BaySaver Technologies ● 1030 Deer Hollow Drive ● Mt. Airy, MD 21771

July 11, 2014

Robert E. Cooper, PE

Stormwater BMP Technical Specialist

Virginia Department of Environmental Quality

P.O. Box 1105

Richmond, VA 23218-1105

Subject: BaySaver Technologies Submittal for Bayseparator and Bayfilter Technologies

Dear Mr. Cooper:

Thank you for affording BaySaver Technologies the opportunity to be considered for the Virginia BMP

Clearinghouse.

Enclosed are the summary documents (Manufactured Treatment Device (MTD) Registration files) and the

supporting articles of information on both technologies. We have included our Technology Evaluation

Report (TER) for Washington State Department of Ecology, which is under review by Ecology. We will

forward you our formal acceptance once we receive notice and are listed on their website with our other

Ecology designations.

The primary information we have submitted for your analysis for the Bayseparator and the Bayfilter are

the NJCAT/DEP testing and the Richard Montgomery High School (RMHS) data packets, respectively.

Feel free to contact me and discuss this further. We look forward to being included in the Clearinghouse

for both technologies.

Sincerely,

Brian M. Rustia, PE

Eastern District Manager, Bayfilter Technologies, LLC / ADS

cc: D. Hurdis, BaySaver/ADS

J. Clark, ADS

Enclosures

1

Manufactured Treatment Device (MTD) Registration

1. Manufactured Treatment Device Name: BayFilter™ Stormwater Cartridge System

2. Company Name: Baysaver Technologies, LLC

Mailing Address: 1030 Deer Hollow Drive

City: Mount Airy

State: MD Zip: 21771

3. Contact Name (to whom questions should be addressed): Brian Rustia

Mailing Address: 5941 Innisvale Drive

City: Fairfax Station

State: VA Zip: 22039

Phone number: 866-405-9292

Fax number: 866-397-2505

E-mail address: brian.rustia@ads-pipe.com

Web address: www.baysaver.com

4. Technology

Specific size/capacity of MTD assessed (include units): Bayfilter system is sized by cubic

feet per second (cfs) or gallons per minute per square foot (gpm/sq ft) of filter area

media. Baysaver has various filter cartridge size configurations (i.e., vertical heights)

2

and flow rates (i.e., gallons per minute – gpm) and is sized depending on the application.

We recommend a maximum loading rate of 0.5 gpm/sq ft for our current filtering devices.

Range of drainage areas served by MTD (acres): Non-Applicable (N/A), Bayfilter

cartridge system is a modular and scalable system sized to treatment cfs entering the

treatment vault/manhole.

Include sizing chart or describe sizing criteria: See above, 0.5 gpm/sq ft of filter media

area is our recommendation for this submittal.

Intended application: on-line or offline: Both, special consideration should be taken for

in-line applications with little to no pretreatment and/or upstream detention components.

Most filtering devices recommend some level of pretreatment to protect premature

fouling of the filtering media by such things as high sediment loads, debris, and

hydrocarbons.

Media used (if applicable): Bayfilter cartridges contain a blend of zeolite, perlite,

activated alumina, and in some cases silca sand depending on the stormwater pollutants

targeted for removal.

5. Warranty Information (describe, or provide web address):

All Products manufactured by BaySaver Technologies are warranted for a period of one (1)

year to be free of any material and manufacturing defects. This applies only to Separators

and Filter Cartridges manufactured by BaySaver Technologies and does not include Precast

Concrete Components or other Components not manufactured by BaySaver Technologies.

This warranty is limited to providing a replacement unit (the same or equivalent) and does

not include any installation or other costs associated with its replacement. This warranty

does not extend to product defects or system failures due to improper installation, lack of

maintenance, or improper system design.

6. Treatment Type

Hydrodynamic Structure

Filtering Structure

Manufactured Bioretention System

Provide Infiltration Rate (in/hr):

Other (describe):

7. Water Quality Treatment Mechanisms (check all that apply)

Sedimentation/settling

Infiltration

Filtration (specify filter media)

Adsorption/cation exchange

Chelating/precipitation

Chemical treatment

Biological uptake

3

Other (describe):

8. Performance Testing and Certification (check all that apply):

Performance Claim (include removal efficiencies for treated pollutants, flow criteria,

drainage area): 80 % TSS, > 50% TP removal at 0.5 gpm/ sq ft of filtering media. Note: The

test data submitted exceeds these values.

Specific size/Capacity of MTD assessed: 0.5 gpm/sq ft of filtering media

Has the MTD been "approved" by an established granting agency, e.g. New Jersey

Department of Environmental Protection (NJDEP) , Washington State Department of

Ecology, etc.

No

Yes; For each approval, indicate (1) the granting agency, (2) use level if awarded (3) the

protocol version under which performance testing occurred (if applicable), and (4) the date of

award, and attach award letter.

http://www.ecy.wa.gov/programs/wq/stormwater/newtech/technologies.html

Table of Bayfilter Major National Approvals

Agency Level of

award

Protocol Used Date of

Award

Award letter

Maryland

Dept. of

Environment

Stand Alone

Water

Quality Use

TARP

Protocol,

Approved for

TP and TSS

January

2008

See attachment

NJCAT/DEP Interim

Certification

TARP-TSS July 2008 See attachment

WDOE General Use TAPE

Protocol- TSS

Basic

Treatment

August

2011

See WDOE website at:

www.ecy.wa.gov/programs/wq/sto

rmwater/newtech/technologies.ht

ml

WDOE Conditional

Use

TAPE

Protocol-

Enhanced and

TP

December

2014

See WDOE website at:

www.ecy.wa.gov/programs/wq/sto

rmwater/newtech/technologies.ht

ml

WDOE

General Use TAPE Protocol

–TP

Pending *1

(Summary

Data and

Report

provided)

Pending, Report submitted July

2014

*1 Tape Testing at initial site did not have sufficient Phosphorus load for enough

qualifying events (Influent TP between 0.1 mg/l and 0.5 mg/l). Testing was moved to

another site which provided enough qualifying events. This testing yielded TP removal

rates of over 75%.

4

Was an established testing protocol followed? Yes

No

Yes, (1) Provide name of testing protocol followed- TARP and TAPE where applicable

(2) List any protocol deviations: None

Provide the information below and provide a performance report (attach report):

See Attached, Richard Montgomery High School (RMHS) Report.

See Attached, WDOE Interim TER Report

For lab tests: N/A, RMHS report and WDOE study were field tests.

i. Summarize the specific settings for each test run (flow rates, run times, loading

rates) and performance for each run:

ii. If a synthetic sediment product was used, include information about the particle

size distribution of the test material:

iii. If less than full-scale setup was tested, describe the ratio of that tested to the full-

scale MTD:

For field tests:

i. Provide the address, average annual rainfall and characterized rainfall pattern, and

the average annual number of storms for the field-test location: RMHS Testing:

250 Richard Montgomery Dr., Rockville MD 20852. Rainfall depths of the first

20 monitored storm events ranged from 0.24 to 3.04 inches, the site is

representative of rainfall patterns seen in Virginia. WDOE Testing: Two Sites:

Grandview Place Apartments, 19420 Southeast 20th Street in Vancouver,

Washington. Rainfall depths of the qualifying events ranged from 0.20 to 0.39

inches. The Woodinville Sammamish test site is located at/near the intersection of

175th Street and 131st Ave NE. in Woodinville, Washington. Rainfall depths of

the ten qualifying events at Woodinville ranged from 0.20 to 0.94 inches.

ii. Provide the total contributing drainage area for the test site, percent of impervious

area in the drainage area, and percentages of land uses within the drainage area

(acres): RMHS site: 3.62 acres, 83% is impervious, and 17% is vegetated. 100%

of the area is classified as urban, commercial-institutional use. Grandview site:

9.9 acres, but only 1.35 acres of this site drains into the Bayfilter vault and the

area is classified as urban, commercial-institutional use. For the Woodinville

site: the total site is 52 acres and it all drains into the Bayfilter vault, the acreage

is 49 acres is impervious, and 3 acres are considered vegetated. The site is

considered urban, commercial-institutional use.

iii. Describe pretreatment, bypass conditions, or other special circumstances at the

test site: For RMHS: A Bayseparator unit was used for pretreatment, sampling

equipment was located around the Bayfilter to evaluate the performance of the

filter independently. The system was designed to treat the Water Quality volume

and bypass larger events around the Bayfilter system. For Grandview: no device

5

was used for pretreatment, sampling equipment was located around the Bayfilter

to evaluate the performance of the filter independently. The system was designed

to treat the Water Quality volume and bypass larger events around the Bayfilter

system. For Woodinville: A 5K Bayseparator unit was used for pretreatment,

sampling equipment was located around the Bayfilter to evaluate the performance

of the filter independently. The system was designed to treat the Water Quality

volume and bypass larger events around the Bayfilter system.

iv. Provide the number of storms monitored and describe the monitored storm events

(amount of precipitation, duration, etc.): For RMHS: 20 storm events qualified,

See Table 6-1 on page 20 of the report for more detailed precipitation/duration

data. For Grandview 8 storm events qualified, and for Woodinville 10 storm

events qualified, see the TER report for more detailed information on

precipitation and duration.

v. Describe whether or not monitoring examined seasonal variation in MTD

performance: No seasonal variation observed for either testing location (MD or

WA).

vi. If particle size distribution was determined for monitored runoff and/or sediment

collected by the MTD, provide this information: For RMHS: PSD was conducted

four times during the study, See Discussion on Page 29 and 30 along with

information on Figure 6-1 and Table 6-10. For Grandview and Woodinville, PSD

information is detailed in Tables 27 and 28 of the report.

9. MTD History:

How long has this specific model/design been on the market? 8 years (2006)

List no more than three locations where the assessed model size(s) has/have been

installed in Virginia. If applicable, provide permitting authority. If known, provide

latitude & longitude:

- Potomac Yard, Alexandria, VA- City of Alexandria;

- Fordson Place, Alexandria- Fairfax County;

- Fort Lee Army Base, Hanover, VA- Prince George County

List no more than three locations where the assessed model size(s) has/have been

installed outside of Virginia. If applicable, provide permitting authority. If known,

provide latitude & longitude:

- Harmony Place, Bowie Maryland, Prince Georges’ County;

- Paint Branch High School, Burtonsville, Maryland, Montgomery County;

- Woodinville, Washington State DOE.

10. Maintenance:

6

What is the generic inspection and maintenance plan/procedure? (attach necessary

documents): Immediately after installation and construction closeout, followed by 6

months after initial installation, and then followed by annual inspections. See

attachment.

Is there a maintenance track record/history that can be documented?

No, no track record.

Yes, track record exists; (provide maintenance track record, location, and sizing of

three to five MTDs installed in Virginia [preferred] or elsewhere):

- Archstone 12, Rockville, Maryland; Last Maintained: May,2013, System Installed

October, 2008

- Richard Montgomery High School, Montgomery County, Maryland; Last Maintained

June 2013; System Installed December 2008.

- Trinity Church, William Street, Fredericksburg, VA; Last Maintained April 2010,

Mini Filter Drain Down Modules changed out (not filters), System Installed June

2009

Recognizing that maintenance is an integral function of the MTD, provide the following:

amount of runoff treated, the water quality of the runoff, and what is the expected

maintenance frequency for this MTD in Virginia, per year?

Maintenance on the Bayfilter cartridge is site dependent, as different sites produce

different pollutant volumes and types. A recent evaluation by AAA Stormwater

Management Facilities Repair Group has produced an estimate of an average of 4 to 5

year life. BaySaver recommends assuming an average maintenance interval of between

3-5 years from a moderate to light anticipated pollutant load respectively.

Total life expectancy of MTD when properly operated in Virginia and, if relevant, life

expectancy of media:

One hundred plus (100+) years, or the life of the concrete structure. BayFilter systems

are always restored to an “as new” condition when fully maintained and cartridges are

replaced. The cartridges are exchanged and the vault fully cleaned at each

maintenance, this is important because many filtration practices collect pollutants deep

in the media, but do not change the entire media layer at maintenance, unless this “less

than as new” maintenance procedure is tested there can be no assurance that the device

continues to operate at design efficiencies after this type of maintenance.

For media or amendments functioning based on cation exchange or adsorption, how long

will the media last before breakthrough (indicator capacity is nearly reached) occurs?

This is non-applicable for Bayfilter cartridges, no breakthrough can occur, and the

system is maintained to “as new” condition with each maintenance operation. The

7

BayFilter cartridges will stop flowing / filtering when total maintenance has been

disregarded and effluent flow rate falls off rapidly. This prevents release of pollutants

due to pipe-lining or media breakthrough, and provides a clear indicator that the

cartridges must be exchanged.

For media or amendments functioning based on cation exchange or adsorption, how has

the longevity of the media or amendments been quantified prior to breakthrough (attach

necessary performance data or documents)?

As the BayFilter matures, the efficiency increases slightly, which is a clear indicator that

breakthrough does not occur. Other than testing over a one year period, there has been

no longer term testing of the BayFilters TP removal, ionic exchange capacity.

Considering that the TP removal data increases over time (longer use) there is no

indication that the ionic capacity is a limiting factor. Extreme loads of dissolved TP,

that would not be expected in stormwater may cause the media to reach ionic saturation,

however since this level of loads are extraordinary and unexpected in normal conditions

no further ionic capacity testing has been performed.

Is the maintenance procedure and/or are materials/components proprietary?

Yes, proprietary

No, not proprietary, filters can be changed by anyone

Maintenance complexity (check all that apply):

Confined space training may be required for maintenance of some systems

Liquid pumping and transportation

Specify method: Standard Vactor Truck

Solids removal and disposal

Specify method: Conventional Landfill

Other noteworthy maintenance parameter (describe):

11. Comments

Include any additional explanations or comments:

The Bayfilter technology has been submitted nationally for use as an advanced

stormwater device. New Jersey, Washington, and Maryland are the major states we have

sought approval for use. Currently, we are in the final stage of achieving our General

Use Level Designation (GULD) Phosphorus, Enchanced (Metals), and O&G for the

Bayfilter in Washington State using the TAPE protocol. We have included the final

report of the Phosphorus Data for this Virginia submittal.

We have not met the TARP threshold of enough qualifying storms with sufficient

Dissolved Copper loads to meet the WDOE Enhanced treatment levels (Dissolved Zinc

has been met). With the Pacific Northwest is now in its “Dry Season” and more

qualifying storms are unlikely until late September 2014. BaySaver has submitted to

Washington State Department of Ecology (WDOE) the Technical Evaluation Report

(TER) for a GULD approval for TP as well as Oils and Grease as the TAPE Testing

exceeds those performance thresholds.

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If Virginia is going to accept TP data from any source other than WDOE, we believe that

this report should be considered as evidence that the BayFilter exceeds the requirements

for obtaining the interim 50% TP removal rating.

12. Certification

Signed by the company president or responsible officer of the organization:

“I certify that all information submitted is to the best of my knowledge and belief true,

accurate, and complete.”

Signature:

Name: Brian Rustia

Title: Eastern Division Manager

Date: July 10, 2014

NOTE: All information submitted to the department will be made publically accessible

to all interested parties. This MTD registration form will be posted on the Virginia

Stormwater BMP Clearinghouse website.

B A Y S A V E R T E C H N O L O G I E S , I N C .

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Maintenance of the BayFilter™ System The BayFilter™ system requires periodic maintenance to continue operating at the design efficiency. The maintenance process comprises the removal and replacement of each BayFilter™ cartridge and drain down module and the cleaning of the vault or manhole with a vacuum truck. BayFilter™ maintenance should be performed by a BaySaver Technologies, Inc. certified maintenance contractor.

The maintenance cycle of the BayFilter™ system will be driven mostly by the actual solids load on the filter. The system should be periodically monitored to be certain it is operating correctly. Since stormwater solids loads can be variable, it is possible that the maintenance cycle could be more or less than the projected duration.

The BayFilter systems in New Development applications are designed to treat the WQv in 24 hours initially. Later in the cycle these cartridges will flow at a slower rate, and when the WQv does not drain down within +/- 40 hours after the storm event, the system must be maintained.

When a BayFilter™ system is first installed, it is recommended that it be inspected every six (6) months. When the filter system exhibits flows below design levels the system should be maintained. Filter cartridge replacement should also be considered when sediment levels are at or above the level of the 4 inch manifold system. Please contact the BaySaver Technologies Inc. Engineering Department for maintenance cycle estimations or assistance at 1.800.229.7283.

Chapter

4

B A Y S A V E R T E C H N O L O G I E S , I N C .

23

Maintenance Procedures

1. Remove the manhole covers and open all access hatches.

2. Before entering the system make sure the air is safe per OSHA Standards or use a breathing apparatus. Use low O2, high CO, or other applicable warning devices per regulatory requirements.

3. Using a vacuum truck remove any liquid and sediments that can be removed prior to entry.

4. Using a small lift or the boom of the vacuum truck, remove the used cartridges by lifting them out.

5. Any cartridges that cannot be readily lifted directly out of the vault should be removed from their location and carried to the lifting point using the Trolley system installed in the Vault (if applicable).

6. When all cartridges and drain down modules are removed, remove the balance of the solids and water; then loosen the stainless clamps on the Fernco couplings in the pipe manifold; remove the drain pipes as well. Carefully cap the manifold and the Fernco’s and rinse the floor removing the balance of the collected solids.

7. Clean the manifold pipes, inspect, and reinstall.

8. Install the exchange cartridges and close all covers.

9. The used cartridges must be sent back to BaySaver Technologies, Inc. for exchange/recycling and credit on undamaged units.