Post on 04-Feb-2021
Wastewater Alternative
Technology Acceptance
in Colorado
David Kurz, P.E.
Lead Wastewater Engineer
Engineering Section
CDPHE Water Quality Control Division
July 15, 2015
Objectives
Provide information to facilitate:
• Use of proven technologies in Colorado
• More efficient interactions between manufacturers, owners,
engineers, and the WQCD for design reviews.
• Better understanding of the process for alternative
technology acceptance
• Clarification of the role of pilot tests at domestic
wastewater treatment works
Clarifications
Domestic wastewater treatment = state design review
Industrial wastewater treatment = no state design review
Both require discharge permit
Regulatory Framework
Legislature – Colorado Water Quality Control Act
(Title 25, Article 8, C.R.S.) (25-8-702 – Site location and design review required for domestic wastewater treatment works)
WQCC – Regulation No. 22 (5 CCR 1002-22, revised 2009) (Site application, design review, in-kind replacement, pilot tests)
WQCD - Policies • Reg 22 Guidance document (August 2010)
• Policy 6 (WQSA-6 Multiple OWTS)
• Wastewater design criteria (Policy WPC-DR-1)
Steps in Review Process (WWTP Steps 1-4, Lift Station/Interceptor Steps 2-3)
1. Preliminary Effluent Limits (PELs) (WWTPs changing discharge, Permits Section, informs site location review)
2. Site Location Application (*local agency review first*, Engineering Section, informs CDPS permit)
3. Design Review (Engineering Section)
• Lift Station or Interceptor = Basis of Design Report (BDR) together with
Final Design
• WWTP = Process Design Report (PDR) then Final Design (possibly
streamlined final design review certified by design engineer §22.11)
4. Discharge Permit (Permits Section)
Site Application Review
• Review ability of proposed treatment process(es) to meet
the PELs or effluent limitations [§22.9(1)(g)]
• What criteria to be used for the design review phase?
• Already included in the adopted wastewater
design criteria (WPC-DR-1)
or
• Developed through an alternative technology
acceptance
Alternative Technology Acceptance
• New or non-conforming technologies not represented in the
wastewater design criteria (reconfiguration, combinations,
packages)
• Established or innovative technology with existing
compliance record
• Not for emerging treatment techniques without compliance
history
• Described in section 1.8.0 of the wastewater design criteria
Alternative Technology Process
• Manufacturer submittal of information in §1.8.0 of the
wastewater design criteria (e.g., engineering basis,
operating history)
• Timing = submit for alternative technology review as soon as
practical before a site application
• Alternative technology submittal checklist (see website)
• Alternative technology recognition statement for a specific
project (if for a specific project)
Alternative Technology Review
• Review history of successful operations
• Evaluate efficacy of technology in providing reliable
wastewater treatment under a range of operating
conditions throughout Colorado (elevations,
temperatures)
• Not just pass/fail or averages
• Develop appropriate criteria for technology design
review
Data!
• Document assumptions, calculations, process modeling
• Actual full-scale operating experience
• Pilot test work results (long periods, seasons)
• Limiting conditions (temperature, elevation)
• Reliability, sensitivity (influent variations, conditions)
Acceptance ≠ Design Approval
• Site location and design approval still required for
each location where use of accepted technology is
proposed (just as for other technologies in design
criteria)
Pilot Testing Authority
• Site location approval requirements in Amendment section
[§22.8(2)(vii)] provide for conducting pilot projects.
• Regulation 22 Guidance Document provides additional
descriptive information. [Page 62, line 2954]
• Pilot Test Plan is required.
• Limited period of up to 12 months, with possibility for one
extension of additional 12 months.
Note: “Pilot testing” in the wastewater regulatory realm is not the same as in the drinking water regulatory realm.
Pilot Testing Goals
• Goals and scale of pilot tests vary:
• Sidestream test of established technology to evaluate appropriateness
for a particular WWTF
• Testing of emerging technology without compliance track record
• For alternative technology evaluations where a compliance
history is not available:
• Much higher requirement for information to be provided by the pilot test
• Pilot test must provide adequate level of data to establish alternative
technology compliance record and design requirements
• Pilot test plan must be more robust
• Note: “pilot test completed = alternative technology
acceptance” is NOT an automatic conclusion
Tips to Avoid Pitfalls
• Use Reg. 22 Guidance and Wastewater Design Criteria
• Provide complete submittals with documentation
• Consider pre-meeting with Engineering Section
• Alternative technology identified early to David Kurz:
david.kurz@state.co.us or 303-692-3552
mailto:david.kurz@state.co.us
Website Tips
• http://www.colorado.gov/CDPHE/WQCD
• Facility Design and Approval
• Forms
• Domestic wastewater alternative technologies
= list with accepted technology letters
• Guidance (Regulation 22 guidance)
• Policies (design criteria)
• Regulations (WQCC – Regulation 22)
Innovation Ideas
• Retrofit: Anoxic Basin on RAS line with carbon source
diverted from influent wastewater stream; benefit is higher
MLSS, smaller basin and available carbon source
• Zero liquid discharge at East Cherry Creek reverse osmosis
drinking water plant. Distillation of waste stream.
Highest Potential Needs
• Larger facilities:
sulfate, selenium, dewatering for biological phosphorus
• Medium facilities:
assistance for lagoons with ammonia and beyond
• Small facilities (discharge to groundwater):
low cost/high treatment/easy operations options to meet
effluent limit of 10 mg/L TIN
TDS
Barriers and Hurdles
• Poor testing prior to bringing to the state.
• Come with defensible evidence of operations
for all conditions
Suggestions to Help Innovation Needs
• Collaboration on innovation and pilot tests
• Various entities request pilot tests and sometimes we see
the same for different facilities. May or may not need
separate pilot tests.
• An operating WWTF willing to pilot different ideas that
could possibly coordinate with other facilities to test viable
technologies for all to see and possibly use (publish results).
• Example - Test a technology at one representative facility
where entities can contribute $ and ideas about how the
work will be completed.
Questions?