LEVEL 1 STATUS 9/27/2016 OVERVIEW

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Betty Foster
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1 YOU FIND YOURSELF IN ERA LEVEL 1 WHAT SHOULD YOU DO NOW? CDIM Engineering, Inc. Environmental Science & Engineering 45 Polk Street, 3 rd Floor San Francisco, California 1 OVERVIEW Level 1 Status Short Term and Long Term Strategies Conventional BMPs Advanced BMPS Treatment Technologies Representative Cost Conclusions 2 CDIM Downey Brand 2 LEVEL 1 STATUS 3 1

variety of pollutant categories, mostly from EPA s benchmark values Base Parameter Instantaneous Maximum (mg/l) Ann. Average (mg/l) ph 6-9 ph units TSS 400 100 O & G 25 15 AdditionalParameter Ann.

2 HOW DID YOU GET HERE? Baseline Status Qualified Storm Events Numeric Action Levels Level 1 Exceedance Response Action You re not alone! 4 CDIM Downey Brand 4 NUMERIC ACTION LEVELS Instantaneous maximumnals for total suspended solids (TSS), ph and oil and grease (O&G), mostly calculated from a California dataset Annual averagenals for variety of pollutant categories, mostly from EPA s benchmark values Base Parameter Instantaneous Maximum (mg/l) Ann. Average (mg/l) ph 6-9 ph units TSS O & G AdditionalParameter Ann. Average(mg/L) BOD 30 COD 120 Aluminum 750 Ammonia 2.14 Nitrate/ite 0.68 Copper Cyanide Arsenic 0.15 Cadmium Iron 1.0 Lead Magnesium Mercury Nickel 1.02 Selenium Silver Zinc CDIM Downey Brand 5 LEVEL 1 WHAT DO I DO NOW? Designate a Qualified Industrial Storm Water Practitioner (QISP) By October 1, perform a Level 1 Source Evaluation with the assistance of the QISP By January 1, submit and certify a Level 1 Technical Report using SMARTS Revise the SWPPP as necessary and update and certify in SMARTS Ensure QISP provides training to employees 6 CDIM Downey Brand 6 2

3 LEVEL 1 SOURCE EVALUATION REPORT IGP, Section XII.C.1: Complete an evaluation, with assistance of QISP, of the industrial pollutant sources that are (or may be related) to the NAL exceedance Identify corresponding BMPs in the SWPPP and additional BMP/SWPPP revision Focus on drainage areas where the NAL exceedance occurred, but consider all drainage areas IPG Factsheet, Section K.4 Include a review of SWPPP for compliance with effluent and receiving water limitations Ensure that: All potential pollutant sources that could be causing or contributing are fully characterized Current BMPs are adequately described Employees responsible for implementing BMPs are appropriately trained Internal procedures are in place to track that BMPs are being implemented as designed in the SWPPP 7 CDIM Downey Brand 7 LEVEL 1 SHORT TERM STRATEGY 8 LEVEL 1 SHORT TERM STRATEGY 1. Perform thorough review of storm water results Was sampling location representative of discharge? Were sample procedures correct? What areas and results exceed NALs? 2. Perform site walk through Results clearly associated with pollutant sources, or is it a mystery? Do you have non-industrial or background pollutants? Do BMPs actually affect suspected pollutant sources? Improve representativeness of sample locations? More? Other? Are all minimum BMPs (IGP Section X.H) implemented? How well are existing BMPs implemented now? Are there opportunities for new BMPs? 9 CDIM Downey Brand 9 3

4 LEVEL 1 SHORT TERM STRATEGY 3. Review your SWPPP and other records Does it accurately reflect what you observed in your site visit Is documentation sufficient? Compare BMPs against CASQA BMP fact sheets Download your competitor s SWPPP and data from SMARTS Is there a procedure in place for maintaining BMPs? Are employees trained? 4. Determine your next steps Perform conventional BMP upgrades What is likelihood of achieving NALs? Set strategy for Level 2 demonstration (industrial, non-industrial or background) Develop data collection plan 10 CDIM Downey Brand 10 LEVEL 1 SHORT TERM STRATEGY 5. Document your Source Evaluation by October 1 Completed form, internal memorandum, draft Technical Report Sign it, date it and file it with SWPPP 6. Complete Technical Report and upload to SMARTS by January 1 CASQA Suggested Table of Contents: Keep it concise 1.0 Site Information Consider legal review 2.0 QISP 3.0 NAL Exceedances 4.0 SWPPP Review 5.0 Evaluation/Identification Potential Pollutant Sources 6.0 Minimum BMP Evaluation 7.0 Advanced BMPS 8.0 Additional/New BMPS 9.0 MIP Modifications 10.0 Submittal Summary 11 CDIM Downey Brand 11 SAMPLING STRATEGIES Rethink discharge points More discharge points could (possibly) be better than few discharge points Can problematic drainage areas be isolated? Can problematic discharge points be eliminated? More (not less) sampling Avoid sample reduction strategies, don t base decisions on one data point Does your sampling program focus only on pollutant sources? Better understand your discharge, not just the first flush Consider time-compositing of samples where appropriate Level 1/2 data collection Start thinking about Level 2 data collection Non-representativeness Chemical specific targeting vs. method defined parameters Chemical speciation Particle size and dissolved fraction 12 CDIM Downey Brand 12 4

CONVENTIONAL BMPS UPGRADES Make operational changes Consolidate pollutant sources Housekeeping improvements Advanced sweeping,

1. Evaluate potential outcomes Meet NALs and head back to Baseline Status after 4 QSEs Level 2 Advanced BMPs to meet NALS Level 2

Plan for Advanced BMPS Communicate with management Evaluate capital expenditure planning Understand what your industry is doing

5 CONVENTIONAL BMPS UPGRADES Make operational changes Consolidate pollutant sources Housekeeping improvements Advanced sweeping, coincide with rain Catch basin inserts 13 CDIM Downey Brand 13 LEVEL 1 (OR 2) LONG TERM STRATEGY 14 LEVEL 1 (OR 2) LONG TERM STRATEGY 1. Evaluate potential outcomes Meet NALs and head back to Baseline Status after 4 QSEs Level 2 Advanced BMPs to meet NALS Level 2 Industrial Demonstration (BAT/BCT) Level 2 Non-Industrial or Background Demonstration 2. Plan for Advanced BMPS Communicate with management Evaluate capital expenditure planning Understand what your industry is doing Prepare a rational, multi-year, stepwise approach Budget for collection system and treatment improvement Try to coordinate storm water improvements with other upgrades 15 CDIM Downey Brand 15 5

ADVANCED BMPS EXPOSURE MINIMIZATION Overhead coverage

sources Feasible for new projects, and many retrofits

at a water treatment plant Fuel storage 16 CDIM Downey

containment Discharge reduction Recycling, infiltration,

can be high Curbing and catch basin install Discharge to

6 ADVANCED BMPS EXPOSURE MINIMIZATION Overhead coverage Prevents storm water contact with potential pollutant sources Feasible for new projects, and many retrofits Unloading area at a recycling facility Chemical storage at a water treatment plant Fuel storage 16 CDIM Downey Brand 16 ADVANCED BMPS CONTAINMENT Storm water containment Discharge reduction Recycling, infiltration, sanitary sewer Typical for new construction Retrofit cost can be high Curbing and catch basin install Discharge to POTW Pumping retrofit at outfall 17 CDIM Downey Brand 17 STORM WATER TREATMENT 18 6

t work 2. Hire an experienced engineer 3.

Develop a basis of design Flow / volume requirements

Project phasing based on unit operations 6.

Infiltration Filtration Enhanced filtration (flocculation)

7 RATIONAL TREATMENT SYSTEM DESIGN 1. One size doesn t fit all, and poorly designed systems don t work 2. Hire an experienced engineer 3. Characterize your discharge 4. Develop a basis of design Flow / volume requirements Treatment objectives 5. Project phasing based on unit operations 6. Pilot testing 7. Full design 8. Construction 9. Performance verification 19 CDIM Downey Brand 19 TREATMENT TECHNOLOGIES Source control Sand/oil interceptors Infiltration Filtration Enhanced filtration (flocculation) Enhanced filtration (electrocoagulation) Enhanced filtration (media filtration) Ion exchange / carbon adsorption 20 CDIM Downey Brand 20 INLETS, BASINS, SAND/OIL SEPARATORS 21 CDIM Downey Brand 21 7

8 INFILTRATION Storm water flows to subsurface Requires pretreatment Wastewater ponds Infiltration galleries NONA Groundwater protection 22 CDIM Downey Brand 22 FILTRATION Pumps push water through a filter Remove TSS Sand filters (pressure and gravity) Bag filters 23 CDIM Downey Brand 23 ENHANCED FILTRATION FLOCCULATION/COAGULATION Use of polymers or other flocculants Static charges make particles agglomerate Filter to remove agglomerated particles Generate a waste stream 24 CDIM Downey Brand 24 8

ENHANCED FILTRATION ELECTROCOAGULATION Uses

and then agglomerate Some effectiveness for

filter Pollutant-specific media Generates waste

solid phase (water softening) Most effective

media GAC most commonly used for organics, but

9 ENHANCED FILTRATION ELECTROCOAGULATION Uses cathode anode take particles out of solution and then agglomerate Some effectiveness for dissolved metals Produces waste stream Power use/maintenance 25 CDIM Downey Brand 25 ENHANCED FILTRATION MEDIA FILTRATION Gravity filter Pollutant-specific media Generates waste stream Larger footprint than pressure systems 26 CDIM Downey Brand 26 ION EXCHANGE AND CARBON ADSORPTION Transfer pollutants from liquid to solid phase (water softening) Most effective for dissolved metals Ion exchange uses custom media GAC most commonly used for organics, but effective on other pollutants Generates waste stream 27 CDIM Downey Brand 27 9

10 REPRESENTATIVE COSTS 28 COSTS FOR ONE FLOCCULATION / FILTRATION SYSTEM Design Basis, technology screening, hydraulics, layout, installation support Major capital costs Interceptor pumps/controls Pipe, valves and fittings Tanks Tank level detector Anti-Siphon air valve Static mixer Injection pumps EM flow meter Sand filter skid (including controls) Plumbing connections General contractor/labor Electrical contractor Operating costs Biopolymer flocculant Power Operator TreatmentSystem TS-1 TS-2 TS-3 Flowrate (gpm) Capital Costs Conveyance $107,000 $82,000 $56,000 Treatment $130,000 $130,000 $58,000 Installation $65,000 $65,000 $65,000 $302,000 $277,000 $179,000 Capital Cost (annualized) 1 $40,000 $36,000 $20,000 Annual Operating Cost $18,000 $16,000 $12,000 Total Annual Cost $58,000 $52,000 $32, Assumes a 10-year treatment system lifespan and interest rate of 5% 2. Operating costs do include waste disposal 29 CASQA CONCLUSIONS 30 10

11 CONCLUSIONS Level 1 is here! Dischargers must plan for Level 2 Treatment does not guarantee NAL compliance Take a rational approach if treatment is required 31 CDIM Downey Brand 31 CONTACTS Sophia Belloli Nicole Granquist Don Sobelman Melissa Thorme Scott Bourne sbelloli@downeybrand.com ngranquist@downeybrand.com dsobelman@downeybrand.com mthorme@downeybrand.com sab@cdimengineering.com CDIM Downey Brand 32 11

How will the new changes affect Solid Waste Companies? By 1

How will the new changes affect Solid Waste Companies? By 1 California State Water Resources Control Board New General Permit For Storm Water Discharges Associated with Industrial Activities Order NPDES No. CAS000001 Effective July 1, 2015 How will the new changes