Geosyntec_Attachment_L_Method_of_Approach.pdf

Request for Proposal

Solicitation No. BPM005664 Advanced Water Purification Technical Support

Arizona Department of Environmental Quality - Procurement Office

1110 W. Washington St.

Phoenix, AZ 85007

Solicitation Attachment – Method of Approach | Revision No. 1 | Revised 11-22

Attachment L – Method of Approach

The Offeror shall provide a narrative response to each section that demonstrates their understanding of the Scope of Work requirements and describes the company’s overall method of approach for providing the Service(s) stated in this Solicitation.

Responses for each question shall not exceed two (2) pages in length with size ten (10) font.

Offeror shall provide a response either after each section or in a separate document entitled: “Attachment L - Method of Approach.” If a separate document is used, please clearly designate each section and double-check to ensure that each question has been answered. If any information provided is considered CONFIDENTIAL by Offeror, the information must be specifically included in the Confidential Information Designation Attachment and related documentation to be assessed for confidential treatment under A.A.C. R2-7-103.

Our team’s responses to the below questions are included on the following pages.

1. Explain how to establish the minimum number of diverse mechanisms that are needed to control pathogens without being prescriptive of the technology.

2. Explain how to establish the number of diverse mechanisms that are needed to control chemicals without being prescriptive of the technology.

3. What are the minimum number of barriers needed to control pathogens without being prescriptive of the technology?

Provide rationale for the choice.

4. What are the minimum number of barriers needed to control chemicals without being prescriptive of the technology?

Provide rationale for the choice.

5. Describe the challenges if any associated with assigning credits to a WWTP via sampling of the treated wastewater and how that can be addressed.

6. Provide a table of content for an Operations and Maintenance Manual for an Advanced Water Purification System.

7. Describe how you would approach Enhanced Source Control for an AWP project.

8. How should failure response be managed in a direct to distribution and in raw water augmentation project?

9. Describe how you would approach the Operator Certification requirements for the AWP program.

10. Describe what AOP addresses and why it is necessary in an AWP project. Address what is enough AOP.

11. Describe how low molecular weight compounds should be addressed in a carbon train an in an RO train within an AWP project.

12. What is enough treatment for ozone/BAC and should it be required as part of RO trains? Explain why or why not.

1. Explain how to establish the minimum number of diverse mechanisms that are needed to control pathogens without being prescriptive of the technology.

Narrative Response:

In an AWP treatment train, the use of multiple diverse treatment processes is a means to produce and maintain high-quality advanced treated water. It also helps maintain water quality in the case of an individual treatment process unit failure.

States with proposed or final regulations have taken different approaches to the minimum pathogen treatment requirements. At a minimum, states such as Colorado and California have required three and four barriers, respectively, for AWP facilities (5 Code of Colorado Regulations [CCR] 1002-11 § 11.14, 2023).1

Some of the primary considerations for establishing the number of diverse mechanisms needed for pathogen control include the following:

• Whether pathogen removal technologies can overlap effectively with chemical removal unit processes

• Establishing what constitutes a unique treatment mechanism; for example, ozone and ultraviolet employ diverse mechanisms for treatment but may be grouped together as an advanced disinfection mechanism that generally does not produce a chemical residual

• Whether the treatment mechanism removes each of the three primary pathogen (viruses, Cryptosporidum, and Giardia) or a subset of the group2

• Compliance with existing SDWA regulations

• Compliance with established log removal requirements for AWTFs

• How treatment is organized between a potential water recovery facility, advanced water treatment facility, and drinking water treatment facility; chemical disinfection at a WRF would need to be addressed and considered differently than chemical disinfection performed at a drinking water treatment facility

In addition, each treatment mechanism should have minimum expectations, as follows:

• Minimum and maximum LRV requirements, typically 0.5 and 6 respectively, that can be counted toward each unit process (e.g., if the process cannot remove at least 0.5 LRV, it cannot be counted as a unique unit process)3

• The pathogens removed by each unit process should be considered; one way to manage this is to require that a process must remove at least two of the three primary pathogens to be accepted as a unique pathogen removal process

• In addition, two unique processes should be able to remove each of the three major pathogens of concern

Historically, drinking water treatment plants have included two mechanisms for pathogen control: filtration (or physical separation of some kind) and disinfection (often chemical disinfection to maintain a secondary chemical residual).4 In AWP applications, the lower water quality of influent and the limited time to address treatment failures necessitates additional unit processes. Therefore, an additional treatment mechanism can be used to add to the robustness of the overall treatment train. There are several options that could be used to meet the third pathogen removal mechanism, such as UV,5 ozone, or water recovery facility with a performance validation process.6

1 California Water Resources Control Board. 2023. Direct Potable Reuse Regulations (SBDDW-23-001).

https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/dpr-regs.html 2 US EPA. 2017. 2017 Potable Reuse Compendium. Prepared by CDMSmith. https://www.epa.gov/sites/default/files/2018- 01/documents/potablereusecompendium_3.pdf 3 US EPA. 2006. Ultraviolet Disinfection Guidance Manual for the Final Long Term 2 Enhanced Surface Water Treatment Rule. Office of Water.

4 US EPA. 1996. Safe Drinking Water Act. 40 CFR 141. USEPA. https://www.epa.gov/sdwa 5 US EPA. 2020b. Disinfection profiling and Benchmarking: Technical Guidance Manual. June. https://www.epa.gov/system/files/documents/2022- 02/disprof_bench_3rules_final_508.pdf 6 Water Research Foundation. 2021. Membrane Bioreactor Validation Protocols for Water Reuse. Project Number 4997.

https://www.waterrf.org/research/projects/membrane-bioreactor-validation-protocols-water-reuse

KEY TAKEAWAYS

• The minimum number of diverse should consider the potential technology overlap with chemical control and the efficacy of the technology to address multiple pathogens.

• Three barriers for pathogen control is likely the default minimum required.

• Our team has a strong understanding of the process to develop LRV credits.

https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/dpr-regs.html https://www.epa.gov/sites/default/files/2018-01/documents/potablereusecompendium_3.pdf https://www.epa.gov/sites/default/files/2018-01/documents/potablereusecompendium_3.pdf https://www.epa.gov/sdwa https://www.epa.gov/system/files/documents/2022-02/disprof_bench_3rules_final_508.pdf https://www.epa.gov/system/files/documents/2022-02/disprof_bench_3rules_final_508.pdf https://www.waterrf.org/research/projects/membrane-bioreactor-validation-protocols-water-reuse

Benefits of the Geosyntec-Carollo Team:

• Our team has a deep understanding of the LRV credit process and the impact of the process on protecting public health.

Key Staff Andy Salveson and Eva Steinle-Darling have worked on developing LRV targets for utilities evaluating AWP based on detailed pathogen sampling campaigns in at least a half-dozen states, including Colorado, Texas, and California and several others where rules are still pending. Unlike other teams, this means we truly understand the strengths and weaknesses of the various regulatory approaches to determining and granting LRV credits. Our feedback to ADEQ is thus based on real experience in the implementation of various approaches to handling WWTP LRV credit.

• In addition, our team has been highly involved with the ADEQ AWP roadmap development and understand the dynamics of protecting public health and the viewpoints of local stakeholders.

2. Explain how to establish the number of diverse mechanisms that are needed to control chemicals without being prescriptive of the technology.

Narrative Response:

For AWP processes, as for any drinking water system, the goal of the treatment system is to meet drinking water standards; however, the source water is considerably more complex with wider ranges of potential chemicals of concern and higher influent concentrations due to the lack of an environmental buffer, which increases the potential risk to public health. Risk factors are mitigated by including additional measures, such as Enhanced Source Control, monitoring programs, and optional engineered storage. However, these programs can only mitigate the risks and developing a robust treatment process is required to ensure that drinking water standards are met, and public health is protected. Due to the complexity of the constituents in municipal wastewater, no single treatment mechanism can achieve drinking water standards for all potential chemicals, and not all chemicals of concern have drinking water standards. For example, per and poly-fluoroalkyl substances (PFAS) require a different treatment mechanism than copper. Therefore, the minimum number of mechanisms is directly correlated to the unit operations needed to adequately reduce contaminants to concentrations that meet the drinking water standards and/or other treatment goals.

A major challenge of establishing treatment water quality goals specific to potable reuse is that the projects must address not only known contaminants of concern but also establish an approach to addressing CECs as a category without clear water quality benchmarks and protect against "unknown unknowns." To meet this higher burden of proof compared to other types of projects, our team thus proposes a performance-based indicator (PBI) approach that provides two benefits: First, it establishes that treatment train processes can provide acceptable removals across a wide range of known and unknown chemical contaminants as well as (2) confirming through a PBI-based monitoring program that this performance is being achieved.

Without being prescriptive of technologies, a programmatic case-by-case approach to establishing the mechanisms to meet drinking water standards is required. Key steps that would be included in determining the number of mechanisms are as follows:

• Analyzing the AWP source water quality—Each facility must analyze its AWP source water quality to identify the chemicals present, including regulated chemicals with SDWA primary and secondary MCLs and unregulated chemicals. The chemicals typically found in AWP source water include trace organic compounds such as pharmaceuticals, PFAS, and hormones, disinfection byproducts (DBP) and DBP precursors, inorganics, and nutrients.

• Risk Assessment—Once chemicals are identified in the AWP source water, a risk assessment must be performed to identify and prioritize chemicals based on their impacts on human health and the environment.

• Regulations/Guidelines—Review any federal or state-provided guidelines for AWP and follow the treatment objectives and removal standards for specific chemicals.

• Treatment—Once the chemicals of concern are identified, a list of treatment technologies must be shortlisted based on the chemicals found in the AWP source water. Informed by the type of chemicals detected or suspected, facilities can adopt a PBI approach to meet the treatment objectives of chemicals in AWP source water.

These steps offer AWP facilities the flexibility to identify the treatment mechanisms required to protect human health and the environmental based on the specific chemicals or families of chemicals identified in the facility’s AWP source water.

Benefits of the Geosyntec-Carollo Team:

The combined experience of Geosyntec and Carollo provides a wealth of knowledge on understanding the advanced technologies to address typical and emerging chemicals of concern. Carollo has developed chemical removal approaches for CECs and unknown unknowns for several dozen planned and implemented potable reuse projects across the US. While various approaches have been used to confirm adequate chemical removals, Carollo staff Dr. Kyle Thompson established the performance-based indicator approach discussed above. This well-documented approach was subsequently built into the Colorado DPR regulations. Geosyntec has worked on dozens of municipal, industrial, mining, RCRA, and CERCLA sites with complex mixtures of contaminants that require multiple mechanisms to address various types and concentrations of chemicals of concern. One of many examples includes a large

KEY TAKEAWAYS

• Complexity of the wastewater creates a potentially greater risk to public health.

• The required minimum number of diverse mechanisms is driven by chemicals present in each specific wastewater system.

• Our team has experience developing diverse treatment mechanisms to address complex waste streams to produce potable water.

Superfund Site in California on which Geosyntec worked where the groundwater is highly contaminated with chlorinated solvents, perchlorate, 1,4-dioxane, chromium, and nitrate. Based on a thorough evaluation of treatment technologies and pilot testing, a treatment train was designed and constructed consisting of granular activated carbon (for chlorinated solvents), ion exchange (for perchlorate), advanced oxidation (for 1,4-dioxane), and reverse osmosis (for nitrate and chromium) to produce potable effluent water that is directly discharged into the existing potable water system for the region.

3. What are the minimum number of barriers needed to control pathogens without being prescriptive of the technology? Provide rationale for the choice.

Narrative Response:

The goal of the multi-barrier approach used in AWP applications is to ensure that public health is protected throughout the entire range of the influent conditions and expected treatment conditions. Technical guidance and regulatory language are revised periodically, so requirements must be sufficiently protective of users while accommodating expected changes in process, analytical, and technological capabilities.

In AWP applications, due to challenges measuring pathogens to expected discharge limits and the probabilistic nature of microbial populations in wastewater, the treatment goals are typically integrated into log removal values (LRVs) through use of a quantitative microbial risk assessment (QMRA), rather than defined effluent limits.1 These LRV requirements have been broadly applied in federal drinking water standards and by states including Colorado and Texas for their AWP programs. This LRV can be used to establish the minimum number of barrier required for pathogen control without prescriptive technology requirements. The summary of an LRV-based approach is outlined below:

• QMRAs can incorporate conservative assumptions for incoming and acceptable effluent pathogen concentrations as well as failure assumptions to reach a final LRV that provides a simple and comprehensive design and operation goal for engineers and utilities.

• A sufficiently protective LRV goal with boundaries on maximum log removal credits per unique unit treatment process allows for flexibility for the future without sacrificing protection of users.

• The prescribed LRV should include the amount of redundancy deemed appropriate by ADEQ. A baseline LRV requirement of 13, 10, 10 for virus, Cryptosporidum, and Giardia has been identified by ADEQ as an appropriate baseline LRV goal.

• As discussed at length during the TAG meetings, prior guidance, and a recent publication by Gerrity et al. (on which Key Staff member Eva Steinle-Darling was a co-author), an alternative approach to defining site-specific LRV goals should be allowed and be based on collection of a minimum of 24 pathogen samples in the proposed AWP source water.3

With the LRV approach, the minimum number of barriers is defined by the ability of each unit process to remove pathogens. A set of processes that have relatively high pathogen removal per process may require fewer total barriers than one with lower removal in each unit process. Naturally, the regulatory structure must include guardrails to ensure protection to treatment goals. Some important boundaries are listed as follows:

• Maximum LRVs per unit process per pathogen should be included. Six LRV is a common cutoff as it is the maximum LRV typically awarded to a well-performing UV system.2

• Early identification of process failures is necessary. Each treatment process used for pathogen removal must function as a critical control point with performance criteria set that indicate pathogen removal indirectly.

• Site-specific pilot testing should be performed to establish actual LRVs that are achieved by individual unit processes in the overall advanced water treatment train.

• Consideration should be taken if a conventional water treatment plant is included in the treatment configuration to ensure it can meet expected LRV in the proposed configuration.

Based on typical available technological configurations, it is expected that at least three pathogen removal steps will be required in advanced water treatment trains.

1 Soller, J.A., S.E. Eftim, I. Warren, and S.P. Nappier. 2017. “Evaluation of microbiological risks associated with direct potable reuse.” Microbial Risk Analysis. 5: 3–14 US EPA. 2017. 2017 Potable Reuse Compendium. Prepared by CDMSmith. https://www.epa.gov/sites/default/files/2018- 01/documents/potablereusecompendium_3.pdf 2 US EPA. 2006. Ultraviolet Disinfection Guidance Manual for the Final Long Term 2 Enhanced Surface Water Treatment Rule. Office of Water.

3 Daniel Gerrity, Katherine Crank, Eva Steinle-Darling, Brian M. Pecson, 2023. Establishing pathogen log reduction value targets for direct potable reuse in the United States. AWWA Water Science, Vol 5, Issue 5. DOI: 10.1002/aws2.1353

KEY TAKEAWAYS

• The number of barriers required can be based on sufficiently protective LRV requirements.

• This would protect human health while maintaining streamlined rules and requirements.

• Our team has a deep understanding of the pathogen control strategies and the key stakeholders involved in the AWP development process.

As we stated in response to Question 1, our team has a deep understanding of approaches to pathogen control based on design of multiple IPR and DPR systems and we also understand and can help to represent the perspectives of the key local stakeholders that are involved and intend to implement AWP processes.

4. What are the minimum number of barriers needed to control chemicals without being prescriptive of the technology? Provide a rationale for the choice.

Narrative Response:

The goal of AWP treatment is to meet drinking water quality requirements and ensure public health protection. However, the chemicals present and the concentrations in wastewater can vary significantly from day to day and even within a single day. As a result, the ability of AWP facilities to meet the drinking water standards requires that the system have a level of redundancy to account for potential variability and to ensure an adequate level protection. Like other state agencies, ADEQ is requiring that a multi-barrier approach be implemented at AWTFs to maximize risk mitigation.

Barriers can be technical, managerial, and operational. Enhanced Source Control can be considered as a managerial barrier, and an engineered storage buffer can be considered an operational barrier.

For wastewater facilities, the US EPA guidance document Design Criteria for Mechanical, Electric and Fluid Systems and Component Reliability (EPA 430-99-74-001) requires different levels of redundancy based on the class of facility. For Class I reliability facilities, which is the highest level, the guidelines require redundancy across multiple items throughout the facility, including sufficient pumping capacity so that the design peak flow can be handled with a failure of the largest pump. Similarly, clarifiers, trickling filters, activated carbon, and effluent filters are required in sufficient quantity and capacity to be able to handle 75% of the design flow with the largest unit out of operation. Aeration basins and flocculation basins are required to have at least two units, but no other redundancy requirements are listed. There are no specific regulatory requirements for a multi-barrier approach.

For drinking water facilities, there are specific redundancy requirements for meeting disinfection targets but there are no specific redundancy requirements in the surface water drinking rules based on the treatment of chemicals, beyond requiring that the facility always be able to meet drinking water quality standards. Similar to wastewater treatment facilities, there are no requirements for several barriers of treatment.

In their recently published AWP regulations, Texas requires two technical barriers for chemical control while Colorado and California both require three technical barriers for AWTFs. Considering the complexity and variety of the wastewater constituents, having a minimum of two technical barriers at the AWTF can eliminate a broad spectrum of chemicals and provide process redundancy. With the risk of a potential breakthrough of a single process, providing a third barrier (consisting of either engineered storage with sufficient volume to allow time for AWTF monitoring system to identify and divert off-spec water or a third barrier to provide another treatment barrier) provides an additional safeguard to public health.

Benefits of the Geosyntec-Carollo Team:

Our team has a deep understanding of the existing regulations for AWP processes as part of our involvement with the AWP roadmap preparation and associated TAG. Key Staff Jason Kerstiens, Tasha Simon, Eva Steinle-Darling, Kirk Craig, and Jason Flowers were all involved with the AWP roadmap process and TAGs. In addition, our team has implemented various AWTF facilities across the country including in the City of El Paso and at several superfund site locations.

KEY TAKEAWAYS

• Current drinking water and wastewater treatment systems have no specific requirements for multi-barrier systems.

• Texas, California, and Colorado have minimum requirements for barriers for AWP facilities.

• The minimum number of barriers is influenced by the presence of engineered storage.

• Our team was highly involved with the AWP roadmap preparation, including the TAGs, and we have experience implementing multi-barrier approaches for AWTFs.

5. Describe the challenges if any associated with assigning credits to a WWTP via sampling of the treated wastewater and how that can be addressed.

Narrative Response:

Provided that we consider ourselves to be an extension of the ADEQ team, our objectives do not include dictating to ADEQ as to how to resolve difficult questions like this. Rather, we look to educate, discuss openly, advise, and develop a consensus. It is in these areas—rather than simply imparting value judgements—that the Geosyntec-Carollo Team provides its greatest value.

Any regulatory question must begin with an examination of the regulatory precedents. The following examples should be considered as ADEQ determines its approach to WWTP log reduction value (LRV) credit:

• California determines WWTP LRVs based on site-specific pathogen sampling, with minimal credits awarded. Membrane bioreactors (MBRs) are an exception: California is in the process of adopting the tiered WaterVal approach developed by Key Carollo Staff Member Amos Branch. Some “Tier 1” credits are assigned simply for operating within certain requirements;

additional “Tier 2” credits can be given based on site-specific sampling, similar to the approach for conventional wastewater.

• Colorado rules allow a standard 12/10/10 approach but do not allow credit for wastewater treatment. Thus, the 12/10/10 standard is essentially applied to a wastewater effluent starting point, similar to Texas.

• Texas avoids the question altogether by only considering LRVs after the WWTF step.

Engineering considerations for this question include the low sample recoveries in raw wastewater, which results in very expensive analyses and uncertain results. Typical outcomes are in the 1-log credit range (Orange County Sanitation / Water Districts substantial efforts have yielded less than 1 log each). Laboratory and sampling challenges can be overcome, but unlike for other advanced treatment processes, there are no credible surrogate measurements that can confirm in “real time” that the LRVs are being achieved.

Parallels with surface water treatment rules should also be considered. Assigning credits based on an initial, time-limited sampling campaign meets a higher standard than the standard LRVs assigned for conventional surface water treatment (the “treatment technique” approach). This is different than credits given to typical disinfection processes, which are designed, tested, and monitored online to confirm proper operation. For example, UV LRV is monitored by dose algorithm that is based on direct measure of light intensity in the reactor; membrane processes integrity is measured directly via pressure decay and continuously using filtrate turbidity (MFGM) or monitoring of surrogates such as conductivity or total organic carbon for nanofiltration/reverse osmosis.

Understanding and acknowledging the existing “double standard” in how different process classes are handled in existing surface water treatment regulation allows for important analogies to their handling in AWP and could be used to justify either a standard uniform (“treatment technique”) or site-specific sampling-driven approach to LRV credits for WWTPs.

Benefits of the Geosyntec-Carollo Team:

• Key Staff Andy Salveson has worked with several utilities in California pursuing WWTP LRV credit. Key findings include (1) sampling and analysis for pathogens in raw wastewater is difficult and costly, and (2) this approach yields very little credit for the effort. This background will allow our team to accurately provide ADEQ with cost/benefit considerations for whether to grant LRV credits for WWTPs, and if so, how to do so.

• Finally, members of our team have been involved in the development of US EPA guidance that determines LRV credit for key unit processes, including Key Staff Harold Wright, who co-authored the US EPA’s UV Disinfection Guidance Manual 2020 “Innovative Approaches” update that published UV doses required to achieve up to 6-log. Our deep understanding of these more comprehensive and defensible approaches to LRV determination provides insight into the different levels of rigor applied to different processes for LRV credit in surface water treatment and reuse.

KEY TAKEAWAYS

• We seek to educate, discuss, and advise–not simply impart judgement– on important issues like this one.

• Our team has a deep, multifaceted, and practice-driven understanding of existing and proposed regulations relative to how LRVs are assigned, including to WWTPs.

• Sampling for pathogens in raw wastewater is difficult and expensive and does not yield many LRVs. MBRs are an exception.

• Regulatory precedents and analogies with existing surface water treatment LRV credit paradigms open the path for different approaches.

6. Provide a table of content for an Operations and Maintenance Manual for an Advanced Water Purification System.

Narrative Response:

The following pages present a Table of Contents for a draft Operation and Maintenance Manual that Geosyntec prepared for a confidential client.

DRAFT OPERATION AND

MAINTENANCE MANUAL

CLIENT AND SITE REDACTED

Prepared by

Geosyntec Consultants, Inc.

Draft O&M Manual, Revision 1 iii February 7, 2022

TABLE OF CONTENTS

1. INTRODUCTION

1.1 REDACTED LOCATION Interim Remedy Overview

1.2 Operation and Maintenance Manual Objectives

1.3 Roles and Responsibilities

1.3.1 USEPA Remedial Project Manager

1.3.2 Technical Oversight and Support

1.3.3 Respondent’s Project Coordinators

1.3.4 Respondent’s Supervising Contractor

1.3.5 O&M Manager

1.3.6 O&M Operator

1.4 Report Organization

2. HEALTH AND SAFETY PROTOCOLS AND REQUIREMENTS

2.1 General Health and Safety Protocols

2.2 Electrical Safety

2.2.1 General Electrical Hazards

2.2.2 High Voltage Hazards

2.2.3 Arc Flash Hazard

2.2.4 Electrical PPE

2.2.5 Lockout-Tagout Requirements

2.3 Chemical Handling Procedures

2.4 Emergency Shutdown Procedures

2.5 Procedures and Notifications for Spills and Releases

2.6 Emergency Equipment Inventory

3. REGULATORY AND TRAINING REQUIREMENTS

3.1 Operator Training and Certification Requirements

3.2 Permits to Operate

3.3 Groundwater Extraction from REDACTED LOCATION

3.4 Treatment Requirements and Effluent Standards

3.5 Wastewater Discharge

3.6 Monitoring and Reporting Requirements

4. REDACTED LOCATION INTERIM REMEDY DESCRIPTION

4.1 Groundwater Extraction and Conveyance System

4.2 Treatment Plant

4.3 Redundancy and Backup Systems

4.4 Inventory of Equipment

Draft O&M Manual, Revision 1 iv February 7, 2022

4.5 Treated Groundwater Discharge

5. GROUNDWATER EXTRACTION AND CONVEYANCE SYSTEM OPERATION

5.1 Design Criteria and Operating Parameters

5.2 Description of System Components

5.2.1 Groundwater Extraction Wells

5.2.2 Extraction Well Vaults and Wellheads

5.2.3 Groundwater Extraction Well Pumps

5.2.4 Conveyance Pipelines

5.3 Groundwater Extraction and Conveyance System Maintenance Procedures

5.3.1 Wellhead Maintenance

5.3.2 Well Inspection and Maintenance

5.3.3 Air Release Procedures for Extraction Wells

5.3.4 Conveyance Pipeline Maintenance

5.3.5 Bollards and Locks

5.4 Groundwater Extraction and Conveyance System Operating Procedures

5.4.1 Routine Safety Check

5.4.2 Startup Procedures

5.4.3 Continual Operation

5.4.4 Shutdown Procedures

5.4.5 Traffic Control

5.5 Groundwater Extraction and Conveyance System Component Operating Procedures 23

5.5.1 Wellheads

5.5.2 Well Pumps

5.5.3 Conveyance Pipeline

5.5.4 Operator Troubleshooting

5.5.5 Spare Parts

6. OPERATING PROCEDURES FOR THE TREATMENT PLANT

6.1 Introduction and Process Flow

6.2 Design Criteria and Operating Parameters

6.2.1 Influent Equalization Tank

6.2.2 Sulfuric Acid Feed Pump and Storage Tank

6.2.3 Multimedia Filtration System

6.2.4 Ultraviolet/Oxidation System

6.2.5 Liquid-Phase Granular Activated Carbon System

6.2.6 Bag Filtration System

6.2.7 Reverse Osmosis System

Draft O&M Manual, Revision 1 v February 7, 2022

6.2.8 Effluent Storage System

6.2.9 Wastewater Storage Tank

6.3 Treatment Equipment Maintenance Procedures

6.3.1 Lockout/Tagout Procedures

6.3.2 Influent Equalization Tank

6.3.3 Booster Pump Systems

6.3.4 Chemical Storage and Dosing Systems

6.3.5 Multimedia Filtration System

6.3.6 Ultraviolet/Oxidation System

6.3.7 Liquid-Phase Granular Activated Carbon System

6.3.8 Bag Filters

6.3.9 Reverse Osmosis System

6.3.10 Wastewater Storage Tank

6.3.11 Sumps

6.3.12 Effluent Discharge (to Storm Drain)

6.3.13 Eyewash and Showers

6.3.14 Canopy

6.3.15 Treatment Plant Lighting

6.3.16 Fence and Gates

6.3.17 Surveillance Cameras

6.3.18 Secondary Containment

6.4 Electrical Maintenance

6.4.1 Maintenance Tasks

6.4.2 Inspection and Tightening of Electrical Connections

6.4.3 Inspection of Power and Control Enclosures for Moisture

6.4.4 Inspection of Motors

6.5 Treatment Plant Operating Procedures

6.5.1 General Procedures

6.5.2 Routine Safety Check

6.5.3 Continual Operation

6.5.4 Shutdown Procedures

6.5.5 Influent Equalization Tank

6.5.6 Booster Pump Systems

6.5.7 Chemical Storage and Dosing Systems

6.5.8 Multimedia Filtration System

6.5.9 Ultraviolet/Oxidation System

6.5.10 Liquid-Phase Granular Activated Carbon System

Draft O&M Manual, Revision 1 vi February 7, 2022

6.5.11 Quenching Liquid-Phase Granular Activated Carbon System

6.5.12 Bag Filtration System

6.5.13 Reverse Osmosis Treatment System

6.5.14 Wastewater Storage Tank

6.5.15 Spare Parts

6.5.16 Sumps

6.5.17 Effluent Discharge (to Storm Drain)

6.5.18 Monitoring, Handling, and Disposal of Solids Accumulated during Treatment

Processes

6.5.19 Treatment Plant Lighting

6.5.20 Eyewash and Showers

7. STARTUP PROCEDURES

7.1 Groundwater Extraction and Conveyance System Startup

7.2 Treatment Plant Startup

7.3 Pre-Shakedown Phase

7.3.1 Pre-Shakedown Preliminary Testing and Inspection Activities

7.3.2 Pre-Shakedown Inspection

7.3.3 Pre-Shakedown Pressure Testing

7.3.4 Pre-Shakedown Flushing

7.4 Shakedown Testing

7.4.1 General Shakedown Testing Sequence

7.4.2 System Shakedown Testing Criteria

7.4.3 Shakedown Testing Stages

7.5 Temporary Facilities

8. FIELD MONITORING, SAMPLING, AND TROUBLESHOOTING

8.1 On-site Monitoring

8.2 Process Monitoring

8.3 Water Quality Sampling

8.4 Monitoring Procedures during Treatment Plant Operation

8.4.1 Monitoring Procedures for Extraction Wells

8.4.2 Monitoring Procedures for Equalization Tank System

8.4.3 Monitoring Procedures for Booster Pump Systems

8.4.4 Monitoring Procedures for Chemical Storage/Injection Systems

8.4.5 Monitoring Procedures for Bag Filtration System

8.4.6 Monitoring Procedures for Ultraviolet/Oxidation System

8.4.7 Monitoring Procedures for Liquid-Phase Granular Activated Carbon System .95

Draft O&M Manual, Revision 1 vii February 7, 2022

8.4.8 Monitoring Procedures for Reverse Osmosis System

8.4.9 Monitoring Procedures for Effluent Storage Tank System

8.4.10 Monitoring Procedures for Wastewater Storage Tank System

8.4.11 Monitoring Procedures for Control Systems

8.5 Sampling and Analysis Procedures

8.6 Troubleshooting

8.6.1 Booster Pump System Troubleshooting

8.6.2 Chemical Dosing System Troubleshooting

8.6.3 Bag Filtration System Troubleshooting

8.6.4 Ultraviolet/Oxidation System Troubleshooting

8.6.5 Liquid-Phase Granular Activated Carbon System Troubleshooting

8.6.6 Cartridge Filter Troubleshooting

8.6.7 Reverse Osmosis System Troubleshooting

9. MAINTENANCE SCHEDULES

9.1 Maintenance Schedule for Groundwater Extraction and Conveyance System

9.2 Maintenance Schedule for Treatment Plant Facilities

10. OPERATION AND MAINTENANCE DATA RECORDING, MANAGEMENT, AND

REPORTING

10.1 Data Recording and Management

10.1.1 Operating Logs

10.1.2 Inspection and Service Records

10.2 Reporting

11. OPERATIONAL AND FUNCTIONAL DETERMINATION

11.1 Groundwater Extraction Wells

11.2 Conveyance System and Influent Water

11.3 Multimedia Filtration System

11.4 Ultraviolet/Oxidation System

11.5 Liquid-Phase Granular Activated Carbon System

11.6 Quenching Liquid-Phase Granular Activated Carbon System

11.7 Bag Filtration System

11.8 Reverse Osmosis System

11.9 Treated Water Storage and Conveyance System

11.10 Wastewater Discharge

11.11 Operational and Functional Reporting

12. OPERATION AND MAINTENANCE COST ESTIMATE

Draft O&M Manual, Revision 1 viii February 7, 2022

13. WARRANTY PROVISIONS

14. LIMITATIONS

15. REFERENCES

Draft O&M Manual, Revision 1 ix February 7, 2022

LIST OF TABLES

Table 2-1: Release of Reportable Quantity for Chemicals On-site Table 3-1: Permit Compliance Requirements Table 3-2: REDACTED LOCATION Constituents Requiring Treatment Table 3-3: Anticipated Water Quality Sampling Summary Table 4-1: Segments for Pipeline from Extraction Wells to Treatment Plant Table 4-2: Setpoints for Operational Parameters Table 4-3: Inventory of Equipment Table 5-1: Troubleshooting for Groundwater Extraction and Conveyance Systems Table 5-2: Spare Parts for Groundwater Extraction and Conveyance Systems Table 6-1: Descriptions of Treatment Plant Processes Table 6-2: RO System Operating Summary Table 6-3: Estimated Amount of Wastewater Generated During Routine Operations Table 6-4: Tasks for Electrical Maintenance Table 6-5: List of Treatment System Enclosures Table 6-6: UV/Ox System Operation Summary Table 6-7: Valve Sequences for LGAC 4700A/B Table 6-8: Valve Sequences for Quenching LGAC Table 6-9: Spare Parts for the Treatment Plant Table 6-10: Flushing Times of Eyewash and Showers for Treatment Plant Table 6-11: Main Components of the Treatment System Table 7-1: Summary of Shakedown Test Stages Table 7-2: Performance Metrics of Individual Unit Processes Table 8-1: Field Analytical Equipment Table 8-2: Treatment Plant Continuous Monitoring Parameters and Locations Table 8-3: Treatment Plant Component Monitoring Locations and Frequency Table 9-1: Recommended Maintenance Schedule for the Groundwater Extraction and

Conveyance System Table 9-2: Recommended Maintenance Schedule for the Treatment Plant Table 11-1: Estimated Extraction Rates at Incremental Static Groundwater Elevations Table 12-1: Engineer’s Opinion of Estimated Annual O&M Costs

Draft O&M Manual, Revision 1 x February 7, 2022

LIST OF FIGURES

Figure 1-1: Remedial Action Project Team Organization Chart Figure 4-1: REDACTED LOCATION Interim Remedy Site Features Figure 4-2: Layout of Treatment Plant Figure 6-1: Treatment Plant Process Flow Diagram Figure 6-2: P&ID of Multimedia Filters Figure 6-3: P&ID of LGAC System Figure 6-4: P&ID of Quenching LGAC System Figure 6-5: RO Stage 1 Valve Positions Figure 6-6: RO Stage 2 Valve Positions Figure 6-7: Timer Setup for Site Lighting Figure 8-1: Sampling Locations

LIST OF APPENDICES

Appendix A: Response to USEPA Comments Appendix B: As-Built Drawing Sheets Appendix C: Photographs of The Constructed Treatment System Appendix D: Safety Data Sheets Appendix E: Regulatory Permits Appendix F: Manufacturers/Vendors Manuals Appendix G: Operational Data Log Forms Appendix H: Service and Inspection Forms Appendix I: Sampling and Analysis Plan Appendix J: Operational and Functional Performance Checklist

7. Describe how you would approach Enhanced Source Control for an AWP Project

Narrative Response:

One of the three primary objectives of the National Pretreatment Program (NPP) is to “improve opportunities to recycle and reclaim municipal and industrial wastewaters and sludges” (emphasis added). While this objective has been a part of the pretreatment program since inception, many programs are focused on the other objectives concerned with protection of the POTW and the POTW’s ability to effectively treat wastewater. The Geosyntec-Carollo Team recommends building on the regulatory and technical framework included in the NPP as the basis for Enhanced Source Control associated with AWP projects, while incorporating the recently published water recovery facility (WRF) guidance 4960: An Enhanced Source Control Framework for Industrial Contaminants in Potable Reuse.

The NPP, as traditionally implemented, is designed to protect waters of the state (or US) and biosolids produced by wastewater utilities from dangerous levels of constituents of concerns (COCs). While the NPP does not specifically address human health concerns associated with using wastewater as source water for AWP, the framework exists, and consideration of water reuse appears to have been contemplated by the initial creators of the NPP. The framework of the NPP coupled with recent WRF projects, recommendations from the AWP TAG, guidance from other states, and our assembled team of experts will serve as the basis for developing a mechanism to address the concerns of an Enhanced Source Control Program for AWP.

Enhanced Source Control programs for AWP must build on the traditional components of the NPP (listed to the right) to expand the program to incorporate the protection of public health necessary for water reuse by incorporating robust programs based on the components of the NPP and especially for the following:

1) Identification of COCs: Each individual AWP project will have site-specific COCs. This can include traditionally regulated compounds (those that are regulated by the CWA or the SDWA, or state-specific standards), chemicals previously identified by ADEQ or US EPA as potential risks for reuse based on human health risk, or performance-based indicators used monitor effectiveness of the AWP.

2) Monitoring and Assessment: Monitoring programs for AWP projects focus data collection on the raw wastewater influent and the transfer point of treated wastewater to the advanced water treatment facility. These monitoring programs should also consider non-domestic discharges to the POTW (as part of the development of an inventory of COCs) as the domestic contribution is important in understanding the uncontrollable load to the collection system and informing the public outreach needs.

3) Source Investigations and Inventory of COCs: Once the COCs have been identified, the program needs to determine where the COCs enter the collection system (wastewater discharges, hauled wastes, byproducts of chemical breakdown) and create an inventory that can be regularly monitored and updated to inform the development of mitigation measures to limit inputs of COCs in source water to the advanced water treatment system.

4) Public Outreach: Treatment by industrial or commercial dischargers to remove COCs to levels acceptable for AWP may prove to be cost-prohibitive, thus necessitating a program that encourages product substitution, alternative disposal mechanisms, best management practices, and other creative solutions. Additionally, domestic sources of COCs are not legally controllable via the existing NPP framework; therefore, public outreach to promote household product substitution and proper disposal may become key components to an effective Enhanced Source Control program.

The Geosyntec-Carollo Team plans to develop a program by implementing the phased approach detailed by WRF 4960 with additions and modifications to specifically address the needs of Arizona POTWs. The four proposed phases are as follows:

KEY TAKEAWAYS

The Geosyntec team combines significant experience developing unique, site-specific local limits as part of municipal industrial pretreatment programs with thought leadership in Enhanced Source Control program framework development for AWP.

We propose to build on the Team’s extensive knowledge of existing NPP applications, AWP programs, and the guidance provided by WRF, other states, and the AWP TAG.

KEY NPP COMPONENTS FOR ENHANCED

SOURCE CONTROL PROGRAMS

1) Legal and Regulatory Authority

2) Program Implementation Procedures

3) Program Funding and Resources

4) Local Limits Development

5) Enforcement Response Plans

6) Identification of Industrial Users

Benefits of the Geosyntec Team:

The Geosyntec-Carollo Team combines Geosyntec’s extensive experience in industrial pretreatment development, including innovative approaches for new and challenging contaminants provided by high-tech industries with Carollo’s thought leadership in extending the existing NPP to achieve enhanced source control for potable reuse applications.

Geosyntec’s proposed key staff members Elizabeth Toot-Levy and Loren Gormley contribute substantial experience implementing the NPP, including specific experience with the evaluation of site specific COCs for inclusion into traditional municipal industrial pretreatment programs. These experiences provide us with unique skill sets to assist with the development of Enhanced Source Control programs as part of AWP projects. Additionally, our team regularly updates or develops sewer use ordinances or other regulatory control mechanisms in accordance with the NPP and can readily incorporate Enhanced Source Control components to the existing regulatory structure. A key component of an Enhanced Source Control program will be the sampling and monitoring programs which we have significant experience developing and implementing.

Carollo’s proposed key staff members are Dr. Eva Steinle-Darling (PI on the first WRF project to address real-time collection system monitoring for DPR, WRF #4908) and Andrew Salveson (PI and Co-PI on the two additional WRF projects providing additional guidance on collection system monitoring WRF and developing a step-by-step approach to developing a comprehensive Enhanced Source Control program, WRF #4960 and WRF #5048, respectively). These studies defined an industrial source control framework that was incorporated into the Colorado direct potable reuse guidelines and presented during TAG meetings with ADEQ.

Additionally, key staff member Corin Marron is supporting development of El Paso’s approach to Enhanced Source Control program for its direct potable reuse project, which includes complete diversion of discharges from a refinery. Thus, the Carollo team members bring directly relevant experience in the application of Enhanced Source Control for AWP.

Together, Geosyntec and Carollo provide a unique combination of expertise supporting municipal clients through each stage of the source control process as they address new, diverse, and difficult-to-treat pollutants. Experience extending and applying these principles specifically to AWP makes us ideally suited to develop the additions to existing NPP guidance that would apply to AWP in Arizona.

Phase 1: Initial Review and Planning

Feasibility Study: Authorities, Stakeholder Identification, Program Capacity, COC Identification

Phase 2: Risk Assessment and Analysis

Facility Planning: Industrial Risks, Chemical Inventory, Initial Monitoring, Source Investigations

Phase 3: Contaminant Monitoring and Tracking

Preliminary Design: Data Collection, Local Limits Development, Robust Sampling and Monitoring Plan, COC Inventory

Phase 4: Enhanced Source Control Plan Implementation

Permitting and Implementation: Program Implementation and Refinement, Documenting and

Reporting, Monitoring and Response

8. How should failure response be managed in a direct to distribution and in raw water augmentation project.

Narrative Response:

There are two important concepts embedded in this question: the question of failure response and the question of differentiation between direct to distribution and raw water augmentation. Key Staff Andy Salveson and Eva Steinle-Darling co-authored the original guidance on failure response for DPR (WRRF 12-06). The industry has built on this to establish additional guidance around the critical control point (CCP) approach to operations, including failure response protocols (WRRF 13- 03). The key to failure response is to understand the nature of the risk (acute or chronic) and the amount of response time available to act if any given failure occurs.

For acute risks (pathogens, nitrate, etc.), the available response time drives decisions about monitoring requirements, staffing requirements, and the stringency of standard operating procedures developed in the case of a given failure.

For a typical raw water augmentation project with a large raw water reservoir, a failure response time may be on the order of days, allowing for remote or on-call after-hours operator supervision, whereas for a typical direct-to-distribution project, the response time may be measured in minutes or a small number of hours and requires very close monitoring and operational oversight. What this looks like in detail must be considered within a robust CCP framework, which our team is uniquely qualified to help ADEQ develop.

At both the conceptual and implementation level, there is no need to differentiate between the two forms of AWP listed in the question. They should be considered as part of a continuum, as shown in the diagram and as real projects have illustrated. The DPR project in Wichita Falls, Texas, incorporates mixing of microfiltration/reverse osmosis treated effluent with 50% surface water, followed by conventional water treatment with enhanced disinfection for additional LRV credit. This is the second full-scale DPR project in the US and illustrates the importance of providing a framework that accommodates a wide range of projects.

Benefits of the Geosyntec-Carollo Team:

Our team has developed the existing industry guidance on this topic and has also defined the first CCP program for a DPR project in the US: the direct-to-distribution AWP Facility in El Paso, Texas, which will go to construction in 2024. With experience in guidance and real implementation, our team is best suited to help ADEQ develop a stringent, but extensive CCP framework that determines appropriate failure response across a range of potential future AWP project scenarios.

KEY TAKEAWAYS

• It is important to rely on the Critical Control Point (CCP) concept.

• ADEQ needs a stringent, but general CCP framework that will provide adequate failure response across many AWP project scenarios.

• Failure response requirements depend heavily on available response time.

• Our team developed original guidance and the only CCP program for a real DPR project in the US; this combination is the ideal basis for developing a regulatory CCP framework for ADEQ.

FRT = Failure Response Time RRT = Response Retention Time (Storage Volume)

Continuum of DPR Failure Response Scenarios (from WRRF https://watereuse.org/wp-content/uploads/2015/05/Engineered-Storage.pdf https://watereuse.org/wp-content/uploads/2015/05/Engineered-Storage.pdf

9. Describe how you would approach the Operator Certification requirements for the AWP program.

Narrative Response:

ADEQ has an established wastewater operator certification program that consists for four grade levels. To achieve a specific grade level, an operator is required to meet specific education and work experience along with passing the specific test for that level. Currently, ADEQ’s highest level for water and wastewater operators is Grade 4, which requires 2–3 years of experience depending on the education background before taking the Grade 4 exam.

The other states that are developing AWP programs have addressed the issue of operator certification with different strategies. Colorado requires a Class A wastewater operator for the wastewater facility and a Class A water treatment operator for the pathogen or chemical control portion of the facility.