Pressure Washwater Management for Marina/Boatyard Industries

Transcription

1 Pressure Washwater Management for Marina/Boatyard Industries Paul G. Richard, P.E. Senior Program Director EBI Consulting

2 Agenda Introduction Storm Water vs. Industrial Wastewater Industrial Washwater (powerwashing management) Pressure Washwater Disposal Options Common Design Considerations Powerwash Solids Solid Waste vs. Special Waste Collection and Treatment Systems Powerwash Wastewater Sampling System Selection Considerations

3 Today s Meeting will give you an opportunity to receive information about: 1. Industrial wastewater compliance associated with power washing boat bottoms 2. The different wastewater discharge options 3. My recent experiences and knowledge associated with power wash wastewater collection and treatment systems

4 Storm Water vs. Industrial Wastewater Storm Water: Rain/storm event water and snow melt runoff via a point source Discharges associated with industrial activities typically managed via EPA General Permitting Program (NPDES) Industrial Wastewater: Liquid waste (wastewater) resulting from industrial or manufacturing processes. Dirt or Clean! Discharges have several management options more control compared to storm water.

5 Industrial Wastewater (Powerwashing) Why is this a problem? This is an industrial wastewater discharge to either the Waters of the US or groundwater or POTW. These discharges need to be permitted. These discharges need to be treated. Waters of the US = EPA NPDES Permit Groundwater = Mass. DEP Groundwater Discharge Permit POTW = Sewer Use Discharge Permit (i.e., Deer Island MWRA)

6 Industrial Wastewater Options What Are My Options? There are five (5) options 1. NPDES Direct Discharge Permit 2. Groundwater Discharge Permit 3. Sewer Use Discharge Permit (SUDP) 4. Closed-Loop Recycle System 5. Holding Tank/Offsite Disposal Options 1 & 2 not recommended WHY?

7 Sewer Use Discharge Permit (SUDP) What is a SUDP? A permit issued by a POTW allowing the discharge of industrial wastewater into a local sewer system (i.e., MWRA) Must comply with their local limits for various pollutants (i.e., Cu, Pb, Hg, Oil and Grease, BOD, TS, TSS, etc ) POTW Self Monitoring Requirements (Sampling) Most pressure washwater must be pretreated before being discharged

8 Closed-Loop What is a Closed-Loop recycling system? A system or systems, used to collect and reuse wastewater over and over again (treating while reusing) and adding make-up water for losses Zero Discharge = No direct or indirect discharge to the environment No Permits or Approvals Local Approval!!!

9 Holding Tank What is a holding tank/onsite collection system? Wastewater is collected in either an underground or aboveground storage tank (AST or UST) Collected washwater is then transported to an offsite disposal facility (i.e., 3,000 5,000 gallon vacuum truck) Wastewater typically non-regulated material (not hazardous waste) Prior approval with a disposal facility State Industrial Wastewater Holding Tank Permit (314 CMR 18.00) Access to sewer Holding Tank Permit not allowed.

10 SUDP/Pretreatment Discharge to Sewer Pros Easy to comply with POTW requirements Accessibility and convenient Discharge volumes unlimited Flexibility Cons Sewer Access/Permitting approval Initial capital cost expensive Operated by licensed certified operators Seeking local approval Discharge limits changing Compliance Sampling

11 Closed-Loop Recycle Systems Pros Access to the sewer not required No permit or regulatory approvals (local understanding) Don t need licensed certified operators Cons Initial capital cost expensive Water quality (topside washing & employee exposure) Odorous water & bacteria growth Operating costs (filter, media, etc ) Down time during system O&M activities

12 Holding Tank/Offsite Disposal System Pros Access to the sewer not required Don t need licensed certified operators Minimal equipment costs and maintenance Cons Wastewater generation rate need to be low Disposal facility approval 314 CMR Holding Tank Permit Scheduling pick-ups - milk run UST/AST installation design approval Changing UST requirements Contaminated wastes

13 Common Design Considerations Need a wastewater collection system Want to collect industrial wastewater only Want to promote large solids removal Want to allow storm water to discharge Expansion capabilities Characterize Wastewater for Treatability

14 Collection Systems #1

15 Collection Systems #2

16 Collection Systems #2

17 Collection Systems #2

18 Collection Systems #2

19 Collection Systems #2

20 Collection Systems #3

21 Collection Systems #3

22 Collection Systems #3

23 Collection Systems #4

24 Powerwash Solids Collected from aprons, trenches, sumps, treatment solids, etc. from boat bottom washing activities Weeds, brown algae/slime, mussels, barnacles, mud shrimp, paint chips, dirt, grit, debris, etc 4 samples analyzed by EBI for TCLP RCRA 8 Metals: Arsenic (All Below Detection Limit) Mercury (All Below Detection Limit) Barium (All Below Detection Limit) Selenium (All Below Detection Limit) Cadmium (All Below Detection Limit) Silver (All Below Detection Limit) Chromium (All Below Detection Limit) Lead (Below Detection Limit, one sample had 0.7 mg/l Limit is 5.0 mg/l) Non-Regulated Material Perform your own sampling to confirm. Is this a Solids Waste?

25 Solid Waste vs. Special Waste 310 CMR Solid Waste Management What is a Solid Waste? Easier explained: What it doesn t include: Hazardous Waste Sludge or septage that are land applied (310 CMR 32.00) Wastewater treatment facility residuals & POTW sludge ash Etc. What is a Special Waste? any solid waste that is determined not to be a hazardous waste (310 CME 30.00) and that exists in such a quantity or in such chemical or physical state, so that particular management controls are required to prevent an adverse impact from the collection, transport, transfer, processing, treatment or disposal of the solid waste.

26 Solid Waste vs. Special Waste (cont.) Good News! MA DEP, right now, is considering marina solids generated from boat bottom powerwashing as a Solid Waste (Must pass TCLP) Important - can not contain any free flowing liquids Dumpster and Landfill MA DEP Contact: Paul Emonds Solids Waste Division

27 Power Wash Wastewater Samples

28 Treatment Systems Sewer Discharge Precipitation process Permit Limits Chemicals Licensed operators Solids management

29 Treatment Systems Closed-Loop Electro-coagulation - uses electricity cathode and anode Causes precipitation Solids holding tank Solids dewatering Clean water supply tank and pump No chemistry?

30 Treatment Systems Closed-Loop Simple concept Filtration Aeration Equalization Bag Filter Polishing Media Canisters

31 Treatment Systems Closed-Loop Equalization Filtration Aeration Clarification (Settling Tank) Bag Filter and Media Solids Dewatering

32 Treatment Systems Closed-Loop Cyclone Separation Filtration UV Disinfection Bag Filter and Cartridges Bulk holding tank (Solids) Solids Management

33 System Selection Considerations Expect operational change!!! Permitting, end-of-pipe, closed-loop, collection Volume of water needed per day Volume of water to be treat per day Quality of water for reuse Representative sample & pilot test Down time for system O&M Operator friendly Automation $$$ Customer/employee exposure Odors large water volumes in UST Solids Management

34 Questions? Paul G. Richard, P.E. Senior Program Director EBI Consulting