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Impact of EPA ASR Letter on Florida’s ASR Facilities
Joseph Haberfeld, P.G. Aquifer Protection-UIC Program Florida Department of Environmental Protection January 2014
ASR – Cross Section View Shallow Monitoring Well
ASR Storage Zone Monitoring Well
ASR Well
ASR Storage Zone
Overlying Aquifer
Confining
Confining
Pyrite Crystals
10 μm 10 μm
10 μm
Photos from FL Geological Survey
Scattered Pyrite in Dolomite Photo by FL Geological Survey
0
10
20
30
40
50
0 25 50 75 100 125 150 175 200Volume Recovered (mg)
As
Con
cent
ratio
n (p
pb)
Attenuation of Arsenic
Cycle 3
Cycle 4
Cycle 5
Previous Standard
New Standard
Tampa Rome Ave.
Cycle 6
TYPES OF ASR PROJ ECTS IN FLORIDA
• Drinking Water (potable) • Raw Ground Water • Treated Ground Water • Treated Surface Water • Reclaimed Water
SUMMARY OF AQUIFER STORAGE AND RECOVERY
IN FLORIDA ASR System Type Active Inactive/Planned
Drinking Water 22 7
Reclaimed Water 11 4
Surface Water 5 1
Abandoned
Canceled
On Hold for As solution
ASR – A Regulatory Timeline
• 2005 “Position Paper” to EPA • 2008 Began Using Enforcement Documents to Permit ASR • 2010 “Non-Endangerment” Proposal to EPA • 2011 Additional Information to EPA
“This letter addresses the need for public water systems experiencing water shortages to store treated drinking water underground for later use as a source of drinking water.”
“……innovative water management tools will be increasingly important to sustain water availability.”
15
Regional Water Supply Plans • Planning horizon of at
least 20 years • Options must be feasible • Coordination with local
governments, suppliers • Updated every 5 yrs.
Plans should include: Quantification of Needs Water supply development options Enhanced water conservation Water resource development MFLs, recovery and prevention strategies
Funding strategy
Florida Fresh Water Demand & Use
0.00
0.50
1.00
1.50
2.00
2.50
3.00
3.50
4.00
2005 2010 2015 2020 2025 2030
Wat
er D
eman
d (b
gd)
Year
Public Water Supply
Domestic and Small Public Supply
Agricultural Irrigation
Recreational Irrigation
Commercial/Industrial/Institutional
Power Generation
“This letter describes how Florida can apply UIC requirements to ASR wells used by public water systems when mobilization of arsenic is a concern.”
• The Safe Drinking Water Act - Section 421(d)(2)
Focuses on protection of public water systems
• Federal Regulation - 40CFR144.12(a)
• Focuses on protection of the USDW
“….Florida could decide in some cases that it is appropriate for these ASR wells to remain open under permits with conditions designed to protect public health and maximize protection to the USDW.”
“Permit conditions should require practices designed to reduce arsenic mobilization and minimize the area within which arsenic mobilization could occur.”
Federal Regulation 40CFR144.12(c)
For Class V wells, if at any time the Director learns that a Class V well may cause a violation of primary drinking water regulations under 40 CFR part 142, he or she shall: (1) Require the injector to obtain an individual permit; (2) Order the injector to take such actions (including, where required, closure of the injection well) as may be necessary to prevent the violation. For EPA administered programs, such orders shall be issued in accordance with the appropriate provisions of the SDWA; or (3) Take enforcement action.
Federal Regulation 40CFR144.84(b)(1)
• (b) Circumstances in which permits or other actions are required. • (1) You fail to comply with the prohibition of
fluid movement standard in §144.12(a) and described in §144.82(a) (in which case, you have to get a permit, close your well, and/or comply with other conditions determined by the UIC Program Director in your State or EPA Region)
“A user of the USDW other than the public water system operating the injection well should not have access to the impacted area…..”
“….prevent the burden of public health protection from being transferred to any entity other than the ASR operator…..”
Tampa Rome Ave.
WELL ASR-1
Volume Recovered, in MGal
0 50 100 150 200 250
Ars
enic
Con
cent
ratio
n, in
mg/
L
0.00
0.01
0.02
0.03
0.04
0.05
MCL 10 ppb
CYCLE 3CYCLE 4CYCLE 5CYCLE 6CYCLE 7CYCLE 8
ASR-1 thru ASR-3 & ASR 5, 6, 8, As Concentrations
-0.0050
0.0000
0.0050
0.0100
0.0150
0.0200
0.0250
0.0300
0.0350
0.0400
0.0450
0.0500
0.0550
0.0600
04/0
2/02
05/1
4/02
06/1
9/02
05/2
9/03
07/0
2/03
08/0
6/03
02/0
4/04
06/1
6/04
01/2
6/05
03/1
0/05
04/1
3/05
05/1
7/05
03/2
4/06
04/1
2/06
05/0
1/06
05/1
7/06
06/0
5/06
06/2
1/06
03/2
8/07
05/0
3/07
Sample Date Range
Ars
enic
mg/
l
ASR-1
ASR-2
ASR-3
ASR-5
ASR-6
ASR-8
Marco Lakes ASR
10 µg/L
Potable Water ASR Operation Permits Issued
• Marco Lakes – 2010 • Peace River – 2013 • Bradenton - 2013 • Tampa Rome Ave. - 2013
Key: Injected Water Arsenic Mobilization
“….tools include degasification pretreatment, consistent operation….., and full recovery of injected water when necessary”
“….implementation of ‘site access controls’ such as institutional controls….that restrict well construction within the impacted area……setbacks in the state’s water well construction rules…..that will control access to contaminated groundwater.”
Tools for Addressing As
• Point of Injection Treatment. Treatment of the injectate to reduce arsenic
mobilization may be feasible for some systems.
• Point of Recovery Treatment. Treatment used to render waters with high TDS
levels potable will reduce As levels. Treatment includes blending and re-treating at
WTP
Tools for Addressing As
• Provide for the use of institutional controls when As values >10 µg/L off-site.
• Aquifer Exemptions (minor) when the TDS is greater than 3,000 mg/L.
• State water quality criteria exemptions. • Provide for a zone of discharge that would
allow As values >10 µg/L on-site.
Punta Gorda ASR
ASR and Monitor Well Spacing City of Tampa Tippin WTP
Example of Institutional Control Tampa Rome Ave.
• An Ordinance limiting use of
the ASR storage zone is a control for smaller sites
• City of Tampa successfully eliminated competing use of the aquifer, connected private domestic wells to the public supply
ASR and Monitor Well Spacing
From CH2M Hill, Dec. 2006
Bradenton ASR Volume and Arsenic Concentration
0
5
10
15
20
25
3011
/1/0
411
/8/0
411
/15/
0411
/22/
0411
/29/
0412
/6/0
412
/13/
0412
/20/
0412
/27/
041/
3/05
1/10
/05
1/17
/05
1/24
/05
1/31
/05
2/7/
052/
14/0
52/
21/0
52/
28/0
53/
7/05
3/14
/05
3/21
/05
3/28
/05
Ars
enic
ug/
l
-5
0
5
10
15
20
Cum
ulat
ive
Volu
me
(MG
)
RechargeRecovery
Cumulative VolumeArsenic
I 1
R1
I2 R2
I 3
R3 I 4 R 4
0
5
10
15
20
25
30
35
40
45
50
55
60
65
70
75
80
May-05 Aug-05 Nov-05 Feb-06 May-06 Aug-06
Ars
enic
ug/
l
0
10
20
30
40
50
60
70
80
90
100
110
120
130
140
150
160
Cum
ulat
ive
Stor
age
Volu
me
mg
asr1 SZMW Cumulative Storage Volume mg
Bradenton ASR
Joseph Haberfeld, P.G. Aquifer Protection-UIC Program Florida Department of Environmental Protection 850-245-8655 [email protected]
