ENGINEERING

Discharges to a Sewer

Disposal of industrial wastes via a Publicly Owned Treatment Works (POTW) requires a permit. These wastes are often subject to effluent pretreatment, monitoring and reporting requirements. Modifications to a facility's operations may minimize the need for pretreatment resulting in cost savings. Bench scale testing (as pictured here) is another way to save money.

Surface Water Discharges

National Pollution Discharge Elimination System (NPDES) permits are required for surface water discharges. These permits must be renewed every five years. NPDES renewals can require an extensive amount of data and often raise new issues. Changes in receiving water body quality or concerns about thermal pollution may cause regulatory agencies to impose very stringent effluent limits. These restrictions can significantly affect your facility's production and operating costs. Through our experience with NPDES issues, we help our clients to develop an effective permitting strategy.

Solvent Control/Slug Prevention Programs

Clients who discharge process wastewater to a publicly owned treatment works (POTW) are often required to submit documentation detailing how a facility will prevent the discharge of slugs or handle the discharge of solvents to avoid damaging the POTW.

High Purity Water Systems

Irwin Engineers has experience in designing potable water, USP 24/25 water, WFI, and micro electronics grade water systems. We can work with the client to design a new system, to increase the capacity of an existing system, or to improve water quality in an existing system. In these instances, high purity water needs to be treated as a key feed stock to manufacturing.

We work with Owner/Operators to ensure that the risks inherent in handling chemicals are being properly handled.

Most often, we work with the client to implement or audit the implementation of OSHA's Process Safety Management regulation, which is intended to protect workers and the public from chemicals released in work place incidents. The chemicals may be flammable, corrosive, toxic, and/or reactive. The OSHA standard covers 13 listed areas of owner/operator responsibility in an integrated approach to managing the risk.

Irwin Engineers can assist the Owner/Operator in writing a Process Safety Management Program for his/her specific facility, choosing the appropriate Process Hazard Analysis (PHA) for the facility, leading/documenting the Process Hazard Analysis, and auditing Process Safety Management compliance.

For facilities covered by OSHA's PSM regulations, PHA's are required every five (5) years. For High Hazard Materials (HHM's), Owner/Operators often opt to hold a PHA every three (3) years.

REGULATORY DEADLINE - NOV. 10, 2011 FOR COMPLIANCE WITH NEW REGULATIONS

SPCC Plans are required for facilities with large amounts of oil¹ storage:

• Underground storage of 42,000 gallons or more; and/or
• Aboveground storage of more than 1,320 gallons total in containers of 55 gallons or more in capacity.

These plans must be approved by a Professional Engineer. The Plans contain descriptions of Good Engineering Practices for facility systems, procedures for avoiding spills and containment measures.
IRWIN adds value by conducting a detailed systems review for hazard assessment within the range of operating conditions and non-routine conditions. The assessment identifies key components that should be subject to regular preventative maintenance and/or testing. Spill pathway mapping and reporting protocols are also established.

IRWIN has developed an emergency Oil Spill Notification card for use in Massachusetts. Print it out for a handy reference.

SPCC Plans can also be part of a comprehensive Integrated Plan designed to address all aspects of Contingency Planning that apply to your facility.

Note 1 - According to the U. S. EPA, the term oil means oil of any kind or in any form, including, but not limited to: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils, including oil from seeds, nuts, fruits, or kernels; and other oils and greases, including synthetic oils and mineral oils.