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Pressure Washwater Management for Marina/Boatyard Industries
Paul G. Richard, P.E.
Senior Program Director
EBI Consulting
617.715.1825
Agenda
Introduction
Storm Water vs. Industrial Wastewater
Industrial Washwater (powerwashing management)
Pressure Washwater Disposal Options
Common Design Considerations
Powerwash Solids
Solid Waste vs. Special Waste
Collection and Treatment Systems
Powerwash Wastewater Sampling
System Selection Considerations
Today’s Meeting…
…will give you an opportunity to receive information about:
1. Industrial wastewater compliance associated with power washing boat bottoms
2. The different wastewater discharge options
3. My recent experiences and knowledge associated with power wash wastewater collection and treatment systems
Storm Water vs. Industrial Wastewater
Storm Water:
Rain/storm event water and snow melt runoff via a point source
Discharges associated with industrial activities typically managed via EPA General Permitting Program (NPDES)
Industrial Wastewater:
Liquid waste (wastewater) resulting from industrial or manufacturing processes. Dirt or Clean!
Discharges have several management options – more control compared to storm water.
Industrial Wastewater (Powerwashing)Why is this a problem?
This is an industrial wastewater discharge to either the Waters of the US or groundwater or POTW.
These discharges need to be permitted.
These discharges need to be treated.
Waters of the US = EPA NPDES Permit
Groundwater = Mass. DEP Groundwater Discharge Permit
POTW = Sewer Use Discharge Permit (i.e., Deer Island MWRA)
Industrial Wastewater Options
What Are My Options?There are five (5) options
1. NPDES Direct Discharge Permit
2. Groundwater Discharge Permit
3. Sewer Use Discharge Permit (SUDP)
4. Closed-Loop Recycle System
5. Holding Tank/Offsite Disposal
Options 1 & 2 – not recommended
WHY?
Sewer Use Discharge Permit (SUDP)
What is a SUDP?
A permit issued by a POTW allowing the discharge of industrial wastewater into a local sewer system (i.e., MWRA)
Must comply with their local limits for various pollutants (i.e., Cu, Pb, Hg, Oil and Grease, BOD, TS, TSS, etc…)
POTW Self Monitoring Requirements (Sampling)
Most pressure washwater must be pretreated before being discharged
Closed-Loop
What is a Closed-Loop recycling system?
A system or systems, used to collect and reuse wastewater – over and over again (treating while reusing) and adding make-up water for losses
Zero Discharge = No direct or indirect discharge to the environment
No Permits or Approvals
Local Approval!!!
Holding TankWhat is a holding tank/onsite collection system?
Wastewater is collected in either an underground or aboveground storage tank (AST or UST)
Collected washwater is then transported to an offsite disposal facility (i.e., 3,000 – 5,000 gallon vacuum truck)
Wastewater typically non-regulated material (not hazardous waste)
Prior approval with a disposal facility
State Industrial Wastewater Holding Tank Permit (314 CMR 18.00)
Access to sewer – Holding Tank Permit not allowed.
SUDP/Pretreatment Discharge to Sewer
Pros
Easy to comply with POTW requirements
Accessibility and convenient
Discharge volumes unlimited
Flexibility
Cons
Sewer Access/Permitting approval
Initial capital cost expensive
Operated by licensed certified operators
Seeking local approval
Discharge limits changing – Compliance Sampling
Closed-Loop Recycle Systems
Pros
Access to the sewer not required
No permit or regulatory approvals (local understanding)
Don’t need licensed certified operators
Cons
Initial capital cost expensive
Water quality (topside washing & employee exposure)
Odorous water & bacteria growth
Operating costs (filter, media, etc…)
Down time during system O&M activities
Holding Tank/Offsite Disposal System
Pros
Access to the sewer not required
Don’t need licensed certified operators
Minimal equipment costs and maintenance
Cons
Wastewater generation rate – need to be low
Disposal facility approval
314 CMR 18.00 Holding Tank Permit
Scheduling pick-ups - ”milk run”
UST/AST installation design approval
Changing UST requirements
Contaminated wastes
Common Design Considerations
Need a wastewater collection system
Want to collect industrial wastewater only
Want to promote large solids removal
Want to allow storm water to discharge
Expansion capabilities
Characterize Wastewater for Treatability
Collection Systems #1
Collection Systems #2
Collection Systems #2
Collection Systems #2
Collection Systems #2
Collection Systems #2
Collection Systems #3
Collection Systems #3
Collection Systems #3
Collection Systems #4
Powerwash SolidsCollected from aprons, trenches, sumps, treatment solids, etc.… from boat bottom washing activities
Weeds, brown algae/slime, mussels, barnacles, mud shrimp, paint chips, dirt, grit, debris, etc…
4 samples analyzed by EBI for TCLP RCRA 8 Metals:
Arsenic (All Below Detection Limit)Barium (All Below Detection Limit) Cadmium (All Below Detection Limit)Chromium (All Below Detection Limit)Lead (Below Detection Limit, one sample had 0.7 mg/L – Limit is 5.0 mg/L)
Non-Regulated Material – Perform your own sampling to confirm.
Is this a Solids Waste?
Mercury (All Below Detection Limit)Selenium (All Below Detection Limit)Silver (All Below Detection Limit)
Solid Waste vs. Special Waste
310 CMR 19.00 - Solid Waste Management
What is a Solid Waste? – Easier explained: What it doesn’tinclude:
Hazardous WasteSludge or septage that are land applied (310 CMR 32.00)Wastewater treatment facility residuals & POTW sludge ashEtc….
What is a Special Waste? – any solid waste that is determined not to be a hazardous waste (310 CME 30.00) and that exists in such a quantity or in such chemical or physical state, so that particular management controls are required to prevent an adverse impact from the collection, transport, transfer, processing, treatment or disposal of the solid waste.
Solid Waste vs. Special Waste (cont.)
Good News!
MA DEP, right now, is considering marina solids generated from boat bottom powerwashing as a Solid Waste (Must pass TCLP)
Important - can not contain any free flowing liquids
Dumpster and Landfill
MA DEP Contact: Paul Emonds – Solids Waste Division
Power Wash Wastewater Samples
Treatment Systems – Sewer DischargePrecipitation process
Chemicals
Solids management
Permit Limits
Licensed operators
Treatment Systems – Closed-LoopElectro-coagulation - uses electricity cathode and anode
Causes precipitation
Solids holding tank
Solids dewatering
Clean water supply tank and pump
No chemistry?
Treatment Systems – Closed-Loop
Simple concept
Filtration
Aeration
Equalization
Bag Filter
Polishing Media Canisters
Treatment Systems – Closed-Loop
EqualizationFiltrationAerationClarification (Settling Tank)Bag Filter and MediaSolids Dewatering
Treatment Systems – Closed-Loop
Cyclone SeparationFiltrationUV DisinfectionBag Filter and CartridgesBulk holding tank (Solids)Solids Management
System Selection Considerations
Expect operational change!!!
Permitting, end-of-pipe, closed-loop, collection
Volume of water needed per day
Volume of water to be treat per day
Quality of water for reuse
Representative sample & pilot test
Down time for system O&M
Operator friendly
Automation $$$
Customer/employee exposure
Odors – large water volumes in UST
Solids Management
Questions?
Paul G. Richard, P.E.
Senior Program Director
EBI Consulting
617.715.1825
