Post on 14-Jul-2015
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
California Environmental
Protection Agency
Cal-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)
• 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
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
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
Regional Water Quality Control Board
2. NPDES permitting
• Industrial facilities
• Municipal waste water treatment
• general permit (by category)
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
Regional Water Quality Control Board
How are the policy and cleanup standard
set?
• Legislation and laws
• Use of science, staff recommendations
• Public participation (all stakeholders)
• Board meeting adoption (public forum)
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
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)
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
Typical In-Situ Injection
SchematicRemoved leaking tank
Specialized
Injection Trailer
Saturated ZoneWater
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
Typical full-scale in situ Injection
system layout
Full-
Scale
Injection
Oxidant Storage
TankActivator
Tank
Batch Tank
In-situ remediation injection accident
In-situ remediation injection accident
General Waste Discharge
Requirements (WDRs)o 9/11/2014, Los Angeles Regional Water Quality
Control Board adopted Renewal of General WDRs (2014)
o Last General WDRs were adopted in 2007
o The WDRs authorized the use of various materials to be injected into groundwater for in-situ remediation
o Seen at http://www.waterboards.ca.gov/losangeles/board_decisions/adopted_orders/ (under WDRs, Order No. R4-2014-0187)
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
Changes in 2014 version
o Add chemicals and micro-organism
to promote in-situ remediation
- 2014 list contains ~80 materials
- 2007 WDRs contains ~40 materials
o Delegate Executive Officer (EO)
authority to revise the list of
materials for injection periodically
General WDR working groupo In 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
o The group has met 9 times since
o Primary function: to review information and
prepare the remedial injection material list
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.
Documents or materials needed to be included in the
General WDRs
- Narrative summary of the compound
- MSDS
- 3 case studies to demonstrate it works
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
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
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.
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
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
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
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 groupa. 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)
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)
Thank You!!
Questions?