Don't miss MaximoWorld 2024, the premier conference on AI for asset management!

Experience the future of asset management with cutting-edge AI at MaximoWorld 2024.

Sign Up

Please use your business email address if applicable

Reliability in the Regulatory and Compliance Environment

The last fifty years has seen the greatest increases in the amount of legislation, laws, rules, and enactments that have ever been produced to benefit the health and safety of the population of the United States. This is especially true of environmental law and standards. It’s very easy to assume that it’s only in recent times that the importance of keeping the environment safe and healthy has become a matter of concern that requires our attention. But as you can see from the statement above, the matter has been the subject of great concern for much longer than we might think.

The most interesting part of the statement above to me isn’t the date so much as is the recognition that something needed to be done. We tend to think of pollution as a recent phenomenon. Problems that our more modern society has caused due to industrialization or population expansion. Interest in subjects such as global warming, carbon emissions and alternative energy sources has often taken center stage in the media, academia and most recently, in our wallets. We are learning that there is a price that will have to be paid if we don’t address these vital issues by changing the way we think about and co-exist with nature and the environment. It can’t be “business as usual” anymore. We are going to have to change the way we do business if we want to stay in business.

The early settlers of South Carolina realized very quickly that protecting their natural environment was going to be a matter of great concern. Settlers came to the new world for many reasons but most of them came to make a new start and be profitable at the same time. This was especially true of South Carolina. South Carolina was founded as a Proprietary Colony and the business of South Carolina was to be profitable for the Lord Proprietors who by the way never set foot in South Carolina. They had people for that.

The earliest industries in South Carolina focused on the natural environment and how to make a profit from it. Rice, indigo, tobacco, and of course eventually cotton were cultivated and processed for profit. Equally important though were the natural resources needed to support this enterprise. Water and its sources took on great importance to the early settlers and the colonial legislators who were responsible for making sure the colony remained profitable. They enacted legislation to insure that the water supply needed to support their efforts remained the way it was found. Reliable.

Since 1671 there have been a lot of changes made in how we regulate the treatment of our water and its sources. Most of us would agree that the changes in how water is treated for consumption have consistently changed for the better. What many of us may not be as familiar with is how that 1671 law has developed into the body of legislation, regulations and directives that govern the treatment of wastewater. Of more importance for many is how that system of laws and codes affect the requirements and performance of the assets we maintain to ensure that those standards are complied with.

Our Mission is to protect public health and enhance the environment of our service community by providing clean water services of exceptional quality and value.

The Charleston Water System has always been at the forefront of complying with and exceeding water quality standards. Public health and the health of the environment are central to not only our business goals but in how we select, operate and maintain the equipment necessary to achieve those goals. Our mission statement clearly establishes our purpose and how important we believe this to be.

Most of us are concerned more with the water we see coming into our homes than what’s going out When you turn on the tap to get a drink, bath or even wash your car you don’t want to see anything but nice clear liquid coming through that tap. That’s pretty understandable. In other words we expect certain standards of water quality. After all, you are a customer. You pay for that service and you should expect quality and value. And you also want to know that there are regulatory standards that govern that quality.

What happens after we use that water is not normally a subject we care to discuss. That’s pretty understandable also. We need to realize though that there are as many regulations and directives that have an effect on the wastewater industry as there is the water treatment.

My job is with the Charleston Water System’s Environmental Resources Department. I work at the Plum Island Wastewater Treatment Plant as a Maintenance Support Technician where I am responsible for the day to day operation of the Computerized Maintenance Management System and our Inventory/Spare parts facility. I also am a member of the Environmental Resources Departments (ERD) Environmental Management Steering (EMS) Committee. As a member of this team I assist in developing and monitoring our departments Emergency Preparedness Program. Finally, I am also a member of the company Safety Committee.

I first became interested in the how Regulatory and Compliance directives affect Reliability as a direct result of being a member of our EMS Steering Committee. Charleston Water System underwent the International Standards Organization certification process several years ago. This standard is called ISO 14001. These standards relating to environmental management are provide organizations with the elements of an effective environmental management system (EMS) that can be integrated with other management requirements and help organizations achieve environmental and economic goals.

This International Standard specifies requirements for an environmental management system to enable an organization to develop and implement a policy and objectives which take into account legal requirements and information about significant environmental aspects. It is intended to apply to all types and sizes of organization.

Now this program does not address equipment or asset performance as such, but it does focus a company’s attention on critical elements like environmental regulations and compliance issues which can affect overall plant performance. These documents must be constantly reviewed and updated as needed. If there is a problem, the standard requires action to correct the deficiency. Not just a statement that you plan to do something about the problem when you get the time and money.

Many critical aspects that impact the environment were discovered and eventually brought into compliance over a period of time. Charleston Water System continues to maintain this certification as an effective means of communicating to our customers and local governments our commitment to safeguarding the environment.

Another program that helped me to start thinking about our overall maintenance reliability efforts was Vulnerability Self-Assessment Training (VSAT). This program sponsored by the Department of Homeland Security and the Water Environment Federation provides water and wastewater utilities a self-assessment software program that allows the user to determine the severity of the risk of an event.

severity of the risk of an event

This matrix may look very familiar to some of you. Again it does not specifically address issues of reliability as such, but it does permit the user to gain an understanding of how risk is measured. The purpose of this particular program is to identify critical facilities, processes and equipment that may be at risk to terrorism or natural disasters. At present, it is a compulsory program for water treatment only. Wastewater treatment facilities are encouraged to perform the assessment though.

We have conducted benchmarking of our Computerized Maintenance Management System (CMMS) to see where we are in terms of being able to perform better equipment, inventory and job analysis. Finally, we are also re-organizing our Operations and Maintenance (O&M) Manual Library to be sure that we have the right information for the right equipment.

A company-wide strategic review of critical business areas has been established and one of them is our Asset Management Team. Presently and in the not so distant future this team will begin to implement more Reliability Centered Maintenance.

As the person responsible for insuring that the capabilities of our CMMS are compatible with existing plant equipment status requirements and work practices, I must insure that the data going into the CMMS is accurate, comprehensive and retrievable for use at any moment. This especially includes prioritizing equipment criticality, work requests, work orders and critical spares inventories. It’s important to be sure that that equipment that we think is critical has been assigned the appropriate level of urgency for work orders and other maintenance support. Reviewing work order and equipment histories was where I began to think about Reliability Centered Maintenance in a Regulatory and Compliance Environment. I wanted to know why certain levels of importance were placed on some equipment more than others.

I remembered that our Environmental Management System (ISO 14001) program helped us to identify critical business aspects and goals and that it relied heavily on legal and other regulatory and compliance standards. During the Vulnerability Self-Assessment review, I had to identify those plant structures and the equipment they contained that were most susceptible to natural and man-made disasters.

I also remembered that both of those programs required extensive review and implementation of a wide variety of regulations, directives and methods of measuring compliance. I wanted to know what were the environmental standards that could apply to reliability maintenance. The picture below will probably explain why more than any written explanation,

Charleston Water System, Charleston, SC

The environment is all around me where I work. Our working environment is the environment.

The first thing I needed to know was who are the major players in the protection of the environment. One should be pretty easy.

Enviromental Protection Agency

Environmental Protection Agency The second one might not be as familiar to you if you’re not from South Carolina, but no matter what state or territory you are from, I guarantee there is an agency very similar to this.

South Carolina Department of Health and Environmental Control

South Carolina Department of Health and Environmental Control

These two are the most important regulatory agencies that we at Charleston Water System must be concerned with. In the wastewater industry, they have the authority to shut you down. And quickly. They take their mission very seriously because they answer to the American people and do not tolerate a lot of excuses from businesses that are not conforming to the standards they set.

You might notice that I refer to the wastewater industry as a business. I get a lot of perplexing looks when I tell people that. They don’t understand that the wastewater treatment process is just like any other production facility or company that makes something. We do make something and we are very proud of it. We make clean water. We take very seriously our mandate to protect the health of the environment. And we take equally serious our commitment to our customers. Meet some of our customers.

south carolina enjoys clean water

These are the customer that the EPA and SC DHEC speak for. And as you can see, some of them vote, and some of them don’t. It doesn’t matter though. They all receive the protection of those agencies. And rightfully so.

At Plum Island, all of us consider ourselves as front-line soldiers in the fight to keep the environment safe for all users. Since Reliability Centered Maintenance is expected to play a major role in that battle, RCM is going to have enlist in the war being waged on our environment.

If “rules of engagement” are the standards by which soldiers must conduct themselves in battle, then it’s important for the wastewater industry to know its rules of engagement. I wanted to know what the rules would be in the application of RCM to our initiatives. This is because I tend to think a lot like Gen.Ulysses S. Grant. Not a real popular person in South Carolina but not disliked as much as Gen. Sherman. Grant hated to fight over the same ground twice. He hated doing it so much that after suffering a tactical defeat in the battle of the Wilderness, he and his men picked themselves up and started chasing after Robert E. Lee again.

I wanted to be sure that we had examined all of the relevant regulatory and compliance documents as carefully as possible to ensure we had given them the attention they deserve. I immediately found that the body of Environmental Law is both extensive and formidable as a candidate for casual perusal.

Nevertheless, it can be done. I started with the most obvious enactments. The Clean Air Act of 1970 and the Clean Water Act of 1972. Both of these acts are the source documents all the other laws, regulations and compliance requirements that follow. South Carolina’s detailed regulations are designed to carry out the S.C. Pollution Control Act, the S.C. Safe Drinking Water Act, the S.C. Solid Waste Policy and Management Act, the S.C. Hazardous Waste Management Act, the S.C. Atomic Energy and Radiation Control Act, the S.C. Coastal Zone Management Act and other statutes.

The primary document that wastewater utilities are concerned with though is its National Pollution Discharge Elimination System (NPDES). The National Pollutant Discharge Elimination System (NPDES) Permit Program was created by Section 402 of the 1972 Federal Clean Water Act. In 1975, the SC Bureau of Water received authority from the Environmental Protection Act (EPA) to administer the NPDES Permit Program in SC. The Bureau is responsible for the permitting, compliance, monitoring, and enforcement activities of the program.

To ensure protection of water quality, NPDES permits contain:

  • Effluent limitations on Pollutants of concern;
  • Pollutant monitoring frequencies;
  • Reporting requirements;
  • Schedules of compliance, when appropriate;
  • Operating conditions;
  • Best management practices; and
  • Administrative requirements.

Pictured below is an example of Effluent limitations. This document tells us what is expected from our process. We submit monitoring reports to the appropriate agency, in this case SC DHEC and record the data and they respond if they feel the need to.

Affluent Limitation and Monitoring RequirmentsEffluent Limitation and Monitoring Requirments

SC DHEC does not especially care how you arrive at the permitted effluent limitations, they only care that it gets done. They do encourage “best management practices”. But the main thing they care about is the safety and health of the people of South Carolina, not what brand or cost of what pumps, valves, motors or other essential equipment you use. The EPA is of course also concerned with public health and the effects your effluent will have on whatever receiving waters your effluent flows into.

My goal was to find which if any of our treatment plant processes were most susceptible to creating a situation that would increase our chances of becoming “noncompliant”. I also wanted to see if Reliability Centered Maintenance could be applied to improve our ability to stay in conformance with our NPDES.

During the Vulnerability Assessment, three critical areas were identified as being
the most probable candidates for becoming a serious risk to the health and safety of our
service community and environment. They were:

  • Influent Pumping
  • Aeration
  • Disinfection

It’s important to know that almost all wastewater treatment plants are planned and designed with a certain degree of built-in features designed to prevent a singular event that could shut you down. Pre-planning for redundancy in critical equipment, monitoring devices and even personnel issues are considered and plans and strategies developed to insure that the treatment of wastewater is not disrupted. Future capacity requirements are also allowed for and examination of factors that may contribute to degradation of service are always being planned for.

Nevertheless I wanted to look at how a Risk Analysis could be used to objectively evaluate these areas for factors affecting Criticality, Capacity and Cost. Time and space don’t allow us to examine all three, but I did select Aeration for our purposes because I felt it might be surprising to you. A preliminary study conducted with our plant engineering and process control staff also encouraged me to begin my study with Air.

Why air? Because air is fundamental to life. Wastewater treatment plants are not just a collection of machines, motors and valves. A wastewater treatment plant is a living and breathing process that treats not only inorganic material but organic compounds as well. For our wastewater treatment facility to continue to operate and meet and exceed the effluent limitations of the NPDES, we have to have oxygen.

Compared to our bodies, a wastewater treatment plant is not all that different. As humans we consume raw materials in the form of food and water which our bodies “treat”. Ingestion, screening, digestion, processing of nutrients and the elimination of harmful chemicals and by-products all take place with regularity and consistency. A wastewater treatment plant performs much the same function.

Oxygen for us is essential for any of those activities to continue. We can go without food for a considerable length of time. Less so for water. But air has to be constant. And it has to be a specific mixture.

In the secondary phase of out treatment process, aeration of the “product” takes place. It was at this point that I reviewed what equipment, processes and procedures could be a potential source of problem. I actually ended up focusing on a segment of our “workforce”.

When I first began working at Plum Island, my supervisor was giving me the “grand tour” so that I could understand a little of what went on and meet some of my coworkers. One stop was the Laboratory where the monitoring and testing is done to evaluate the “product” for compliance with the NPDES. He pointed to a chart on the wall and said “I want you to meet the hardest working members of the plant. They work 24 hours a day, 7 days a week, 365 days a year, rain or shine with no pay, no benefits and they don’t complain” Meet just one of the hardest working members of our staff.

Stalked Ciliate

Where can they be found? In the Aeration Basins where Oxygen is introduced. Because just like us, they need air to survive and perform their job. They are one of the higher life forms found in waste water treatment processes. Stalked ciliates are usually an indication of a stable activated sludge operation. Stalked ciliates are found in large numbers when the bacterial population and dissolved oxygen concentration of the treatment process are high, and the wastewater environment is stable. Stalked ciliates usually indicate a stable wastewater environment and a healthy biomass. Heavy attached growth on the stalks usually indicate the stalks have been around quite a while in the system and things have been pretty stable.

The Aeration Basins had already received a critical component rating from the Vulnerability Assessment so it was a good place to look for equipment or processes that might add to the findings. The primary equipment assets I first looked at were the Aeration Blowers and their sub-components themselves. Below is an example of one of four that we use at Plum Island.

The Aeration Blowers at Plum Island are Multi-Stage Centrifugal blowers which have been in service for several years. Checking the Equipment History in the Computerized Maintenance Management System (CMMS), I reviewed the PM, PdM, Corrective Maintenance and Repair Work Orders for each blower. I organized the data for each blower into separate categories and type. Then decided on which form of a Risk Analysis to use. I chose to do a Qualitative Analysis. One reason is because I was more familiar with that from the Vulnerability Assessment and the other reason is that I had access to the data that would be important to me already.

I wanted to answer three questions. They are:

  1. What could happen?
  2. How likely is it to occur?
  3. What is the impact?

I used a simple Risk Analysis matrix to calculate the potential risk to my “hardest working employees”. Below is an example of the one I used.

Risk Analysis matrix

These are the risk levels and how they are interpreted

risk levels and how they are interpreted

The Vulnerability Assessment had established a 1C for the basins based on what could happen. The most extreme occurrence of a natural disaster would be an earthquake, of which Charleston has a significant history. The basins themselves may withstand a moderate to severe earthquake up to a Richter Scale of 6.7. However, after an event of 6.25, there is a serious chance of liquefaction of the underlying soil. If that happens, the most critical asset I would have at Plum Island would be life preservers and life boats.

Hurricanes are a seasonal threat to the eastern seaboard, and from the aerial photo of Plum Island you saw earlier, hopefully you can assume that we have existing emergency plans to prepare for and recover from this type of event. Storm surge is not to be taken lightly though as Katrina proved to some wastewater plants that are still undergoing recovery and reconstruction efforts. The facility that houses the blowers and their support components is of very solid construction though.

For the blowers I wanted a criticality rating based on their performance and the effects their loss could have on my hard working associates. Since redundancy exists, the loss of one blower was not a single event type of failure that would cause serious problems. Even two down for repairs or scheduled maintenance was not a big threat.

The most likely event was the loss of electrical power. If electrical power to the blowers is not disrupted, ciliates and other organisms that are consuming the product, reproducing and providing the means of maintaining that NPDES, will begin to die after four hours. This death may take longer due to climate activities such as temperature, but it is going to start unless we get oxygen to them quickly. If they die, the plant itself goes “dead”. The basins containing the wastewater will become septic. We cannot discharge into the receiving waters, in this case, Charleston Bay or any other natural environment.

However, mitigation and remediation plans already exist. Powerful generators are in place to provide power to not only the basins but the entire plant. Even if these were lost for some reason, contingency plans exist to acquire either vendor or governmental support in the form of generators already designated for that purpose.

One other area concerning the blowers needed to be examined though and that was the subject of power cables and connections. This proved to be a problem for several reasons. One was availability. As they are very expensive and made to order, the feasibility of keeping extra sets of very large and bulky power connections was deemed cost prohibitive. We can acquire them, but the time it takes to make them and be received is a serious consideration. This resulted in the Blowers receiving a 2D or Moderate criticality rating.

Next the ability to properly maintain the blowers and components was examined. The Blower Preventive Maintenance tasks were evaluated to insure the tasks were appropriate for the level of maintenance our staff could provide. The ability to repair was matched against the plant technicians’ qualifications, both mechanical and electrical, and the point where external vendor support would be needed.

Predictive Maintenance technologies were also evaluated. Thermography, Laser Alignment and Vibration Analysis programs were instituted and formalized and the training needed for technicians undertaken to provide greater analysis capabilities.

Spare parts were examined and reviewed to make sure that the correct spare parts were in place. If the part was not available for storage or cost restrictions, the time required to purchase and transport the parts was reviewed to insure parts could be available in a timely manner.

This has been done to insure that we maintain the requirements of the NPDES. Our little friends in the basins who help us to remain in compliance expect that we provide them with only a few things. Food to eat, a place to eat it, and air to breath. Pretty simple and easy for someone who doesn’t get paid. Our customers expect clean water. Our customers also supply my plant with the raw materials to produce our product. Clean water.

Most of our customers are quite unaware of how we do it. They only want results. One last look at one of our customers and the environment they reside in might be a good idea.


Regulatory and Compliance Issues may take a different form for you and your company or organization. Most of us are familiar with OSHA, the Food and Drug Administration, the FCC. Other agencies which could have regulatory and compliance issues that you might need to examine are the Department of Transportation, Commerce or even as we found out the Department of Homeland Security and the Federal Emergency Management Agency(FEMA).

Regardless of which authority or agency has a say in how you make your product, we can not afford to neglect them. Recent news items have shown us what the results are when companies place profits ahead of customer safety and neglect or worse, ignore, those regulatory and compliance standards that are applicable to them.

In Reliability Centered Maintenance or Asset Management strategies, we need to see these agencies as partners, not adversaries. It can be a difficult and strained relationship at times as I’m sure you know, but I feel the value of a good relationship is more important in the long run. The environment I work in demands compliance. Life depends on it. Knowing the importance of those compliance demands that are placed on us in the wastewater industry strengthens us and insures that our product, clean water, will continue to flow from our plant and into the receiving waters around us.

The founders of the Colony of South Carolina knew in 1671 that life and the waters supporting it were crucial to the survival of the people and the natural environment. They also realized that commerce and the ability of the people of South Carolina to make a living were tied to the protection of not only the water resources but the entire natural environment. The law I showed you at the beginning of this presentation has never been rescinded. We owe it to our employees, ourselves and ultimately our customers to make sure we never rescind their rights to expect only the best possible products and service from us.

ChatGPT with
Find Your Answers Fast