Peracetic Acid for Municipal Water and Wastewater Related Processes Online Workshop for Regulators: Part 1
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1 Peracetic Acid for Municipal Water and Wastewater Related Processes Online Workshop for Regulators: Part 1 March 20, :00 5:00 ET No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
2 How to Participate Today **Be sure to enter your audio pin!** (It is unique to you) You can ask questions three ways: Click the icon to raise your hand to let us know that you have a question. Use the chat feature to let us know that you have a question. Submit your questions using the questions pane.
3 Thanks to the project funders! Upper Trinity Basin Water Quality Compact
4 Agenda Time Topic Speaker(s) 2:00 pm Welcome and Logistics Christine Radke (WRF) Allegra DaSilva (Stantec) 2:05 pm Meeting Objectives Bob Bastian (US EPA) 2:10 pm Overview of PAA Wastewater Disinfection in the US Kati Bell (Stantec) 2:35 pm Benefits of PAA Utility Perspectives Tullahoma Utilities Authority (TN) City of Lexington (TN) Denver Metro (CO) Trinity River Authority (TX) Scott Young Steve Hensley, Chris Wallace Blair Wisdom Matt Jalbert 3:15 pm Q&A Lisa Beutler (Stantec) 3:30 pm Break 3:35 pm Benefits of PAA Regulatory Perspective New Jersey Department of Environmental Protection Stephen Seeberger 3:45 pm States Approaches to Permitting PAA George Garden, Ariel Wessel-Fuss, and Angela Jones (TN DEC) 4:00 pm Discussion of Regulatory Hurdles Lisa Beutler 4:20 pm Identification of Discussion Points for Part #2 Lisa Beutler 4:30 pm Wrap Up and Adjourn
5 Meeting Objectives Bob Bastian U.S. EPA No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
6 Meeting objectives Provide an overview of PAA disinfection Summarize the progress of industry efforts in progressing the implementation of PAA WE&RF LIFT 14T16 EPA Innovative Technology Assessment: Operational experiences with peracetic Acid (PAA) for disinfection of municipal wastewater Design and Implementation of Peracetic Acid for Municipal Water and Wastewater Related Processes Outline known regulatory barriers to implementation
7 Meeting objectives, continued Review summary of permitting issues identified by state regulatory authorities 1. Concern about additives or proprietary stabilizers 2. PAA aquatic toxicity and allowable residuals, including H 2 O 2 3. EPA approved PAA measurement methods, 40 CFR Concern regarding ph issues in effluent discharges 5. Known increases in BOD, and how to address in discharge permit requirements, including monitoring methods 6. Virus disinfection efficacy Identify other unknowns to be addressed by future research; those not addressed by current efforts
8 What is need for PAA implementation? Regulatory requirements and data needs Allegra da Silva, PhD, PE Stantec Kati Bell, PhD, PE, BCEE Stantec No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
9 State of PAA disinfection in US
10 What is PAA? EPA Registration (date of registration) Application Rate and Allowable Residual Proxitane WW-12 VigorOx WWT II BioSide TM HS 15% Peraclean 15 Peragreen 22WW (2013) mg/l <1.0 mg/l (2008) ppm <1.0 mg/l, if DF>12, 0.09*DF (2015) mg/l <1.0 mg/l (2015) ppm <1.0 mg/l (2015) mg/l <1.0 mg/l Peracetic Acid (CH 3 COOOH) 12% 15% 15% 15% 22% Hydrogen Peroxide (H 2 O 2 ) 18.5% 23% 23% 23% 5% Acetic Acid (CH 3 COOH) 20% 16% 16% 16% 45% Sulfuric Acid (H 2 SO 4 ) -- <1% -- <1% -- Water (free) balance 45% 45% 45% balance Freezing point to -42.0C (-40.5 to F) -49C (-56 F) -49C (-56 F) -49C (-56 F) < -18C (< 0 F)
11 1. Catalysts and stabilizers Catalysts are not required, but sulfuric acid (H 2 SO 4 ) may be used to increase the reaction rate Stabilizer in EPA labeled products is not proprietary HEDP is widely used for food contact applications is well documented in FDA food contact notifications (FCNs) including environmental fate and ecotoxicity of HEDP. I have reviewed several of our competitors PAA formulations for toll blending and haven t seen anything else.
12 DO (mg/l) Benefits of PAA disinfection Reduces TDS discharges Low carbon footprint Low capital cost Increases DO in discharge Simple to operate May not need quenching Reduces effluent toxicity Reduces halogenated DBPs North Inf DO North Eff DO /30/16 2/2/16 2/5/16 2/8/16 2/11/16 2/14/16 2/17/16 2/20/16
13 Implementation of PAA disinfection Similar chemicals are not commonly used at municipal facilities; safety and engineering control are critically important Online chemical residual monitoring methods are challenging and current installations rely on manual, DPD based measurements, similar to that for TRC, but is not published in 40 CFR 136)
14 Safety and specifications
15 Example process flow diagram
16 EPA registration permitability
17 2. PAA toxicity and allowable residual What has been documented? Unlike chlorine, there is no federal water quality criteria for PAA (there is also none for ozone) WET testing is the gold standard for toxicity PAA disinfected effluent has lower toxicity than chlorinated/dechlorinated effluent Allowable residual has been published on the product labels, but implementation is state specific Some states will not approve PAA because there is not an approved method in 40 CFR 136
18 2. PAA toxicity and allowable residuals The normal WET test for acute and chronic toxicity evaluation is based on static renewal approach PAA is like ozone, it has a rapid decay By the time a sample is delivered to the laboratory, the end of pipe concentration is not represented in the sample The best scenario is to utilize flow through testing, which has been identified as particularly difficult While hydrogen peroxide also decays quickly, it is at a different rate that PAA, is site specific, and determination of toxicity is complicated EPA toxicity database is limited for mixtures
19 EPA database Limited data are available on commercial products which are mixtures Limited data are available for flow through tests
20 Inconsistency in state permits and little guidance from EPA regions State Allowable PAA Residual (ppm) Alabama 1 mg/l Arkansas Up to 2 mg/l in trials California Allowing trials and use of PAA for underperforming UV systems Colorado 0.4 mg/l (mon. average) at DF=0; >0.7 mg/l daily max (trial) Florida 1 mg/l, but require a minimum dose of 2 mg/l Georgia 1 mg/l (trials) Illinois Initially 1 mg/l for trials, but has since been rescinded Iowa 0.7 mg/l Kentucky Per engineer recommendation, generally 1 mg/l Missouri 1 mg/l as a daily maximum, 0.7 mg/l as a monthly average New Jersey 1 mg/l for trials (under review) Ohio 0.33 mg/l (Steubenville, OH) Oklahoma 1 mg/l (Guidance published August 2017) Oregon 1 mg/l, requiring monitoring of enteric viruses Tennessee 0.4 mg/l for low DF; site specific for high DF, up to 2 mg/l has been permitted Texas Anticipate EPA label (1 mg/l); GCWDA did not reopen permit Washington Anticipate EPA label (pilot testing being conducted with 1 mg/l) BALLAST WATER 0.5 mg/l as PAA per USCG 33 CFR Part 151
21 Options for a path forward Develop federal water quality criteria for PAA using 8 species and SFs Develop state water quality criteria for PAA Challenge: Decomposition kinetics Lack of flow through data More testing is needed Treat PAA like ozone or UV and use the WET test
22 3. 40 CFR 136 (EPA approved method)
23 ph (s.u.) 4. PAA is an acid, what about ph? Wastewater alkalinity is variable, and may be low if nitrification is not followed by denitrification Site specific testing is needed, 1 mg/l PAA is equivalent to addition of 11 ug/l of a 15% solution Influent ph Effluent ph North PAA dose /12/16 1/15/16 1/18/16 1/21/16 1/24/16 1/27/16 1/30/16 2/2/16 2/5/16 2/8/ PAA dose (mg/l)
24 5. PAA impacts on BOD/cBOD/COD Known increases in BOD, and how to address in discharge permit requirements, including monitoring methods Considerations Amount of BOD/COD added depends on solution Typically a 1 2 mg/l PAA dose is used We are adding active oxygen, which can and does offset some of the increase in BOD/COD
25 cbod (mg/l) 5. PAA impacts on oxygen demand Stoichiometry What we actually measure for a typical dose Effluent cbod Influent cbod PAA Dose Pre-PAA cbod average = 2.43 mg/l; Post-PAA cbod average = 2.46 mg/l PAA Dose (mg/l)
26 5. PAA impacts on BOD Challenges of the BOD test Seeding Quenching Sample location Compliance Can PAA treated samples be addressed as chlorine treated samples, which are collected prior to chlorine addition if seeding is not required?
27 6. PAA efficacy for viruses Same as chloramination and UV Not as effective as ozone or free chlorination
28 s PAA Chloramine Temporal profiles for reduction of viral infectivity in secondary effluent wastewater (WW) and 0.01 M phosphate buffer (PB): (a) MS2 by NH 2 Cl, (b) MS2 by PAA, (c) MNV by NH 2 Cl (d) MNV by PAA. Hollow symbols with no shading or crosses represent viral concentrations below the sensitivity limit of the assay. Dunkin et al., Environ. Sci Technol. 2017, 51,
29 Introduction 6. PAA efficacy for viruses Dunkin et al., Environ. Sci Technol. 2017, 51,
30 Infectivity Reduction (- log(n/n 0 )) MS2 in 0.01M PBS, ph 7 MS2 in 2 nd Effluent MNV in 0.01M PBS, ph 7 MNV in 2 nd Effluent Delivered UV Dose (mj/cm 2 ) Infectivity reduction of MS2 bacteriophage and MNV by UV irradiation in MWW and 0.01 M PBS. The open data symbols signify that the infectivity of the virus was reduced to the detection limits of the assay. The dash and dotted lines represent the linear regression results for MS2 and MNV, respectively.
31 Summary Substantial misinformation being distributed Commercial/proprietary positioning by manufacturer Lack of scientific knowledge Undocumented/anecdotal references that are repeated What is needed? Peer review documentation of data/science (this project) Regulatory clarity, at the federal, region and state levels Design guidance Operational guidance More research?
32 WE&RF LIFT14T16 publications Published Comparative Inactivation of Murine Norovirus and MS2 Bacteriophage by Peracetic Acid and Monochloramine in Municipal Secondary Wastewater Effluent Infectivity Reduction Efficacy of UV Irradiation and Peracetic Acid-UV Combined Treatment on MS2 Bacteriophage and Murine Norovirus in Secondary Wastewater Effluent (in press) Peer review to be submitted State of PAA use in North America PAA impacts on effluent quality (ph, BOD, TSS) PAA impacts on DBPs and toxicity Scalability of PAA from bench to pilot to full scale applications Case study articles (Gwinnett County, Metro Denver, etc.)
33 WE&RF LIFT14T16 publications Trade journal articles Methods for measuring and monitoring PAA and discussion on the path forward for obtaining EPA 40 CFR 136 status coordination with Standards Methods committee and EPA is currently ongoing; WE&T Economic analysis tool and sensitivity analysis targeted for WE&T and included in WEF guidance document Peracetic Acid Full-Scale Trial at East Bay Dischargers Authority for Disinfection of Secondary Effluent; to be published in California Clean Waters, Q Presentations at numerous industry conferences
34 Utility Perspective Scott Young, PE Tullahoma Utilities Authority (TN) Blair Wisdom, PE Denver Metro (CO) Matt Jalbert, PE Trinity River Authority (TX) Steve Hensley Chris Wallace City of Lexington (TN) No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
35 Utility Perspective 1. Why did your organization consider PAA? 2. What did your state require? 3. How did it turn out? a) Are the objectives that you were looking for when you turned to PAA met? b) Any surprises? 4. Are you satisfied?
36 Q&A Lisa Beutler Stantec No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
37 Regulator Perspective Stephen Seeberger New Jersey Department of Environmental Protection No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
38 Regulator Perspective 1. When and why did NJ first explore PAA disinfection? 2. What have you required in pilots, permits, etc.? 3. How did it turn out? a) Are the objectives that you were looking for when you turned to PAA met? b) Any surprises? 4. Are you satisfied? 5. What would you do differently?
39 States Approaches to Permitting PAA George Garden, PE, BCEE Angela Jones, PE Ariel Wessel-Fuss, EIT Tennessee Department of Environment and Conservation, Division of Water Resources No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
40 Map Summary
41 Qualifications Map may not match another that you have seen? Incomplete: WE&RF LIFT14T16 study to date Moving target (states and utilities moving on and off the permitted list at this point) Final result will be verified by the States prior to publication
42 Major Categories of Permits < 1 ppm PAA after disinfection and 7Q10 dilution < 1 ppm PAA at end of pipe ph limits Mixing study PAA concentration of 4.6 ppm Pilot testing (usually temporary permitted activity) Disinfection efficacy vs. Macro-Invertebrate surveys before and after and/or Whole Effluent Toxicity for PAA as diluted discharge concentration limit Backup for UV or other chemicals
43 Sources of delays/non-acceptance Awaiting water quality standard/criteria to be promulgated Investigating pretreatment with PAA causing WWTP problems Storage issues Addition of oxygen demand (CBOD5, BOD5, COD) and lowering ph EPA Regional stance UV PAA; insufficient or cost of adding detention time Cost compared to chlorine/dechlorination or UV
44 Challenge Summary Lack of published water quality/standards Diversity of products Suspicion of contents Little guidance on decision process
45 Discussion of Regulatory Hurdles Lisa Beutler Stantec No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
46 Discussion States What do the you need? If you're not permitting, or you're not comfortable with the way you're permitting, what do you want to know? EPA regions What do EPA regional offices need? What can they provide to states? EPA HQ What does EPA HQ need and what can it provide to regions and states?
47 Discussion Topics for Session #2 Lisa Beutler Stantec No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
48 Wrap Up Lisa Beutler Stantec No part of this presentation may be copied, reproduced, or otherwise u tilized without permission.
49 Wrap up Summary of themes expressed today Next step: Session #2 is on Tuesday, April 3, 2:00pm-4:00pm US-ET Discussion topics for Session #2 Charting a path forward What info or actions are needed to have PAA supported as a viable alternative to UV, ozone, and chlorine-based alternatives? Regulatory actions Research Other? Whose responsibility? When?
50 Thank you Please plan on attending Part 2 of this Workshop on Tuesday, April 3, :00-4:00 ET Registration will open following today s session
51 Speakers/Panelists/Moderators Bob Bastian U.S. EPA Katy Bell Lisa Beutler Allegra da Silva Stantec Angela Jones Ariel Wessel-Fuss George Garden Tennessee Department of Environment & Conservation, Division of Water Resources Blair Wisdom Denver Metro Matt Jalbert Trinity River Authority Scott A. Young Tullahoma Utilities Authority Stephen Seeberger New Jersey Department of Environmental Protection Steve Hensley Chris Wallace City of Lexington, TN Christine Radke The Water Research Foundation
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