Bulletin11.

1: Tighter Ammonia Criteria On The Way for NPDES Renewals

Kevin R. Chaffee, P.E., Chief Engineer & Inventor of the EnviroFilter

NPDES permits are subject to review/renewal on five-year cycles. When renewal is sought, the wastewater discharger must comply with both the TMDL requirements and any new applicable criteria that may have been established. The EPA has urged all states to adopt numeric nutrient standards (for Total Nitrogen and Total Phosphorous) and these standards are likely to be adopted by individual states. Additionally, the EPA has issued a Draft Update to Ambient Water Quality Criteria (AWQC) for Ammonia, which will be finalized soon, which may impact many existing NPDES permit holders anticipating permit renewal over the next one to five years. States will be expected to incorporate the new ammonia criteria during their next triennial review of water quality standards. The challenge in meeting these new ammonia standards will be difficult for many existing decentralized wastewater treatment systems. If in compliance with all other discharge limits, it is difficult to justify replacement of the total system. Alternatively, engineers will need to identify cost effective solutions to address the ammonia limit for their clients. Here we will discuss the new proposed ammonia criteria and a cost-effective tertiary upgrade to existing systems to meet these new limits. The draft update to AWQC for ammonia is applicable to fresh water only, and is based on protecting aquatic life. In this update, the focus is on freshwater mussels as they are especially sensitive to ammonia. The draft update standards represent a significant reduction in permitted ammonia; by a factor of almost 5 on chronic permit limits (based on CCC) and by a factor of about 2 on acute daily limits (based on CMC). Here is a comparison of the new 2009 updated criteria for ammonia versus the existing 1999 criteria (calculated at standard conditions of 25C, ph of 8, assuming mussels present): Ambient Water Quality Criteria (AWQC) for Ammonia (mg/L, Mussels Present) 1999 Update 2009 Update Acute (CMC) Limit 5.6 2.9 Chronic (CCC) Limit 1.2 0.26 While these are levels for the receiving waters, not the effluent levels, and mixing zones are allowed, the lower AWQC values will likely offset the dilution impact of the mixing zone and present potential to exceed these standards. It should also be noted that the mussels are

March 8, 2011

likely to be present in most of the streams in the Mississippi River and Great Lakes basins; impacting a large segment of the country. With this significant change and the potential impact on existing facilities with NPDES permits on the horizon, now is the time to begin considering cost effective upgrades to ensure compliance with the anticipated new standards. The EnviroFilter System, an attached growth Package Recirculating Media Filter (PRMF) utilizing textile chips as the media, is an excellent technology for the reduction of ammonia in wastewater. Used as a tertiary polishing wastewater treatment, the PRMF can be hydraulically loaded at higher levels than when used as a secondary wastewater treatment system (due to lower organic strength) optimizing the value of the PRMF when utilized in this capacity. By utilizing underground installation, which keeps the unit insulated from cold temperatures that significantly impede the nitrification process, the EnviroFilter PRMF consistently reduces ammonia to levels below 0.2 mg/L on a year-round basis. Inside the EnviroFilter tank, the textile chip media is randomly laid in a two-foot thick bed atop a drainage grate. Chips orient largely horizontally with significant spacing between the chips for optimal air and water flow. It is in the lower portion of the two-foot bed where conditions develop allowing the sensitive nitrification bacteria to thrive. This is where the combination of temperature, ph, dissolved oxygen, and BOD is in the optimal range for the Nitrosomonas and Nitrobacter organisms to perform their facultative function. The EPA had signaled that it would publish the finalized ammonia criteria in 2010, along with implementation guidance on how the criteria are to be interpreted. As of this writing, this finalization has yet to occur. Nevertheless, it is never too early to be proactive with clients regarding upcoming NPDES reviews. Utilizing the EnviroFilter system as a polishing reactor represents a simple, cost-effective add-on technology to existing systems of all types that, in future, may need to comply with stricter requirements, to address approaching capacity limits or require additional surge capacity. HydroLogex welcomes the opportunity to supply information and provide system solutions to ammonia issues. For more information about decentralized wastewater treatment systems and the EnviroFilter technology, please contact HydroLogex at info@hydrologex.com or visit our website at www.hydrologex.com.

March 8, 2011