Desalination Concentrate Management Policy for the Arid West Bob RaucherStratus Consulting

Ed ArchuletaUniversity of Texas at El Paso

Scott ReinertEl Paso Water Utilities

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A Few Notes Before We Get Started…

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Today’s Presenters

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Edmund ArchuletaUniversity of Texas, El PasoFormerly, El Paso Water Utlities

Robert RaucherStratus Consulting

• Overview of El Paso desalination

• Project objectives and methods

• Need, opportunity, and value for inland desalting

• 30,000-foot review of Issue Papers

• Review of Workshop, El Paso, October 2012

• Key findings and recommendations

Presentation Overview

• Opened in 2007 to deal with:• Drought • Emergency situations • Growth• Brackish water intrusion

Kay Bailey Hutchison Desalination Plant

Project Objectives1. Describe barriers to concentrate

management (CM), focus on arid Southwest

2. Identify and explore potential solutions

3. Lay out potential paths forward for implementing solutions

• Develop issue papers and case studies to examine barriers:• Regulatory and permitting• Legal and other institutional/policy• Economic and financial• Technological• Hydrogeological

• Identify potential solutions to policy, regulatory, and permitting barriers

• Conduct expert workshop to further explore these topics

• Final report submitted July 2013

Overview and Methods

• Need: Freshwater withdrawals as a percent of available precipitation (2005)

Need, Opportunity, and Value . . .

Need: Projected Change in Drought Frequency

• Opportunity: Availability of brackish groundwater resources in the United States(TDS < 3,000 mg/L)

Need, Opportunity, and Value . . .

Opportunity: Brackish Water Availability

Value: Triple Bottom Line Analysis to Compare Alternatives

• Financial outcomes

• Social outcomes

• Environmental outcomes

Environmental (> $15.7M)

• Air quality related health risk reduction ($2.4M) • Supply reliability (+)• Climate-insensitive supply source (++) • Sustaining agricultural communities (+)

Social (> $2.4M)

Financial ($967M)• 74% cost saving to supply water to all EPWU

customers

• Carbon footprint reduction ($15.77M)• Energy savings 3.6M MWh• Air quality (+)• Groundwater quality (+)• Surface water (+)• Carbon footprint of piping (+)

El Paso Triple Bottom Line: Desal and Reuse appear Expensive, But Save Big $s in the End

Number of Desalting Plants by State(through 2010) source: Mickley 2012

• Inland desalting technically viable

• There is need, opportunity, and value

• Barriers to inland desalting:• Costs: declining, especially relative• Energy demands: growing efficiency• Concentrate (brine) management: the most significant remaining hurdle

• Concentrate management (CM) challenge that extends to water reuse and any facility that uses membrane processes.

First Step: Issue Papers, Key Findings

• Surface water discharge

• Wastewater treatment plant/sewer

• Land disposal (land application)

• Evaporation ponds

• Deepwell injection (DWI)

• High recovery (e.g., zero liquid discharge) and beneficial use

Options for Inland CM

• Surface Water Discharge or Wastewater Treatment Plant• Generally infeasible except in coastal settings with adequate dilution (NPDES permits)• Brine lines to coastal outfalls will facilitate discharge in some locations

• Land disposal/application• Environmental limitations due to impacts on soils, vegetation, habitat, underlying groundwater, etc.

• Evaporation Ponds• Limited to small scale, flat terrain settings with no flooding or over-topping risk • Expensive liner requirements to protect underlying groundwater• Solids and near solids may need ultimate disposal at landfill

• High recovery• Tends to be very energy intensive and expensive• New approaches being investigated

Most CM Options Impractical for Many Locations and Municipal Scale Operations

LINED EVAPORATION POND

• Regulated under Underground Injection Control (UIC) program, per SDWA• State primacy• Regional EPA

• UIC Class I, II, and V wells

Deepwell Injection

Injection Well JDF-3

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• Municipal wastes (wastewater)

• Industrial wastes (hazardous and non-hazardous)• Including desal concentrate and other drinking water treatment residuals

• Stringent requirements

• < 600 nationwide

Deepwell Injection: Class I

• Class II: Oil and gas

• Class V: Miscellaneous nonhazardous

• Class VII?? (precedent for new “classes”)

Deepwell Injection: Other Classes

• Underground Source of Drinking Water (USDW)• TDS < 10,000 mg/L• Aquifer Exemption (AE) process

• Primary standards requirement for Class V

• Regulations not specific to desal concentrate

Deepwell Injection: Key UIC Barriers

• Lengthy and expensive permit process • Procedural and technical requirements • Multiple agencies involved• Limited experience in some states• Lack of UIC Program funding• Different mentalities for Class I and II regulations

Deepwell Injection: Key UIC Barriers

• Create “General Permit” under Class I• Texas precedent shows promise• Extend to federal level (federal primacy)

• Redefine USDW

• Streamline AE process

• Broaden opportunities under Class II

• Create new desal concentrate Class VII

• Others?

Deepwell Injection: Potential Solutions

Concentrate Management WorkshopConcentrate Management Workshop

October 2012

• Convened a diverse group of participants in October 2012• Regulators• Utility professionals• Researchers and consultant experts spanning relevant disciplines

• Reviewed a series of Issue Papers and Case Studies

• Developed and prioritized a suite of potential solution approaches

• Breakout groups fleshed out the top 5 solution options

Workshop Approach

Concentrate Management WorkshopOctober 2012

1. Create Class V subclass • Include “treatability” component• Identify statutory and regulatory changes to redefine endangerment • Clarify point of compliance• Identify constraints/costs for future use• Work with state partners

Workshop Recommendations

Concentrate Management WorkshopOctober 2012

2. Develop compilation/guidance for state DWI permit processes and practices• Regulatory agencies, policy-makers, utilities, stakeholders• Technical criteria• Public participation practices• Permitting practices• Develop template for model general permit• Develop review process for states/EPA

Workshop Recommendations

3. Develop General Permit under Class I (similar to TX)• Reduce public notification requirements• Require PE and PG approval• Implement at state and federal levels• Develop guidance for implementation based on review of current permitting processes, best practices,

and potential legal barriers

Workshop Recommendations

4. Provide primacy to states for AE process• Avoid a second-level AE review by EPA after state review has already been completed

Workshop Recommendations

5. Hold competition for developing technological advances to enable beneficial use and/or higher recovery• “SALT Prize” for best technology innovation• Reduce desal costs by identifying innovative low-cost, environmentally sound CM strategies

Workshop Recommendations

1. Reg and permit process changes (altering procedural or technical requirements)

2. Advocacy (lobbying and champions) – who and how to make the push for change, to which audiences, using what messages

3. Research needs and demos (to show it works, or to develop solutions)

4. Tools and/or Guidance

5. Public outreach and education

6. Funding to make it happen

Dimensions of the Path Forward

• Organize the relevant groups and stakeholders to:• Examine new classification under UIC program for drinking water treatment and/or desal residuals• Develop talking points to support the need for states/EPA to create “general permit”

Next Steps

• Develop systematic characterization of saline groundwater resources

• Separate desal concentrate from other waste streams to help with public perception, and facilitate more suitable requirements

• Promote near-term and long-term solutions that would allow for more meaningful changes to statutory and/or regulatory process

Next Steps

• WateReuse Research Foundation Project #11-09 (Deana Bollaci, PM)

• Co-funders: WaterRF, WERF

• El Paso Water Utilities (Ed Archuleta, PI, Mike Fahy, Hector Gonzalez, Scott Reinert)

• CHIWAWA (UTEP, TAMU, NMSU)

• Stratus Consulting (Bob Raucher, Janet Clements, Jeff Oxenford, Stratus Consulting)

• Mickley and Associates (Mike Mickley)

• Bickerstaff Heath, LLP (William Dugat)

Acknowledgments

• Project Advisory Committee• Jeffrey Moeller, Water Environment Research Foundation• Jennifer Warner, Water Research Foundation• Jonathan Gledhill, Policy Navigation Group• Sean Lieske, City of Aurora• Andrew Shea, HDR Engineering

Acknowledgments

Questions?

egarchuleta@utep.edusreinert@epwu.org

braucher@stratusconsulting.com