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?