Upload
others
View
1
Download
0
Embed Size (px)
Citation preview
Wastewater Alternative
Technology Acceptance
in Colorado
David Kurz, P.E.
Lead Wastewater Engineer
Engineering Section
CDPHE Water Quality Control Division
July 15, 2015
Objectives
Provide information to facilitate:
• Use of proven technologies in Colorado
• More efficient interactions between manufacturers, owners,
engineers, and the WQCD for design reviews.
• Better understanding of the process for alternative
technology acceptance
• Clarification of the role of pilot tests at domestic
wastewater treatment works
Clarifications
Domestic wastewater treatment = state design review
Industrial wastewater treatment = no state design review
Both require discharge permit
Regulatory Framework
Legislature – Colorado Water Quality Control Act
(Title 25, Article 8, C.R.S.) (25-8-702 – Site location and design review required for domestic wastewater treatment works)
WQCC – Regulation No. 22 (5 CCR 1002-22, revised 2009) (Site application, design review, in-kind replacement, pilot tests)
WQCD - Policies • Reg 22 Guidance document (August 2010)
• Policy 6 (WQSA-6 Multiple OWTS)
• Wastewater design criteria (Policy WPC-DR-1)
Steps in Review Process (WWTP Steps 1-4, Lift Station/Interceptor Steps 2-3)
1. Preliminary Effluent Limits (PELs) (WWTPs changing discharge, Permits Section, informs site location review)
2. Site Location Application (*local agency review first*, Engineering Section, informs CDPS permit)
3. Design Review (Engineering Section)
• Lift Station or Interceptor = Basis of Design Report (BDR) together with
Final Design
• WWTP = Process Design Report (PDR) then Final Design (possibly
streamlined final design review certified by design engineer §22.11)
4. Discharge Permit (Permits Section)
Site Application Review
• Review ability of proposed treatment process(es) to meet
the PELs or effluent limitations [§22.9(1)(g)]
• What criteria to be used for the design review phase?
• Already included in the adopted wastewater
design criteria (WPC-DR-1)
or
• Developed through an alternative technology
acceptance
Alternative Technology Acceptance
• New or non-conforming technologies not represented in the
wastewater design criteria (reconfiguration, combinations,
packages)
• Established or innovative technology with existing
compliance record
• Not for emerging treatment techniques without compliance
history
• Described in section 1.8.0 of the wastewater design criteria
Alternative Technology Process
• Manufacturer submittal of information in §1.8.0 of the
wastewater design criteria (e.g., engineering basis,
operating history)
• Timing = submit for alternative technology review as soon as
practical before a site application
• Alternative technology submittal checklist (see website)
• Alternative technology recognition statement for a specific
project (if for a specific project)
Alternative Technology Review
• Review history of successful operations
• Evaluate efficacy of technology in providing reliable
wastewater treatment under a range of operating
conditions throughout Colorado (elevations,
temperatures)
• Not just pass/fail or averages
• Develop appropriate criteria for technology design
review
Data!
• Document assumptions, calculations, process modeling
• Actual full-scale operating experience
• Pilot test work results (long periods, seasons)
• Limiting conditions (temperature, elevation)
• Reliability, sensitivity (influent variations, conditions)
Acceptance ≠ Design Approval
• Site location and design approval still required for
each location where use of accepted technology is
proposed (just as for other technologies in design
criteria)
Pilot Testing Authority
• Site location approval requirements in Amendment section
[§22.8(2)(vii)] provide for conducting pilot projects.
• Regulation 22 Guidance Document provides additional
descriptive information. [Page 62, line 2954]
• Pilot Test Plan is required.
• Limited period of up to 12 months, with possibility for one
extension of additional 12 months.
Note: “Pilot testing” in the wastewater regulatory realm is not the same as in the drinking water regulatory realm.
Pilot Testing Goals
• Goals and scale of pilot tests vary:
• Sidestream test of established technology to evaluate appropriateness
for a particular WWTF
• Testing of emerging technology without compliance track record
• For alternative technology evaluations where a compliance
history is not available:
• Much higher requirement for information to be provided by the pilot test
• Pilot test must provide adequate level of data to establish alternative
technology compliance record and design requirements
• Pilot test plan must be more robust
• Note: “pilot test completed = alternative technology
acceptance” is NOT an automatic conclusion
Tips to Avoid Pitfalls
• Use Reg. 22 Guidance and Wastewater Design Criteria
• Provide complete submittals with documentation
• Consider pre-meeting with Engineering Section
• Alternative technology identified early to David Kurz:
[email protected] or 303-692-3552
mailto:[email protected]
Website Tips
• http://www.colorado.gov/CDPHE/WQCD
• Facility Design and Approval
• Forms
• Domestic wastewater alternative technologies
= list with accepted technology letters
• Guidance (Regulation 22 guidance)
• Policies (design criteria)
• Regulations (WQCC – Regulation 22)
Innovation Ideas
• Retrofit: Anoxic Basin on RAS line with carbon source
diverted from influent wastewater stream; benefit is higher
MLSS, smaller basin and available carbon source
• Zero liquid discharge at East Cherry Creek reverse osmosis
drinking water plant. Distillation of waste stream.
Highest Potential Needs
• Larger facilities:
sulfate, selenium, dewatering for biological phosphorus
• Medium facilities:
assistance for lagoons with ammonia and beyond
• Small facilities (discharge to groundwater):
low cost/high treatment/easy operations options to meet
effluent limit of 10 mg/L TIN
TDS
Barriers and Hurdles
• Poor testing prior to bringing to the state.
• Come with defensible evidence of operations
for all conditions
Suggestions to Help Innovation Needs
• Collaboration on innovation and pilot tests
• Various entities request pilot tests and sometimes we see
the same for different facilities. May or may not need
separate pilot tests.
• An operating WWTF willing to pilot different ideas that
could possibly coordinate with other facilities to test viable
technologies for all to see and possibly use (publish results).
• Example - Test a technology at one representative facility
where entities can contribute $ and ideas about how the
work will be completed.
Questions?