S02 Feasibility Study Wastewater Treatment Mabbett.pdf

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FEASIBILITY STUDY FOR WASTEWATER

TREATMENT

Jamaica Plain Veterans Affairs Medical Center 105 South Huntington Avenue Jamaica Plain, Massachusetts 02130

December 2023

Prepared for:

U.S. Department of Veterans Affairs Boston Healthcare System (BHS) 940 Belmont Street Brockton, MA 02301

Mabbett & Associates, Inc. www.mabbett.com 105 Central Street, Suite 4100 Stoneham, MA 02180 T. 781-275-6050

Massachusetts | Virginia | Rhode Island | New York

FEASIBILITY STUDY FOR WASTEWATER TREATMENT

Jamaica Plain Veterans Administration Medical Center

Mabbett & Associates, Inc. Page i December 2023 Project No. R2022083.002 JP VAMC Wastewater Treatment

ACKNOWLEDGEMENT

Mabbett & Associates, Inc. (Mabbett®) prepared this Feasibility Study for Wastewater Treatment (the Study) as a reference document to support the removal of mercury from the Massachusetts Water Resources Authority (MWRA) discharge at the Jamacia Plain Veterans Affairs Medical Center at 150 South Huntington Avenue in Jamacia Plain, Suffolk County, Massachusetts. Mabbett prepared this Study for the U.S. Department of Veterans Affairs (VA) under Contract Number 36C24123P0990.

This Feasibility Study for Wastewater Treatment was prepared for use by the VA. Use of this Study, in whole or in part, at other locations, or for other purposes, may lead to inappropriate conclusions; Mabbett does not accept any responsibility for the consequences of such use(s). Furthermore, reliance by any party not identified in the agreement, for any use, without our prior written permission, shall be at that party’s sole risk, and without any liability to Mabbett.

This report has been prepared by:

Mabbett & Associates, Inc.

Emily C. Glennon, EI Project Civil Engineer

This Study has been reviewed and approved by:

Mabbett & Associates, Inc.

Robert B. Blanchette, PE Director of Engineering and Infrastructure Group

Mabbett & Associates, Inc. Page ii December 2023 Project No. R2023114.000 JP VAMC Wastewater Treatment

TABLE OF CONTENTS

SECTION PAGE

1.0 Introduction and Project Description

1.1 Regulation Supporting Treatment System Installation

1.1.1 MWRA Permit

1.1.2 Notice of Noncompliance

1.1.3 Sample Location 103 Description

1.2 Historical and Current Mercury Use at the JP VAMC

2.0 Other Applicable Requirements

2.1 VA Physical Security and Resiliency Design Manual (VA PSRDM)

2.2 VA Plumbing Design Manual

2.3 Massachusetts Department of Environmental Protection (MassDEP) Requirements

3.0 Site Visit

3.1 Building 1 (Floor 2) - SPS

3.2 Building 1 - Basement

3.3 Building 1 - Sub-Basement

4.0 Existing Conditions of Sample Location 103

4.1 Flow

4.2 Pollutant Levels

5.0 Treatment System Performance Requirements

5.1 Flow Rate

5.2 System Footprint

5.3 Clearance

6.0 General Equipment Descriptions

6.1 Equalization Tank

6.2 Level Switch

6.3 Transfer Pumps

6.4 Micron Filters

6.5 Pressure Gauges

6.6 PLC/Automation

7.0 Option 1: Carbon and Ion Resin Treatment

7.1 General Sequence of Operations

7.2 Critical Components for Option 1

8.0 Option 2: Coagulation/Precipitation/ Filtration with Aluminum Sulfate Treatment

8.1 General Sequence of Operations

8.2 Critical Components for Option 2

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9.0 Option 3: Oberlin Filter Treatment

9.0 General Sequence of Operations

9.1 Critical Component for Option 3

10.0 Rough Order of Magnitude Costs

10.1 Construction Costs

10.2 Routine Operations & Maintenance

10.2.1 Option 1

10.2.2 Option 2

10.2.3 Option 3

11.0 Conclusions

11.1 Option 1

11.1.1 Advantages

11.1.2 Disadvantages

11.2 Option 2

11.2.1 Advantages

11.2.2 Disadvantages

11.3 Option 3

11.3.1 Advantages

11.3.2 Disadvantages

12.0 References

TABLES (in-text)

Table ES.1 – Summary of ROM Costs Table 4.1 – Sample Location 103 Daily Flow Rates (2022 to 2023) Table 4.2 – Sample Location 103 MWRA Semi-Annual and Notice of Violation Sampling Results (2022 to 2023) Table 10.1 – Summary of ROM Construction Costs Table 10.2 – Operations and Maintenance Projected ROM Cost

FIGURES

FIGURE 1 – OPTION 1 (A & B): ION RESIN AND CARBON TREATMENT

FIGURE 2 – OPTION 2: COAGULATION/PRECIPITATION/FILTRATION ALUMINUM SULFATE TREATMENT

FIGURE 3 – OPTION 3: OBERLIN FILTER TREATMENT

ATTACHMENTS

ATTACHMENT A – Massachusetts Water Resources Authority Permit No. 51005733 ATTACHMENT B – Site Visit Memorandum 14 September 2023 ATTACHMENT C – JP VAMC Flow Data 3 July to 25 August 2023 ATTACHMENT D – Compiled Laboratory Data for Sample Location 103 Collected from 2022 to 2023

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LIST OF ACRONYMS

CMR Code of Massachusetts Regulations EQ Tank Equalization Tank GPM Gallon per Minute GPD Gallon per Day JP Jamacia Plain MassDEP Massachusetts Department of Environmental Protection mg/L Milligram per Liter MWRA Massachusetts Wastewater Resources Authority NON Notice of Noncompliance O&M Operations and Maintenance ORP Oxidation Reduction Potential PLC Programmable Logic Controller psi Pounds per square inch PSRDM Physical Security and Resiliency Design Manual ROM Rough Order of Magnitude Study Feasibility Study for Wastewater Treatment SPS Sterile Processing Service VA U.S. Department of Veterans Affairs VAMC Veterans Affairs Medical Center

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EXECUTIVE SUMMARY

This Feasibility Study for Wastewater Treatment (the Study) was prepared for the Jamacia Plain Veterans Affairs Medical Center (JP VAMC) at 150 South Huntington Avenue in Jamacia Plain, Suffolk County, Massachusetts. The JP VAMC provides primary care and specialty health services to Veterans throughout the greater Boston area. The JP VAMC is authorized, under Permit No. 51005733, expiring 15 August 2024, to discharge to the Massachusetts Water Resources Authority (MWRA) sewer system subject to the conditions of the permit. The conditions of the permit include sampling and reporting of pollutants on a semi-annual basis, as well as daily flow monitoring.

The purpose of the Study was to investigate potential methods for supplemental removal of mercury from industrial wastewater in response to the issuance of a Notice of Noncompliance (NON) for the discharge of excessive levels of mercury to the MWRA sewer system. The NON was issued on 7 April 2023 and required the VA to institute corrective action(s) to mitigate further discharge of mercury. The MWRA prohibits the discharge of mercury to their system; however, 0.001 milligram per liter (mg/L) is used as the criteria limit. As of the date of this Study, four extensions have been granted with the most recent requiring a response on 4 October 2023 and was approved and extended until 2 January 2024.

The Study utilized extensive information provided by VA, such as the flow and contamination data, as well as desktop research and vendor interviews.

The Study investigated the three potential remedial options listed below:

Option 1: Ion Resin Treatment

Option 1A: Ion Resin Treatment with Operational Redundancy Option 1B: Ion Resin Treatment without Operational Redundancy

Option 2: Coagulation/Precipitation/Filtration with Aluminum Sulfate Treatment Option 3: Oberlin Filter Treatment

ASSUMPTIONS

Mabbett assumes the life expectancy is approximately 20 years for all three systems with proper maintenance and operation by licensed operators. Pumps are likely to require replacement in approximately 8 to 10 years;

while larger components, such as tanks and vessels, may require replacement in approximately 20 years. Both Option 1 and 2 would require some level of structural improvements to the building to support the installation of the system, which is not included in the overall cost of the treatment system presented in Section 10.0. The equipment expected to require consideration for structural improvements include, but are not limited to, the following:

Tanks, vessels, and skid mounted equipment assemblies;

Piping to, through, and from the treatment system.

CONCLUSIONS

Mabbett reached the following conclusions based on our analysis of the three options being considered:

The most favorable location for the treatment system is the sub-basement of Building 1 of the JP VAMC due to the structural improvement requirements, as well as space limitations noted in the other two potential locations (Basement and Floor 2 of Building 1 at the JP VAMC).

Option 2 would require the largest system footprint, followed by Option 1A, 1B, and 3, due to the quantity and size of critical system components.

Options 1 and 2 are more traditional, but proven, technologies requiring full time operator oversight;

whereas Option 3 is the newest technology, requiring the smallest system footprint and minimal operator oversight requirements. Although newer, the manufacturer did state other hospitals in the state of

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Massachusetts have installed similar treatment systems to Option 3 and experienced success in the removal of contaminants, including mercury.

All three options have the capability to be automated with a programmable logic control (PLC) system;

however, Option 2 would have the most difficulty in its installation due to the complexity of the system and more manual operation requirements.

Options 1 and 2 would require the highest disposal and cleaning costs due to the media and chemical additions, respectively, while Option 3 would only require the disposal of contained filter media cakes (likely to be non-hazardous but would require bench line testing to determine).

Option 3 would also require less sampling locations (only influent and effluent), while Option 1 would require the most sampling (influent, pre-carbon, post carbon/pre-resin, and post resin/discharge) in order to monitor for breakthrough and determine media breakthrough rates.

A summary for the procurement, installation, and first year operations and maintenance (O&M) rough order of magnitude (ROM) costs is presented in Table ES.1 Summary of ROM Costs. Costs for each subsequent year are estimated to include only the annual O&M costs for each respective option; however, it should be noted procurement of replacement of components such as pumps, pressure gauges, and other miscellaneous items is not included.

Table ES.1 Summary of ROM Costs

ROM Cost Option 1A Option 1B Option 2 Option 3 Procurement and Installation $1,020,000 $960,000 $1,300,000 $1,000,000

Annual O&M costs $517,000 $426,000 $396,500 $334,000 Total for Year 1 (Installation & Operation) $1,537,000 $1,386,000 $1,696,500 $1,334,000

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1.0 INTRODUCTION AND PROJECT DESCRIPTION

The U.S. Department of Veterans Affairs (VA) has contracted with Mabbett & Associates, Inc. for support in assessing the feasibility of wastewater treatment options for supplementary mercury removal at the Jamaica Plain Veterans Affairs Medical Center (JP VAMC) from its industrial wastewater discharge (the Study). Mabbett evaluated the following three options for this feasibility study:

Option 1: Ion Resin Treatment Option 1A: Carbon and Ion Resin Treatment with Operational Redundancy Option 1B: Carbon and Ion Resin Treatment without Operational Redundancy

Option 2: Coagulation/Precipitation/Filtration with Aluminum Sulfate Treatment Option 3: Oberlin Filter Treatment

Mabbett prepared this Study to provide the JP VAMC with options available for the treatment process, as well as support in the decision-making process. This Study includes a description of the current permit regulations, existing conditions of the discharge flow at the JP VAMC, three options for possible treatment, and rough order of magnitude estimated costs for each option.

1.1 Regulation Supporting Treatment System Installation

1.1.1 MWRA Permit

The JP VAMC is authorized, under Permit No. 51005733, expiring on 15 August 2024, to discharge to the Massachusetts Water Resources Authority (MWRA) sewer system subject to the conditions of the permit. A copy of the permit is included as Attachment A for reference. The conditions of the permit include sampling and reporting of associated pollutants and pH on a semi-annual basis, as well as daily flow monitoring. The primary limitations of this permit monitor flow, pH, and metals with MWRA daily maximum limits. Seven locations within the JP VAMC are currently authorized to discharge to the MWRA system and are subject to permit requirements.

1.1.2 Notice of Noncompliance

A Notice of Noncompliance (NON) was issued to the JP VAMC for the discharge of mercury above permitted limits to the MWRA sewer system from Sampling Location 103. The NON was issued on 7 April 2023 and required the JP VAMC to institute corrective action(s) to mitigate further discharge(s) of mercury above acceptable MWRA discharge requirements. The MWRA prohibits any discharge of mercury to their system; however, 0.001 milligram per liter (mg/L) is used as the criteria limit.

1.1.3 Sample Location 103 Description

Wastewater samples are collected from one of three spigots for Location 103 which is located in the storage area of the basement in Building 1 at the JP VAMC. Sample Location 103 includes the wastewater generated from the Sterile Processing Service (SPS) area on the second floor of Building 1 at the JP VAMC. SPS serves the following departments: dental, blood laboratory, and dialysis for equipment decontamination. A spigot is located on the combined discharge line of the surgical tool cleaning device in the SPS area prior to mixing with any other wastewater streams. Composite and grab samples for Sample Location 103 are historically collected from one of the three sample ports and monitored for flow within the basement of Building 1 at the JP VAMC. Recent laboratory data and flow information for Sample Location 103 are discussed further in Section 4.0.

1.2 Historical and Current Mercury Use at the JP VAMC

JP VAMC utilizes and disposes of mercury generated by the Dental Department, located in Building 1 on Floor 2.

The dental practice places and removes mercury amalgam. Following best management practices, certified amalgam separators are utilized in the dental disposal design, such as chair-side traps and vacuum pumps with traps or filters, for mercury amalgam removal from rinse water. According to JP VAMC representatives, this

Mabbett & Associates, Inc. Page 2 December 2023 process separates mercury contamination from the discharge water of the chair-side traps and vacuum pumps for proper disposal and is not connected to the MWRA sewer discharge associated with Sample Location 103.

Although mercury amalgam and rinse water are collected, treated, and disposed of separately from the MWRA discharge line, dental tools are sterilized within a communal area for various departments at SPS. It is believed that trace mercury contamination in dental equipment is present prior to the sterilization process, which then results in mercury within the wastewater flow collected at Sample Location 103. Details regarding this location are further discussed in Section 4.0.

VHABHSCrockE Highlight

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2.0 OTHER APPLICABLE REQUIREMENTS

The selected treatment system should be designed and constructed in compliance with the most recent version and stringent of all applicable local, state, and federal regulations. These include, but are not limited to, the following.

2.1 VA Physical Security and Resiliency Design Manual (VA PSRDM)

According to the VA PSRDM, Table 1-5 Facilities with/Varying Designations identifies SPS as critical, essential, and/or ancillary designation with the note that it must follow the designation of the highest level of a supported entity on the campus. Critical Facilities are defined as “those intended to remain fully functional during and following a natural or manmade extreme event or national emergency, in addition to protecting the life safety of occupants”. Essential Facilities are defined as “those intended to remain functional with minor repairs during and following a natural or manmade extreme event or national emergency, in addition to protecting the life safety of occupants”. Ancillary Facilities are defined as “those intended to protect the life safety of occupants in case of emergency”.

The Annex to the VA PSRDM Chapter 1, Section A-1.4.2a, identifies sewerage and waste systems as critical for the continuity of operations at the facility. As the treatment system design is solely required for the waste discharge of the SPS department, the inclusion of requirements set by the PSRDM are necessary unless a waiver during the project planning, before development of scope and budget, is requested to deviate from the default designation as discussed in Section 1.4.2 of the VA PSRDM.

According to Table 2-1 of the VA PSRDM, row 10 stipulates that when the replacement of a specific building system(s) such as electrical, mechanical, plumbing, telecommunications, etc. is less than 50 percent of the total building system, compliance with requirements for the Alteration/Renovation of Existing Facilities must be followed for only the portion of the building system being replaced. Should the treatment system be considered critical equipment, row 20 indicates requirements set forth in Chapter 8 Utilities and Building Services, as well as Chapter 9 Building Systems must be followed.

2.2 VA Plumbing Design Manual

Although the VA Plumbing and Design Manual does not specifically discuss procedures for the treatment of industrial wastewater discharge to the city sewer system, Section 5.1.7 indicates laboratory waste or other special waste should be separate from the general use sanitary system and provided in accordance with the general discharge design consideration for the conventional waste system. It further stipulates that where pH adjustment systems are utilized, which is applicable for Option 1 and 2 of this Study, they should be active type, capable of positively neutralizing acid or caustic pH to acceptable parameters in consideration of varied inflow rates and pH levels via automatic injection and mixing of acid and base reagents, monitored, and controlled by a PLC. pH systems are required to be fully accessible and not located in rooms housing air handler units or mechanical air intakes, with the segregation of the treatment system and chemicals in a dedicated properly ventilated area.

Furthermore, Section 10.6.1 discusses incoming water quality treatment to SPS and specifies that the water treatment system should be located in a secure location immediately adjacent to the areas in which the treated water is to be used. Access to the treatment location should be restricted to those responsible for monitoring and maintaining the system. Alarms for low water levels, and likely the high-water levels of the storage tank are required to sound both in the water treatment area, the occupied SPS space, and the VAMC central alarm monitoring location. Although the treatment system discussed within this Study is related to the treatment of discharge from the SPS facility, the future design likely would need to acknowledge and comply with similar considerations with these guidelines.

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2.3 Massachusetts Department of Environmental Protection (MassDEP) Requirements

According to 257 CMR (Code of Massachusetts Regulations) 2.15: Permit for Discharge, a permit for discharge requires the rating of the system for permit categories. Rating includes the unit operations and designation as a Type I or II Facility. A Type I facility is any facility that has less than three-unit operations as listed in 257 CMR 2.15

(2) and has a rating of less than 20 points.

According to requirements set in 314 CMR 7.05: Activities Not Requiring a Permit, fully automated systems would require a Grade 1I or 2I operator to inspect the facility twice per week and on-call during operation. For non-fully automated systems, a Grade 1I, 2I, or higher would be required to monitor the system at minimum 8 hours per day.

Any direct discharge to the MWRA is required to provide pretreatment necessary to ensure the discharge complies with 360 CMR 10.00: Sewer Use. Pretreatment is defined as a reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of pollutant properties in wastewater prior to, or in lieu of, discharging or otherwise introducing such pollutants into a publicly owned treatment works (POTW). Due to the treatment system’s design modifying the existing MWRA connection, a sewer system connection or extension permit issued by DEP pursuant to M.G.L. c. 21, § 43, and 314 CMR 7.00: Sewer System Extension and Connection Permit Program is required.

In regard to Option 2, additional consideration should be given to the storage and usage of hazardous chemicals.

These considerations include, but are not limited to, the creation or update of the JP VAMC’s Spill Prevention, Control and Countermeasure (SPCC) Plan.

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3.0 SITE VISIT

On 14 September 2023, Mabbett representatives Darren Andrews, Senior Environmental Technician, and Emily Glennon, EI, Project Civil Engineer, met with JP VAMC representatives including John Hughes, GEMS Program Manager VA Boston, Cale Putnam, Engineering Manager Jamaica Campus, and Graham Barkson, Operations Foreman Jamaica Plain Campus. The purpose of the site visit was to obtain information regarding existing conditions, potential areas of interest for the treatment system location, and constraining factors of these locations. Key notes from the site visit are discussed below and a memorandum of the full meeting notes is included as Attachment B. The site visit included viewing the SPS located on Floor 2 in Building 1, and basement and sub-basement of Building 1 for the possible locations for a treatment system.

3.1 Building 1 (Floor 2) - SPS

Communal sterilization area consists of a three-part decontamination sink as well as sterilizers.

VA representatives stated there may be other connections to this line from other departments on various floors; however, due to the age of the JP VAMC and the configuration of piping within walls and/or floors, other connections are unknown at this time.

Piping from the multi basin sink with one discharge point and sterilizers connect directly to the sink and continues to basement of Building 1 (Sample Location 103).

JP VAMC representatives stated samples have been collected from the discharge line downstream of the three-part decontamination process and mercury was detected.

The semi-annual MWRA compliance samples have been historically taken in the basement of Building 1 (Sample Location 103), as it was believed this location directly and solely connected to the SPS discharge line, not the SPS discharge line on Floor 2 of Building 1 prior to entering any combined waste stream as the MWRA permit stipulates. If JP VAMC representatives are correct in their indications of potential flows from other floors entering this line, it should be noted that the future treatment system must only connect to the discharge from the SPS Department. Rerouting of other waste streams is considered beyond the scope of this Study.

3.2 Building 1 - Basement

Vertical and horizontal clearance constraints.

IT Closet Storage Area (behind Sample Location 103) and general storage areas may limit available space.

Storage areas cannot be relocated as the hospital is already limited in space (storage areas are extending into adjacent hallways).

Maintenance area to the right of Sample Location 103 limits available space in that direction.

Caged Storage area cannot be relocated.

Direct access is available from the main lobby via elevator to this location.

3.3 Building 1 - Sub-Basement

Vertical and horizontal clearance constraints due to piping overhead and along walkways.

Discharge point is higher than sub-basement elevation.

Distance from SPS SPS is located two floors above the sub-basement, which would increase the quantity of piping.

Limited space

Although the space in the sub-basement is not as constricted as the basement, existing treatment units, storage, and piping still limit the available footprint for a new treatment system.

Access route for construction and maintenance constraints

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Requires entrance through basement loading dock followed by key operated freight elevator.

Requires construction in place for larger components.

The maximum height of the sub-basement is approximately 7 feet. This would limit vertical height for treatment equipment.

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4.0 EXISTING CONDITIONS OF SAMPLE LOCATION 103

This section describes the current conditions of Sample Location 103 at the JP VAMC, including the flow and recent laboratory results. As Sample Location 103 is the driving factor for the proposed supplemental wastewater treatment system, other sample locations identified within JP VAMC’s MWRA permit are not discussed within this section.

4.1 Flow

Flow data at the JP VAMC for 24 January 2022 to 25 August 2023 was provided by the JP VAMC. A complete table of this data is provided as Attachment C. A summary of the maximum, minimum, and average daily flow rates in gallons per day (GPD) and gallons per minute (GPM) is presented in Table 4.1.

Table 4.1 Sample Location 103 Daily Flow Rates (2022 to 2023)

Sample Location

Total Gallons (January 3rd, 2022-August 25th, 2023)

Average

GPD

Average

GPM

Maximum

GPD

Minimum

GPD

Maximum

GPM

Minimum

GPM

103 3,006,593 5,019 3.49 29,135 47 20.23 0.033 Notes:

1. Hand logged data provided by JP VAMC and transposed electronically.

2. Some data was omitted due to possible transposition errors and/or lower values than the previous day’s log.

3. The maximum GPD was identified on 28 December 2022; the minimum GPD identified on 8 April 2022.

According to the flow data provided by the JP VAMC, the average flow rate for the dates provided was approximately 5,019 GPD; however, it should be noted that a maximum GPD was identified as 29,135 GPD with previous and post readings around the date in question within the 20,000 GPD as well. Reviewing the yearly GPD throughout the timeline provided also indicated dates of 11,000 to 19,000 GPD readings.

4.2 Pollutant Levels

Laboratory data for Sample Location 103 from December 2022 to May 2023 indicates the total mercury detected during these sampling events ranged from 0.00031 to 0.00366 mg/L with an average of 0.00129 mg/L. This data is compiled in Attachment D. Table 4.2 summarizes laboratory data for metals at Sample Location 103 between 2022 and 2023 (collected during the semi- annual and notice of violation MWRA sampling events).

Table 4.2 Sample Location 103 MWRA Semi-Annual and Notice of Violation Sampling Results (2022 to 2023)

TOTAL

METALS

Laboratory Report ID:

L2270547 -01

L2234315 -01

L2234619 -01

L2235080 -01

L2224817 -01

L2306598 -01

L2307244 -01

L2307419 -01

L2329223 -01

Collection Date: 12/14/22 6/28/22 6/29/22 6/30/22 5/10/22 2/7/23 2/8/23 2/9/23 5/24/23

CRITERIA

(mg/L)

Chromium, Total 1.0 ND NA NA NA ND NA NA NA ND

Copper, Total 1.0 0.017 NA NA NA 0.064 NA NA NA 0.0672

Lead, Total 0.2 ND NA NA NA ND ND ND ND ND

Mercury, Total 0.001

(Prohibited) 0.00058 0.00127 0.00064 0.00047 0.00137 0.00287 0.00366 0.00044 0.00031

Nickel, Total 1.0 ND NA NA NA ND NA NA NA ND

Zinc, Total 1.0 ND NA NA NA ND NA NA NA 0.0139 Notes:

ND = Non-detect NA = Not Analyzed Bold text indicates values were detected.

Red highlighted values were detected at levels above the Criteria Limits stipulated within the MWRA Permit. It should be noted that although samples collected on 12/14/2022 and 6/29/2022 are below the criteria limits when all significant digits are used, the MWRA rounds to the third significant digit, resulting in an exceedance.

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5.0 TREATMENT SYSTEM PERFORMANCE REQUIREMENTS

The following performance requirements were selected for Option 1 (Section 7.0), Option 2 (Section 8.0), and Option 3 (Section 9.0). Due to the JP VAMC operations, all three options for the treatment system are anticipated to run 24 hours a day, 7 days a week. The treatment system is all critical components in relation to the storage, filtration, treatment, and discharge of the flow.

5.1 Flow Rate

The flow rate selected for sizing a treatment system was 6,000 GPD (4.17 GPM) for all of three options. This was selected upon the review of flow data provided and average flow, discussed in Section 5.1. As described in Section 5.1, the current flow ranged from below 1,000 GPD and above 24,000 GPD with an average of 5,019 GPD. Mabbett selected 6,000 GPD as the basis for sizing and costing of the treatment system for this Study. The design of the treatment system would need to consider the minimum and maximum flows of the existing system at the time of the system design. A flow test for the SPS Facility could assist in obtaining a more accurate representation of the flow rates.

5.2 System Footprint

Mabbett anticipates a treatment system could require approximately 1,500 square feet (30-foot by 50-foot) of area. This area does not include manufacturer’s and/or maintenance clearance requirements for components. A vertical height of 7 feet is anticipated.

5.3 Clearance

Installation and maintenance clearance requirements are expected to be 5 feet on all sides which would bring the treatment system area needed to approximately 2,400 square feet.

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6.0 GENERAL EQUIPMENT DESCRIPTIONS

For all three options, the following equipment would be required for the system to operate properly.

6.1 Equalization Tank

The Equalization Tank (EQ Tank) is utilized as a holding vessel for incoming industrial water of the system from SPS. Equalization provides hydraulic and pollutant load buffering for downstream processes within the system through the reduction of peak flow loading to the system. A white EQ tank is a redundant monitoring option as it allows the operator to visually observe the water level height within the tank.

To maintain operational efficiencies and facilitate inspections of the system, maintenance such as tank cleaning would likely be required at minimum on an annual basis; however, should the tank exhibit signs of significant deterioration prior to these scheduled activities, cleaning may be warranted more frequently.

6.2 Level Switch

The EQ tank would include one high-level switch to monitor water level in the tank. Upon reaching the high-level switch, the PLC would be alerted to activate one of the two transfer pumps to start the treatment process through the system.

A low-level switch would be included within the EQ Tank to have the PLC alert the system to turn off when the water level is not adequate to flow through the system.

A high-high-level switch should also be included in the as a safety factor to alert the operator of system error and/or failure, which could result in a possible overflow of the system to the surrounding area.

The floor sump would also include low-, high-, and high-high-level switches. The low- and high-level switches would activate the transfer pump to allow flow to the EQ tank, while the high high-level switch would serve as an additional safeguard to notify the operator of an event of possible overflow or flooding to the ground. The high-high-level switch would be at the height above the high-level switch allowable to provide time for repair failure or emergency system shutdown prior to the overflow occurring from the EQ tank.

6.3 Transfer Pumps

One transfer pump would be installed in the floor sump to pump water to the EQ tank. Two transfer pumps would be utilized to pump water from the EQ tank through the treatment process. Only one of the two pumps would activate at a time, with the offline pump installed for redundancy.

6.4 Micron Filters

Micron filtration would provide an opportunity for smaller particle debris to be removed from the system prior to media treatment and polishing. Three stages of filtration would be utilized in the conceptual design, allowing influent to filter through three decreasing stages of filtration via various size micron bag filter. This process prevents the buildup of debris and small particles within the piping of the system, as well as in the media.

Preventing buildup of the piping, as well as void buildup within the media, maintains maximum flow through the system and efficiency of the media, respectively.

6.5 Pressure Gauges

Pressure gauges would be included throughout the treatment system to monitor pressure differentials of the system. This would allow the operator to monitor equipment operation and how filters are performing.

Monitoring the pressure gauges would also indicate when bag filters need replacement.

6.6 PLC/Automation

A PLC is a user programmable memory for storing instructions of functions, logic, timing, counting, communication, as well as data filing and processing. The selected system would require PLC and/or automation

Mabbett & Associates, Inc. Page 10 December 2023 for certain critical components of the system, such as level switches, transfer pumps, and pH monitoring. This allows the system to properly activate/deactivate for treatment once the EQ tank reaches associated water level heights.

The PLC/automation could further be used for the entire system in order to monitor the system function, which would offer automated switchover of redundant lines, data monitoring and logging (flow, pressure, and pH), as well as alarms to be available through the PLC remotely. Should the system be fully automated, it could reduce user errors, maintain electronic data logs as daily flow logs are necessarily per permit requirements, and reduce repair and/or shutdown time of the system.

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7.0 OPTION 1: CARBON AND ION RESIN TREATMENT

This section describes the use of Carbon and Ion Resin Treatment at the JP VAMC. Figure 1 shows two sub-options (operational redundancy [Option 1A] and non-operational redundancy [Option 1B]). For the purpose of this Study, operational redundancy is defined as secondary lines of duplicate components, allowing for one leg of the system to be online while the other is offline. Non-operational redundancy is defined as a single line of components online with no duplicity.

7.1 General Sequence of Operations

Option 1 (both sub-options A and B) includes the following general sequence of operations. Incoming industrial water from the SPS facility would gravity flow through a basket filter for the initial filtration of larger particles from the industrial water stream, prior to being held within an EQ tank. A separate floor sump with its own associated transfer pump, as well as low, high, and high-high-level switches, would be piped to the EQ tank and provide storage of small quantities of water during maintenance activities (i.e. bag filter replacements) to be treated through the system. The floor sump would be at a lower grade than all other components to allow water flow to slope towards the sump.

Upon the height of the stored water in the EQ tank reaching the high-level switch, one of the two transfer pumps is activated to begin emptying the EQ tank through various levels of filtration filters. After filtration, the water then enters the top of the carbon vessel, flowing through the carbon media for preliminary treatment, and discharges from the bottom of the vessel. From the carbon discharge point, the water enters the top of the primary resin vessel for further polishing, flowing through the resin for treatment and discharges at the bottom of the vessel. Upon discharging from the primary resin vessel, the water flows through a secondary resin treatment vessel, flowing again top to bottom, through the media. After the secondary resin treatment, the water enters a final filter and continues to the final monitoring location, where pH and flow data can be logged prior to discharging to the MWRA.

Option A includes operational redundancy for all system components, including the bag filters, carbon vessels with associated media, as well as resin vessels with associated media. Operational redundancy allows for the wastewater operator to conduct maintenance and/or repairs to one line of components within the system, while the other is still active. Ultimately, reducing the downtime of the system. It also prevents overuse of equipment, as the operator can switch the activity of the system between two functional lines to prevent burnout of system components such as pumps.

Option B does not include operational redundancy, aside from dual transfer pumps after the EQ Tank. This limits the ability of maintenance and repairs and could lead to burnout of select system components.

7.2 Critical Components for Option 1

EQ Tank Level Switches Transfer Pumps Micron Bag Filters Carbon Vessels Resin Vessels Pressure Gauges pH Monitor

Due to the nature of the contaminant of concern, it should be noted that the adsorption process of mercury is irreversible, thus prohibiting the regeneration of the resin for future reuse. Spent resin would require disposal as a hazardous waste and new resin would need to be supplied once breakthrough is detected in the existing vessels.

Sample Ports

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In order to comply with semi-annual MWRA sampling requirements, as well as to monitor media breakthrough, sample ports would be included throughout the pre- and post-treatment design. Sample ports would provide the opportunity to collect baseline data from the influent water prior to entering the EQ tank and further collect pre-carbon treatment, post-carbon treatment (i.e., pre-resin treatment), and post-resin (final discharge monitoring point) treatment data.

Collection of data between the media vessels is vital to allow the operator to validate treatment effectiveness by each component of media, as well as to monitor media breakthrough rates for future procurement and maintenance purposes.

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8.0 OPTION 2: COAGULATION/PRECIPITATION/ FILTRATION WITH ALUMINUM SULFATE TREATMENT

This section describes the use of coagulation, aluminum sulfate treatment, and filtration process at the JP VAMC.

Figure 2 shows the general schematic process and instrumentation design layout.

8.1 General Sequence of Operations

Option 2 includes the following general sequence of operations. Incoming industrial water from the SPS facility would gravity flow through a basket filter for the initial filtration of larger particles from the industrial water stream, prior to being held within an EQ tank. A separate floor sump with its own associated transfer pump, as well as low, high, and high-high-level switches, would be piped to the EQ tank and provide storage of small quantities of water during maintenance activities (i.e. bag filter replacements) to be treated through the system.

The floor sump would be at a lower grade than all other components to allow water flow to slope towards the sump. Upon the height of the stored water in the EQ tank reaching the high-level switch, one of the two transfer pumps is activated to begin emptying the EQ tank through one 10-micron filter.

After filtration, the water would then enter the mercury treatment tank where acid, base, coagulant, and a selected mercury treatment chemical would be mixed. Water level, pH, and oxidation reduction potential (ORP) would be monitored in this tank. Upon the height of the stored water in the mercury treatment tank reaching the high-level switch, a pump would activate transferring metal sludge to a sludge filter press followed by a decant transfer tank fitted with a pump. This level switch would also automatically activate the transfer valve to transfer treated water to the decant transfer tank. Following this transfer, water would be pumped to the final pH adjustment tank consisting of acid and caustic chemical treatment. The final discharge location would be fitted with a pH and flow monitoring system prior to discharging to the MWRA.

8.2 Critical Components for Option 2

Equalization Tank Decant Transfer Tank Level Switches Final pH Adjustment Tank Transfer Pumps Metal Sludge Transfer Pump Micron Bag Filters Sludge Filter Press Mercury Treatment Tank PLC Automation Acid and Base Mixing Tank Pressure Gauges Coagulant and Selected Mercury Chemical Storage pH Monitor Sampling Ports

In order to comply with semi-annual MWRA sampling requirements, as well as monitor media breakthrough, sample ports would be included throughout the pre- and post-treatment design. Sample ports would provide the opportunity to collect baseline data from the influent water prior to entering the EQ tank and further collect pre-chemical treatment, post-chemical treatment (final discharge monitoring point) treatment data.

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9.0 OPTION 3: OBERLIN FILTER TREATMENT

This section describes the use of Oberlin Filters for treatment, and filtration process at the JP VAMC. Figure 3 shows the general schematic process and instrumentation design layout.

9.0 General Sequence of Operations

Op�on 3 includes the following general sequence of opera�ons. Incoming industrial water from the SPS facility would gravity flow through a basket filter for the ini�al filtra�on of larger par�cles from the industrial water stream, prior to being held within an EQ tank. Upon the height of the stored water in the EQ tank reaching the high-level switch, one of the two transfer pumps is ac�vated to begin emptying the EQ tank to the process tank fited with a mixer. A dry powder mixture of filter aid, polymers, and clay would be added to the tank to absorb mercury in its various forms. A�er a certain contact �me, that slurry would be pumped through an Oberlin Filter which is dressed with a low micron media.

The filter cycling starts with a pneuma�c airbag holding the filter upper chamber against the lower chamber, where a liquid-�ght seal is surrounding the filter media. Solid-bearing liquid is pumped into the upper chamber from the EQ tank, where the pump pressure would force the liquid through the filter media prior to being collected in the lower chamber and draining out. The solids are held back on the filter media. Following the filtering cycle and once the filter pressure reaches 30 to 40 pounds per square inch (psi), pressurized air is fed into the upper chamber forcing the liquid through the filtered solids and media to dry the solids present on the media. A�er the solids are dried, which is determined through the back pressure and �me elapsed, the chamber is li�ed. Once the drying cycle is completed, the discharge cycle of solids is started automa�cally using a disposable media reroller or endless belt conveyor. The solids are discharged into a hopper fited with a shed skirt to cover the discharge area adjacent to the collec�on disposal method (drum or other holding device). A�er the discharge is complete the process would automa�cally start again.

The filtrate (discharge water) can then be collected and tested to ensure it is below non-detectable limits for mercury. Once cleared, the filtrate is drained to the final discharge tank would be fited with a pH and flow monitoring system prior to discharging to the MWRA.

9.1 Critical Component for Option 3

Equalization Tank Level Switch Transfer Pumps Oberlin Filter

The model OFP-7MD filter was quoted as a conservative estimate with the design; however, it should be noted actual filter size and tanks required would be determined through bench line testing conducted by the manufacturer. This model allows for a 7 square foot filtering area for a water base capacity size of 280 GPM. This filter is constructed with painted carbon steel frame per manufacturer’s standards. All wetted components are 304L or dual grade 304/304L. The filter operates at up to 40 pounds per square inch (psi) differential pressure and utilizes continuous cleanable belt media to remove solids. The solids are separated from the media and the media is rerolled at each cycle. One roll of media is supplied with the filter.

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10.0 ROUGH ORDER OF MAGNITUDE COSTS

Mabbett assessed the findings above with vendor guidance to develop a Rough Order of Magnitude (ROM) construction costs associated with the construction of a supplemental wastewater treatment system to address mercury discharges to the MWRA system.

Mabbett selected the following three options to evaluate:

Option 1: Ion Resin Treatment Option 1A: Ion Resin Treatment with Operational Redundancy Option 1B: Ion Resin Treatment without Operational Redundancy

Option 2: Coagulation/Precipitation/ Filtration with Aluminum Sulfate Treatment Option 3: Oberlin Filter Treatment

10.1 Construction Costs

Table 10.1 provides a summary of ROM construction costs for the treatment system. Design, operations, structural improvements to Building 1, electrical power supply to the system, rearranging existing piping to accommodate the treatment system, maintenance, and operations costs were not included within Table 10.1 below.

Table 10.1 Summary of ROM Construction Costs

ROM Cost Option 1A Option 1B Option 2 Option 3 $1,020,000 $960,000 $1,300,000 $1,000,000

Notes:

1. ROM costs include the system component procurement and installation. Design costs not included.

10.2 Routine Operations & Maintenance

Routine operation and maintenance are required in order for the system to function appropriately and efficiently.

These operations include, but are not limited to, sampling to determine breakthrough and adequate treatment, bag filter changeouts, as well as monitoring and logging of system functions.

Table 10.2 discusses typical costs associated operations and maintenance with each option. Maintenance costs include both routine and non-routine maintenance. Notes are included to describe details pertaining to assumptions and frequencies.

Table 10.2 Operations and Maintenance Projected ROM Cost

Description Cost

Option 1A Option 1B Option 2 Option 3 Operations

Wastewater Operator – 1I or 2I License1 $110 $110 $110 $0 Wastewater Operator – 3I or 4I License1 $130 $130 $130 $0

Wastewater Operator – License Renewal1 $75 $75 $75 $0 Wastewater Operator Training (Annual)1 $2,000 $2,000 $2,000 $0

Wastewater Operator Oversight (Annual) 2 $200,000 $200,000 $200,000 $100,000 Wastewater Operator Oversight, On-Call, (Annual) 2 $120,000 $120,000 $120,000 $60,000 Laboratory Costs – Sample Bottles, Analysis, etc. 3 $12,000 $12,000 $8,000 $6,000 Maintenance (Routine & Non-Routine)

Tank Cleaning (Annual) 4 $72,000 $36,000 $15,000 $4,560 Micron (10, 5, 1) Filter Replacement

(Annual) 5 $4,000 $2,000 $500 $0 Media Replacement (Annual)

Carbon Media $1,500 $750 $0 $0

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Description Cost

Option 1A Option 1B Option 2 Option 3 Resin Media $4,000 $2,000 $0 $0

Media Replacement, Tank Cleaning, Media Disposal, & Labor6 $100,000 $50,000 $0 $0

Chemical Replacement (Annual) Acid, Base, Coagulant Chemicals $0 $0 $30,000 $0

TOTAL ANNUAL ROM O&M COST $517,000 $426,000 $396,500 $334,000

Notes:

1. Current fees associated with Massachusetts wastewater operator licenses require an initial testing fee of $75 for a 1I or 2I license or $100 for a 3I or 4I license, both with an additional $30 administration processing fee; followed by a $75 renewal fee every two years to have the license remain active. During the renewal period, 20 training contact hours are also required. Assumes 4 operators require training and renewals.

2. Wastewater operator oversight is assumed to have staffing for 4 operators working 8-hour shifts (allowing 24-hour monitoring) a day at a standard hourly rate. On-call oversight includes additional overtime pay for hours beyond the typical workday/week.

Option 3 assumes first shift only with 20 hours per week (Monday to Friday) with a 2-hour (minimum) at an hourly rate of $95 and an overtime work for 2nd and 3rd shift, weekends, and holiday with two 4-hour (minimum) shifts on Saturday and Sunday at an hourly rate of $142.50.

3. Laboratory costs for Option 1 assumes total metals sampling only for 4 locations weekly, Option 2 assumes total metals sampling for 3 locations weekly, and Option 3 assumes total metals sampling for 2 locations weekly.

4. Assumes 2 technicians for 4-hour shift on weekend for cleaning of tank(s) and associated equipment. Tank cleanings are estimated to occur 4 times per year at a daily rate of $1,600. Assumes one 4-hour shift is adequate for activity.

5. Micron filter replacement assumed to be on as needed schedule to maintain proper operations of the system, at minimum weekly. Cost shown assumes annual procurement and replacement once per week per filter size for a conservative estimate.

6. Due to the impact of mercury on the media, media disposal would require a hazardous waste classification and need to be disposed of at an incineration facility. Media regeneration would not be feasible due to this classification as discussed in Section 6.2.

10.2.1 Option 1

Option 1 would require routine operations include sampling of the influent, carbon influent, carbon effluent (i.e.

resin influent), and resin effluent (i.e., discharge). A licensed wastewater operator would be required for system oversight and operations 24 hours a day (including on call time). Additionally, the operator would be required to monitor daily flows, pH levels, and pressure readings. Pressure readings across the micron bag filters would indicate when the micron filters need replacement.

Non routine operations would include the procurement, removal of media, cleaning of tanks, and replacement of new media. At times, the operator may be required to break up the media within the vessels to prevent channeling of the media. Disposal of the spent media would also be required as the contaminant of concern prevents regeneration of the media for future reuse.

10.2.2 Option 2

Option 2 would require routine operations include sampling of the chemical addition, storage, and mixing activities. A licensed wastewater operator would be required for system oversight and operations 24 hours a day (including on call time).