construction dewatering permitting &...
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Construction Dewatering
Permitting & Streamlining September 11, 2017
Ed Abbasi, P.E.King County
Industrial Waste Program Seattle, WA
ed.abbasi@kingcounty.gov (206) 477-5406
34 local sewer agencies (cities & sewer districts)
420 square miles
1.5 million people
3 Regional plants (West & South Plants, Brightwater)
2 local plants (Carnation & Vashon Island)
42 Pump Stations
389 miles of conveyance lines
38 Combined Sewer Overflows (CSO’s) and 4 CSO treatment facilities
Average 175 million gallons per day (MGD) treated wastewater
King County Wastewater Treatment Division
Since 1969, the King County Industrial Waste Program has administered regulations for businesses discharging wastewater into King County's sewage system.
We work cooperatively with more than 650 industrial users to:
Regulate
Provide technical assistance
Protect biosolids, water quality, POTW, and health and safety of sewer workers, and
Equitably recover treatment and program costs.3
King County Industrial Waste: What We Do
Metal finishing / Electroplating Pharmaceutical manufacturersCan makers Iron manufacturingCentralized waste treatmentFood processors Contaminated stormwaterConstruction dewatering
4
KCIW Works With Many Industries
Construction Dewatering King County
During construction, workers pump groundwater, process wastewater and contaminated stormwater away from the site.
This water may be sent into the sewer only if authorized by King County and the local city or local sewer agency.
We accept construction wastewater under some conditions
Sewer connections must be approved by the LSA.
LSA sets conditions for:
Discharge point(s)
Maximum discharge rate (gpm)
Reporting procedures to determine sewer fees. 6
Construction Dewatering
Types of Authorizations Letter of Authorization
(Small uncontaminated flows, monitoring not required, KCIW does not perform preoperative inspection)
Minor Authorization(Small uncontaminated flows, monitoring required and shall be kept on site, KCIW does perform preoperative inspection)
Major Authorization(Larger flows with some contaminations, monitoring and reporting required, KCIW does perform preoperative inspection)
Permit(Larger flows with significant amount of contaminations, monitoring and reporting required, KCIW does perform preoperative inspection and sampling) 7
Construction Dewatering Authorization
Contractors
KCIW
Local agencies
The impact on the wastewater system from small projects is minimal.
A permitting problem: Lots of work; little benefit
Use the same time and resources to permit both small and large construction projects
Long issuance process(For smaller projects 2- 8 weeks)
Same effort spent on large and small projects
Inconsistency and confusion
(too many types of authorizations)
Incomplete applications
And more….9
What could be the problem?
Interviewed KCIW investigators
Interviewed stakeholders and customers
Internal agencies within King County
Large and small contractors
WS-DOT
Seattle-DOT
Reviewed active authorizations for smaller and relatively cleaner sites
10
How to Streamline?
About 40% of the construction permit applications come from small and clean sites discharging less than 25,000 gpd
Many of these are short term projects (<6 months)
KCIW write each approval individually
11
Streamline Process & Findings
Small, Clean Sites
40%Remaining 60%
The Remaining 60% of applications are for projects that are:
>1 acre
>25,000 gpd
1 year < Duration <5 year
Moderately to high contamination
12
Streamline Process / Findings
Small, Clean Sites40%Remaining
60%
Guiding Principles
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Streamline Process
Question• Is it possible to offer a General
Authorization using the “Presumptive Approach” similar to the Ecology Construction Stormwater General Permit?
Answer: Yes, we can.
We call it: General Letter of Authorization (GLA)14
Phase I - General Authorization
Small, Clean Sites40%
What the Presumptive Approach Requires?Pre-approved and appropriate
BMPs on site Site must be less than an acre Site must not be contaminated The discharge must be less than
25,000 gpd15
Phase I – The Presumptive Approach for General Authorization
Small, Clean Sites40%
Presumptive approach is consistent with 40 CFR 122.44(k)(3).
It relies on proven BMPs prescribed by King County Industrial Waste (KCIW)
16
Phase I – The Presumptive Approach
Guidelines, instruction, graphics, and design basis for settling tanks are
provided on King County’s websites for public use.
http://www.kingcounty.gov/services/environment/wastewater/industrial-waste.aspx
Small, Clean Sites40%
Developed a simpler application form
Developed template
Expanded KCIW Webpage
Developed FAQs
17
Phase I - How General Authorization Was Developed?
Small, Clean Sites40%
Shorter and simpler application for small projects
Quicker turn-around time (within 1 week or less)
Less back & forth between King County, LSA, and builders
No reporting requirements (monitoring data kept on site)
Protects water quality and biosolids, and
Saves time & Lowers the costs
Supports the regional economy
Superior customer service
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Phase I - Benefits of Streamlining
Small, Clean Sites40%
Confirm if LSA accepts construction wastewater.
Consult with KCIW.
Select and download appropriate application: i.e., General or Individual.
Submit to KCIW completed application
Receive from KCIW authorization.
Contact LSA for discharge point(s) and other requirements.
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Steps to Receive General Authorization
Construction Dewatering Streamlining Phase 1
How is it working?
Since March 2016 >120 issued
Conducted random inspections
Generally in good compliance
Receiving positive feedbacks from customers
West Point • About 90 mgd during the dry months
• Provides secondary treatment for about 300 mgd during wet season
• Provides primary treatment and disinfection for flows exceeding 300 mgd and up to 440 mgd
West Point > 250,000 gpd 21
Phase II – Discharge AuthorizationRedefine Significant Industrial User (SIU)
for Construction Wastewater for each POTW
The Other
60%
South Treatment Plant• About 90 mgd during the dry months
• Up to about 300 mgd during wet season
South Treatment > 200,000 gpd
22
Phase II – Discharge AuthorizationRedefine Significant Industrial User (SIU)
for Construction Wastewater for each POTW
TheOther…
Brightwater Treatment Plant
• Brightwater treats an average of 36 mgd
• By 2040, the treatment capacity may be expanded to 54 mgd
Brightwater > 50,000 gpd
23
Phase II – Discharge AuthorizationRedefine Significant Industrial User (SIU)
for Construction Wastewater for each POTW
The Other …
Identified pollutants of concern Settleable Solids, pH,
Oil & Grease
Sulfides
Organic Compounds
Dry cleaning based
Petroleum based
Other compounds 24
Phase II – Discharge Authorization
The Other …
Phase II – Discharge Authorization
A new Ranking Criteria is based on
Duration of Discharge
Simultaneous Point of Discharge
Maximum daily discharge volume gpd
Presence of Combined Sewer System
The Ranking Criteria is used to decide DA vs. Permit
25
The Othe…
Ranking Criteria
26
New Application & Inspection FormNew Ranking CriteriaNew Template with,Consistent LanguagePre-defined monitoring &
reporting frequency for each treatment plant
Pre-defined concentration and loading limits
27
Phase II – Discharge AuthorizationForm updates
The Other
60%
When Q < SIU & Contaminants Present
28
When Q > SIU & no Contaminants Present
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Outcome• Fewer Authorization Types: GLA, DA or Permit
• Greater Standardization & Consistency
• Quicker Turnaround and Superior Customer Service
GLA (within 1 week or less)
DA (within 1 month or less)
Permit (within 2-3 months)
• Superior Customer Service
30
Phase II – Discharge Authorization
The …
Ed Abbasi, P.E.
ed.abbasi@kingcounty.gov
(206) 477-5406
Department of Natural
Resources and Parks
KSC – NR – 0513
201 South Jackson Street, Suite 513
Seattle, WA 98104-3855
Thank you. Questions?
33
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