Clean Wastewater, Clear Wins
Guidance on navigating wastewater compliance for industrial manufacturing success.
December 8, 2025
By: Gary P. Yakub and Shaun Gilday, CPEA, PMP
Managing industrial wastewater can feel complex, but with the right approach, compliance becomes an opportunity to strengthen operations and reduce risk. The Environmental Protection Agency (EPA) notes that non-compliance with the National Pollutant Discharge Elimination System (NPDES) can result in significant fines and environmental impact. For industrial operators, effective wastewater management is both a regulatory requirement and a strategic advantage.
In industries like food and beverage, chemical processing, and pulp and paper, wastewater matrices can be unpredictable. Each production change can affect discharge composition. While this adds complexity, it also creates opportunities to refine treatment processes, improve data accuracy, and ensure reliable compliance.
Understanding the Stakes
Effective wastewater management protects both your operations and the environment. Facilities that maintain pollutant levels within permitted limits avoid costly violations, protect finances, and maintain credibility with regulators.
Failing to track key metrics, such as biological oxygen demand (BOD) or nutrient levels, can harm downstream water bodies. Accurate and timely data provides the foundation for informed decisions, operational efficiency, and confident compliance.
The Complexity of Wastewater Matrices
TSS
Total Suspended Solids
HEM
Hexane Extractable Material
BOD
Biochemical Oxygen Demand
Industrial wastewater is rarely uniform. Total suspended solids (TSS), oil and grease, and BOD can fluctuate due to sampling, handling, or lab processes. Even small variations can lead to significant differences in reported results.
These challenges can be used to improve precision. By carefully reviewing raw data, auditing sample collection, and validating lab methods, facilities can turn variability into actionable insight. High-quality data ensures compliance and highlights opportunities for operational improvement and cost control.
Data validation is critical for confident compliance. Proactive review of lab results and strict oversight of processes reduces the risk of violations and financial exposure.
For facilities discharging to publicly owned treatment works (POTWs), validation is especially important. Partnering with accredited laboratories and applying robust review procedures ensures results are accurate and defensible.
Many facilities are indirect dischargers under the EPA Pretreatment Program (40 CFR Part 403). Pretreatment permits define pollutant limits, flow restrictions, sampling requirements, and reporting obligations.
Rather than seeing them as a burden, treat permits as operational guides:
- Maintain current permits and understand all conditions.
- Conduct regular self-monitoring and certification sampling.
- Keep thorough records and report anomalies promptly.
Approached strategically, permits provide clarity and support continuous improvement.
Leading facilities anticipate regulatory requirements rather than reacting to them. Effective strategies include:
- Tracking legislative and regulatory updates.
- Reviewing data for early warning signs of exceedances.
- Conducting internal audits to confirm process integrity.
- Working with consultants to validate methods and interpret permits.
Proactive management reduces risk, improves efficiency, and positions your facility as a reliable, expert operator.
Key Takeaways
- Compliance is continuous: monitor, review, and document performance at every step.
- Treat indirect discharge permits with the same rigor as direct discharge permits.
- Data validation and lab oversight are essential to defending results.
- Collaborate with regulators and experts to anticipate changes and maintain flexibility.
With a structured, proactive approach, wastewater management becomes more than a regulatory requirement—it becomes an operational advantage. Facilities that follow these practices protect the environment, maintain regulatory integrity, and minimize operational and financial risk.
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Shaun Gilday, CPEA, PMP
Vice President Risk Management Solutions
Mr. Gilday is Vice President Risk Management Solutions at Montrose with over 20 years of EHS auditing and compliance experience. Mr. Gilday has served as audit program manager for a number of large multi-media audit engagements as well as lead auditor for national and international audits across the oil and gas, chemical, and industrial manufacturing space and for a number of railroad operators and food and beverage clients. Mr. Gilday has broad multi-media experience and expertise in regulatory interpretations and EHS Program Development. Mr. Gilday has designed and established audit EHS programs and management systems for several fortune clients.
Gary P. Yakub
Associate Principal Chemist/Audit Program Manager
Mr. Yakub has more than 35 years of experience in environmental and wastewater quality assurance, laboratory testing, NPDES permit compliance, and data validation. He has performed over 500 environmental laboratory compliance audits for RCRA, industrial wastewater, and municipal wastewater scopes, ensuring adherence to EPA and CWA methods, NELAC and State Environmental Laboratory Accreditation Standards, CWA/SDWA/NPDES compliance, and client-specific quality assurance programs. His expertise includes wastewater testing, QA/QC, wastewater microbiology, NPDES Permit compliance, wastewater process troubleshooting, and data validation of wastewater monitoring results and consent-decree deliverables.
