From safety and compliance to maintenance and communication, owning a water or wastewater treatment plant involves a wide array of duties. Drawing on the lessons learned from our company’s 20-year experience, we’ve outlined key areas that demand plant owners’ careful focus.
The plant owner is responsible for ensuring their workplace is safe for everyone who works there. Being safe costs money and effort, but the alternative is even more costly in possible OSHA fines, lost workdays, and lawsuits. In the end, a safe workplace is worth every penny.
The Occupational Safety and Health Act (OSHA) of 1970 dictates that employers must provide their staff with a hazard-free work environment. It includes a comprehensive set of standards employers must meet to ensure compliance. There are rare instances where some organizations are fully or partially excluded, but even in these cases, it is prudent to abide by the standards to prevent accidents and injuries. U.S. Water routinely helps clients evaluate compliance with OSHA standards by identifying potential safety hazards through site safety audits and proposing mitigations to fill gaps. Although we can provide this guidance, the plant owner is still responsible for approving and funding the mitigations and ensuring they are implemented.
The practice we apply at every site is to compare our health & safety policies with our clients and direct our staff to use the most stringent policies. We also continually improve our policies by incorporating the most effective practices used by our clients and subcontractors and those recommended by industry leaders. We do not rest on our laurels.
Several references are available to help craft effective site safety plans, policies, and procedures. The Centers for Disease Control and Prevention (CDC) and the National Institute for Occupational Safety and Health (NIOSH) are excellent sources. One often-cited example from NIOSH is the Hierarchy of Controls. This hierarchy sorts control strategies from most effective to least effective. A common misconception is that PPE is the best method to control a hazard, but it is actually the least effective method. Eliminating the hazard from the workplace entirely is the best option, yet this step is often overlooked. You can’t eliminate every hazard, but the closer you get to the top of the hierarchy, the nearer you are to the ideal that makes the workplace as safe as possible. U.S. Water’s maintenance team has completed many projects to address safety concerns, such as installation of controls to limit exposure to chemicals, machine guarding, ventilation systems, and installation of safety features. This concept was the basis for a recent maintenance project to address a significant safety hazard at one of our client’s wastewater treatment plants.
Below is a list of some critical health & safety measures that plant owners are responsible for and should have in place to ensure the safety and well-being of those who work in their plants:
- Site evacuation plan and muster point
- Site spill contingency plan
- Safety orientation training for site staff
- Site-specific documentation (e.g., applicable Material Safety Data Sheets [MSDS] and Safety Data Sheets [SDS])
Most plant owners have one or more environmental permits governing activities at their site. Along with specific discharge limits, environmental permits also require plant owners to provide adequate capital funding to maintain the plant in good working order to ensure permit compliance. U.S. Water understands the importance of compliance in our client’s facilities. Our environmental/contractual compliance record is > 99.98% compliant with all key performance indicators.
Plant owners who have a State Pollutant Discharge Elimination System (SPDES) or Significant Industrial User (SIU) permit are responsible for the following:
- Communicating permit non-compliance to regulating authorities.
- Maintaining a sufficient budget to operate the facility in compliance with all permits.
- Ensuring permits do not expire.
- Communicating permit modifications (e.g., more frequent sampling or more stringent requirements) with their partners.
- Addressing communications from regulatory agencies.
- Providing the means for obtaining certified analytical results that confirm permit compliance.
- Paying any fines and penalties if there is non-compliance.
Maintenance is a critical component for maintaining and protecting your facility assets. U.S. Water recommends that our clients adopt a proactive, preventative maintenance approach versus being reactive, as it is typically much more costly to address unforeseen issues. When performed correctly, preventative maintenance increases equipment service life; maintains equipment warranties; improves operational efficiency; reduces energy costs; minimizes downtime due to unscheduled repairs; improves safety; minimizes costly major equipment repair and replacement; and maintains overall site aesthetics. When emergency situations occur or when unplanned repairs are required, a timely and effective response is required. U.S. Water maintains a staff of skilled maintenance technicians and craftsman that can travel nationwide to perform maintenance activities wherever needed.
At a minimum, plant owners are responsible for having a solid maintenance plan that includes these items:
- A means to safely access equipment so routine maintenance can be performed.
- Manufacturer operation and maintenance manuals.
- Specialty tools required to perform maintenance.
- A relationship with skilled subcontractors to perform specialized maintenance when needed.
- Adequate storage and inventory of spare parts and consumables (e.g., bearing oils, motor greases, bearing greases, air filters, oil filters, gaskets, O-rings, penetrating oils, bearings, oil seals, mechanical seals, drive belts, motor couplings, etc.).
- Utilities, including electricity, potable water, and sanitary services that support maintenance and repair activities.
- A legal means to dispose of hazardous waste.
A solid communication plan is imperative for successful plant operations. A site document that clearly lays out a communication plan, including lines of communication, contact information, and areas of responsibility, will go a long way to ensure smooth operations in normal operations, reduce confusion, and improve response times when an emergency situation arises. A communications plan is also a valuable reference for newly onboarded members of the project team.
U.S. Water’s project managers collaborate with site owners to develop communication plans and ensure they are in use at your sites. At a minimum, the site communication plan should:
- Designate responsible personnel along with contact information for each operations area, including permit compliance, safety, maintenance/emergency repair, waste disposal, procurement, spills/emergency, security, after-hours, and budget/change orders.
- Establish clear lines of communication and responsibility through a site organization chart.
- Establish communication procedures (e.g., verbal, e-mail, written report, etc.).
Reliable professional service providers are critical for successfully operating a wastewater treatment plant. From emergency repairs and specialty trade crafts to laboratory and security services and everything in between, plant owners should maintain relationships with skilled service providers who can work at their site safely and effectively.
U.S. Water maintains relationships with national and local service providers. We vet our subcontractors’ safety performance and references and maintain long-term professional relationships in all areas required in water and wastewater treatment facilities. Examples of professional service providers that your site might require include:
- Forklift service
- Fire suppression systems
- Tank inspections
- Mechanical, electrical, and HVAC service
- Site security and alarm
- Environmental services
- Air compressor maintenance
- Analytical testing laboratory
- Chemical supply vendors
- Uniform service
- Site-specific equipment vendors
- Landscaping, lawncare, and snow removal
- Waste disposal
- Emergency clean-up services
- Specialty maintenance contractors
- Engineering and facility design support
A vast and diverse responsibility
Being a plant owner is a big responsibility with many critical tasks. U.S. Water can leverage our extensive experience to help owners fulfill their responsibilities using a partnering approach that includes guidance, mentoring, and collaboration. Please contact us if you have any questions or concerns about plant owner responsibilities.