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[Guest Speaker] Yue Rong - GEOs Gas Thermal Remediation Workshop Series - Los Angeles (Nov 2014)


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In-situ groundwater remedial technologies have been recently used more and more. To regulate the injection materials to groundwater, the California Regional Water Quality Control Board uses the Waste Discharge Requirements (WDRs) to permit the injection materials. This presentation is to review the contents of the new version of 2014 WDRs (R4-2014-0187) that was just adopted on September 11, 2014 by the Los Angeles Regional Water Quality Control Board, and to provide an overview of the process used to select materials permitted for in-situ remediation injection and to apply the WDRs.

Published in: Environment
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[Guest Speaker] Yue Rong - GEOs Gas Thermal Remediation Workshop Series - Los Angeles (Nov 2014)

  1. 1. Los Angeles Workshop by GEO Regulatory Update on Los Angeles Regional Water Quality Control Board’s Injection Permit of Waste Discharge Requirements (WDRs) (2014) November 12, 2014 Yue Rong Los Angeles Regional Water Quality Control Board
  2. 2. California Environmental Protection AgencyCal-EPA •State Water Resources Control Board (including 9 Regional Boards and a Drinking Water Division) •Air Resources Control Board •Department of Pesticide Regulations •Department of Toxic Substances Control (DTSC) •Office of Environmental Health Hazard Assessment (OEHHA)
  3. 3. •Region 1: North Coast •Region 2: San Francisco Bay •Region 3: Central Coast •Region 4: Los Angeles •Region 5: Central Valley •Region 6: Lahontan •Region 7: Colorado River Basin •Region 8: Santa Ana •Region 9: San Diego Regional Water Boards
  4. 4. Regional Water Quality Control Board Main Functions: 1.Develop regional water quality plan 2.Issue discharge permit (National Pollutant Discharge Elimination System, i.e.,NPDES) 3.Clean up pollution sources that threaten water quality
  5. 5. Regional Water Quality Control Board 1. Water Quality Control Plan (basin plan): •Water beneficial uses (e.g., municipal usage, industrial usage, recreation, aquaculture, wetland habitat, etc.) •Water quality objectives (numerical) •Implementation plan
  6. 6. Regional Water Quality Control Board 2. NPDES permitting •Industrial facilities •Municipal waste water treatment •general permit (by category)
  7. 7. Regional Water Quality Control Board 3. Cleanup program: •Petroleum hydrocarbons (gasoline) •Other pollutants: chlorinated solvents, heavy metals, emerging compounds (e.g., perchlorate, Chromium VI) •Brownfield sites for city redevelopment
  8. 8. Regional Water Quality Control BoardHow are the policy and cleanup standard set? •Legislation and laws •Use of science, staff recommendations •Public participation (all stakeholders) •Board meeting adoption (public forum)
  9. 9. Regulatory Permitting for Groundwater In-situ Remediation •In California, the permit is the Waste Discharge Requirements (WDRs) •Industry used for more in-situ groundwater remediation •More economical and less disturbing •Need to regulate the injected compounds to the water of the State •General WDRs can be issued by the Water Board Executive Officer, therefore, more efficient
  10. 10. In-situ Chemical Injection•In-situ Chemical injection is a treatment technology that uses chemicals or micro-organism to destroy contaminants in groundwater. Injection wells are installed at the source area containing high concentrations. •Injection of: •oxidation/reduction compounds (e.g., hydrogen peroxide (H2O2)) •surfactant (like soap) •activated carbon (like sorbent) •zero-valent iron (nano technology) •micro-organism (like bacteria)
  11. 11. In-situ bio-injection •Inject oxygen (bio-venting) = encourage native bacteria to grow•Inject oxygen generating chemicals •Inject man-made microbial = introduce non-native bacteria to grow•Inject bacteria nutrients•Bio-GAC •Combination of all above
  12. 12. Typical In-Situ Injection Schematic Removed leaking tank Specialized Injection Trailer Saturated Zone Water supply well GW flow direction Unsaturated zone (vadose zone) Oxidant injected into dissolved contaminant plume P/T monitors PVC wells Image source: _chemical_oxidation_technologies.pdf
  13. 13. Typical full-scale in situ Injection system layout Full- Scale Injection Oxidant Storage Activator Tank Tank Batch Tank
  14. 14. In-situ remediation injection accident
  15. 15. In-situ remediation injection accident
  16. 16. General Waste Discharge Requirements (WDRs) o9/11/2014, Los Angeles Regional Water Quality Control Board adopted Renewal of General WDRs (2014) oLast General WDRs were adopted in 2007 oThe WDRs authorized the use of various materials to be injected into groundwater for in- situ remediation oSeen at WDRs, Order No. R4-2014-0187)
  17. 17. General Waste Discharge Requirements (WDRs) Advantages a) simplify the application process for dischargers, b) allow more efficient use of Regional Board staff time, c) minimize the time needed for Regional Board to adopt WDRs, d) enhance the protection of surface water quality by eliminating the discharge of treated groundwater to surface waters, e) preserve water resources by re-injection of treated groundwater into aquifers, f) provide a level of protection comparable to individual, site-specific WDRs, g) embrace new technologies, h) Consistent with practice of other Regional Boards
  18. 18. Changes in 2014 version oAdd chemicals and micro-organism to promote in-situ remediation -2014 list contains ~80 materials -2007 WDRs contains ~40 materials oDelegate Executive Officer (EO) authority to revise the list of materials for injection periodically
  19. 19. General WDR working group oIn 2013, a working group established including stakeholders from material manufacturer, water purveyor, environmental consultant, local regulatory agency, and academia for peer review and input from the regulated community oThe group has met 9 times since oPrimary function: to review information and prepare the remedial injection material list
  20. 20. Criteria for addition of materials a. Effective to remediate targeted constituents; b.Minimum degradation of water quality that will not cause or contribute to exceedance of water quality objectives (WQOs); c. Protective of human health and safety; d.Availability on the market for a minimum of three years.
  21. 21. Documents or materials needed to be included in the General WDRs -Narrative summary of the compound -MSDS -3 case studies to demonstrate it works
  22. 22. The General WDRs would allow the following materials to be used for in-situ remediation purposes 1.Chemical Oxidants 2.Chemical Oxidant Activators 3.Aerobic Bioremediation Enhancement Compounds 4.Anaerobic Degradation Enhancement Compounds 5.Reduction Degradation Enhancement Compounds 6.Metals Precipitation / Stabilization 7.Surfactants/Co-solvents 8.Bio-augmentation Organisms 9.Tracer Study Compounds 10.Buffer Solutions and pH Adjusters
  23. 23. Pros: 1.Clear in terms of which compound is in and which is out 2.Easy for staff to evaluate 3.Can be issued quickly by Executive Officer therefore faster site cleanup Cons: 1.Difficult to add new products 2.Difficult to evaluate in multiple compounds application 3.Slower to issue WDRs for compounds that are not listed in the WDRs, therefore slow down site cleanup. Pros and Cons for this WDRs
  24. 24. General WDR Rule-making Process 1.Comply with CEQA process and Califorinia Water Code requirements (sections 13260 and 13263) 2.Public notice must comply with CEQA process (draft for public comments and respond to the comments) 3.Present to the Regional Water Quality Control Board in a public form for adoption of the final version 4.Once adopted by the Board, the Executive Officer is given the authority to issue the General WDRs. The Executive Officer’s decision is based on staff recommendations.
  25. 25. General WDR Application Process 1.Furnish a site-specific Remedial Action Plan (RAP) and get approved by the lead regulatory agency 2.Go on LARWQCB website for WDR information (under Board Decision => adopted orders (WDR R4-2014-0187) 3.Fill out Application Form 200 (for WDR) 4.Pay the fees 5.Send in the WDR Application Package (form, fee, and approved RAP) to LARWQCB 6.Conduct field work once the General WDR is approved
  26. 26. General WDR Application Evaluation 1.Approval of the site-specific remedial action plan (prior) 2.Regulatory staff evaluation of the WDR Application 3.A cover letter to approve the Application of the General WDR 4.A site-specific groundwater monitoring program, which specifies the compounds to be analyzed, the monitoring locations (usually upgradient vs. downgradient wells and temporal patterns after the injection, etc.) 5.Annual fee to pay until the WDR is terminated
  27. 27. 1.What happens if the injection compounds are not listed in the General WDRs (R4-2014-0187)? Answer: apply for site-specific WDRs, which will go through the CEQA public notice process. 2.What happens if Responsible Party (RP) wants to change the compounds of injection? Answer: if the compounds on the WDRs list, => apply for an amendment. if the compounds not on the list, => apply for site-specific WDRs. Common questions
  28. 28. 3. How can a new in-situ chemical be added to the General WDRs? Answer: wait until next update of General WDRs list, and will go through the peer review and screening criteria (1) Provide information -summary of the compound -MSDS -3 case studies to demonstrate it works (2) Evaluate against that 4 screening criteria by staff and working group a. Effective to remediate targeted constituents; b. Minimum degradation of water quality that will not cause or contribute to exceedance of water quality objectives (WQOs); c. Protective of human health and safety; d. Availability on the market for a minimum of three years. Common questions (2)
  29. 29. 4. Is the General WDR good for groundwater re- injection? Answer: Yes. 5. Does RP allow to inject treated groundwater with remedial materials back to the aquifer? Answer: Yes. But, only in the “treatment” zone. Common questions (3)
  30. 30. Thank You!! Questions?