Impact of EPA ASR Letter on Florida s ASR Facilities

Transcription

1 Impact of EPA ASR Letter on Florida s ASR Facilities Joseph Haberfeld, P.G. Aquifer Protection-UIC Program Florida Department of Environmental Protection January 2014

2 ASR Cross Section View ASR Well Shallow Monitoring Well ASR Storage Zone Monitoring Well Overlying Aquifer Confining ASR Storage Zone Confining

3 Pyrite Crystals

4 10 μm 10 μm Photos from FL Geological Survey 10 μm

5 Scattered Pyrite in Dolomite Photo by FL Geological Survey

6 Attenuation of Arsenic As Concentration (ppb) Cycle 6 Cycle 3 Cycle 5 Previous Standard Cycle 4 New Standard Volume Recovered (mg) Tampa Rome Ave.

7 TYPES OF ASR PROJECTS IN FLORIDA Drinking Water (potable) Raw Ground Water Treated Ground Water Treated Surface Water Reclaimed Water

8 SUMMARY OF AQUIFER STORAGE AND RECOVERY IN FLORIDA ASR System Type Active Inactive/Planned Drinking Water 22 7 Reclaimed Water 11 4 Surface Water 5 1

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11 Abandoned Canceled On Hold for As solution

12 ASR A Regulatory Timeline 2005 Position Paper to EPA 2008 Began Using Enforcement Documents to Permit ASR 2010 Non-Endangerment Proposal to EPA 2011 Additional Information to EPA

13 This letter addresses the need for public water systems experiencing water shortages to store treated drinking water underground for later use as a source of drinking water.

14 innovative water management tools will be increasingly important to sustain water availability.

15 Regional Water Supply Plans Planning horizon of at least 20 years Options must be feasible Coordination with local governments, suppliers Plans should include: Quantification of Needs Updated every 5 yrs. Water supply development options Enhanced water conservation Water resource development MFLs, recovery and prevention strategies Funding strategy 15

16 Florida Fresh Water Demand & Use 4.00 Public Water Supply Water Demand (bgd) Domestic and Small Public Supply Agricultural Irrigation Recreational Irrigation Commercial/Industrial /Institutional Power Generation Year

17 This letter describes how Florida can apply UIC requirements to ASR wells used by public water systems when mobilization of arsenic is a concern.

18 The Safe Drinking Water Act - Section 421(d)(2) Focuses on protection of public water systems Federal Regulation - 40CFR144.12(a) Focuses on protection of the USDW

19 .Florida could decide in some cases that it is appropriate for these ASR wells to remain open under permits with conditions designed to protect public health and maximize protection to the USDW. Permit conditions should require practices designed to reduce arsenic mobilization and minimize the area within which arsenic mobilization could occur.

20 Federal Regulation 40CFR144.12(c) For Class V wells, if at any time the Director learns that a Class V well may cause a violation of primary drinking water regulations under 40 CFR part 142, he or she shall: (1) Require the injector to obtain an individual permit; (2) Order the injector to take such actions (including, where required, closure of the injection well) as may be necessary to prevent the violation. For EPA administered programs, such orders shall be issued in accordance with the appropriate provisions of the SDWA; or (3) Take enforcement action.

21 Federal Regulation 40CFR144.84(b)(1) (b) Circumstances in which permits or other actions are required. (1) You fail to comply with the prohibition of fluid movement standard in (a) and described in (a) (in which case, you have to get a permit, close your well, and/or comply with other conditions determined by the UIC Program Director in your State or EPA Region)

22 A user of the USDW other than the public water system operating the injection well should not have access to the impacted area...prevent the burden of public health protection from being transferred to any entity other than the ASR operator..

23 Tampa Rome Ave WELL ASR-1 Arsenic Concentration, in mg/l MCL 10 ppb CYCLE 3 CYCLE 4 CYCLE 5 CYCLE 6 CYCLE 7 CYCLE Volume Recovered, in MGal

24 ASR-1 thru ASR-3 & ASR 5, 6, 8, As Concentrations Marco Lakes ASR ASR-1 ASR-2 ASR-3 ASR-5 ASR-6 ASR Arsenic mg/l /02/02 05/14/02 06/19/02 05/29/03 07/02/03 08/06/03 02/04/04 06/16/04 01/26/05 03/10/05 04/13/05 05/17/05 03/24/06 04/12/06 05/01/06 05/17/06 06/05/06 06/21/06 03/28/07 05/03/07 10 µg/l Sample Date Range

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26 Potable Water ASR Operation Permits Issued Marco Lakes 2010 Peace River 2013 Bradenton Tampa Rome Ave

27 Key: Injected Water Arsenic Mobilization

28 .tools include degasification pretreatment, consistent operation.., and full recovery of injected water when necessary.implementation of site access controls such as institutional controls.that restrict well construction within the impacted area setbacks in the state s water well construction rules..that will control access to contaminated groundwater.

29 Tools for Addressing As Point of Injection Treatment. Treatment of the injectate to reduce arsenic mobilization may be feasible for some systems. Point of Recovery Treatment. Treatment used to render waters with high TDS levels potable will reduce As levels. Treatment includes blending and re-treating at WTP

30 Tools for Addressing As Provide for the use of institutional controls when As values >10 µg/l offsite. Aquifer Exemptions (minor) when the TDS is greater than 3,000 mg/l. State water quality criteria exemptions. Provide for a zone of discharge that would allow As values >10 µg/l on-site.

31 Punta Gorda ASR

32 ASR and Monitor Well Spacing City of Tampa Tippin WTP

33 Example of Institutional Control Tampa Rome Ave. An Ordinance limiting use of the ASR storage zone is a control for smaller sites City of Tampa successfully eliminated competing use of the aquifer, connected private domestic wells to the public supply

34 ASR and Monitor Well Spacing From CH2M Hill, Dec. 2006

35 30 Bradenton ASR Volume and Arsenic Concentration 20 Arsenic ug/l I 1 R1 I2 R2 I 3 R3 I 4 R Cumulative Volume (MG) /1/04 11/8/04 11/15/04 11/22/04 11/29/04 12/6/04 12/13/04 12/20/04 12/27/04 1/3/05 1/10/05 1/17/05 1/24/05 1/31/05 2/7/05 2/14/05 2/21/05 2/28/05 3/7/05 3/14/05 3/21/05 3/28/05 Recharge Recovery Cumulative Volume Arsenic

36 Bradenton ASR Arsenic ug/l Cumulative Storage Volume mg 0 May-05 Aug-05 Nov-05 Feb-06 May-06 Aug-06 0 asr1 SZMW Cumulative Storage Volume mg

37 Joseph Haberfeld, P.G. Aquifer Protection-UIC Program Florida Department of Environmental Protection