Lisa Knerr

Transcription

1 Lisa Knerr

2 New Permittee Concord Energy NDR issued in July Fracking Produced water and flowback water Some in EPA call it all produced water with flowback water and brine Pretreated produced water NOT flowback water or raw produced water Submitted BMR 40 CFR 437, POTW s preliminary effluent limitations, produced water general permit, EPA recommendations EPA determination that the facility is a CWT, but does not meet any of the sub-categories Division determined that they are NOT categorical Discharging to a POTW discharging to a T&E segment Gave Concord stream standards as their indirect discharge limits in their NDR Assumed complete flow through of pollutants POTW is an unapproved program and has no applicable local limits No discharge, no DMRs, to date

3 Concord Energy Boron Post treatment: mg/l Produced Water General Permit: 0.75 mg/l (monthly avg) Copper Post treatment: mg/l POTW PEL: mg/l (monthly avg) Nickel Post treatment: 5.12 mg/l POTW PEL: mg/l (monthly avg)

4 Concord Energy Zinc Post treatment: 1.94 mg/l POTW PEL: mg/l (daily max) TDS Post treatment: 4,782 mg/l Produced water GP: 3,500 mg/l Chloride Post treatment: 1,640 mg/l Produced water GP: 250 mg/l

5 Concord Energy NDR Limits No one source of a full list of pollutants of concern Did a lot of research and asking around Limits for 58 pollutants Some limits depend on the month Some metals are total and dissolved Limits based on Clifton s PEL (preliminary effluent limitations) Did not give Concord dilution (although dilution will occur)

6 Industrial Waste Management Section of Discharge Permits The Permittee shall analyze the treatment facility sludge (biosolids) prior to disposal, for the presence of toxic pollutants listed in 40 CFR 122 Appendix D (NPDES Application Testing Requirements) Table III at least once per year. If the Permittee does not dispose of biosolids during the calendar year, the Permittee shall certify to that in the Pretreatment Annual Report and the monitoring requirements in this paragraph shall be suspended for that calendar year.

7 Biosolids Disposal State Landfill EPA Landfill Compost Beneficially use etc EPA would initiate enforcement, so test for table III POCs if you do almost anything with biosolids

8 Discharge Permit Renewals Division moved to a watershedbased permit renewals Finishing up Regulation 34-San Juan River and Dolores River basins Regulation 35-Gunnison River and Lower Dolores River Basins Starting in 2014 Regulation 32-Arkansas River Basin Regulation 36-Rio Grande Basin Pretreatment information in permit renewal notification letter

9 Drinking Water Design Criteria Effective September 1, 2013 Section Discharges from WTFs to POTWs Waste disposal and discharge evaluation and plan Must evaluate and develop a plan for waste residuals Treatment waste discharges Sanitary sewer Plan must include Surface water We also have a direct discharge permit Groundwater Impoundments Radioactive materials

10 9.2.1 Discharges to Sanitary Sewer The plan must include acceptance of the industrial wastewater by the domestic wastewater treatment facility and any pretreatment processes necessary for the discharge (e.g., flow equalization, chemical pretreatment, filtering) with a management plan for associated pretreatment wastes, if any.

11 Waste Pharmaceuticals CO Solid Waste Regs (13.9.1) list the allowable disposal methods Down the sewer is NOT an option Therefore it is prohibited Medical equipment provider asked about irrigation fluids from surgical/medical procedures Not blood waste that is solidified and disinfected and put into red bag waste or landfill Pay by weight Irrigation fluids contain epinephrine, antibiotics, and other pharmaceuticals and are usually discharged to the sewer Hazardous Waste Division looking into the issue

12 Regulation 85 Nutrients Reg. #85 Nutrients Management Control Regulation Became effective September 30, 2012 >2 mgd=nutrients being incorporated into preliminary effluent limitations (PELs) right now 1-2 mgd=have 10 years Technology-based limits

13 Summary of Monitoring Requirements in Regulation 85 < 1.0 MGD >1.0 MGD Domestic Disadvantaged community Other Domestic Effluent only (bimonthly) Effluent only (bimonthly) Effluent only (bimonthly) Effluent and In-stream (monthly) For more information: [click on I m looking for Rivers, Lakes On page, top ribbon: Nutrient Monitoring ]

14 Effluent Sampling (All dischargers) Phosphorus Total phosphorus Nitrogen Total Nitrogen Total Inorganic Nitrogen Flow Total daily flow in MGD on the day that nitrogen and phosphorus samples are collected.

15 Stream Sampling (Dischargers > 1 MGD) Phosphorus Total Phosphorus Nitrogen Total Nitrogen Flow Daily average flow (cfs, typically from a downstream gaging station)

16 Regulation 85-Monitoring Requirements for POTWs Reg 85 requires a Sampling and Analysis Plan (SAP) Not required to submit plan, but must certify that you have one by March 1, 2013 A SAP template has been developed Contents Facility specific info Monitoring location info Info on who conducts the sampling The lab that will analyze the sample

17 Contacts for Nutrients/Reg 85 Questions PELs and POTW Permits: Eric Oppelt Monitoring: Arne Sjodin

18 Questions?