PADEP to Adopt New Treatment Standards for High TDS Wastewaters
In an effort primarily to address the potential impacts from the development of the Marcellus Shale reserves, the Pennsylvania Department of Environmental Protection (“PADEP”) has announced its intention to adopt new treatment requirements and water quality standards to control total dissolved solids, sulfates and chlorides.
According to PADEP, the justification for its new permitting strategy is a finding of high TDS concentrations in the Monongahela River and West Branch of the Susquehanna River. That surface water is used by power plants, steel mills and other industries as a source of cooling water and the high TDS was causing operational issues.
In its Permitting Strategy for High Total Dissolved Solids Wastewater Discharges (April 11, 2009), PADEP describes a program that requires new high-total dissolved solids (“TDS”) dischargers to install adequate treatment to meet requirements based on the receiving stream’s assimilative capacity, and dischargers to publicly owned treatment works must meet local limits.
A high TDS discharge is proposed to be anything that exceeds a TDS concentration of 2,000 mg/l or exceeds 100,000 pounds per day. Existing dischargers, including power plants, chemical manufacturers, food processors, and mining and mineral producers, will be impacted, as many of them have discharge levels that would exceed the proposed limits.
No new or expanded high TDS wastewater sources will be permitted unless the applicant proposes to install adequate treatment of TDS by January 1, 2011.
For existing industrial facilities – PADEP will permit the continued treatment and disposal of existing sources of High-TDS wastewaters at existing permitted facilities as follows:
1. Existing industrial sources of High-TDS wastewaters will be able to continue to operate under their existing permit limits and conditions until such time as they propose to expand or to increase their existing daily discharge load of any pollutant of concern. At that point, such a facility would be subject to the following schedule:
• Prior to January 1, 2011, for new sources of High-TDS industrial waste proposing treatment for DS, an allocation of available assimilative capacity may be authorized. Wastewaters discharged from these facilities also must meet any other applicable treatment standards and requirements.
• After January 1, 2011, the more stringent of the applicable effluent standards or water quality based effluent limitations.
These new regulations, which are to be proposed for comment within the next few months, have the potential to significantly affect discharge requirements for most major NPDES permit holders. The technology required to treat high TDS discharges is very expensive both from a capital cost and operating cost perspective, and limited to reverse osmosis and evaporation/crystallization. Both would still result in either a highly concentrated brine, or a solid crystalline material that would require off-site disposal.
For more information on this topic, or for help with identifying and implementing a strategy to meet the schedule(s) listed above, please contact Don Olmstead, PE – Manager Engineering, Venture Engineering & Construction, at 412-231-5890, ext. 302.