Getting Ahead of the Regulations
By Mike Pruitt, PHPM
Green cars, green houses, green shopping bags; what’s next, green cheese?
The answer is quite probably, yes.
An exhaustive analysis of a major national congressional study by three noted public affairs professors indicates that 40% of the U.S. population (based on this representative survey) think that the government should “do a lot more regarding the protection of community drinking water,” and “reducing pollution of the nation’s rivers, lakes and ecosystems.” An additional 31% think that the government should “do a little bit more” regarding the protection of community drinking water. An additional 29% think that the government should “do a little bit more” to reduce the pollution of the nation’s rivers, lakes and ecosystems. A remaining 26% think that the government should be “doing about the same” on both issues.
Based on this study, it is clear that the vast majority of the public wants cleaner drinking water and cleaner rivers, lakes and ecosystems. This trend toward increased environmental concern is apparent in the media and will not come as a surprise to most people in the water and wastewater industry.
This same study shows that several other significant contemporary issues, such as urban air pollution, preserving national forests, preventing loss of the world’s tropical forests, reducing emissions of CO2 and preventing damage to the ozone layer, trail the issues of cleaner drinking water and healthier rivers and lakes.
In America, Today, Concerns About Water Pollution Outweigh Concerns About Air Pollution
The trend toward a stronger emphasis on environmental issues, with a priority on water-related issues, suggests that tighter effluent regulations will be coming to most areas of the United States sooner than later.
Water quality concerns have led to stringent new discharge limits on the release of nutrients, such as phosphorus and nitrogen, to surface waters associated with Chesapeake Bay, for example. (Cap and trade arrangements for these nutrients are being seriously discussed by Chesapeake authorities and local action groups.)
In May 2009, an Executive Order was released by the White House regarding the enforcement of water quality standards in and around the Chesapeake Bay area. In this document, the President ordered greater accountability, increased planning and shared Federal leadership.
This special attention to water quality is in no way isolated to the Chesapeake Bay area, however. It just serves as a good example of the trend. Several states, including Washington, Idaho, Arizona, Michigan, New York and Vermont, have all enacted tough new restrictions on the release of nutrients into public waters. Many of these are exceptionally stringent. Some of the tougher requirements go into effect in 2010.
What does this mean to the cheese production facilities of America?
Most will agree that the cheese industry currently enjoys a positive image among the consuming public. This is perhaps more about the wholesomeness associated with cheese products, rather than specific knowledge about the modern cheese-making process. The positive public view of cheese products and-by association-the cheese making-process is an extremely valuable asset to the industry today, and will become perhaps even more valuable in the future.
For centuries, the agrarian heritage of cheese making-and the dairy business in general-has been one of leadership in conservation, and these efforts have earned an enviable reputation for the industry as stewards of the land.
It has often been stated that reputations take eons to establish and moments to destroy. This is especially true of the reputations of certain industries in the news today. We have all witnessed in horror the almost instant decline in the reputations of investment bankers. Some have noticed the slower-paced but equally devastating decline in the reputation of the electric utilities industry, which has been profoundly sullied by its significant reliance on 30-year-old coal technology. The decline in the reputation of investment bankers could have been prevented if different decisions had been made years ago. The decline in the reputation of electric utilities could have been avoided by more attention to air quality issues sooner before public sentiment took the lead, before years of positive actions and investments were overwhelmed by a rapid change in public attitudes that are now driving the rule-making of the future. As with so many situations, recognition of public interests and active leadership in support of public sentiment provides the bridge to common interests and continued public respect.
In virtually all cases, leadership is the key to maintaining a strong positive public reputation. And, today the evidence is clear that it is time for the cheese industry to take the lead in the role it plays relative to water quality.
Cheese making is a water intensive process. From the volumes of water used in cleaning-often employing cleaners which can be rich in phosphorus-to the processing and disposal of by-products such as whey, the effluent of a typical modern cheese plant is equal to that of a small city.
For example, the average cheese plant (including evaporating whey) produces 168.3 gallons of wastewater per 1000 pounds of milk processed. Without whey evaporation, the volume of wastewater per 1000 pounds of milk processed can reach almost 300 gallons. This makes the cheese industry an important part of the water quality issue. For this reason, the industry cannot avoid its role or responsibility in the protection of water resources. To ignore an issue this large in which the industry is so obviously involved would of course be fool hearty. However, the urge to “look the other way” is tempting because the challenges are daunting.
The biological oxygen demand of the unprocessed effluent from the typical cheese plant is six to 10 times that of the average city wastewater treatment plant. Plus, nitrogen levels can be several times those of a city wastewater treatment plant. Nitrogen levels of 15 to 20 mg/L were reported at a southwestern cheese plant recently, and this is probably not unusual. Phosphorus levels of 15 to 20 mg/L are also common -- this at a time when many water authorities are requiring levels of 1 mg/L or less. Wastewater from cheese plants also can contain significant concentrations of chlorides and these have to be managed as well because at levels above 395 mg/L they are toxic to aquatic life.
Biological oxygen demand can be managed with aeration, conventional activated sludge processes, sequencing batch reactors and alternative tactics such as land application-though cold weather can complicate these solutions. However, removal of nitrogen and phosphorus to the levels that are necessary to effectively protect surface waters and meet impending regulations is a major challenge that requires enhanced nutrient removal technologies. Removing nitrogen and phosphorus is technically challenging and ENR technologies typically require a substantial investment. This, combined with wastewater management being a non-revenue generating cost, can easily reinforce the urge to ignore wastewater effluent issues altogether. This, however, is not an option-not with public opinion so completely focused on water quality.
What leadership in water quality means to the cheese industry
Establishing a leadership position relative to water quality is an option that is currently open to the industry. No one has pointed a finger at the cheese industry and suggested that the industry is not doing what it should relative to its wastewater, as of yet. If this should occur, the industry could very well be put on the defense. For that reason, establishing a position of leadership on water issues is an important preemptive move and doing so with a sense of urgency is necessary for several important reasons.
One, the industry will be forced to meet enhanced water quality regulations in the foreseeable future, based on the importance of the water quality issues to the public.
Two, if the industry takes the lead, the industry will gain valuable public relations benefits for its investment.
Three, the industry will avoid negative editorial content and unfavorable images in the media.
Four, by taking the lead, individual plants will enhance community relations and increase cooperation with local officials.
And, five, in the long run, it is the right thing to do.
What are the practical issues of cheese industry leadership relative to water quality issues?
The largest issue is costs, which is why the cheese plants of America have not already dealt with effluent-related issues comprehensively. Matters are made worse because water and wastewater management is an investment that is clearly not revenue generating. It can only be viewed as a cost of doing business. Obviously, if only certain plants incur the costs of improving wastewater treatment it will give a cost advantage to the plants that do not spend on wastewater treatment at this time. More critically, any plant that attracts the attention of the public due to negative impacts on water quality it has allowed to exist will paint the entire industry with the same dark brush. For these reasons, it is important that the industry as a whole find a way to self-regulate and work toward an industry-wide policy relative to wastewater issues. Getting ahead of regulations-especially when regulations are inevitable-is to the long-term advantage of the entire industry.
What are some of the technology options available to the industry today?
There are many options currently available to the industry, most of which can render cheese plant effluent harmless to the waters and wildlife they encounter upon release. Comments from specialists in dairy and cheese plant wastewater processing make it clear that proven options are readily available.
Some of the options focus on reducing wastewater solids by separating the whey from the wastewater stream, according to Mike Jakob and Madhavi Batchu of the Parkson Corp. This can easily be accomplished using rotary screening systems, which reduce treatment volumes and create solids that are then removed from the waste stream. These solids can be further dewatered and sold as a by-product. According to Jakob, options for the remaining volumes typically include high-efficiency, ultra-fine bubble aeration to reduce the BOD loading, then, advanced filtration technologies can be used effectively to remove phosphorus and nitrogen.
“Cost-effective enhanced nutrient removal filtration technologies are currently being used by several cheese plants and they are achieving phosphorus levels as low as 0.07 mg/L consistently,” Batchu said.
Much of the technology that has been developed in recent years for municipal application has been proven to be effective in meeting the specific needs of the cheese industry, which means the total number of options are literally too numerous to list. What this means is that the question is less about how to clean up wastewater and more about the commitment to invest in cleaning it up.
The green wave of public sentiment is building as evidenced by a major national study and extensive anecdotal media content. The focus of this green wave centers on water quality. This is already affecting surface water release standards and regulations in several of America’s most sensitive water basins. To maintain the excellent public image of the cheese industry, it is important for the industry, as a whole, to take a proactive stance. This will add an additional cost to the production of cheese, but if the industry encourages leadership relative to water resources, the industry will gain in the long-term. The wholesome positive image of cheese and cheese production will be preserved and enhanced.
Cost-effective technologies already exist and have been proven effective in cheese industry applications.
The industry clearly has the opportunity to ride the green wave, rather than take the risk of being drowned by it. Given the mood of the nation as it relates to water, it may be the perfect time for cheese to go green.
About the Author:
Mike Pruitt heads the consulting firm of Pruitt Humphress Powers & Munroe Inc., and has more than 25 years of experience in the water and wastewater industry.
Harrington, Winston. 2003. Regulating Industrial Water Pollution in the United States. Resources For The Future.
Konisky, David M. (corresponding author), Milyo, Jeffrey, Richardson, Lilliard E., Jr. 2008. Environmental Policy Attitudes: Issues, Geographical Scale, and Political Trust, University of Missouri, Truman School of Public Affairs, April 2008.
Phillips, David.2007. Desert Cheese. Dairy Foods.
President. 2009. Chesapeake Bay Protection and Restoration, Executive Order, May 12.
Rodenberg, Jerry. 1998. Waste Management Issues For Dairy Processors Bureau of Cooperative Environmental Assistance, Wisconsin Department of Natural Resources, December.
Wendorff, Bill. 2007. A Technical Update for Dairy Product Manufacturers. Department of Food Science, University of Wisconsin-Madison, UW Dairy Alert, , May.
The 2007 Cooperative Congressional Election Study (CCES).2007. Administered in November 2007 by Polimetrix, Palo Alto, California.
Nitrogen Levels Stall Waste-Water Plans for Clovis Cheese Plant. 2007. Albuquerque Journal