Hydrovac Slurry Management - esaa.org

1 Hydrovac Slurry ManagementRick BerkenboschLand PolicyAlberta Environment and ParksEnvironmental Services Association of Alberta (ESAA)April 3, 2018 What is Hydrovac Anyways? Hydrovac is a process which creates a Slurry mixture of liquid with a high solids content. The resulting Hydrovac Slurry is approximately 60% liquid and 40% , Why is the Province Looking at Hydrovac Slurry Suddenly? Increase in Hydrovac activity across the province resulting in unauthorized dumping or unauthorized land applications Repeated application of the Slurry mixture to top soil results in the degradation of the top soil.

2 High potential for degradation of groundwater and surface water bodies. Potential to contaminate lands What Does the Rule Book Say?Waste Control Regulation [ (mm)] waste any solid or liquid material or product or combination of themthat is intended to be treated or disposedof or that is intended to be stored and then treat or disposed of, but does not include recyclablesEnvironmental Protection and Enhancement Act (EPEA) [ (eee)] recycle recycle means to do anything that results in providing a use for a thing that otherwise would be disposed of or dealt with as waste, including collecting, transporting, handling, storing, sorting, separating and processing the thing, but does not include the application of waste to land or the use of a thermal destruction process;Waste Example An appleis not a waste until there is no one or thing that can use the apple, or no one that wants the appleanymore.

3 The owner of the applemust decide how the apple should be managed; if off site regulation says it must at least go to a waste Management facility (transfer station, landfill or composting facility). From there the risks associated with the long term Management of the appleand all the other apples(odours, liquids from decomposition, solid residuals, etc.) can be risk managed. Now replace applewith Hydrovac Slurry ..Back to the Rule BookEnvironmental Protection and Enhancement Act (EPEA) [ ] No personal shall dispose of waste except At a waste Management facility, or in a container the contents of which will be taken to a waste Management facility, that is the subject of the appropriate approval, registration or notice required under this Act, or In accordance with the written authorization of the Does Being a Waste Mean Slurry taken offsite must be managed at an authorized waste Management facility Waste characterization criteria applies.

4 Alberta User Guide for Waste Managers NOT Tier 1 TCLP BTEX and TCLP Metals NOTtotal analysis To land apply is not recycling Land applications of waste must be Director Authorized Land applications will also require Tier 1 analysis compared to background levels ( BTEX, F1-4, total metal, SAR/EC, chlorides etc. etc. etc.)I Get It s a Waste. But It s Also Just Wet Soil So What s the Big Deal? Hydrovac is most often used in sensitive areas where underground utility damage from conventional excavations could occur.

5 These utility corridors serve as conduits for contamination to travel: be aware of activities nearby. Unlike conventional excavation techniques the Hydrovac process: does not separate soil horizons. What results when dried is a clay like mixture that does not support plant growth mobilizes potential contaminants through the excavation addition of water (solvent) and agitation Chlorides (road salt), hydrocarbons (pipelines, gas stations), halogens (drycleaners), metals (gas stations, service stations)What About Onsite Management ?

6 Remember the apple? If the apple never becomes waste is doesn t have to be managed as a waste Onsite Management cannot create an adverse effect. Applies to both solids and We Know So Far .. We know Hydrovac Slurry is a waste We know we can manage Hydrovac Slurry onsite We know if we manage Hydrovac Slurry offsite it must occur at an authorized waste Management facility We know that there is no beneficial use to agricultural land applications We know there is potential for a wide range of contaminantsThe Problem Current waste Management infrastructure developed for solids or liquid waste- Slurry is too wet for direct landfill disposal.

7 - Slurry has too much solid content for typical waste water treatment such as:- sewer discharge, surface water discharge or deepwelldisposal. Limited number of facilities in the province to manage Slurry type waste. Generators, operators and waste facilities are asking for clarityWhat is Government Doing to Solve the Problem? Past work Late 2016: A internal cross departmental project team was created consisting of operations compliance, operations approvals and waste policy to create key requirements for Hydrovac generators, haulers and receivers.

8 March 2017 May 2017: On March 23, 2017 interim guidance was distributed to the industry & a FAQ followed. Jan 2018: Hydrovac Fact sheet are the facilities ? Facilities continue to be authorized to accept Hydrovac waste as they apply. 23 known sites (as of Nov 2017) Almost all facilities are not standalone Hydrovac facilities. They are landfills or hazardous waste storage/treatment with Hydrovac infastuctureFacility TypeTypeRestrictions / Notes#Regional Waste LandfillsNon-hazardousPhase separation and disposal of solids into landfill4 Hazardous Waste Management FacilitiesHazardous and Non-hazardousPhase separation and disposal of solids into landfill14 Storage SitesNon-hazardousPhase separation and disposal of solids into treatment FacilitiesPhase separation and disposal of solids into landfillNOTE.

9 Land applications of biosolids may be restricted due to Hydrovac presence1 Hydrovac Treatment FacilityNon-hazardous waste onlyGravel reused, water sold back to Hydrovac companies and fines are sent to landfill for daily cover1On-siteOnsite managementFirst Party solids treatment and de-watering-Total23 More Solutions?Solve the Problem? Current Work Work underway to develop technical working groups to consider practical non-regulatorysolutions: providing clarity and consistency for facilities, communicating with land owners, generators about treatment options and risks, and Alberta List of Hydrovac FacilitiesMoving ForwardLand Application When applying Hydrovac solids or Slurry to agricultural land there is no beneficial use so this should be avoided There may be a benefit using the dried solids as construction fill ( non-structural fill) Onsite Management or via a facility approval CAUTION using Tier 1 do not create pollute-up-to situations.

10 Use background where possible Authorizations to land apply Hydrovac are generally not entertained on a case-by-case basis authorizations granted to facilities holding EPEA approvalsMoving ForwardOn-Site Drying ApplicationThis flow process can only work if: there are no contaminants at site, there is sufficient space on-site to dry truck/equipment must be clean and the water used cannot introduce a contaminate to the processMoving ForwardFacility Design Applying current non-hazardous waste policy to Hydrovac facilities Code of Practice for Land Treatment of Soil Containing Hydrocarbons (2008) Code of Practice for Compost Facilities Code of Practice for Landfills Standards for Landfills in Alberta (2010) Standards for Compost Facilities in Alberta (2007)