Reference_-_G_Other_Disposal_Requirements_Report_10_30_22_v3f_3.pdf

Operation and Maintenance of Ohmsett Contract E17PC00014

Other Disposal Requirements Report

Prepared for:

BSEE Contracting Officer’s Representative (COR) Frank Jurado

BSEE Oil Preparedness Division 45600 Woodland Road

Sterling, VA 20166 Email: Frank.Jurado@bsee.gov

Phone: (571) 279-7896

Prepared by:

Applied Research Associates, Inc.

Ohmsett Facility P.O. Box 150

Leonardo, NJ 07737 www.ara.com

(732) 866-7183

Date: October 27, 2022 mailto:Frank.Jurado@bsee.gov http://www.ara.com/

Operation and Maintenance of Ohmsett Contract E17PC00014 i

Table of Contents

1. Requirement

2. Approach

2.1. Removal of Diatomaceous Earth

2.1.1. Solid Waste Hauler

2.1.2. Hazardous Waste Disposal Service

2.2. Sewer Discharges

2.2.1. Standard Discharge Source and Location

2.2.2. Discharge Specification

2.2.3. Analysis and Documentation

2.2.4. Refurbishment Discharge Protocol

2.3. Water Discharges

2.3.1. Periodic Storm Water Accumulation

2.3.2. Five-Year Maintenance and Repairs

2.4. Renewal of NJPDES-DSW Permit

2.5. Training

2.6. Other Reporting

Other Disposal Requirements Report

1. Requirement Other Disposal Requirements report includes a summary of the status of the following.

• Arrangements for the removal of diatomaceous earth

• Obtaining and maintaining the required discharge permits covering water discharges into

Sandy Hook Bay and Middletown Sewerage System

• Keeping records of any water discharges into Sandy Hook Bay and Middletown Sewerage

System and the resulting chemical analyses necessary to meet the most stringent applicable regulations

• Reports to the Middletown Authority on discharges to their system

• Proper disposal of non-hazardous chemical by-products from the chemistry laboratory and other non-hazardous waste products as required by the most stringent applicable regulation

• Training and personnel designation for handling of hazardous materials and waste first annual hazardous waste training

2. Approach

2.1. Removal of Diatomaceous Earth

The Ohmsett facility routinely uses diatomaceous earth (DE) as a solid or granular media for the filtration of the test tank saltwater. In addition to DE, the facility may use specific grades of cellulose fiber as a filter aid. The use of cellulose is always in conjunction with the normal DE media. Spent DE or DE/cellulose mixture is processed through slurry compression in a filter press to remove free water and much of the pellicular water. The resultant filter cake is disposed offsite through one of two main solid-waste stream routes.

2.1.1. Solid Waste Hauler

Filter cake, a by-product from tank water filtration, which contains no significant source of dispersed oil or other hazardous substances, is presented for disposal through a solid waste hauler. Non-hazardous disposal is permitted and performed in accordance with New Jersey ID- 27, Dry Industrial Waste, based upon previous classification analyses performed by Accredited Analytical Resources, LLC (Accredited), a certified New Jersey laboratory. Presently, the waste hauler is Republic Services of Tinton Falls, New Jersey. Additionally, this waste DE is presented to the hauler as a segregated product in a dedicated container.

2.1.2. Hazardous Waste Disposal Service

Dewatered, spent DE filter cake produced during periods where, by virtue of operational or testing parameters, known levels of dispersed oils or other hazardous materials can be expected in the water column, a hazardous waste disposal service is used. This presumed hazardous waste stream is segregated in lined containers designated for pickup by the hazardous waste service.

Presently, the hazardous waste disposal service used is Veolia Environmental Services of Middlesex, New Jersey.

2.2. Sewer Discharges

Routine and effective operations in the Ohmsett Facility test tank require that the tank water level be maintained at or about eight feet in depth. An inch of rain (or equivalent precipitation) in the open tank equates to approximately 1.3 inches of rise in the water level. This difference is due to the large number of adjacent walkways and containment surfaces that drain to the tank.

Evaporation rates from the tank surface are generally not sufficient to offset this rain accumulation; therefore, significant periods of precipitation often result in a high-water condition in the tank that is operationally undesirable. To counter this net gain in water level and allow the Ohmsett facility to continue to operate optimally, it becomes necessary to periodically discharge water from the tank. The Township of Middletown Sewer Authority (TOMSA) is the publicly owned treatment works (POTW) permitted to treat sanitary sewer influent from the region in which the Ohmsett facility operates. Ohmsett maintains two accounts with TOMSA. One account is for sanitary sewerage discharged from facility buildings R-24 and R-26; the second account was established in 2019 to handle excess treated tank water. ARA has worked diligently with the technical staff of TOMSA to define acceptable discharge criteria including discharge quality limits, flow rates, and the logistics of discharge events.

2.2.1. Standard Discharge Source and Location

Part of maintaining water quality in the Ohmsett test tank includes routine filtering through a DE and supplemental media filter system in a closed loop to and from the tank. Tank water enters the filtering system through a 12-inch inlet in a sump at the northeast corner of the test tank.

Filtration takes place at a volume flow rate range of 1,500 to 2,000 gpm. The effluent from this operation is the source of filtered water for discharge to TOMSA during tank level-lowering events.

The final metered, reduced flow discharge is directed to an on-site granular activated carbon (GAC) filter system and, subsequently, to the sanitary sewer manhole and pump station located in the ground just north and west of the test tank. This manhole is designated as TOMSA MH#5- 103, the northernmost manhole on Cedar Avenue in Leonardo, New Jersey.

Figure 1. Standard discharge protocol process flowchart

2.2.2. Discharge Specification

Discharge to the sanitary sewer is conducted through one-inch reinforced tubing tapped from a six-inch standpipe that is part of the filtered water return (12-inch pipe) to the Ohmsett tank.

Ohmsett strictly adheres to discharge flow limits of 10 gpm instantaneous flow rate, and a total cumulative daily discharge volume of no more than 25,000 gallons (refer to N.J.A.C 7:14A-1.2 and the definition of significant indirect user). Discharge will only occur during regular, eight-hour shifts with Ohmsett personnel on site to tend to system operation and monitoring, unless authorized by TOMSA.

A discharge event is only initiated after laboratory-analyzed water quality is within the limits set forth in TOMSA’s Rules and Regulations. Discharge is conducted through a totalizing flow meter that is monitored and recorded during the discharge event. In addition to monitoring discharge flow rate and flow totalizing via a meter, total discharge from the tank is confirmed by physical sounding of the Ohmsett test tank before and after a discharge event. TOMSA reserves the right to suspend acceptance of discharge from the Ohmsett tank if it believes that the discharge has had or will have a negative impact on its conveyance and/or treatment facilities.

2.2.3. Analysis and Documentation

Prior to notification of the intent to discharge to TOMSA, the following analyses will be conducted at the Ohmsett facility to assure water quality:

• Tank water is visually inspected. The surface water over the tank water inlet to the filter system is actively cleared using high-pressure water fan(s) and surface oil that may be present is skimmed and removed.

• A tank water grab sample of appropriate volume is taken from a sampling point down-stream of the filter and prior to the discharge point to TOMSA.

• The grab sample is tested in the Ohmsett laboratory for total recoverable oil and grease by non-dispersive infra-red (NDIR), total dissolved solids (TDS), salinity and conductivity, free chlorine, density, pH, turbidity, and oxidation/reduction potential (ORP).

• In the event of dispersant testing prior to the intent to discharge, the Ohmsett laboratory conducts interfacial tension (IFT) analyses on samples of tank water prior to dispersant testing and after dispersant removal from the tank water.

Tank water analytical data produced by the Ohmsett laboratory is reported to TOMSA as part of the notification to discharge process. If a discharge period extends beyond 72 hours, an additional set of Ohmsett laboratory analyses is conducted and reported for each additional 72-hour period.

Ohmsett submits a report to TOMSA for billing and historical purposes. This report includes discrete discharge period water volumes with accompanying Ohmsett laboratory analytical report, the start and end time and date for each discharge, total volume discharged each calendar day, cumulative monthly water discharge volume, and quarterly certified analytical data as appropriate.

The total quantity of water discharged to TOMSA in the standard discharge protocol was 510,740 gallons over the reporting period.

2.2.4. Refurbishment Discharge Protocol

As part of the Tank Refurbishment Program, ARA used TOMSA to accept residual water left in the tank after the Sandy Hook Bay discharge, plus additional storm-related accumulation during the effort. The special TOMSA refurbishment configuration for the Ohmsett Tank is shown below.

Figure 2. Refurbishment discharge protocol process flowchart

ARA maximized control of over residual dust and cuttings associated with tank surface preparation, including a “Zamboni” style unit for water and sediment control using silt barriers and screening systems. Three large fractionation tanks, totaling 63,000 gallons, were emplaced on site to serve as a transitional storage for wastewater after being removed from the tank, but before treatment and sewer discharge. Prior to discharge, the water was treated using the GAC (granular activated carbon) filter units set up for the authorized bay discharges. These were significantly oversized for the TOMSA application but performed without issue. Per temporary agreement with TOMSA Executive Director Brian Rischman, the enhanced system discharges up to 52 gpm (gallons per minute) versus 10 gpm for the standard discharge rate. This yielded daily discharge volumes of 14,025 gallons to 24,248 gallons per eight-hour supervised duty day, within the standard limit of 25,000 gallons imposed by the New Jersey Department of Environmental Protection (NJDEP) and the U.S. Environmental Protection Agency (EPA) for non-permitted daily water discharge quantity.

2.3. Water Discharges

The Ohmsett facility maintains a New Jersey Pollutant Discharge Elimination System (NJPDES) Discharge to Surface Water (DSW) permit, NJPDES-DSW Permit #NJ0005762, which authorizes and establishes discharge limits of test tank water to the Sandy Hook Bay, which lies adjacent to the facility. This type of discharge is used for the following two purposes.

2.3.1. Periodic Storm Water Accumulation

Periodic discharges are done as a means of releasing excess storm water accumulation in the test tank. This is completed in cases when TOMSA cannot accommodate discharge to their facility, or when the volume of water is greater than the limitations established through the agreement with TOMSA. There was no tank water discharged to Sandy Hook Bay for periodic storm water accumulation during the reporting period.

The only other mode of water discharge from the Ohmsett facility would be normal surface and routine storm water discharge via the base storm water system and through the base storm water discharge permit.

2.3.2. Five-Year Maintenance and Repairs

Periodic emptying of the test tank is performed to achieve cleaning, inspection, resurfacing/painting, maintenance, repairs, and upgrades. Due to situational issues surrounding the COVID-19 pandemic, the scheduled 2020 tank refurbishment was delayed. The refurbishment started in May 2021, the test tank was completely drained by July 30, 2021, and the tank was refilled in April 2022.

Figure 3. Typical Sandy Hook Bay discharge process flowchart

2.4. Renewal of NJPDES-DSW Permit

The Ohmsett permit for industrial water discharge to Sandy Hook Bay (NJPDES-DSW Permit #NJ0005762) was renewed on July 1, 2022.

2.5. Training

Eight-hour HAZWOPER (Hazardous Waste Operations and Emergency Response) refresher training was conducted during Summer 2022 for appropriate ARA staff. Training was done primarily online and is ongoing (the Facility Manager obtained refresher certification during the Northwest Oil Spill Control Course in Port Angeles, Washington, in August 2022).

2.6. Other Reporting

Chemical Facility Anti-Terrorism Standards (CFATS) is the national regulatory program focused specifically on security at high-risk chemical facilities. The Department of Homeland Security (DHS) manages the CFATS program by working with facilities to ensure security measures are in place to reduce the risks associated with certain hazardous chemicals and to prevent them from being exploited in a terrorist attack. Ohmsett staff self-assessed the facility and determined that storage quantities of Chemicals of Interest (COI) are below triggering amounts for CFATS oversight. If this status changes, Ohmsett will enter the program via the Chemical Security Assessment Tool (CSAT) Top Screen process. This will officially validate if enough quantities of COI are stored at the facility and evaluate security, handling, and accountability procedures. ARA has operated within the CFATS program at two other facilities.