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ELG Compliance: Cover Your Bases with a Comprehensive Implementation Plan

Turn Your Plan Into Action

This is the last post of a four part series on ELG Compliance

In previous posts I discussed the planning process—performing the data gathering studies, piloting the equipment, selecting the appropriate technology, and scheduling the project to meet your compliance deadlines. This series would not be complete, however, without a closer look at the implementation process — the construction, startup, and operation of your new wastewater treatment systems.

One issue we’ve seen quite a few power plants struggling with is selecting the best project delivery method. The chosen method can have a significant impact on the schedule, cost, and even the level of input on design and construction that your team will have. It’s important to evaluate the options thoroughly, and choose the best method given your team’s experience, your compliance schedule and your organization’s preferences.

There are several delivery options utilized today, and multiple variations of each add complexity when deciding which option is right for you.

  • A traditional design/bid/build (DBB) approach, one commonly utilized method, typically provides you the greatest amount of control over the entire process, including design input, technology vetting and selection, equipment provider selection and contractor selection. However, it also involves multiple contracts, requires more experience and team involvement on your end, and usually involves a longer schedule to completion.
  •  A design/build approach lessens the number of contracts (one primary entity/one contract/one point of responsibility), and will shorten the schedule time, but it also can limit your voice in the decision-making process for the project.
  • Design/build/operate/maintain (DBOM) contracts, where the contractor not only designs and builds the facility, but also operates and maintains the facility for a given period of time, is another option to consider, especially if your operations staff’s experience with the selected technologies is limited.

Making the choice can be a challenge, so be sure to sit down with someone familiar with each delivery option. It’s important to understand the implications of each option so you can negotiate a contract that provides what you are looking for and meets your schedule.

Another option to consider is whether you want to conduct a Front End Engineering Design (FEED) study before you move forward with the full implementation phase. You’ll need to consider the schedule implications of adding another step into the process, but this study can be valuable in helping you to better understand your investment costs and identify any technical fatal flaws.

Planning Around Challenges

Regardless of the delivery method, there are a couple of significant challenges nearly every plant will face as they work through the implementation process: space constraints, drawing and equipment lead times, and site traffic.

Space Constraints

If you’re situated on an older, constrained site, you might need to get creative to accommodate new equipment. For instance, if you’re closing a CCR pond to comply with the CCR regulation, you may be able to use the reclaimed space for your new equipment. Some sites are so confined, it requires careful planning using plant modeling tools to take everything into consideration and minimize operational interferences. It’s important to account for what’s already onsite, from current equipment to undergrounds to foundations, and come up with a solid plan to avoid existing piping and other utilities.

Drawing & Equipment Lead Times

Given the novelty and newness of these ELG compliance options, seldom will the equipment you choose be off-the-shelf, which means your technology provider has to create project specific drawings for your plant. If you are tight for space, the equipment supplier and engineer may need to do some additional customization of the design in order to make it fit into the available space. You can’t finalize the building layout or foundation design until the equipment drawings are ready, so this step has the potential to slow you down.

Fabrication and delivery can take six months, or even a year depending on the complexity of the system, the technology selected and the availability of shop space. Some equipment providers contract with sub-suppliers for fabrication, opening the door for an additional supply chain bottleneck. So it’s critical to plan some flexibility into your schedule to account for potential delays. Make sure delivery dates are confirmed upfront, before you issue that PO, as well as the supplier’s schedule for submittal of equipment drawings. As I mentioned before, receipt of these drawings (not just equipment lay out drawings, but also electrical and controls drawings) will drive your engineering design schedule, and likewise your construction schedule.

Site Traffic

Roadways for site traffic can add to the complexity of your design. If you’re installing a filter press for processing sludge from the new treatment processes, for instance, the solids from your system will increase truck traffic as those processed solids are hauled off for disposal. You will also need to work with your operations crew to coordinate traffic flow and equipment movements during construction – construction of these systems will require significant effort and there will be a lot of added materials and people flowing in and out of the site. Coupling this with any site work related to CCR or other regulations, planning ahead to avoid construction traffic from impacting normal plant operations and planned outages will be crucial.

Four More Factors to Think About

There’s a gamut of other challenges that can arise, so be sure to check your decisions against your goals, and stay focused. Here are four additional factors to think about as you are planning your implementation process:

  1. Seasons. Pouring concrete in the dead of winter is complicated and expensive. If your schedule allows it, coordinate construction during the warmer months for the best quality. Piloting systems during the winter months can also be a challenge, when you need to start considering heat tracing and protection of the equipment from the elements and the associated expenses.
  2. Concrete proximity. Concrete can only be on the road for two hours, so if your solution requires a lot of it, pinpoint the location of the nearest concrete plant, and consider a backup plant, just in case. In remote locations, the best option may be producing concrete onsite.
  3. Labor pool. In remote locations it may be difficult to find qualified local craft—especially if you’re using specialized products like FRP pipe or welding exotic alloys. Your schedule may be slowed due to a learning curve, or you may need to hire trained workers from outside the project area.
  4. Plan and Design for Commissioning. Planning how the system will be commissioned and brought online is crucial for minimizing impact to existing plant operations. During engineering design and construction, it’s important to properly design and install tie-ins to existing plant systems to minimize outages needed. Be sure to consider in advance how off-spec system effluent will be handled. Plan for sufficient storage and install temporary recirculation lines to support commissioning needs. Also, be sure that your project schedule includes milestone dates that take into account the time needed to commission the system. Remember, the milestone date in your NPDES permit is an in-service date, not a start-up date. The technologies for ELG can be complex and may require weeks to commission and test, so plan ahead to ensure you’re able to produce a quality effluent in time.

Bottom Line

Planning for ELG compliance is complex. Many factors weigh into every decision—careful planning is the key. You might be tempted to skip a step or two — take a short cut — but doing so sets you up for hurdles. Be sure to cover your bases:

  • Build a knowledgeable team
  • Leave time in your schedule for contingency
  • Vet your design through a pilot

My parting thought for this series is to plan practically and thoroughly — it may cost a little more up front, but it’s worth it in the long run. If you think through the process from start to finish, and plan well, success is within reach.