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.

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
yrong@waterboards.ca.gov

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. •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. 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. 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. Regional Water Quality Control Board
2. NPDES permitting
•Industrial facilities
•Municipal waste water treatment
•general permit (by category)

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. 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. 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. 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. 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. 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:
www.waterboards.ca.gov/water_issues/programs/ust/cleanup/docs/final
_chemical_oxidation_technologies.pdf

13. Typical full-scale in situ Injection
system layout
Full-
Scale
Injection
Oxidant Storage
Activator Tank
Tank
Batch Tank

14. In-situ remediation injection accident

15. In-situ remediation injection accident

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 http://www.waterboards.ca.gov/losangeles/board_decisions/adopted_orders/(under WDRs, Order No. R4-2014-0187)

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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. Thank You!!
Questions?