Planning
Know your Options ?
If your business will or now generates an industrial water (a regulated substance),
are you addressing compliance with these associated regulations with the
ongoing goal of obtaining the most favorable impact on your bottomline ?
If you are not taking the initiative understand the available options and consequences,
are you ready to accept the eventual option selected by the regulating agency ?
If you make a business decision that directly or indirectly changes the quantity and/or quality of
industrial water,
are you aware of the concurrent changes in options for industrial water management ?
Major industries and commercial activities typically have regulatory staff to identify, review, and select options that are favorable to their bottomlines. However, most smaller businesses spend minimal time addressing these options and, unfortunately, can find themselves boxed into a regulatory option with severe financial costs. Projects can be delayed, with labor on stand-by for days or weeks, until a minor or inexpensive industrial-water permit is obtained. Similarly, projects may be faced with extensive analytical requirements for industrial waters when some preliminary analyses may have reduced this substantial compliance cost to a more reasonable amount.
As presented below, decisions during the Planning and Design Phase and during the Operations Phase of an industrial or commercial activity can have serious impacts on the available options for handling of industrial water.
Planning and Design Phase
This phase involves decisions on site selection, facility design, and operations. Each type of decision-making effectively reduces the regulatory options available for industrial water management and in some instances earlier decisions preclude feasibility of options normally considered during later decisions. These options include options for disposal and for recycling, with the latter providing opportunity to generate additional revenue.
As the proposed project moves through construction and towards the Operations Phase, management efforts need to confirm as the regulatory options decrease (see curve in chart) the remaining available options continue to be acceptable to the business.
An example of being boxed into a regulatory option is provided below which includes a favorable outcome.
- A major industry was to be located on the edge of an urban area and planned on sending their industrial water, under a pretreatment permit, to the nearest wastewater treatment works. The economics of the plant changed and the cost of this option would impact the feasibility of the plant. Fortunately, an arrangement was worked out with an adjacent agricultural activity that could use the industrial water under certain conditions on a seasonal basis.
Operations Phase
Once industrial water is being generated during the Operations Phase, there is still a need to be aware of changes in the above options. For example, sources of such changes could include:
- changes in regulations, policies, practices of regulating agencies
- changes to onsite industrial/commercial activities
- changes in adjoining land-uses
- increased knowledge of industrial water gained during monitoring and compliance activities
A common perspective in the private sector is try to acquire the most favorable permit and then avoid making any changes during the 5-year term of the permit. Concurrently, the regulatory agency supports this approach since additional work is avoided, although agencies are supposed to update permits whenever regulations change. In many instances, a wise business practice would be to amend the permit to take advantage of favorable regulatory or other changes before the end of the 5-year period.
A new emerging perspective is to be attentive to options for converting the industrial water from a liability to an asset through exploring and pursuing recycling opportunities. These opportunities could supported by changes in operations that would increase the suitability of the industrial water for recycling.