility generating the sludge).
  • Mass or volume of the shipment.
  • Transporter name.
  • Shipment/Receiving dates.
  • Name of the disposal or processing facility that the sludge was shipped to. 

Answer Partial Yes if: Your facility has a process to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge, and documentation is available, however:

• The documentation has not been obtained for all sludge disposals; and/or
• The documentation does not contain all of the information noted below:
  • Shipper (the facility generating the sludge).
  • Mass or volume of the shipment.
  • Transporter name.
  • Shipment/Receiving dates.
  • Name of the disposal or processing facility that the sludge was shipped to.

If you answer Yes or Partial Yes to this question, you will be asked the following sub question(s):

• Does your facility use authorized third party for legal disposal of domestic wastewater sludge? 
• Does your facility retain documentation of all wastewater sludge transportation and disposal/treatment companies?
  • Note: This refers to the legally required amount of time that documentation must be retained, which may vary by jurisdiction. If there are no legal requirements, documentation must be retained for at least two (2) years.
• Are all domestic wastewater sludge transporters, treatment, and disposal facilities licensed and permitted?
• Please upload documentation.

Suggested Uploads:

• Samples of waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge.
• Copies of sludge handling/treatment/disposal vendor licenses and/or permits that show they are authorized to receive, process and dispose of the sludge.

Note: Uploading of all manifest or other documentation 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 processes are in place to obtain and retain information related to the handling, transportation, processing, and disposal of domestic wastewater sludge and to ensure that any third-party waste vendors have the required legal approvals to receive, process and dispose of the facility’s sludge.

Technical Guidance:

To ensure proper accountability, facilities should have established processes in place to maintain documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge. Often the minimum requirements for generating and maintaining documentation related to waste disposal are governed by legal requirements and all applicable requirements should be met by facilities. 

In addition to any legal requirements, facilities should ensure that a waste manifest or a similar local transport document that contains the following information is obtained and maintained for each sludge shipment as a good practice. If needed this additional information can be requested from waste vendors:

• Shipper (the facility generating the sludge).
• Mass or volume of net shipment.
• Transporter name.
• Driver’s name/signature.
• Name of the disposal or processing facility that the sludge was shipped to.
• Name/signature of personnel at the disposal or processing facility certifying acceptance of the sludge.

Facilities should also ensure that any third-party waste vendors used have the required legal approvals to receive, process and dispose of the facility’s sludge. Facilities should ensure that part of the waste vendor approvals process include the verification of all legally required approvals (e.g., licenses and permits). It is considered a good practice (if not legally required) for facilities to request and maintain up-to-date and valid copies of vendor approvals onsite.

Resources:

• ZDHC Sludge Reference Document https://downloads.roadmaptozero.com/output/Sludge-Reference-Document 

Wwsludgeaccount Verification And Scoring

How This Will Be Verified:

Full Points:

Full points will be awarded for facilities that have established processes to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge and all of the following conditions are met:

• Documentation has been obtained that accounts for all sludge disposals and contains all of the required information.
• Documentation is retained onsite for at least the legally minimum required length of time.If there are no legal requirements, documentation must be retained for at least two (2) years.
• Any third-party waste vendors used have the required legal approvals (e.g., licenses and permits) to receive, process and dispose of the facility’s sludge.

Note: Points will be awarded automatically in the Higg FEM based on the responses to the main and sub questions.

Documentation Required:

• Documentation that shows the facility has obtained and maintains waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge and that sludge is being received by authorized vendors. This may include: 
  • Waste manifests or other transport documentation.
  • Waste vendor licenses and/or permits that show they are authorized to receive, process and dispose of the facility’s sludge.

Interview Questions to Ask:

• Staff responsible for managing wastes can explain the facilities procedures to obtain and maintain manifests and/or other transport information related to sludge disposal and how the facility ensures that waste vendors have the required approvals to collect, receive, or process the facility’s sludge.  

Inspection - Things to Physically Look For: 

• Observations indicate that sludge is being collected and treated per the process reported by the facility (e.g., sludge disposal records, sludge storage conditions, presence of waste contractors onsite during verification, etc.)

Partial Points:

Partial points will be awarded for facilities that have established processes to obtain and retain waste manifests or similar documentation related to the handling, transportation, processing, and disposal of domestic wastewater sludge, and documentation is available, however one (1) or more of the following conditions exist:

• Documentation has been obtained but does not account for all sludge disposals or does not include the required information; and/or
• Documentation is not retained onsite for at least the legally minimum required length of time .If there are no legal requirements, documentation has not been retained for two (2) years; and/or
• Any third-party waste vendors used do not have the required legal approvals (e.g., licenses and permits) to receive, process and dispose of the facility’s sludge.

Note: Points will be awarded automatically in the Higg FEM based on the responses to the main and sub questions.

Wwseptictankupgrade

26. Do you have a plan to upgrade your septic tank to a more modern wastewater treatment approach?  (Ref ID: wwseptictankupgrade)

Answer Yes if: Your facility has a documented plan with a defined timeline to upgrade your septic system to a more advanced treatment system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility.

If you answer Yes to this question, you will be asked the following sub question(s):

• If yes, when do you plan on having the upgrade completed? 
• If yes, please upload documentation.

If you answer No to this question, you will be asked the following sub question(s):

• If no, please describe why you do not plan to upgrade your septic tank?

Suggested Uploads:

• Documentation that supports the facility’s plans to upgrade the septic system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility (e.g., records of purchase of wastewater treatment system, contract for planned construction of new treatment facility or removal of septic system, agreement with offsite wastewater treatment facility to begin receiving the facility’s wastewater, etc.)  

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 there is an established plan in place to upgrade the septic system to a more advanced treatment system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility.

Technical Guidance:

Septic systems provide a basic level of treatment for wastewater that are often not capable of providing a sufficient level of treatment before discharging wastewater directly to the environment. Additionally, in most cases it is not practical to effectively monitor effluent from the septic system to ensure that potential environmental impacts are being minimized. Effluent from septic systems can often contain levels of pathogens (e.g., E. coli), chemicals, and nutrients (e.g., nitrogen and phosphorus) that can contaminate groundwater or nearby surface water.

Upgrading a septic system to a more advanced type of treatment system (e.g., primary, secondary, and tertiary treatment) can reduce the risk of adverse impacts to the environment and allow facilities to ensure wastewater is appropriately treated before being discharged. 

An alternative solution to a septic system upgrade could also include discontinuing the use of the septic system and directing wastewater to an authorized offsite wastewater treatment facility for treatment.

Wwseptictankupgrade Verification And Scoring

How This Will Be Verified:

Note: This question is unscored.

Documentation Required:

• Documentation that demonstrates the facility has an established plan to upgrade the septic system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility. This may include:
  • Records of purchase of new wastewater treatment system.
  • Contract for planned construction of new treatment facility or removal of septic system.
  • Agreement with offsite wastewater treatment facility to begin receiving the facility’s wastewater.
  • Documented timelines for project completion if available.  

Interview Questions to Ask:

• Staff responsible wastewater management can explain the facility’s plans to upgrade the septic system or discontinue the use of septic system and direct wastewater to an authorized offsite wastewater treatment facility. 

Inspection - Things to Physically Look For: 

• If applicable, observations are consistent with the facility’s reported plans (e.g., observed onsite construction activities or preparations for system upgrades) 

Wwqualitytest

27. Have you requested wastewater quality test results from the offsite wastewater treatment plant?  (Ref ID: wwqualitytest)

Answer Yes if: Your facility obtained wastewater results from the offsite wastewater treatment plant in the Higg FEM reporting year or your facility has formally requested the offsite wastewater treatment plant to provide these results, or the wastewater treatment plant posts their effluent testing data online and the facility has access to this.

Notes: 

• Formally requested means that the facility has contacted the wastewater treatment plant or operator (via email, letter, or other means of communication) to request wastewater quality test results.
• If results have formally been requested and the facility has documentation of this request and results are not provided, and there is supporting evidence of the refusal, Yes can be selected for this question.

If you answer Yes to this question, you will be asked the following sub question(s):

• How / What action did you take to make the request?
  • Request Permit / compliance status of offsite Wastewater treatment plant.
  • Email
  • Research online record.
  • Send official request to offsite Wastewater treatment plant.
  • Other
    • If Other, please describe.
• Please upload documentation, if available.
• If you cannot upload the documents, please describe here.

Suggested Uploads:

• Offsite wastewater treatment plant quality test records for the FEM reporting year (if provided). 
• Documentation of your request to the offsite wastewater treatment plant for wastewater quality records in the FEM reporting year. 

What is the intent of the question?

The intent of this question is for facilities to demonstrate that they are proactively seeking to verify that wastewater from the offsite treatment plant is compliant with applicable legal and understand any potential impacts the facility’s wastewater may have on the offsite treatment plants operations.

Technical Guidance:

The objective of requesting wastewater quality test results from the offsite treatment plant is for a facility to proactively verify that treated wastewater effluent discharged from the offsite facility to the environment is compliant. 

Although facilities do not have operational control over the third-party treatment provider, it is important to be aware of any non-compliances and to what extent the facility may be contributing to non-compliances. This information is useful to help understand your situation and identify risk factors and/or opportunities for improvement.

It is recommended that facilities establish procedures to obtain (when possible), verify, and track this data on a regular basis (e.g., monthly, quarterly, etc) to monitor compliance as part of their environmental management program. 

Wwqualitytest Verification And Scoring

How This Will Be Verified:

Full Points:

Documentation Required:

• Offsite wastewater treatment plant quality test records for the FEM reporting year (if provided). 
• Documentation of your request to the offsite wastewater treatment plant for wastewater quality records in the FEM reporting year. 

Interview Questions to Ask:

• Staff responsible for wastewater management at the facility can explain how wastewater treatment plant quality test records are obtained and/or requested from the offsite treatment plant.

Inspection - Things to Physically Look For: 

• Observations indicate that the wastewater test results or requests made are for the offsite treatment plant used by the facility. 
   

Partial Points: N/A