pressure washwater management for marina/boatyard industries

Pressure Washwater Management for Marina/Boatyard Industries

Paul G. Richard, P.E.

Senior Program Director

EBI Consulting

617.715.1825

prichard@ebiconsulting.com

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

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

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.

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)

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?

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

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!!!

Holding TankWhat 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.

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

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

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 18.00 Holding Tank Permit

Scheduling pick-ups - ”milk run”

UST/AST installation design approval

Changing UST requirements

Contaminated wastes

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

Collection Systems #1

Collection Systems #2

Collection Systems #2

Collection Systems #2

Collection Systems #2

Collection Systems #2

Collection Systems #3

Collection Systems #3

Collection Systems #3

Collection Systems #4

Powerwash SolidsCollected 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)Barium (All Below Detection Limit) Cadmium (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?

Mercury (All Below Detection Limit)Selenium (All Below Detection Limit)Silver (All Below Detection Limit)

Solid Waste vs. Special Waste

310 CMR 19.00 - Solid Waste Management

What is a Solid Waste? – Easier explained: What it doesn’tinclude:

Hazardous WasteSludge or septage that are land applied (310 CMR 32.00)Wastewater treatment facility residuals & POTW sludge ashEtc….

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.

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

Power Wash Wastewater Samples

Treatment Systems – Sewer DischargePrecipitation process

Chemicals

Solids management

Permit Limits

Licensed operators

Treatment Systems – Closed-LoopElectro-coagulation - uses electricity cathode and anode

Causes precipitation

Solids holding tank

Solids dewatering

Clean water supply tank and pump

No chemistry?

Treatment Systems – Closed-Loop

Simple concept

Filtration

Aeration

Equalization

Bag Filter

Polishing Media Canisters

Treatment Systems – Closed-Loop

EqualizationFiltrationAerationClarification (Settling Tank)Bag Filter and MediaSolids Dewatering

Treatment Systems – Closed-Loop

Cyclone SeparationFiltrationUV DisinfectionBag Filter and CartridgesBulk holding tank (Solids)Solids Management

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

Questions?

Paul G. Richard, P.E.

Senior Program Director

EBI Consulting

617.715.1825

prichard@ebiconsulting.com