Geosyntec and ATM to Present at WEFTEC
George Hollerbach, P.E., BCEE, CSP, Edward Horai, (New Jersey), Rishab Mahajan, P.E., CFM, CPSWQ, (Illinois), Adrienne Nemura, P.E., Elizabeth Toot-Levy (Ohio), and Steve Peene, Ph.D., (Florida), will present at WEFTEC, the annual technical conference of the Water Environment Federation (WEF), at the Ernest N. Morial Convention Center in New Orleans, Louisiana, on October 10–12, 2022.
George Hollerbach is a Senior Principal Engineer based in New Jersey with more than 35 years of experience focused on water and wastewater, remediation, construction management, environmental health and safety (EHS), and pharmaceutical projects.
Ed Horai is a Senior Staff Engineer based in New Jersey with experience focused on civil engineering with a concentration in environmental engineering. In addition to leading and executing numerous environmental sampling field events, his professional experience includes industrial wastewater analysis and treatment technology evaluation report preparation.
Rishab Mahajan is a water resources engineer focused on providing clients with affordable solutions to meet their regulatory obligations through numerical modeling and data analysis. He has over 14 years of experience developing and calibrating surface water models. Rishab conducts hydrologic and hydraulic modeling and stormwater design to find resourceful solutions to the most complex situations.
Adrienne Nemura is a Principal Water Resources Engineer based in Ohio with more than 35 years of experience focused on helping clients identify cost-effective and sustainable solutions to meet their water quality goals. She has worked for more than 40 cities and wastewater utilities, state and federal regulatory agencies, industrial facilities, airports, attorneys, consulting firms, nonprofit organizations, and trade associations.
Steven Peene is a Senior Principal with ATM, A Geosyntec Company; he is based in Florida and offers more than 32 years of experience focused on the water resources practice. He has extensive experience in water resources analysis including sea level rise–coastal surge modeling, watershed planning, stormwater management planning, NPDES MS4 permitting, evaluation of nonpoint and point source pollution in surface water systems, hydrologic, hydrodynamic, sediment transport and water quality modeling for lakes, rivers, estuaries, coastal embayments, and offshore; evaluation of impacts to ecological resources in surface waters; design and implementation of monitoring in surface water systems; and hydrologic and water quality restoration.
Elizabeth Toot-Levy has 19 years of experience working in the field of environmental and regulatory compliance. Her expertise includes Clean Water Act (CWA) compliance, water quality standards, water quality and environmental monitoring, risk communication, watershed management, industrial and municipal pretreatment, integrated planning and many other aspects related to local, state, and federal compliance with the CWA.
WEFTEC brings together water professionals from around the world and offers water quality education, access to leading experts, the latest technology and trends, and proven solutions.
WEF is a nonprofit association that provides technical education and training for thousands of water quality professionals who clean water and return it safely to the environment. WEF members have proudly protected public health, served their local communities and supported clean water worldwide since 1928.
Road Trip! Following the WEF Roadmap to Integrated Planning
Moderator: John Phillips, Parametrix
Invited Speakers: Adrienne Nemura, Geosyntec; Sarah Dominick, Hazen and Sawyer
Date/Time: October 10, 2022, at 1:00–1:12 p.m. CDT
The WEF Integrated Planning Task Force will present a draft version of the Roadmap to Integrated Planning. A fun interactive Road Trip on Integrated Planning led by the primary authors. Audience members will have a seat on the journey from concept to draft and learn about all of the bumps in the road. Integrated Planning is a concept that supports prioritization of capital investments of water infrastructure designed to protect human health and the environment, and to incorporate societal objectives in the most cost-effective, affordable way, that can create more economical and sustainable outcomes that result in better overall water quality. Integrated Planning advances the protection of water quality and quantity in all areas of the water cycle by working together with stakeholders to form an integrated local plan that evaluates comprehensive alternatives, prioritizes and achieves multiple goals to optimize the use of resources and funding while providing the highest attainable outcomes. Integrated Planning incorporates one water concepts and guides wise use our limited resources. IP provides more coordination and up-front planning at the local level along with local stakeholder accountability. The result is less overall cost to achieve ultimate goals, compliance with regulations, and successful outcomes.
NARP: A Novel Watershed-Based Permitting Approach to Address Nutrient-Related Impairments
Speaker: Rishab Mahajan, Geosyntec Consultants
Date/Time: October 10, 2022, at 3:30–3:50 p.m. CDT
Efforts to reduce nutrient loading from point sources (such as wastewater treatment plants and municipal separate storm sewer systems or MS4s) and non-point sources (stormwater runoff, agriculture) are being used to address the Gulf of Mexico hypoxia, harmful algal blooms in Western Lake Erie, and numerous other nutrient-related impairments in local water bodies. These efforts are picking up pace across the U.S.. The US Environmental Protection Agency (EPA) has been working with states, U.S. territories, and tribes (hereinafter referred to as "states") to adopt numeric nutrient criteria (NNC) for total phosphorus (TP) and total nitrogen (TN) since 2000. These NNC are then used to develop effluent limits for National Pollution Discharge Elimination System (NPDES) permits for point source discharges. EPA released new guidance to help states adopt NNC for lakes and reservoirs in 2021 (EPA, 2021). Few states, however, have been able to develop NNC for all lakes/reservoirs due to the complexity of the relationship between stressors (nutrients) and response (algae blooms, dissolved oxygen, pH, etc.). The development of NNC for streams has proved to be even more challenging. For example, Illinois's Nutrient Science Advisory Committee (NSAC) developed recommended NNC for streams and rivers (Illinois NSAC, 2021). However, these criteria have not been adopted by Illinois. Illinois EPA received numerous comments that the NSAC's recommendations were unsupportable, did not account for site-specific conditions, and were unnecessarily stringent. The complexity of nutrient impacts on receiving water requires adoption of innovative strategies for nutrient load reduction planning and implementation. The strategies involve watershed approaches which include load reductions from both point and non-point sources and other measures.
NUTRIENT ASSESSMENT REDUCTION PLAN
Illinois EPA had proposed a total phosphorus effluent standard of 1.0 milligrams per liter (mg/L) for major publicly owned treatment works (POTWs). Environmental non-governmental organizations (ENGOs) were concerned that an effluent limitation of 1 mg/L would not address phosphorus-related impairments or protect local waterways and instead proposed an effluent limitation of 0.1 mg/L. The Illinois Association of Wastewater Agencies (IAWA) was concerned that the ENGOs' proposed 0.1 mg/L would impose significant financial burdens on ratepayers and would not necessarily achieve measurable water quality benefits due to site-specific conditions. This disagreement created a substantial permitting backlog in Illinois. Illinois EPA, IAWA, and the ENGOs negotiated the Nutrient Assessment Reduction Plan (NARP) permit requirement in 2018 to overcome the permitting backlog, make progress towards reducing phosphorus loads at POTWs, and restoring local water bodies.
The NARP requirements apply to POTWs discharging to downstream segments of water bodies which are impaired related to phosphorus loads or at risk of eutrophication. These major POTWs are required to develop a NARP to address phosphorus-related impairments in streams. The purpose of the NARP is to identify phosphorus input reductions and other measures needed to help ensure that numeric dissolved oxygen (DO) criteria and narrative criteria for offensive conditions (aquatic algae and plants) are met in the respective segments of the water body. The POTW can work with other stakeholders in the watershed to develop the NARP or develop a stand-alone NARP. This unique watershed-based approach has resulted in several POTWs forming watershed groups to develop the NARP. Currently, there are 90 major POTWs that are part of six major watershed groups. These watershed groups have embarked on multi-year monitoring and modeling efforts to identify phosphorus reductions and other measures needed to eliminate phosphorus-related impairments. In addition to the POTWs participating in the watershed groups, Illinois EPA has put the NARP requirements in 53 other major POTWs and the agency is currently in the process of determining the status of the NARP requirement for another 33 major POTWs. Figure 2 shows the status of NARP requirements for major POTWs in Illinois.
METHODOLOGY FOR DEVELOPING A NARP
Illinois EPA has provided flexibility to POTWs on developing a NARP since each watershed is different. Figure 2 shows a suggested NARP development process. A key requirement of the NARP is to establish site-specific water quality targets or adopt the NSAC's statewide recommendations. The NARP needs to identify point source reductions, non-point source reductions, and other measures to eliminate the impairments. Illinois EPA acknowledges that it is possible that the NARP may not recommend point source reductions. Finally, the NARP needs to include an implementation schedule.
CASE STUDIES ON NARP
This presentation will provide case study descriptions of different approaches to develop a NARP. The case studies will include examples of stand-alone NARPs including a large regional utility developing a PARP (Phosphorus Assessment Reduction Plan) for a network of receiving water bodies and a POTW located in headwaters of a watershed. The case studies will also include several different examples of watershed groups that are developing NARPs to address impairments throughout a watershed.
The complexity of nutrient impacts on receiving waters requires the use of watershed-based approaches to eliminate impairments. Illinois' novel strategy of allowing POTWs to develop watershed-based NARPs, including site-specific NNC, will be helpful to stakeholders in other states to address nutrient-related impairments in receiving waters.
Resiliency Planning for Coastal Storm Flooding: Leveraging the Right Data
Speakers: Adrienne Nemura, Geosyntec Consultants; Steven Peene, ATM, A Geosyntec Company
Date/Time: October 11, 2022, at 8:35–8:50 a.m. CT
Infrastructure planning and analysis through the lens of resiliency requires reliance on detailed data and leveraging the most reasonable technical sources. To achieve the best outcome, the following questions must be answered: What? So What? How? What is the purpose (an exposure assessment or vulnerability assessment)? What are the right data for a comprehensive evaluation? Now that we have the right data and comprehensive evaluation, so what? How can the data be used to implement actionable strategies? Utilizing the right data in the right way ensures the right outcomes. These outcomes can influence millions of dollars in capital improvements. Our panelists will share their experiences answering the above questions for several local governments and agencies in the southeast U.S., including the following:
Broward County, FL (100-Year Flood Map and Resiliency Project)
Southeast Palm Beach County Coastal Resiliency Partnership, FL (Multi-Jurisdictional Climate Change Vulnerability Assessment)
Mobile County, AL (Dauphin Island Causeway Living Shoreline)
Based upon real world case studies, four individual presentations by principal scientists and investigators will answer What, So What and How related to infrastructure with a focus on the following climate threats:
Sea Level Rise (tidal flooding and storm surge)
Precipitation Extremes (rainfall-induced flooding)
In addition to addressing the aforementioned climate threats, the scientists and investigators will explain how to:
Develop the right data to assess climate threats
Take the data and make it meaningful for risk assessments
Determine design alternatives for mitigation or adaptation
Pharmaceutical Wastewater Best Practices
Lead Facilitators: Edward Horai, Geosyntec Consultants; Kristen Jenkins, Brown and Caldwell
Assistant Facilitator: Mark Knight, SUEZ – Water Technologies & Solutions
Date/Time: October 10, 2022, at 1:00–1:12 p.m. CT
Pharmaceutical wastewaters containing active pharmaceutical ingredients (APIs) require advanced treatment technologies often requiring several unit processes to meet discharge criteria. Reuse or zero liquid discharge can offer a competitive or less costly approach or could be required by regulating entities. This session will examine three pharmaceutical wastewater evaluations providing attendees with a technical approach to the management of these complex wastewater streams.
Interactive Session | Conversations and Input
Participants will have the best experience during interactive sessions by remaining in the session room until all presentations and accompanying activities are completed.
At the end of this session, attendees will be able to (1) recognize the complexities of treating pharmaceutical wastewaters to surface water discharge standards, (2) explain the advantages of reuse/ZLD as an alternative to treating or discharging pharmaceutical wastewaters, and (3) apply approaches to pharmaceutical wastewater management evaluations.
Zero Liquid Discharge Evaluation of Pharmaceutical Wastewaters in India
Speaker: George Hollerbach, Geosyntec Consultants
Date/Time: October 12, 2022, at 9:25–9:40 a.m. CDT
In late 2018, Geosyntec Consultants, Inc. (Geosyntec) was retained by a confidential pharmaceutical client to perform an independent review of zero liquid discharge (ZLD) systems at two pharmaceutical manufacturing facilities in in India. Geosyntec worked with a local firm who provided on-site observation and evaluated process data from each facility to document the wastewater flow balance and confirm controls were in place. Geosyntec provided project management, technical support and peer review of the final report.
The Central Pollution Control Board (CPCB) of India defines ZLD as the installation of facilities and systems which will enable industrial effluent for absolute recycling of permeate and converting solute (dissolved organic and inorganic compounds/salts) into residue in the solid form by adopting a method of concentration and thermal evaporation.
ZLD is a rising technology in India because of regulatory pressure to select ZLD. Analysis carried out by Global Water Intelligence showed that over 30 environmental clearance reports granted to industrial projects by the Ministry of Environment, Forests and Climate Change (MoEF&CC) since February 2020 showed that all projects have ZLD conditions attached as part of the project development. Other industries in India, such as food and beverage, steel and textile have incorporated ZLD, even with the high energy consumption, operational costs for equipment cleaning and the need for skilled manpower.
In pharma, ZLD was getting attention due to the global concern of antibiotics in the environment and antimicrobial resistance (AMR). The discharge of antibiotics and Active Pharmaceutical Ingredients (APIs) in water bodies have been critically investigated in India for over the last 10 years. As of now, the AMR Industry Alliance has called on pharma facilities to reduce the quantity of API released into the environment and evaluate risk by comparing the predicted environmental concentration (PEC) to the predicted no-effect concentration (PNEC).
Academia and researchers, working to mitigate antibiotic resistance, believe the PEC should be extremely stringent at the fence line, some suggesting that the effluent limit should equal the PNEC. In January 2020, a full year after our evaluation, MoEF&CC announced very strict standards on concentrations for 121 antibiotics found in the waste discharged by pharmaceutical factories into rivers and the surrounding environment. Pharma facilities and common effluent treatment plants (CETP) with membership of bulk drug and formulation units were subject to the rule. The rule also incorporated ZLD as the technology standard. India became the first country in the world to introduce such standards, meant to reduce chances of creating drug-resistant bacteria, and were ahead of the US and EU in developing numerical permit standards. However, the numerical values were eliminated in a revision in the rule published in August 2021, and the rule is silence to the presence of antibiotics in the effluents and the requirements of ZLD.
Treatment Alternatives to Address the Discharge of Antibiotics
Many advanced treatment technologies are available to reduce the concentration of antibiotics and other APIs in the final effluent. ZLD is an approach to water treatment where all water is recovered and contaminants are reduced to solid waste. While many water treatment processes attempt to maximize recovery of freshwater and minimize waste, ZLD is the most demanding target since the cost and challenges of recovery increase as the wastewater gets more concentrated. Salinity, scaling compounds, and organics all increase in concentration, which adds energy costs associated with managing these increases. ZLD is achieved by stringing together water treatment technologies that can treat wastewater as the contaminants are concentrated.
Goals and Objectives
The overall goal was to document that each facility maintained in-plant source control and wastewater treatment systems in place to minimize or eliminate the release of treated wastewater and any antibiotics to the environment. Objectives consisted of confirmation that the two plants are: designed and operated as ZLD with no treated wastewater discharge to the environment; well maintained and operated with trained and qualified personnel; and adequate redundancy is provided for standby equipment and storage volumes.
The Client and Geosyntec conducted the work in a collaborative fashion with the local India team and US team. Our Client's manufacturing platform at the time includes a number of facilities which are in India. Plant A and Plant B, which was the subject of the evaluation, are considered bulk API facilities and designed for antibiotic production.
Our approach to perform the work consisted of reviewing:
Sources of wastewater generation;
Wastewater flow generation;
Treatment system review;
Process flow diagram and hydraulic balance;
Permit limits and conditions;
Residual waste handling and disposal; and
Unit operations evaluation, including evaporator, crystallizer and reverse osmosis units.
Based on our review, our findings were developed and compared to legal and permit requirements and to determine if the facilities were designed and operated as zero liquid discharge with no treated discharge to the environment.
Evaluation of Plant A and Plant B
Pant A and Plant B are similar in design. Figure 1 and Figure 2 present the hydraulic balance and ZLD flow diagram for Plant A, respectively. Figure 3 presents the hydraulic balance for Plant B. Table 1 and Table 2 present the flow evaluation of Plant A and Plant B, respectively. All flows are presented as 1000 liters per day (KLD). The treatment technologies evaluated for the high total dissolved solids (TDS) wastewater included solids removal, steam stripping, multiple effect evaporator (MEE), agitated thin film dryer (ATFD) and salt collection and disposal. Condensate from the MEE and ATFD are combined with the low TDS streams generated from equipment washing, utility blowdown, etc. Subsequential process units consist of primary and biological treatment, membrane bioreactor polishing and reverse osmosis in series for utility reuse.
The paper and presentation will also include other design and operational issues, water chemistry objectives for reuse in utilities and cooling tower makeup, membrane fouling challenges, RO recovery, brine management and disposal alternatives and energy consumption and operational cost.
The ZLD facility at both Plant A and Plant B are designed and operated as ZLD with no treated wastewater discharge to the environment. Both plants are well maintained and operated with trained and qualified staff and adequate redundancy is provided for standby equipment and storage volumes. In addition, periodic reviews are completed and ensure proper operation and consistent performance.
Evaluation of Ohio's First Far-Field Total Maximum Daily Load Developed for the Maumee River Watershed to Address Phosphorus Loads to the Western Lake Erie Basin
Speaker: Elizabeth Toot-Levy, Geosyntec Consultants
Date/Time: October 12, 2022, at 10:35–10:50 a.m. CT
According to EPA, nutrient pollution is one of America's most widespread, costly, and challenging environmental problems. Ohio's ongoing efforts to address nutrient issues in the Western Lake Erie Basin (WLEB) provides a good case-study of the scientific complexity, technical difficulty, and economic hurdles states face when tackling nutrient water quality issues.
After a lengthy legal history, Ohio EPA is now in the process of developing a TMDL for the Maumee Watershed to address shoreline and open water impairments in the western basin of Lake Erie, caused by harmful algal blooms of cyanobacteria. This effort represents Ohio's first attempt at a far-field TMDL.
Ohio's TMDL program has undergone significant revision since Ohio EPA last published a TMDL. In 2015, the Supreme Court of Ohio ruled that a TMDL must be promulgated as a rule prior to implementation in National Pollutant Discharge Elimination System (NPDES) permits as TMDLs establish new, binding standards of water quality. The heart of the case stemmed from the lack of meaningful stakeholder review as part of the TMDL process and the court further held that the rulemaking process (or equivalent) must be undertaken prior to submission of a TMDL to USEPA for approval. Ohio's new TMDLs are subject to administrative procedures including stakeholder involvement at five key stages of the TMDL development process: the project assessment study plan or quality assurance project plan, the biological and water quality report or equivalent, the loading analysis plan, the preliminary modeling results, and the draft TMDL.
This far-field TMDL must consider the entire Maumee watershed and there is not a single project assessment study plan or biological water quality report documenting the significant monitoring and evaluation efforts that have occurred to date. To fulfill the first two steps of the TMDL process, Ohio EPA provided stakeholders with a list of existing documents that collectively fulfill the requirements of the first two stages. The documents included in the list had been made publicly available prior to the commencement of the TMDL process and have previously been subject to stakeholder review.
In September 2021, Ohio EPA published the draft Loading Analysis Plan (LAP) which represents the first "new" document shared with the stakeholders as part of the TMDL development process. The draft LAP confirms Ohio EPA will rely on the phosphorus targets developed for the GLWQA and use the existing conservative Mass Balance Model approach for modeling nutrient loads currently employed to fulfill the state's obligations under House Bill 64 (passed in 2015). The most recent nutrient Mass Balance Report (2020) shows annual average TP loads from the Maumee River to Lake Erie ranging from 1,268 metric tons in water year (wy) 2016 to 3,897 metric tons in wy 2019. The report indicates that less than seven percent of the TP is from point sources and three percent is from home sewage treatment systems. The remaining ninety percent is attributed to nonpoint sources, which include agriculture, urban and rural stormwater runoff, and instream phosphorus cycling. The report is required to be updated in 2022 and should include data from 2013 through 2021. Significant changes are not expected; however, it is possible that for some watersheds (including the Maumee) that there will now be sufficient data to fit statistically valid trends indicating directional change in phosphorus loads.
While the Mass Balance Model may be the best option currently available for TMDL development, it is not without shortcomings that may significantly impact the TMDL if not properly accounted for in the TMDL implementation plan. The most significant concerns identified by the stakeholders include the Mass Balance Model assumes no nutrient attenuation along the entire 137 miles of Maumee River. This assumption (along with the entire Mass Balance Model) has not been validated. Additionally, the model does not account for the role legacy phosphorus plays in the water quality impairments seen in the WLEB. The TMDL will need to include how Ohio EPA will identify, prioritize, and address legacy and excess phosphorus "critical source areas" as chronicled by the Great Lakes Advisory Board (GLAB) in its August 2021 Draft Nutrients Workgroup Report. The draft report states that legacy phosphorus accounts for up to 80% of the load, suggesting that the principal actions the TMDL should focus addressing this legacy load. Unless legacy nonpoint "critical source areas" of phosphorus (including DRP) are clearly identified, their impact quantified, and strategies to address them implemented, it will be impossible to determine the necessary and appropriate reductions for other sources of phosphorus, much less to do so in a fair and equitable manner.
While the TMDL process is ongoing, what has become clear is that any far-field TMDL for the Maumee Watershed must be adaptive, equitable, and feasible. TMDL implementation will require substantial investment to stand a chance at solving the WLEB nutrient-related impairments. A well-defined, structured, adaptive management process is needed so that stakeholders can reach consensus on the priority actions that should be taken first that will achieve the desired outcome, the effectiveness of those actions can be assessed, and consideration given to the most-effective actions that should be taken next. Initial implementation actions should be targeted towards priority projects that have a high likelihood of effecting meaningful change. The implementation plan should recognize that greater reductions can be achieved by some point sources (relative to other point sources) and nonpoint sources (relative to other nonpoint sources across the different types of land uses) at lower cost than for others, and that projects in the lower sections of the watershed address the most critical source area and result in the most benefit to the lake. The total cost of implementing the TMDL is of critical importance to every public and private entity, including farmers, cities and counties, businesses, and the cost-share programs that will help fund implementation. It is essential that a process be developed to estimate the cost of the various TMDL scenarios that will be explored. It is also critical that Ohio EPA coordinate funding opportunities and strategies with other governmental stakeholders. If the cost exceeds available/affordable funding, then the TMDL will essentially be unimplementable.
This paper evaluates the development of Ohio's first far-field TMDL. The analysis will provide point source and nonpoint source perspectives in moving the needle toward the 40% reduction (from 2008 levels) in TP load required in the GLWQA and report on progress toward developing a truly adaptive TMDL that can serve as a model for other nutrient-impacted waterbodies.
Geosyntec's WEFTEC-Related Specialties
- Engineering and design
- Water reuse, minimization and zero discharge
- Process optimization and numerical modelling
- Water resiliency and security
- Biological and advanced treatment
- Treatment of emerging contaminants (e.g., PFAS, selenium, 1,4-dioxane, pharmaceuticals)
- Coastal resiliency
- Construction management
- D/B, CMAR and P3 projects
- Sustainability and green infrastructure
Geosyntec's Primary Client Sectors
- Food and Beverage
- Consumer Products
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