Proposal to rectify IETS

1. Hot water bath beside quenching tank need to discharge in proper manner during tank cleaning.

Matter to discuss:
Do 31 parameter testing and compare with current equalization sump water IECS result.
If similar we can treat with the current system.
If no, we need to have a different system specifically for this effluent.

2. Release water from Rinse Tank to Equalization Sump only during monthly tank cleaning, not to
treat continuously like current practice. Because if the water still can be use on production, we
should not to treat it as wastewater.

Matter to discuss:
How to increase equalization sump capacity?

3. Jar test need to be done each time when effluent discharge to equalization sump. The purpose is
to find the optimum dosage to treat effluent. Turbidity meter is required to plot turbidity vs
dosage graph as required by DOE and compulsory to be attached in FTR report. (Attachment 1)

Equipment to purchase:
i) turbidity meter
ii) 1L glass beaker

4. Automation pH adjustment is required to prevent non compliance of discharge. For example,

when pH is low (e.g. pH 8) then we increase pH manually by increase the dosage of caustic soda
to pH adjustment tank, those effluent treated on low pH already flow to the next treatment
process, as a result the treated effluent contains higher concentration of metals. (Metal removal
is by increasing the pH @ hydroxide precipitation). To achieve optimum metal removal for most
metals, pH should be maintained above 9. (Attachment 2 & 3)

Equipment to purchase:
i) pH probe for pH adjustment tank
ii) interlock caustic soda dosing pump with pH controller
5. Only significant parameters are required to be tested weekly by accredited lab and submit the
reports monthly to DOE through OER. Significant parameters are based on IECS. It is not
compulsory to test all 31 parameters on every first week of the month. However, it is a good
practice to show that LCP loving the environment.
* Already double confirm with trainer that recycled effluent is required to perform lab analysis
in case of spillage and non-compliance discharge to environment.

6. Environmental Quality (Industrial Effluent) 2009, Regulation 10(3) showed:

An Owner or occupier of a premises shall ensure that a competent person is on duty at any time
the industrial effluent treatment system is in operation.
Hence, the number of competent persons should be more than 1, in case of sick leave or absent,
included Saturday.
*same goes to Scrubber, Schedule Waste & Dust Collector