GUIDELINES FOR WATER RECYCLING IN COMMERCIAL CAR WASH FACILITIES

Transcription

1 GUIDELINES FOR WATER RECYCLING IN COMMERCIAL CAR WASH FACILITIES AUSTRALIAN CAR WASH ASSOCIATION August 2009

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3 Australian Car Wash Association All rights reserved. No part of the material presented in this document may be used or reproduced in any form or by any means whatsoever without prior written permission from ACWA.

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5 TABLE OF CONTENTS 1 Introduction Structure of the Guidelines Scope of the Guidelines Drivers for Car Wash Water Recycling Definitions Used in the Guidelines Regulatory Framework Risk Management Introduction Elements of the Risk Management Plan Supporting Requirements of the RMP Source Water Treatment Systems Waste Water Storage Monitoring and Performance Risk Analysis Appendices Appendix A Risk Management Template Introduction Site Details Recycling System Details Critical Control Points Operation and Maintenance Plan Incident Reporting Training Requirements Appendix B Sampling Procedures i

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7 1 INTRODUCTION Water scarcity has forced industries across the country to reduce water usage, and the recycling of water by the commercial car wash industry has resulted in significantly less reliance on potable water. The car wash industry and its regulators are keen to maximise the use of recycled water as a potable water replacement for washing cars, and have previously developed a car wash water rating scheme to help measure the use of potable water. These guidelines are designed to assist in covering the management of public and employee health risks associated with on-site recycling of car wash water, through a risk management approach. 1.1 Structure of the Guidelines These guidelines consist of the following sections relating to best practice in managing health risks from recycling car wash water: - an introductory section on the guidelines; - some background on the regulatory requirements for recycling water; - the regulatory requirements behind water recycling in Australia; - information on risk management for recycling car wash water; - information on monitoring and performance outcomes of water recycling systems; and - appendices containing a risk management plan template and a sampling guide. 1.2 Scope of the Guidelines These guidelines are particularly targeted towards car wash owners, water recycling manufacturers, workplace health and safety regulators and health authorities. They are intended to meet the following criteria: - inform car wash owners of potential risks with on-site water recycling and provide information to assist them through the system selection process; - suitable for use by non-experts in water recycling; - supportive of sustainability through achievable water savings; - practical and pragmatic; and - based on scientific evidence in relation to water quality and public health protection. 1.3 Drivers for Car Wash Water Recycling Water scarcity has encouraged all Australians to reduce water use. The car wash industry and government regulators across various states have been working together to reduce the use of potable water for washing cars. These guidelines are the result of a project initiated by the Australian Car Wash Association (ACWA) to evaluate recycling systems for the vehicle cleaning industry. The project was funded 1

8 by the Victorian Smart Water Fund that was set up to encourage and support water recycling and water saving projects within the community. The project examined the performance of water recycling technologies at a range of sites across Australia; evaluating the amount of water recycled, and the quality of the water produced. The project included sampling and analysis of source and recycled water quality as well as data collection on management practices at a range of car wash sites across Victoria, NSW and Queensland. The aim of the project was to allow car wash businesses to invest more confidently in water recycling equipment as well as providing information for government regulators. This should result in further water recycling by the car wash industry, and further reductions in the use of potable water for washing cars. 1.4 Definitions Used in the Guidelines The following definitions are used in the guidelines: Auto Bay: BOD Combined Feed: Car washing bay where the driver does not get out of their vehicle. This includes stationary automatic bays as well as tunnel wash bays. Biological oxygen demand is a measure of the organic content of a wastewater that can to be broken down microbiologically, usually over a 5 day digestion. Source water that is drawn from both auto bay/s and self serve bay/s. E. coli: Bacteria that is commonly found in the lower intestine of warm blooded organisms. E. coli is commonly used as an indicator organism to test water samples for faecal contamination. Pathogen: Potable Water: Self Serve Bay: Source Water: Treated Water: A biological agent that causes disease or illness to its host. Water that is of sufficiently high quality that it can be consumed or used without the risk of immediate or long term harm (drinking water). Car washing bay where the driver parks their vehicle and uses hand held hoses and brushes to clean their car. This includes the use of portable hand held pressure washing devices. The portion of the water that is collected post car washing that is used as feed to the water recycling system. Water that is collected but not treated (directed to sewer) is not considered source water. Water that has been treated by the recycling system and subsequently shows characteristics that are different to that of the source water. 2

9 2 REGULATORY FRAMEWORK The use of recycled water at workplaces is governed by a number of Guidelines, Acts and Regulations. The following section lists the various national and state documents associated with the management of recycled water schemes. NATIONAL - Australian Guidelines for Water Recycling: Managing Health and Environmental Risks (Phase 1) (2008) - Guidelines for Sewerage Systems - Use of Reclaimed Water (1999) Australian Capital Territory - ACT Occupational Health and Safety Act 1989 and associated regulations - ACT Environmental Health Wastewater Reuse Guidelines (1997) New South Wales - Occupational Health and Safety Act 2000 and associated regulations Northern Territory - Workplace Health and Safety Act Workers Rehabilitation and Compensation Act 2008 and associated regulations Queensland - Workplace Health & Safety Act 1995 and associated regulations - Guide to the workplace use of non-potable water including recycled waters (2007) South Australia - Occupational Health, Safety and Welfare Act 1986 and associated regulations - South Australian Reclaimed Water Guidelines (1999) - Recycled Water Plumbing Guide (2006) Tasmania - Workplace Health and Safety Act Workers Rehabilitation and Compensation Act 1988 and associated regulations - Environmental Guidelines for the Use of Recycled Water in Tasmania (2002) Victoria - Occupational Health and Safety Act 2004 and associated regulations - Industrial Water Reuse Guidelines (2008) - Use of Reclaimed Water - Guidelines for Environmental Management (2003) Western Australia - Occupational Safety and Health Act 1984 and associated regulations 3

10 3 RISK MANAGEMENT 3.1 Introduction Best practice management of water recycling schemes requires the application of a risk management approach. This is in line with the Australian Guidelines for Water Recycling (2008), and the approach to managing occupational health and safety risks in Australia. Preliminary research in the car washing industry indicated that there were vast differences in the way that each site was operated and maintained, therefore best practice management of on-site car wash water recycling systems requires the development of a site-specific risk management plan (RMP). The RMP must set out the risks that are to be managed, how these risks are controlled and the monitoring activities and procedures that will be undertaken to measure the performance of these controls. A comprehensive hazard analysis and critical control point (HACCP) analysis was conducted on variously configured car wash recycling water treatment systems. This risk assessment was used to develop a RMP template. The RMP template was designed to be used by car wash owners / managers and system manufacturers to form a site specific RMP. The RMP template is contained in Appendix A of this document. The template is neither exhaustive nor prescriptive. For example: - additional risks and critical control points may be identified when new or updated systems come into the marketplace that are not covered in the RMP template in its current form. These should be addressed via an addendum to the template; and - car wash sites may choose to go beyond the scope of the RMP template in its current form and manage additional risks and implement additional controls. If the RMP template is implemented at car wash sites, and appropriate actions taken where the need is identified, then the major risks identified with on-site water recycling will be more adequately managed. 3.2 Elements of the Risk Management Plan The RMP template is designed as a questionnaire where the site owner / manager is prompted to fill in specific details about their water recycling system and risk management practices to develop a site specific RMP. There are specific details in the actual template, providing guidance on its completion however some general discussion on the various elements contained are presented in the following sections Site Characterisation General information about the site and its employees and specific system details including a block diagram and contact details of system representatives will be recorded in this section. The block diagram should show and label the areas from where source water is drawn and treated water is stored and used. 4

11 3.2.2 Critical Control Points A range of critical control points were identified in a HACCP analysis on a range of different systems. Each critical control point is designated a section in the template, which through a series of questions and prompts, aims to help the site management self-determine whether or not they have adequate controls in place for particular risks. In general, if Yes is answered to all questions in each applicable section, then adequate risk management measures are thought to be in place. If No is answered, then it is thought that the risk is not adequately managed, unless alternative risk management measures can be identified and documented in the Risk Management Details column where prompted. Again, more detailed guidance on the completion of this section is contained in the actual template in Appendix A Operation and Maintenance Plan This section will contain all the operational requirements of on-site car wash staff. This includes start-up, normal operating, shut down and emergency shut down procedures. If there are separate documents that outline these standard operating procedures, then they can be referenced in this section, providing the documents are held on-site and readily accessible to staff. Such operational procedures might include monitoring and replacing chlorine drums, monitoring pressure gauges, checking treated water for disinfectant residual etc. Routine maintenance that is to be carried out by on-site staff should also be documented in this section. This might include such things as replacing filters, cleaning solids traps, cleaning process tanks etc. Major, more specific maintenance requirements carried out by system representatives need not be included as the RMP is designed to manage day-to-day risks on an operational basis Incident Reporting This section is an acknowledgement that proper incident reporting practices with regards to the water recycling system are undertaken and records are kept on-site. Such incidents that might warrant reporting could include equipment failure, unusual odours observed from treated water, treated water quality complaints and any other unusual observations associated with the recycling system Training Training requirements for operational staff should be conducted by a system representative and should include a formal introduction to the system. Once completed, the site specific RMP should also provide a good training tool, and as such it is also recommended that all staff read and sign the RMP so as to be fully aware of the risks and management practices that are in place, as well as what is required of them on a day-to-day basis. Training should be kept current through updates and developments in the recycling system. 5

12 3.3 Supporting Requirements of the RMP Additional documentation that could support the RMP includes: - map of the site showing areas where treated water is collected, stored and used; - detailed operations and maintenance manuals, standard operating procedures, supplier warranties and any other relevant documentation describing the treatment system and its components and their capabilities. These are of particular importance if the RMP references these documents with regards to the operations and maintenance plan; and - materials safety data sheets and other relevant documentation that describes the chemicals used and their specifications. 3.4 Source Water The major hazards found in car wash water are: - pathogens; - high suspended solids & turbidity; - chemicals from foreign dumping and from wash detergents; and - high BOD (or organic content). The data collected on source water during preliminary research is shown in Table 1. Table 1 Indicative Source Water Characteristics Auto Only Combined Feed Parameter Units Average Range Average Range E. coli org/100ml 1, ,000 9, ,000 ph ph units Total Organic Carbon mg/l Turbidity NTU E. coli and ph data are based on 62 samples for auto systems, and 30 samples for combined feed systems. Total organic carbon and turbidity data based on 21 samples for auto systems and 11 for combined. The results clearly show that for every parameter (except ph), the average concentration of contaminants was greater for combined feed source water than source water from auto bay/s only. This trend was particularly pronounced with regards to E. coli concentrations, with the average for auto only source water 1,300 org/100ml and for a combined feed 9,300 org/100ml. The higher instances of very dirty / muddy vehicles that go through self serve bay/s compared to auto bays could potentially increase the turbidity and suspended solids of the source water. Cleaning of some recreational and commercial vehicles (e.g. horse floats) may also contribute to higher loads of solids and organic content. This may also present higher pathogen risks. It is also more difficult to control foreign dumping in the self serve bay/s so the risk of having chemicals or other foreign materials dumped in the self serve bay/s is higher. 6

13 For these reasons there is more risk involved with recycling water from a combined feed than from the auto bay only. If a combined source water is to be recycled, then there are measures to reduce the risks associated with this. These are all addressed in the RMP template, and include: - signage prohibiting the washing of animal trailers and any foreign dumping in bays that contribute to the source water; - site supervision during operating hours; - surveillance; and - effective solids traps that are properly maintained in car washing bays. These measures are not 100% reliable, so even if they are implemented, the risks associated with recycling a combined feed source water are still considered greater. 3.5 Treatment Systems In general terms, treatment processes should be able to deliver the following objectives: - removal of pathogens; - removal of solids and turbidity; - stabilisation of ph; - reduction of odour potential. 7

14 Table 2 below displays a range of system configurations that were identified in the preliminary studies. Table 2 - Treatment System Configurations System A B C D E F1 F2 G H I J K1 K2 L System Configuration Coarse and fine filtration, chlorination Flocculation, clarification, filtration, and chlorination Flocculation, clarification and filtration with chlorine and ozone disinfection Electroflocculation, media, bag, membrane and activated carbon filtration with chlorination Aeration and bioreactor Hydrocyclone and aeration Hydrocyclone, aeration, ozone and bag filtration Filtration, hydrocyclone and ozonation Filtration and aeration Hydrocyclone, biobed, filtration and ozonation Hydocyclone, filtration, and ozonation Filtration and chemical dosing Hydrocyclone, UV and aeration Aeration, chlorination, flocculation, clarification, filtration and chlorination 8

15 Table 3 contains definitions of the generic unit processes that form the treatment system configurations. Table 3 - Definitions of Treatment Unit Processes Unit Process Biobed Bioreactor Chlorination Clarification Electroflocculation Filtration Flocculation Hydrocyclone Ozonation UV Definition A stationary microbiologically active bed over which the water stream passes for treatment Vessel that supports a biologically active environment Use of chlorine for microbiological disinfection Solids settling Use of an electric current to form larger particles that will settle out more easily Solids separation using filter barriers which can include media filter (sand etc), cartridge filter, bag filter, membrane filter etc. Addition of chemicals to cause particles to agglomerate and settle out more easily A solids separation process using centrifugal forces which is reliant on the density of the particles in the liquid Use of ozone for microbiological disinfection and organic compound oxidation Ultraviolet radiation used for disinfection Indicative performances observed during the preliminary investigation are shown in Table 4 in terms of the percentage removals of E. coli and turbidity. Table 4 Indicative System Performances Parameter Average Range E. coli Removal 57% % Turbidity Removal 39% 0 98% E. coli data is based on 92 samples and turbidity data is based on 32 samples. 9

16 Table 5 shows the statistics obtained on final effluent quality during the preliminary studies. Table 5 Indicative Final Effluent Characteristics Parameter Units Average Range E. coli org/100ml ,000 ph ph units Turbidity NTU BOD mg/l Suspended Solids mg/l The results show a large variability in systems ability to remove E. coli and turbidity and also a very large variability in the quality of the final effluent. This highlights the huge variation in system performance which is due not only to the variations in system design, but also due to operations and maintenance differences between sites. The information displayed on source water quality (Table 1) and final effluent quality (Table 5) demonstrate that E. coli could be found at high concentrations in both source and treated waters. This reflects E. coli survival through recycling treatment processes in some cases, with the increase in risk that microbial pathogens present in the source water would also survive. The reduction in E. coli numbers between source and treated waters is an indication of disinfection by water recycling systems. The research also showed a strong correlation between high BOD and suspended solids and high E. coli concentrations in the final effluent, particularly when chlorine was used as a disinfectant. This indicates that if a system is able to remove BOD and suspended solids, then providing its disinfection stage is operating adequately, the risk of pathogens should be reduced. Microbial re-growth was also identified as a potential issue associated with car wash water recycling. This is primarily a problem with water stored after treatment, which can allow microbes (including some pathogens) to grow. This can be measured using the Heterotrophic Plate Count (HPC) test, which counts a wide range of microbes. If stored water contains a residual of disinfectant such as chlorine, the risk of re-growth is reduced. If treated water is stored in a tank prior to use and a disinfectant residual cannot be maintained (as is the case with some treatment processes such as filtration, UV irradiation or ozonation) then the risk of regrowth is increased. For such systems, re-growth risk can be reduced by continuous recirculation through the treatment process. If a residual is present but the tank contains slime and other material which can protect microorganisms from disinfectants, then the risk of regrowth also increases. For further information around controlling microbial re-growth, the Legionella Guidelines, which are available to members of ACWA via the ACWA website should be consulted. 10

17 With all of this in mind, the recycling system should be able to perform a range of functions to ensure that coupled with best management practices, recycling water risks are kept to a minimum. Below are a range of questions that should be asked of the recycling system manufacturer prior to purchase to assess their system. following on from the questions (in italic print) is further clarification on why the questions are of importance: 1. Does the system incorporate a disinfection stage? Car wash water recycling systems should have some form of microbial disinfection. 2. Is treated water stored prior to use or is it continually recirculated without any final storage? If it is stored, is a disinfectant residual maintained in the final storage tank to reduce the risk of microbial re-growth? If treated water is stored post treatment before being used in the car wash bay, there should be some way for a disinfection residual to be maintained in the storage tank. 3. Does the system incorporate any monitoring equipment and/or alarms to help assess disinfection performance? If not, how is disinfection performance monitored? There should be some way for the disinfection performance to be measured and recorded (i.e. periodic measurements of free chlorine, periodic measurement of microbial concentration etc) 4. Are there any alarms to indicate failure of the disinfection process? Alarms that signal a failure of the disinfection process mean that the problem can be attended to quickly, rather than the failure going unnoticed for extended periods. Alarms might be in the form of a light on a control panel indicating low-level chlorine, or indicating that the ozone system has failed etc. 5. Does the system utilise any online turbidity monitoring to indicate that there is a shock load, or one of the system barriers has failed (filters etc)? This could also be beneficial for early detection of process failure. 6. Does the system have processes that remove BOD, suspended solids and turbidity? Is there any monitoring data to prove this? Car wash water recycling systems should incorporate processes that are proven in the removal of these parameters. 7. Does the system have ph correction? How does it maintain a safe and workable ph in the final effluent given the varying input ph s from car wash chemicals? ph in the final effluent should be able to be maintained at acceptable levels (see Table 6). 3.6 Waste Water Storage As was identified above, microbial re-growth is a factor that needs consideration when deciding on a system configuration. Microbial re-growth is an issue associated with the degradation of stored water, and odour can be another factor that results from this. Waste water degradation depends on a range of factors, including: - temperature degradation occurs more rapidly at increased temperatures; - length of storage obviously degradation increases with increased retention time; - solids accumulation; and 11

18 - disinfection residual (as mentioned earlier). Stored water degradation needs particular attention in the case of stored final effluent degradation, however stored wastewater (prior to treatment) can be a concern, particularly with respect to odour. It is important that these factors are properly understood, and that the recycling system is designed and operated to adequately manage these risks. 3.7 Monitoring and Performance While there is an emphasis on risk management and operations and maintenance through implementation of a RMP, there is some testing that can be undertaken to verify system performance. Best practice suggests that 3 5 samples at weekly intervals be taken of both the source water and final effluent during system commissioning. After that, 6 monthly one-off sampling events should take place for verification purposes. If any changes occur in the system or process configuration (additional process equipment installed or source water origin changed to take in more or less bays), or there are unusual occurrences observed (increased odour, noticeably dirtier water etc) best practice would suggest that one-off samples be taken for verification purposes. Records of monitoring should be kept and every sampling event should be compared to previous results for consistency. Dramatically inconsistent results can indicate some failure in the treatment system and should prompt a response which might include a review of the RMP and operations and maintenance procedures, additional verification testing or both Water Quality Guidelines Table 6 below shows the parameters that should be tested in line with the best practice guidelines and an interpretation as to what the results should suggest. Non-mandatory indicative water quality guidelines are given for E. coli, suspended solids, BOD and ph. The values of 30 mg/l for suspended solids, 20 mg/l for BOD and 10 org/100ml for E. coli come from the Code of Practice for Onsite Wastewater Management (EPA publication 819.2), and is the treated water quality standard that is considered suitable for recycling outdoors via subsurface or surface irrigation. The guidelines given are best practice guidelines and systems that are able to demonstrate performance in line with these guidelines are thought to be performing to best practice standards. 12

19 Table 6 - Analysis Parameters and Results Interpretation Analyte Source Water Final Effluent Interpretation Guide Water Quality Guidelines E. coli Yes Yes There should be a reduction in E. coli between source water and final effluent to demonstrate effective disinfection. 92% Reduction * &/or target effluent concentration of 10 org/100ml Heterotrophic Plate Count (HPC) Yes Yes There should be a reduction in HPC between the source water and final effluent. Higher HPC in final effluent can indicate microbial re-growth through the treatment system. - Free Chlorine Residual - Yes A positive chorine residual should be observed in final effluent if chlorine is used as a disinfectant Target effluent concentration of greater than 0.1 mg/l if chlorine is used as a disinfectant Turbidity Yes Yes There should be a reduction in turbidity between source water and final effluent - Suspended Solids Yes Yes There should be a reduction in suspended solids between source water and final effluent Target effluent concentration of 30mg/L. Biological Oxygen Demand Yes Yes There should be a reduction in BOD between source water and final effluent Target effluent concentration of 20mg/L. ph Yes Yes ph should be stable and close to neutral through the treatment process Target in effluent of The equation below should be used to calculate the percentage removal of E. coli to assess whether 92% removal occurs. % E. coli Removal = 100 [(Final effluent 100) Source water] I.e. if the source water E. coli concentration is 250 org/100ml and the final effluent E. coli concentration is 9 org/100ml: % E. coli Removal = 100 [(9 100) 250] = 96% * It may be that the source water E. coli concentration is too low for 92% removal to be achieved. There should still be a reduction in E. coli between source water and final effluent (as per the interpretation guide) if this is the case. 13

20 Appendix B outlines detailed sampling procedures that should be followed prior to and during sampling events Sampling Points Careful consideration needs to be taken when determining both the source water and final effluent sampling points. Sampling ports (in the form of taps) are recommended as they ensure that the sample is well mixed and more representative than simply taking a grab sample from a tank or pit. As such, best practice management would involve sampling from suitably located ports rather than tanks or pits. The suitability of sampling ports located at different locations along the treatment train is discussed below. Figure 1 - Treatment Train Example (SP = Sampling Port) 14

21 Table 7 - Suitability of Sampling Points in Figure 1 Sample Type Sample Point Suitability Source Water Final Effluent Wash Bay Pit Sampling Port 1 (SP1) Sampling Port 2 (SP2) Sampling Port 3 (SP3) Sampling Port 4 (SP4) Wash Bay Jets Not recommended as it is difficult to get a homogenous sample. SP1 is positioned before the recirculation stream rejoins the source water stream. Sampling from SP1 gives the characteristics of the source water before it is diluted with treated water. SP2 is positioned after the recirculation stream rejoins the source water stream. Sampling from SP2 is suitable to know exactly what strength the treatment process is treating. SP3 is positioned after treatment but prior to final effluent storage. Sampling from SP3 is suitable to determine exactly what the treatment process is achieving, ignoring the effect of possible microbial re-growth in final product storage. SP4 is located after final effluent storage. Sampling from SP4 is the most representative sample of final use recycled water. Especially useful to sample for microbiology to examine the possibility of re-growth and the potential pathogen risk at end use. Not recommended. Often recycled water makes up only a few cycles of the overall car washing process, with fresh water making up the rest of the cycle. The chances of fresh water contaminating the recycled water sample are considered too great and chemicals used in the wash may also affect the sample. 3.8 Risk Analysis This section is designed to guide the user through a basic risk analysis of new car wash installations prior to the selection of water recycling equipment. It should be carried out prior to asking manufacturers the questions detailed in Section 3.5 as a guide as to how robust the system might need to be, given the comparative level of risk involved with their proposed recycling and management options. 15

22 Table 8 - Risk Analysis Risk level Source water origin Wash bay characteristics where final effluent will be used Employees or customer exposure to treated water Site supervision during operating hours Stored final effluent post treatment 1 Auto bay/s only Closed off No person in the bay during wash cycle Constant No 2 Combined feed Open to the environment Employees or customers in the bay during wash cycle Not constant Yes Risk Rating (1 or 2) Overall Risk Rating (5 10) The new owner should make a selection from each column depending on how they propose to manage their water recycling system. Each characteristic is assigned a risk rating of either 1 or 2. The sum of these equates to the overall risk rating of the proposed recycling scheme of between 5 and 10, 5 representing lower risk, and 10 representing higher risk. The higher the overall risk rating, the more robust the water treatment system needs to be. 16

23 4 APPENDICES 17

24 Appendix A Risk Management Template Introduction A comprehensive risk assessment, using the principles of hazard analysis and critical control point (HACCP) was conducted a range of water treatment systems specifically designed for car washing. All critical control points that were identified across all system types have been included in this Risk Management Plan (RMP). It should be noted that this RMP is applied to the water recycling system only. It does not apply to the actual car washing equipment at all. The RMP is designed to allow car wash operators that use a water treatment system to forsee risks associated with using the system and to ensure that they have adequate responses in place to mitigate these risks. It also specifies the operation and maintenance that is required by on-site staff, incident reporting and training requirements with regards to the recycling system. It is designed to not only ensure that the site has adequate risk responses, but also that these responses are documented and that all staff have access to them. The site owner / manager, in conjunction with the recycling system manufacturer / supplier should go through this template and fill out the applicable sections to create their site-specific Water Recycling Risk Management Plan. It should be kept on-site for reference and be made available to all staff for training purposes. 18

25 Site Details Record Business name Your details Site location (property address) Site owner Site manager Other employees Person Responsible for the recycling system Backup Person Responsible for the recycling system Recycling System Details Water Recycling System Block Diagram Sampling points for source water and final effluent should be identified on the block diagram. 19

26 System details Water recycling system supplier Water recycling system supplier contact details (include contact persons name and business and after hours telephone number) Water recycling system supplier secondary contact details (include the same information for the secondary contact in the event that the primary contact is unreachable) if applicable Source water origin (is water recycled from the auto bays, self serve bays, both or from other origins. If other, specify) Treated water final use (is treated water used in the auto bays, self serve bays, both or other areas. If other, specify) Who is responsible for day-to-day operation of the recycling system? (Include company name, contact person s business and after hours telephone numbers) Major system technologies (including filtration, flocculation, sedimentation, hydrocyclone separation etc) Mode/s of disinfection (if any) 20

27 Critical Control Points Section 3 contains all of the major critical control points that were identified in a risk assessment of 13 system configurations. As new technologies come into the market, new critical control points will arise. The subsections need to be updated to include any critical control points that might be identified as part of a system and are not contained in this section. How to Complete This Section Work your way through each of the following sections, identifying which critical control points apply to your water recycling system. If your system does not incorporate a particular critical control point, tick the box labeled No and move onto the next critical control point. If you system does incorporate a particular critical control point, tick the box labeled Yes and proceed with all the following questions in that subsection. If you answer Yes to any questions relating to the critical control points, it generally means that you have adequate risk management measures in place. Provide details where prompted and move on to the next question. If you answer No to any questions, you may not have adequate risk management measures in place. If you answer No, but it is deemed that you are in fact adequately addressing the risk in question through other measures, then write down in the Risk Management Details column the measures that you have in place for this. If it is deemed that you do not have adequate measures in place for the particular scenario, then state this and in the same space, state how you will endeavor to implement adequate risk management measures. This may involve staff training, investment in monitoring or other supporting equipment or simply better housekeeping procedures. So this section can be used as a check list to assess how well the recycling system is operated and maintained. If Yes is answered to all questions, then the major risks associated with the system should be adequately managed. If No is answered to any questions, there may still be adequate risk management measures in place through other measures, or it may be determined that there are inadequate risk management measures in place. 21

28 Bag Filters Hazards Associated with Bag Filters Assessment of Management of Risks Associated with Bag Filter Does your system incorporate bag filtration? (if yes, continue with this section) (if no, move on to next section) Does you bag filter/s have any alarms in place? Risk Management Details If yes, what triggers the alarm? If no, what measures are in place to identify bag failure and to determine when to replace bags? Carry over of solids and carry over of pathogens Are all staff trained in maintaining bag filters? If no, what measures are in place in the case of bag filter failure in the presence of an untrained operator? Is this adequate? How often are bag filters replaced? If no, how will you manage the risk of bag filter failure? Is regular inspection of your bag filters part of your maintenance program? Other issues associated with bag filters? 22

29 Flow Through Process Tanks Flow-through tanks are any tanks or pits found in the treatment train, except final holding tanks. Hazards Associated with Flowthrough Process Tanks Pathogen survival (lack of disinfection) Assessment of Management of Risks Associated with Flow-through Process Tanks Does your system incorporate any flowthrough process tanks? (if yes, continue with this section) (if no, move on to next section) Does your system incorporate disinfection? Risk Management Details If no, how will you address the risk of pathogen growth through the treatment system? If no, how often will the insides of all process tanks be inspected and cleaned to avoid excessive slime build up? How often are the insides of process tanks inspected for cleanliness? Does this appear adequate to avoid excessive slime build-up? Carry over of pathogens If no, how will you address the risk of pathogen growth in storage tanks when system is shut down or idle? Are process tanks drained when system is shut down or idle for extended periods of time? Other issues associated with holding / storage tanks 23

30 Final Product Storage Tank Hazards Associated with Final Storage Tanks Pathogen survival (lack of disinfection) Assessment of Management of Risks Associated with Final Storage Tanks Does your system incorporate any final effluent storage tanks? (if yes, continue with this section) (if no, move on to next section) Does your system incorporate disinfection? Risk Management Details If no, how will you address the risk of pathogen growth in the final storage tank? If no, how will you address the risk of low chlorine residual? Does your system have a free chlorine analyser on the final holding tank? N/A (chlorine not used) What is it? Do you have a threshold for free chlorine residual in the final holding tank? N/A (chlorine not used) Low chlorine residual in final holding tank (if chlorine is used) Are there clearly defined maintenance procedures in the event of low chlorine residual? N/A (chlorine not used) If yes, describe. If no, how will you address the risk of inadequate response to low chlorine residual? Are all staff trained in detecting a low chlorine residual and administering these procedures? N/A (chlorine not used) If no, how will you address the risk of low chlorine residual occurrence under the supervision of an un-trained operator? Is ph measured? N/A (chlorine not used) If no, how will you address the risk of ph impacting on chlorine disinfection effectiveness? 24

31 Hazards Associated with Final Storage Tanks Assessment of Management of Risks Associated with Final Storage Tanks How often are the insides of final effluent storage tanks inspected for cleanliness? Does this appear adequate to avoid excessive slime build-up? Risk Management Details If no, how often will the insides of final storage tanks be inspected and cleaned to avoid excessive slime build up? If no, how will you address the risk of pathogen re-growth in final holding tank? Carry over of pathogens Is water from the final storage tank recirculated to avoid stagnation? Is the final storage tank drained when system is shut down or idle for extended periods of time? If no, how will you address the risk of pathogen growth in the final storage tank when system is shut down or idle? Other issues associated with final storage tanks 25

32 ph Adjustment Hazards Associated with ph Adjustment Assessment of Management of Risks Associated with ph Adjustment Does your system incorporate the addition of chemicals for ph adjustment? (if yes, continue with this section) (if no, follow the prompt in the Risk Management Details column and move on to next section) Risk Management Details How is a safe ph maintained throughout the treatment process and in the final effluent given the range of ph s of the chemicals used? If no, how will you address the risk of ph outside the optimum range (for flocculation / disinfection)? Does your system involve a ph analyser? What is it? Have you set a ph target range? ph too high or too low Are there clearly defined maintenance procedures in the event of high / low ph? If yes, describe. If no, how will you address the risk of ph outside the optimum range (for flocculation / disinfection)? Are all site operators trained in detecting high / low ph and administering these procedures? If no, how will you address the risk of ph outside the optimum range (for flocculation / disinfection)? Other issues associated with ph adjustment 26

33 UV Disinfection Hazards Associated with UV Assessment of Management of Risks Associated with UV Does your system incorporate UV disinfection? (if yes, continue with this section) (if no, move on to next section) Is your UV system serviced? If so, how frequently and by whom? Risk Management Details If no, how will you ensure the system is operating correctly and also if fouling of the UV lamps has been controlled? UV system failure Do you have an alarm on your UV system to indicate if it has failed? Are there clearly defined maintenance procedures in the event of UV system failure? Are all staff trained in detecting a failure and administering these procedures? Is water from the final holding tank recirculated to avoid stagnation? If no, how will you address the risk of UV system failure? If yes, describe. If no, how will you address the risk of inadequate response to UV system failure? If no, how will you address the risk of UV system failure occurrence under supervision of an un-trained operator? If no, how will you address the risk of pathogen re-growth in holding tanks? Carry over of pathogens Are tanks drained when system is shut down or idle for extended periods of time? Does your system have a turbidity analyser and alarm? If no, how will you address the risk of pathogen growth in holding tanks when system is shut down or idle (particularly final holding tank)? If no, how will you manage the risk of high turbidity negatively affecting UV disinfection performance? Does your system incorporate any other disinfection barrier in the event of a failure with the UV system? Other issues associated with UV disinfection 27

34 Chlorination Hazards Associated with Chlorination Assessment of Management of Risks Associated with Chlorination Does your system incorporate chlorination? (if yes, continue with this section) (if no, move on to next section) Risk Management Details If no, how will you address the risk of low chlorine residual? Does your system have a free chlorine analyser on the final holding tank? Low chlorine residual Are there clearly defined maintenance procedures in the event of low chlorine residual? If yes, describe. If no, how will you address the risk of inadequate response to low chlorine residual? Are all staff trained in detecting a low chlorine residual and administering these procedures? If no, how will you address the risk of low chlorine residual occurrence in the presence of an un-trained operator? If no, how will you address the risk of chlorine running out? Carry over of pathogens Does your chlorine dosing system have a low level alarm? Does your system have an alarm to alert when the chlorine dosing system fails? If no, how will you address the risk of chlorine dosing system failure? 28

35 Is water from the final holding tank recirculated to avoid stagnation? If no, how will you address the risk of pathogen re-growth in final holding tank? Does your system incorporate any other disinfection barrier in the event of a failure in the? Other issues associated with chlorination 29

36 Ozonation Hazards Associated with Ozonation Assessment of Management of Risks Associated with Ozonation Does your system incorporate ozonation? (if yes, continue with this section) (if no, move on to next section) Risk Management Details Ozone system maintenance How often is the ozone system serviced? Who services the system? Do you have an alarm on your ozone system to indicate when it has failed? If no, how will you address the risk of ozone system failure? Low ozone dose rate Are there clearly defined maintenance procedures in the event of ozone system failure? Are all staff trained in detecting ozone system failure and administering these procedures? Are you aware whether or not your ozone dosage rate has been optimised to perform the desired function (remove odour, pathogens etc)? Is water from the final holding tank recirculated to avoid stagnation? If yes, describe. If no, how will you address the risk of inadequate response to ozone system failure? If no, how will you address the risk of ozone system failure occurrence under supervision of an un-trained operator? If no, how will you address the risk of poor design in your ozone system? If no, how will you address the risk of pathogen re-growth in holding tanks? Carry over of pathogens Are tanks drained when system is shut down or idle for extended periods of time? If no, how will you address the risk of pathogen growth in holding tanks when system is shut down or idle (particularly final holding tank)? Does your system incorporate any other disinfection barrier? Other issues associated with ozonation 30

37 Sand Filtration Hazards Associated with Sand Filtration Assessment of Management of Risks Associated with Sand Filtration Does your system incorporate sand filtration? (if yes, continue with this section) (if no, move on to next section) Risk Management Details How frequently do you backwash the filter? What happens to the backwash effluent? High turbidity / solids / dissolved matter carried over Do you have any downstream analysis that might indicate that the filter is not operating properly? Are there clearly defined maintenance procedures for sand filter? If no, how will you address the risk of channelling in the sand filter? If yes, describe. If no, how will you address the risk of inadequate maintenance of sand filter? If no, how will you address the risk of sand filter failure in the presence of un-trained operators? Are all staff trained in administering these procedures? Other issues associated with sand filtration 31

38 Bioreactor Hazards Associated with Bioreactors Assessment of Management of Risks Associated with Bioreactors Does your system incorporate bioreactors? (if yes, continue with this section) (if no, move on to next section) Are there clearly defined maintenance procedures for bioreactor (nutrient dosing etc)? Risk Management Details If yes, describe. If no, how will you address the risk of die-off of treatment organisms due to lack of maintenance? Have all staff been trained in these procedures? If no, how will you address the risk of die-off of treatment organisms due to operator error? Pathogen Survival Does your system have a turbidity analyser and alarm downstream of the bioreactor? If no, how will you manage the risk of die-off of treatment organisms due to shock loads? Is a clearly defined start-up protocol implemented following a period of nonoperation? If yes, describe. If no, how will you manage the risk of treatment microorganisms die-off after a period of shutdown? If no, how will you address the risk of blower failure? Do you have an alarm to sound if blower fails? Other issues associated with bioreactor 32

39 Source Water Hazards Associated with Source Water Elevated Suspended Solids (SS) Elevated nutrients, chemicals, oil / petroleum products Assessment of Management of Risks Associated with Source Water Are solids traps maintained sufficiently to minimise the buildup of solids and subsequent elevation in SS in source water? Do you have signage to direct customers what not to dispose of in car wash bays from which water is recycled? Risk Management Details If yes, describe. If no, how will you manage the risk of high SS in source water? If no, how will you manage the risk of contaminants in your source water? Do you have signage to ensure animal trailers and others are not washed in self serve bays? N/A (water recycled from auto bay only) If no, how will you address the risk of faecal matter washed off vehicles? Pathogens Do you recycle wastewater from the dog wash? N/A (no dog wash on-site) If yes, how will you address the risk of the increase in pathogen load to your treatment system Other issues associated with source water 33

40 Recycled Water Supply Hazards Associated with Recycled Water Supply Assessment of Management of Risks Associated with Recycled Water Supply Risk Management Details If yes describe, If no, how will you address the risk of system not operating optimally? Are there clearly defined maintenance procedures for the recycle system? Odours, pathogens, soaps and wax residuals in recycled water Are all staff trained in administering these procedures? If no, how will you address the risk of system management in the presence of un-trained operator? If no, how will you address the risk of system malfunction? Are there alarms on the system to alert operator when something goes wrong? Other issues associated with recycled water supply 34