Los Angeles Workshop by GEO

Regulatory Update on

Los Angeles Regional Water Quality Control Board’s Injection

Permit of Waste Discharge Requirements (WDRs) (2014)

November 12, 2014

Yue Rong

Los Angeles Regional Water Quality Control Board

yrong@waterboards.ca.gov

California Environmental

Protection Agency

Cal-EPA

• State Water Resources Control Board (including 9 Regional Boards and a Drinking Water Division)

• Air Resources Control Board

• Department of Pesticide Regulations

• Department of Toxic Substances Control (DTSC)

• Office of Environmental Health Hazard Assessment (OEHHA)

• Region 1: North Coast

• Region 2: San Francisco Bay

• Region 3: Central Coast

• Region 4: Los Angeles

• Region 5: Central Valley

• Region 6: Lahontan

• Region 7: Colorado River Basin

• Region 8: Santa Ana

• Region 9: San Diego

Regional Water Boards

Regional Water Quality Control Board

Main Functions:

1.Develop regional water quality plan

2.Issue discharge permit (National Pollutant

Discharge Elimination System,

i.e.,NPDES)

3.Clean up pollution sources that threaten

water quality

Regional Water Quality Control Board

1. Water Quality Control Plan (basin plan):

• Water beneficial uses (e.g., municipal

usage, industrial usage, recreation,

aquaculture, wetland habitat, etc.)

• Water quality objectives (numerical)

• Implementation plan

Regional Water Quality Control Board

2. NPDES permitting

• Industrial facilities

• Municipal waste water treatment

• general permit (by category)

Regional Water Quality Control Board

3. Cleanup program:

• Petroleum hydrocarbons (gasoline)

• Other pollutants: chlorinated solvents,

heavy metals, emerging compounds (e.g.,

perchlorate, Chromium VI)

• Brownfield sites for city redevelopment

Regional Water Quality Control Board

How are the policy and cleanup standard

set?

• Legislation and laws

• Use of science, staff recommendations

• Public participation (all stakeholders)

• Board meeting adoption (public forum)

Regulatory Permitting for

Groundwater In-situ Remediation

• In California, the permit is the Waste Discharge

Requirements (WDRs)

• Industry used for more in-situ groundwater

remediation

• More economical and less disturbing

• Need to regulate the injected compounds to the

water of the State

• General WDRs can be issued by the Water

Board Executive Officer, therefore, more

efficient

In-situ Chemical Injection

• In-situ Chemical injection is a treatment technology that uses chemicals or micro-organism to destroy contaminants in groundwater. Injection wells are installed at the source area containing high concentrations.

• Injection of:

• oxidation/reduction compounds (e.g., hydrogen peroxide (H2O2))

• surfactant (like soap)

• activated carbon (like sorbent)

• zero-valent iron (nano technology)

• micro-organism (like bacteria)

In-situ bio-injection

• Inject oxygen (bio-venting) = encourage

native bacteria to grow

• Inject oxygen generating chemicals

• Inject man-made microbial = introduce

non-native bacteria to grow

• Inject bacteria nutrients

• Bio-GAC

• Combination of all above

Typical In-Situ Injection

SchematicRemoved leaking tank

Specialized

Injection Trailer

Saturated ZoneWater

supply

well

GW flow direction

Unsaturated zone

(vadose zone)

Oxidant injected

into dissolved

contaminant

plume

P/T monitors

PVC

wells

Image source:

www.waterboards.ca.gov/water_issues/programs/ust/cleanup/docs/final

_chemical_oxidation_technologies.pdf

Typical full-scale in situ Injection

system layout

Full-

Scale

Injection

Oxidant Storage

TankActivator

Tank

Batch Tank

In-situ remediation injection accident

In-situ remediation injection accident

General Waste Discharge

Requirements (WDRs)o 9/11/2014, Los Angeles Regional Water Quality

Control Board adopted Renewal of General WDRs (2014)

o Last General WDRs were adopted in 2007

o The WDRs authorized the use of various materials to be injected into groundwater for in-situ remediation

o Seen at http://www.waterboards.ca.gov/losangeles/board_decisions/adopted_orders/ (under WDRs, Order No. R4-2014-0187)

General Waste Discharge

Requirements (WDRs) Advantages

a) simplify the application process for dischargers,

b) allow more efficient use of Regional Board staff time,

c) minimize the time needed for Regional Board to adopt WDRs,

d) enhance the protection of surface water quality by eliminating the

discharge of treated groundwater to surface waters,

e) preserve water resources by re-injection of treated groundwater

into aquifers,

f) provide a level of protection comparable to individual, site-specific

WDRs,

g) embrace new technologies,

h) Consistent with practice of other Regional Boards

Changes in 2014 version

o Add chemicals and micro-organism

to promote in-situ remediation

- 2014 list contains ~80 materials

- 2007 WDRs contains ~40 materials

o Delegate Executive Officer (EO)

authority to revise the list of

materials for injection periodically

General WDR working groupo In 2013, a working group established

including stakeholders from material

manufacturer, water purveyor,

environmental consultant, local regulatory

agency, and academia for peer review and

input from the regulated community

o The group has met 9 times since

o Primary function: to review information and

prepare the remedial injection material list

Criteria for addition of materials

a. Effective to remediate targeted

constituents;

b. Minimum degradation of water quality that

will not cause or contribute to exceedance of

water quality objectives (WQOs);

c. Protective of human health and safety;

d. Availability on the market for a minimum

of three years.

Documents or materials needed to be included in the

General WDRs

- Narrative summary of the compound

- MSDS

- 3 case studies to demonstrate it works

The General WDRs would allow the following

materials to be used for in-situ remediation purposes

1. Chemical Oxidants

2. Chemical Oxidant Activators

3. Aerobic Bioremediation Enhancement Compounds

4. Anaerobic Degradation Enhancement Compounds

5. Reduction Degradation Enhancement Compounds

6. Metals Precipitation / Stabilization

7. Surfactants/Co-solvents

8. Bio-augmentation Organisms

9. Tracer Study Compounds

10.Buffer Solutions and pH Adjusters

Pros:

1.Clear in terms of which compound is in and which is

out

2.Easy for staff to evaluate

3.Can be issued quickly by Executive Officer therefore

faster site cleanup

Cons:

1.Difficult to add new products

2.Difficult to evaluate in multiple compounds

application

3.Slower to issue WDRs for compounds that are not

listed in the WDRs, therefore slow down site cleanup.

Pros and Cons for this WDRs

General WDR Rule-making Process

1. Comply with CEQA process and Califorinia Water

Code requirements (sections 13260 and 13263)

2. Public notice must comply with CEQA process

(draft for public comments and respond to the

comments)

3. Present to the Regional Water Quality Control

Board in a public form for adoption of the final

version

4. Once adopted by the Board, the Executive Officer

is given the authority to issue the General WDRs.

The Executive Officer’s decision is based on staff

recommendations.

General WDR Application Process

1. Furnish a site-specific Remedial Action Plan (RAP)

and get approved by the lead regulatory agency

2. Go on LARWQCB website for WDR information

(under Board Decision => adopted orders (WDR

R4-2014-0187)

3. Fill out Application Form 200 (for WDR)

4. Pay the fees

5. Send in the WDR Application Package (form, fee,

and approved RAP) to LARWQCB

6. Conduct field work once the General WDR is

approved

General WDR Application Evaluation

1. Approval of the site-specific remedial action plan

(prior)

2. Regulatory staff evaluation of the WDR Application

3. A cover letter to approve the Application of the

General WDR

4. A site-specific groundwater monitoring program,

which specifies the compounds to be analyzed,

the monitoring locations (usually upgradient vs.

downgradient wells and temporal patterns after the

injection, etc.)

5. Annual fee to pay until the WDR is terminated

1. What happens if the injection compounds are not

listed in the General WDRs (R4-2014-0187)?

Answer: apply for site-specific WDRs, which will

go through the CEQA public notice process.

2. What happens if Responsible Party (RP) wants to

change the compounds of injection?

Answer: if the compounds on the WDRs list,

=> apply for an amendment.

if the compounds not on the list,

=> apply for site-specific WDRs.

Common questions

3. How can a new in-situ chemical be added to the

General WDRs?

Answer: wait until next update of General WDRs

list, and will go through the peer review and

screening criteria

(1) Provide information

- summary of the compound

- MSDS

- 3 case studies to demonstrate it works

(2) Evaluate against that 4 screening criteria by

staff and working groupa. Effective to remediate targeted constituents;

b. Minimum degradation of water quality that will not cause or contribute to

exceedance of water quality objectives (WQOs);

c. Protective of human health and safety;

d. Availability on the market for a minimum of three years.

Common questions (2)

4. Is the General WDR good for groundwater re-

injection?

Answer: Yes.

5. Does RP allow to inject treated groundwater with

remedial materials back to the aquifer?

Answer: Yes. But, only in the “treatment” zone.

Common questions (3)

Thank You!!

Questions?