Australian SQID [Stormwater Quality Improvement Device ... · The reason Task 1 for SWEPP and Stage...

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Publication and Contact Information This report is available on the SPEL website with other supporting documentation at http://spel.com.au/

Australian SQID [Stormwater Quality Improvement Device] Assessment Panel [ASAP]

Process Overview BY: Andy Hornbuckle – National Sales Manager Dr Darren Drapper – Research & Development SPEL Environmental Please note we have prepared this paper as a working document to facilitate the Australian stormwater industries progress to a defined, equitable and sustainable, nationally accredited SQID performance assessment pathway. We are not purporting that the framework outlined in this document is not without flaw, rather that which it is a proven and sound foundation that respected industry peers can work with.

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Background Stormwater Quality Improvement Devices (SQIDs) have been, and continue to be, installed at thousands of locations

across Australia, with the objective to protect our waterways from stormwater pollution. There is, however, varying

opinions on aspects relating to SQIDs – including how effective these devices are at removing pollutants and whether

differing testing procedures (used to demonstrate their performance) are relative to the actual field/operational

conditions in Australia.

There is no Australian industry or government accepted and recognised pathway for the SQIDs performance to be

assessed with equitable accuracy. In the absence of this governing body and framework, Regulators lack the

confidence to approve the installation of emerging technologies, and the manufacturers have no clear methodology

to test and manufacture too with confidence that the final results will be acceptable to the Regulators.

The impact of this conundrum is that the industry has very limited treatment tool options due to the length of time

that it takes for an emerging technology to be accepted on its merits.

Music modelling guidelines 2010 p 42 has been interpreted by many Regulators that the only acceptable way of

proving a SQID is field testing in Australia. To effectively field test one device for 12 – 15 qualifying rain events is an

~AUD $250,000 – $350,000 three year project.

As stated previously, the absence of a clear national approval process, results in the national industry problem of

many Regulators not being sure how to assess or accept the performance of proprietary and non-proprietary

treatment devices, therefore there is a lack of courage and willingness to grant field testing sites to emerging

technologies. Therefore we have a “chicken in the egg” situation where Regulators are asking for field test data on a

product but are not willing to grant field test sites to be able to prove the products.

Furthermore, due to a lack of clear, accepted lab and field test protocols, there is no certainty that when a vendor has

invested in the research, that the data will be accepted as valid by the Regulators and industry peers.

In the face of the lack of clarity of protocol, and working for 2 years with Sunshine Coast City Council, Redlands City

Council, Gold Coast City Council and Moreton Bay Regional Council, SPEL has proactively launched 7 field Testing Sites

at different locations in Australia. At SPEL we take this opportunity to sincerely thank the aforementioned Regulators

relevant personnel for having the courage to grant us the opportunity.

SPEL has a wide range of products targeting the whole spectrum of stormwater pollutants, so we are evaluating each

device for performance individually and in treatment train.

There needs to be a mechanism that allows Councils to easily and confidently facilitate the Australian field testing of

new products.

Frustrated with the stalemate position of the industry, SPEL launched a series of Industry Innovation Forums

nationally in an attempt to escalate action with industry peers who could help make a difference.

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The first forum was in October 2013 with Mr Tom Pank as the guest speaker;

We videotaped the Sydney forum and the recording is available via the below link;

http://spel.com.au/spel-industry-forum/#tom-pank

The second forum was in November 2013 with Professor Carsten Dierkes as the guest speaker; as per below link;

http://us6.campaign-archive1.com/?u=e05366f957ee8cbc8e5e922d1&id=8493b9a1e3&e=

Unfortunately we were unable to get a recording of this conference.

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On Thursday, 10th April Stormwater Queensland hosted a forum on this topic titled “2014 The Performance of

Proprietary SQIDs - The Facts, The Fiction and The Future Testing Protocol”

At this forum a range of issues were discussed including:

· The appropriateness of existing testing procedures applied to assess the performance of SQIDs.

· The accuracy of the reported treatment performances of SQIDs and their applicability to Queensland conditions.

· The suitability of advice within industry-accredited guidelines in relation to SQIDs.

· The development of an Australian Protocol for the assessment of SQIDs (currently being undertaken by Stormwater

Australia).

· The implications that this protocol may have on stakeholders within the industry.

· Perspectives from consultants, asset managers and SQID proprietors.

This forum was recorded and the videos can be found at http://www.siaqueensland.info/previous_events.shtml

Panel Members included:

o Andrew Allan, Stormwater Australia

o Stephen D Baker, Rocla

o Andy Hornbuckle, SPEL Environmental

o Dr Charles Kelly, Humes

o Andrew Macklin, Ecosol

o Stephen Turfrey, Redland City Council

o Tony Weber, BMT WBM

o Michael Wicks, Stormwater 360

Proposed Roadmap

At this forum Andy Hornbuckle the National Sales Manager for SPEL Environmental proposed a roadmap to the future

for the Australian stormwater industry based on the American Washington State Dept. of Ecology model.

A video of this speech can be found at; http://spel.com.au/spel-industry-forum/#andy-hornbuckle

Based on SPEL’s international experience we feel Australia needs to move on from the current parochial approach

and draw on United States, NZ and European Experience.

SWEMA & WaSDoE

The Stomwater Equipment Manufacturers Association [SWEMA] consists of prominent proprietary manufacturers in

America. They have formed the committee and spent two years developing a framework and protocol for Lab & Field

testing.

Washington State Department of Ecology and the New Jersey Corporation of Advanced Technology are operational

organizations that independently validate the performance of proprietary and non-proprietary devices and provide

industry with proven product removal rates.

http://www.siaqueensland.info/previous_events.shtml

http://spel.com.au/spel-industry-forum/#andy-hornbuckle

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THE STATUS QUO

The current working group [CWG] of SAQ forum panellists needs to develop the terms of reference [TOR] for an

evaluation protocol panel referred to from hereon as SWEPP.

The current working group needs to;

1. Agree on what the approval process pathway will need to look like. SPEL’s vision is proposed below.

2. Identify and formalise what SWEPP & ASAP Terms Of Reference need to be

3. Identify and formalise the funding mechanism for SWEPP & ASAP

4. Identify and set scope of work packages for the SWEPP tasks

a. Develop lab and field testing protocols/guidance manuals

b. Develop Quality Assurance Project Plan [QAPP] template

5. Identify and set scope of work packages for ASAP

a. Scope job description and engagement contract for ASAP panellist

b. Identify and undertake PULD evaluation of existing products and research

6. Formally approach in a structured and uniform way relevant industry peers and regulators and engender

their support. Such as;

a. Series of state workshops with key Regulators at which the CWG and Stormwater Australia can

present the proposed roadmap

b. Collate feedback and move forward accordingly

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SPEL PROPOSES A WORKING GROUP/PANEL CALLED SWEPP

Stormwater Australia will be the administrator for the working group/panel in Australia, called the Stormwater

Evaluation Protocol Panel [SWEPP]. SWEPP will consist of;

a) one representative for each vendor and

b) Stormwater Australia state committee representatives,

c) minimum three council/regulator representatives and a

d) minimum of three active university employed academics

SWEPP will be funded by the application fees of the vendors, in combination with Stormwater Australia.

Task 1 for SWEPP is to review current internationally used protocols and they set the bench mark Australian test

protocols for proprietary and non- proprietary devices and the different target pollutants.

This panel can agree on the field and lab test protocols required to test stormwater filters, hydrodynamic separators

and other stormwater treatment devices as required. This project can start immediately and operate in conjunction

with Stage 1 of ASAP.

The reason Task 1 for SWEPP and Stage 1 for ASAP need to happen in parallel is because the ASAP experts that are

reviewing currently available data and working methods will be able to expertly advise SWEPP based on their new

breadth of knowledge as a result of getting down to the nitty gritty of different products and different methodology.

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ASAP - PULD

Stage 1 for ASAP is to begin assessing SQID’s for Preliminary Use Level Designation.

SWEPP engages a list of experts in the industry to form the ASAP. Ideally ASAP panelists will contribute to SWEPP.

This would include people like Tony Weber, Shaun Leinstar, Terry Lucke, Ashantha Goonetilleke, Roger Tomlinson,

Tim Fletcher, Peter Newland, Simon Beecham, James Ball, Ted Gardiner, Murray Powell etc

According to WaSDoE experience it is important to have a large number of industry experts available to choose from

due to work load and juggling potential conflicts of interest.

The objective of stage one is to facilitate by peer review immediate approval progress of products submitted by

vendors based on Australian and International Lab & Field results.

ASAP needs to consider potential conflict of interest situations when selecting five members for a particular project.

Five experts from ASAP [minimum one each regulator, stormwater industry peer and university employed academic

representatives] review all currently available data on a product, draft a defendable paper based on what they have

reviewed, and publishes the nationally acceptable removal rates on the SWEPP-ASAP website.

The published removal rates will set the threshold for how that product is to be modelled in MUSIC.

This gives the vendor permission to do up to 15 installations in each Australian State in a 3 year timeframe, whichever

comes first. Linking the PULD with a timeline is critical to ensure that the vendor keeps moving forward with the

program, or they lose their status to market that particular product.

In the event that a vendor disputes the recommendation of their five ASAP panelists, they can reapply for a lessor fee,

for another different three ASAP panelists to assess and advise if their argument is scientifically defendable. It is not

open to a vendor to challenge the ASAP a third time.

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CULD - GULD

Upon reaching 15 qualifying rain events on one field test site the vendor can then apply for Conditional Use Level

Designation with revised proven performance data.

CULD approval opens this market to 45 installations per state in a six year window, with a view to obtaining one more

field test site in a major state/market to further define product applicability to the local and regional conditions.

The final stage is General Use Level Designation, which will be national approval by ASAP, based on 2 field test sites

each with 15 qualifying rain events.

The product is now industry approved for unlimited installation. In the event that modification is made to the product

the process starts again.

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Doug Howie Workshop

After the progress made at the Stormwater Queensland Forum, SPEL moved quickly to facilitate Mr Doug Howie from

the Washington State Department of Ecology to visit Australia in May 2014 and speak nationally on the progress and

the problems they have encountered with their SQID approval program.

The cities that Doug visited and engaged with the industry can be viewed at this link. Most notably he was received as

a keynote speaker at the Stormwater Victoria conference.

http://us6.campaign-archive1.com/?u=e05366f957ee8cbc8e5e922d1&id=117479c6cb&e=0f510c9dca

SPEL was able to videotape the Sydney conference so that industry members and peers who were unable to attend

Doug’s valuable experience can watch it via this link;

http://spel.com.au/spel-industry-forum/#doug-howie

The rest of this document is a detailed attempt to tailor the TAPE Process Overview document for Australian requirements. Introduction

This document provides an overview of what the potential Australian SQID Assessment Panel (ASAP) process for vendors, designers, and manufacturers (referred to as 'proponents') who wish to have their stormwater treatment technologies certified in Australia by the ASAP program. This guide walks proponents through the ASAP certification process, providing an overview of the program and the specific steps required for certification.

Specific guidance for designing, executing, and reporting on performance monitoring needs to be detailed in protocols developed by SWEPP. Reference documents could include: Technical Guidance Manual for Evaluating Emerging Stormwater Treatment Technologies Technology Assessment Protocol - Ecology (TAPE) (Publication 11-10061) (aka, TAPE Technical Guidance Manual) Guidance for Evaluating Emerging Stormwater Treatment Technologies Technology Assessment Protocol - Ecology (TAPE) (Publication 02-10-037) Guidelines _ for Preparing Quality Assurance Project Plans _ for Environmental Studies (Publication 04-03-030).

SWEPP needs to define a Fee Structure for Program Participation.

Overview of ASAP

The ASAP program provides a peer-reviewed regulatory certification process for emerging stormwater treatment technologies. The ASAP program is administered by Stormwater Australia, with assistance from members of SWEPP, which provides stormwater management assistance including guidance on certification of emerging treatment technologies. To achieve GULD status, performance must be demonstrated by proponents field testing their stormwater treatment technology on catchments representative of the most common application for the device and under rainfall conditions typical of Australia. The testing protocol is specifically designed to evaluate flow-through best management practices (BMPs) with relatively short detention times, and may not be suitable for all stormwater treatment technologies. Based on ASAP technical reviews, ASAP advises industry regarding which stormwater treatment technologies meet performance goals and therefore, will be added to a/the list of approved technologies on the SWEPP/ASAP website.

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Criteria for Certification

POLLUTANT TYPICAL EFFLUENT CRITERIA

TSS - % 80

TP - % reduction 60

TN - % reduction 45

TPH – mg/L <10

GP - >5mm - % reduction 90

Zn - % reduction 60

Cu - % reduction 30

Steps to certification Step 1. Complete the Emerging Stormwater Treatment Technologies: Initial Application for Certification (Initial Application). The Initial Application includes information about your technology and the performance data you have collected to help us evaluate whether your technology shows promise of meeting the ASAP performance goals. When we receive a completed Initial Application, we will assign your technology a case number and contact you if any additional information is required. ASAP will assign five members of ASAP to review and provide comments on the application. If after reviewing this information ASAP finds that your technology shows promise of meeting typical Australian stormwater treatment goals, ASAP will grant your technology either a pilot or a conditional use level designation (PULD or CULD). Our goal is to grant a use level designation within one to two months from receipt of your complete Initial Application. Once the proponent finds a suitable monitoring site and notifies ASAP, the deadlines for QAPP and TER submittal are set.

Initial Application

Submit two (2) hardcopies, and one text-searchable electronic (.pdf) copy Your Initial Application must include as much of the following information as possible. If insufficient information is provided, your Initial Application will be returned without review, pending receipt of adequate information:

Description of physical, chemical, and/or biological treatment functions.

Design drawings/photographs. Description of construction materials. Equipment dimensions. Design flow rate.

Explanation of site installation requirements (e.g., necessary soil characteristics, hydraulic grade requirements, depth to groundwater limitations, utility requirements).

Description of any pretreatment requirements or recommendations. Description of any components of the treatment system that may contain copper, zinc, or phosphorus or any

other constituent of concern that might contribute to increased pollutant concentrations in the effluent.

Description of any components (i.e., concrete) that may result in pH fluctuations in the effluent. Detailed description of the sizing methodology.

Expected treatment capabilities. Maintenance procedures. Description of bypass process.

Comparison of size of laboratory unit to typical field units (if laboratory testing data are submitted). Raw water quality data. Summary of water quality data and removal calculations. Statistical analysis.

Flow rate(s) used for laboratory testing. Influent and effluent flow data.

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Storm event information. Any other information or data that will help determine if your treatment technology can meet or does meet

ASAP's performance goals.

Step 2. Design a performance evaluation study and write a QAPP. The study must generate performance data of sufficient quality and quantity to evaluate with adequate statistical power how the technology performs in the field. Detailed guidance for designing your study, including how to write the QAPP is provided in the TAPE Technical Guidance Manual and in Ecology's Guidelines for Preparing Quality Assurance Project Plans for Environmental Studies (Publication No. 04-03-030, Guidelines for Preparing QAPPs). SWEPP needs to modify this document for Australia. Finding a field site with suitable stormwater flows and influent ranges specified in the TAPE Technical Guidance Manual [SWEPP needs to prepare this document] and Table 1 of this document is often challenging; consequently, proponents are encouraged to identify sites early in the process of designing the study. Selecting multiple field sites is often advantageous to the proponent; the QAPP must address field conditions at each field site where data collection will occur. Local governments must submit a Notice of Intent [another document SWEPP needs to produce] form to SWEPP & ASAP for every PULD/CULD technology that is proposed for installation in their jurisdiction. QAPP Submit 2 hardcopies and 1 text-searchable electronic (.pdf) copy The completed QAPP will be reviewed by at least three experts chosen from ASAP. The ASAP members will address the following question: If the monitoring program described in the proponent's QAPP is substantively followed and completed, will the resulting data and statistical analyses allow ASAP to rigorously evaluate the technology's performance against the stated ASAP/SWEPP performance goals? The five ASAP panelists consolidate their summary report, the vendor agrees with it, and it is then published on the ASAP/SWEPP website. If there is substantial disagreement among the five ASAP panelists, ASAP may request that additional three ASAP members review the QAPP. The final decision to approve the QAPP rests with ASAP. The proponent must submit a QAPP that meets Ecology's QAPP guidance and ASAP Technical Guidance Manual [another document for SWEPP to write] requirements within six months of finding a suitable monitoring site and notifying ASAP. Within three months of receipt of the final QAPP, ASAP will complete the review and make a decision whether field testing can commence. Step 3. Install, operate, and monitor the technology at one or more field sites indicative of the most common catchment application for the product. Prior to the start of field-testing, the QAPP must be approved by ASAP. The approved QAPP must be used to guide project management during this phase of the certification process. While ASAP/SWEPP staff are available to discuss issues arising during the field study, the proponent's independent [University and/or Environmental Consultant] project team is responsible for monitoring the site(s) according to the QAPP. Step 4. Send ASAP the results. Upon completion of the field sampling, use the data analysis and statistical techniques described in your approved QAPP to summarize the results and write the TER. Instructions for completing the TER are found in the TAPE Technical Guidance Manual. Note that the field monitoring samples must be collected by an external professional third party to be delivered to a NATA registered lab. That third party prepares the data collection and analysis and key elements of the TER for all submittals before it is sent to ASAP for review. ASAP will review each TER for completeness and then ask at least five members of the ASAP to conduct a thorough examination of your results, interpretations, and findings. For consistency whenever possible, your TER will be sent to the same reviewers who evaluated your QAPP. Results of the external reviews will be compiled and a summary recommendation will be made to the proponent/vendor. When the vendor and the five ASAP panelists agree on the summary in principle, it will be published on the ASAP/SWEPP website. ASAP intends to complete the review of your TER and make a final certification decision within three months of

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receiving the TER. If/when the TER is approved by ASAP, the technology will be granted a GULD. At a minimum the GULD will identify the acceptable percentage removal for each different pollutant to be applied in MUSIC modelling, the design flow rate, and the required inspection interval.

Confidentiality

Proponents may request that certain records or other information be considered confidential. Such requests will be considered by ASAP. In order for such records or information to be considered confidential, the proponent must certify that the records or information is unique to the design and construction of the technology, or release to the public or to a competitor would adversely affect the competitive position of the proponent. The proponent must request that such records or information be made available only for the confidential use of ASAP. All monitoring data including, but not limited to, laboratory results and field measurements, QA/QC data, data qualifiers, and monitoring site information cannot be considered confidential. To make a request for confidentiality, the proponent must clearly mark only those pages that contain confidential material with the word "confidential" and submit these pages as a separate file to ASAP. Placeholder pages must be placed in the document that state "confidential material has been provided as a separate document to ASAP. The proponent must also provide a letter of explanation as to why these pages are confidential. ASAP will review the request and send notice to the proponent either granting or denying the confidentiality request. Proponents may request return of material if ASAP denies the request for confidentiality. At a minimum, requests for confidentiality require a 1 month review.

Potential Fee Structure based on TAPE FEE CATEGORY AMOUNT DUE Initial Application $2000 Upon submittal of

Initial Application QAPP review $4000 Upon submittal of final

QAPPa

TER review $6000 Upon submittal of final TERb

a. Fee must be paid before ASAP updates the website to reflect the change in the technology's status. Collection of fee does not guarantee approval of QAPP. b. Fee must be paid before ASAP updates the website to reflect the technology's new General Use Level Designation (GULD). Collection of fee does not guarantee approval of TER or guarantee GULD status.

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Australian SQID [Stormwater Quality Improvement Device ... · The reason Task 1 for SWEPP and Stage...

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