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A New Approach to Wastewater Disposal: Cost-Effective Solutions for Non-Hazardous Industrial Wastewater Generators Samuel H. Butterfield, President NewStream LLC, 527 Pleasant Street, Attleboro, MA 02703 508-236-6001 ABSTRACT Formed in 2005, NewStream is an environmental services company specializing in high technology industrial wastewater treatment and high purity process water. Originally built for Texas Instruments (TI), the facility has a treatment capacity of up to 800 gallons per minute of wastewater and the ability to deliver 325 gpm of high purity process water. Rather than let the state-of-the-art facility be razed, the founders of NewStream have transformed the former single-user facility into a successful commercial enterprise. Having received the first permit of its type ever to be issued in Massachusetts, NewStream now receives an average of 10 truckloads per day of non-hazardous wastewater from off-site sources. Additionally, the same network of pipelines that once allowed all of TI’s on-site manufacturing operations to send their wastewater to the plant now allows NewStream to treat wastewater from tenants on site. KEYWORDS Industrial wastewater, non-hazardous wastewater, off-site wastewater treatment, materials recovery BACKGROUND Texas Instruments The 200-plus-acre site that is now TI Corporate Park has a long and rich history. Rathbun Willard first purchased the land, which was part of the Cat-O-Nine-Tail Swamp, in 1926 to accommodate his growing business, General Plate Company. The Company manufactured "gold plate" for the nearby Rhode Island jewelry industry. In 1931, the company merged with Spencer Thermostat Company of Cambridge, Mass. and formed Metals & Controls Corporation. This merger combined the capabilities of metal processing with temperature–sensing control expertise — capabilities that later attracted the attention of Texas Instruments and resulted in the 1959 merger between TI and the former Metals & Controls. Cost Effective Solutions for Non-Hazardous Industrial Wastewater TI continued to expand its manufacturing operations on the Attleboro campus in the years that followed, producing sensors and controls for cars, airplanes and appliances, and distributing them worldwide. A vast array of products have been manufactured on the site, included everything from nuclear fuel rods for Navy submarines to the first clad metals used in "wafered" coins for the US Treasury. In 2003, TI made the decision to move its sensors and controls division overseas, and the site was sold to Preferred Real Estate Investments, a development firm based in Pennsylvania. The Wastewater Treatment Facility Pollution control was a priority for TI, and when new regulations were set forth by the 1970 Clean Water Act, the Company rose to the challenge. In 1977, the $7 million wastewater treatment plant was completed. The plant was designed to handle industrial wastewater from all of the site’s plating and manufacturing operations by virtue of an extensive network of lift stations, pumps and transfer lines. When even more stringent water quality regulations were imposed in the 1980s, TI spent three years and $8 million updating the facility with advanced wastewater treatment technologies. As a result, the facility was able to maintain an on-site surface water discharge for the majority of its wastewater effluent under a National Pollution Discharge Elimination System (NPDES) permit, meaning that water discharged from the facility will not harm even the most sensitive aquatic organism. With additional flows that discharged to the City of Attleboro sewer system under a pretreatment permit, the facility processed up to 0.75 MGD. THE BIRTH OF NEWSTREAM In 2003, TI made the decision to move manufacturing operations for its Materials and Controls Group to other locations and ultimately to divest itself of the entire Attleboro site. The site is being redeveloped into a mixed-use park, which includes state-of-the-art manufacturing space, office buildings, and even retail and residential parcels. The wastewater treatment plant remains a tremendous asset to the site, but was in danger of being shut down for lack of anyone to operate it. The managers of TI’s environmental group decided to investigate the feasibility of converting the plant to a commercial wastewater treatment facility, and eventually floated the idea to Sam Butterfield of Butterfield Environmental Corporation (BEC) in Plymouth, MA, then a supplier and consultant to TI and a veteran of the industrial wastewater industry in New England. Sam saw an opportunity to grow his business and put the high-tech plant to good use. He joined forces with John Theriault, former Chief Operator of the treatment plant for TI, and now co-owner and VP of Operations for NewStream. NewStream, LLC was established in August 2004, and operations of the facility were seamlessly transferred to the new Company in March 2005. In addition to the building and equipment, NewStream acquired all the necessary permits to continue operation. And the Company hired almost all the employees of TI’s environmental services group, including plant operators, chemical control, emergency response and other EH&S staff. But Would It Work As A Commercial Venture? Before finalizing a deal with TI, NewStream’s founders sought and received counsel from a variety of industry experts, legal professionals and regulators. The plant’s tremendous potential as an environmental and/or chemical process facility were unmistakable. The possibilities seemed endless. The facility’s technology, discharge permits, location, railway access and other infrastructure made it a natural fit for the environmental and waste management business, and the fact that TI saw the plant as an expensive decommissioning project that they were eager to unload made it a potentially inexpensive way to enter the market. But there were many hurdles to clear first. Conversion to a hazardous waste disposal facility (RCRA Part B, TSDF) was never considered for reasons of cost, time and local acceptance. Long-term investment in hazardous waste management, furthermore, did not seem sustainable in light of the green revolution and with government and manufacturing trending away from the use of hazardous materials. Besides, big dogs like Clean Harbors guard the door to that sector of the environmental services market. The path was clear that NewStream would have to work as a non-hazardous waste management and recycling facility, or not at all. However, since non-haz wastestreams are loosely tracked at best, and industry knowledge is closely guarded, concrete market data was practically impossible to obtain. Research was limited largely to anecdotal sources. Estimates of over-the-road non-haz wastewater volumes ranged from "not that much" to "huge", and disposal pricing ranged from $0.05 to $1.25 per gallon. On the other hand, both present and potential generators of non-haz wastewater (and other, potentially recyclable, industrial/commercial materials) ranged wide and deep, all the way from large process industries to flooded basements and everything in between. With no way of quantifying just how much water there was or what NewStream’s market share could be, jumping into the market required a great leap of faith. On the regulatory front, the Massachusetts DEP had no precedent for this type of permit since it was the first of its kind ever to be issued in the state, and MADEP’s interpretation differed from the EPA’s as to how the facility would be qualified. For example, was it a CWT (Centralized Waste Treatment) facility, and thereby allowed to accept waste from off-site sources, or not? The City of Attleboro also weighed in with a good deal of anxiety about what exactly qualifies as non-hazardous wastewater and how it would affect their own POTW. Other questions included: Would existing technology and configuration of the plant be sufficient to treat the variety of waste streams that could potentially be received at the plant? Would it be feasible to separate the wastewater treatment plant from a site that had grown so organically over the years? With many of these questions still unanswered, NewStream opened its doors – and its pipelines – to off-site wastewater in July of 2005 with the issuance of a new sewer discharge permit from the MADEP and the City of Attleboro. EVOLUTION OF THE BUSINESS Market Dynamics Some of NewStream’s advisors predicted that the plant would be filled to capacity in no time – that a facility treating only non-hazardous wastewater would fill a niche in the New England region. The industry was clamoring, they claimed, for alternatives to existing disposal options, which included hazardous wastewater treatment plants, which were more expensive; hauling the water great distances, which could be cost prohibitive; and sending the water to select municipal treatment plants, which are limited in what they can treat and not known for being user-friendly. But, would these predictions prove out? Feeling one’s way into the commercial waste management and disposal business was, it turned out, not easy or swift. Could NewStream market directly to generators, or was it necessary to work through waste brokers and other third parties? The sales and marketing team was quick to realize that going direct to the generators could mean alienating the Company’s biggest potential customers: environmental services firms, engineering firms and other brokers. Reaching out to the major players in the industry became an early priority. After attending a series of industry events and open houses at the facility, the word was out. But it would still take more than a year for business to ramp up to projected volumes of wastewater entering the plant. In the mean time, a number of opportunities arose for NewStream to diversify its services and beef up revenues. Synergies with Industry Partners In the fall of 2005, NewStream’s viability seemed in doubt while the company tried to build sales without stepping on too many toes. Not wanting to give up, the founders decided to look for an industry partner that could both infuse the business with some cash and fill it with water at the same time. After entertaining several joint venture and merger proposals, NewStream seemed to find a perfect match in nearby Stoughton, MA. In January of 2006, Al Tucci, owner and CEO of Cyn Environmental Services, Inc. joined NewStream as an equity partner, and a synergy between the companies was born. As a major player in the New England environmental services and waste management business, Cyn Environmental owned and operated a large fleet of equipment as well as a TSDF in Stoughton where it processed oily wastestreams, largely from the automotive market, in order to recover and recycle used oil as an industrial fuel. Since Cyn’s TSDF did not have its own wastewater discharge permit, some 2 million gallons per year of non-haz wastewater generated by this process was being trucked to New York. NewStream, less than 30 minutes away, was a much more attractive disposal option, and it opened the door to other market opportunities for both companies through shared resources, product and service offerings. Diversification During the first full year of operation, several opportunities arose for NewStream to expand is service offerings. Most significant was utilizing the tremendous resources of the former TI environmental group for specialized environmental services such as decommissioning and decontaminating industrial facilities. A good deal of work was done for TI as it transitioned out of its manufacturing operations, as well as other companies who heard about NewStream’s expertise in these areas. Services have since been expanded to include contract operation of other industrial water and wastewater treatment facilities, chemical management and environmental monitoring. Another addition to the service and product line was antifreeze recycling. As a non-haz material, NewStream could accept used antifreeze, collected in small bulk from auto dealerships, service centers and fleet vehicles, process it to recover ethylene glycol, and produce a recycled anti-freeze product for sale back into the automotive market. Rather than investing large capital expenditures for new equipment, NewStream was able to convert one of its three large and sophisticated Reverse Osmosis (RO) units from the plant’s high purity water process into a nano-filter for glycol recovery. The addition of a small Ion Exchange system for chloride removal was all that was needed to allow NewStream to recover a high quality recycled product from the used material. The recovered product is then refreshed with virgin ethylene glycol, corrosion inhibitors, and dye packages to meet customer specifications. The recycled antifreeze can be shipped from NewStream in bulk or drums at very competitive prices. NewStream’s goal is to generate recycled material that is as high quality as virgin material. The recycled material can be sold back to the generator and/or to third parties for re-use in applications such as: • Major auto and truck manufacturing • Aftermarket automotive service • Consumer use (retail) • Fed, state, local government use • Military applications Other processes on the drawing board include recovery of clean "Specification Used Oil Fuel" (a "regulated recyclable" material under Mass regulations) from water-contaminated tank bottoms and the like, recovery of recyclable gasoline from gas/water mixtures, and recovery of oil and recyclable metals from used oil filters. Process Challenges and Modifications Once the permits were in place, the word was out and the water started flowing in, many challenges still remained. The naďve assumption was that since this sophisticated plant, with all its technology, could treat almost any type of hazardous wastewater, any non-hazardous wastewater would be handled with ease. That was not the case: the NewStream team was surprised at the diversity and complexity of the waste streams that were coming in, and by the high volume of high-strength organic wastestreams. Many streams, such as latex waste from the textile industry, had peculiar characteristics that demanded special processing. Others came with odor problems. All streams had to be screened carefully for hidden toxicity characteristics that might pass through to the POTW. NewStream quickly began a series of process modifications that would allow for optimum efficiency and treatment performance in the plant. The most significant improvement was the addition of eight 10,000-gallon holding tanks. The tank farm enables the Company to isolate, analyze and batch treat each individual waste stream as it comes off the truck. The primary advantage to the tank farm system is the guarantee that each and every load arriving at the plant will receive optimum pre-treatment to remove a large bulk of contaminants prior to being equalized with other waste streams. The tank farm allows for greater cost efficiency and in general, better control of the treatment process. Each new waste stream coming into the plant now receives its own unique treatment recipe. The recipe goes on record in a sort of operators’ cookbook, which is followed each time a load of the given stream comes in. Ultimately, the batch treatment process will be automated, allowing operators to plug in a waste profile number to the programmable logic controller (PLC) and automatically treat the entire batch. This method will eliminate operator error and provide for better control over chemical dosage rates, mixing speeds and times. Automated batch treatment works with a variety of different treatment processes, including gravity clarification, chemical oxidation, dissolved air flotation and even biological treatment methods, such as a moving bed bio-reactor (MBBR). The MBBR is another new technology that NewStream expects to put online in 2007. (At this writing, a pilot-scale system is being successfully operated at the plant.) The bioreactor will enable NewStream to treat waste streams with high biological oxygen demand (BOD) by converting contaminants into organic mass and gases. Specifically, the MBBR technology being tested at NewStream uses thousands of biofilm carriers operating in mixed motion to increase the surface area for attached fixed film bacteria. The system offers higher productivity than many other biological systems in use today. WEF 6/8/2007 6 Cost Effective Solutions for Non-Hazardous Industrial Wastewater Other process modifications included retrofitting the existing reverse osmosis (RO) unit as mentioned above in the discussion about antifreeze recycling, and converting two 10,000-gallon tanks for removal of any non-emulsified oil and grease prior to chemical treatment. Quality Control In order to maintain the high standards of treatment expected of NewStream, strict quality control has been critical. Before accepting any waste stream, NewStream’s Quality Control Manager performs extensive treatability testing to: 1. Pre-screen incoming wastestreams to establish influent levels of several contaminants, including metals – utilizing a direct coupling plasma (DCP) unit – as well as COD, TSS, and pH. 2. Determine whether the stream can be treated effectively enough to meet NewStream’s discharge permit limits, and 3. Establish a treatment "recipe" for each stream to be optimally batch treated (as discussed above). Once accepted for processing at the facility, QC must be maintained throughout receiving, treatment and discharge processes. This is accomplished with the use of a Receiving Log that travels with the retain sample and the load itself through the process, getting multiple QC checks at critical points along the way, until it is finally cleared for discharge from the plant. A COST COMPARISON So, when does it make sense for a non-hazardous industrial wastewater generator to truck their water off site to NewStream, as opposed to building and operating their own on-site wastewater treatment plant? An example: NewStream has a customer that manufactures several different health and beauty products. Upon introducing a new product line, the company was notified that they were now in violation of their existing sewer discharge permit. The process associated with manufacturing the new product was generating wastewater that added several new contaminants to the stream. The company considered a complete overhaul of their existing treatment system in order to treat the wastewater generated from the new process. To do everything required to meet permit limits, the capital costs would have been $540,000. O&M costs for the system were estimated at $125,000 per year, not including sewer discharge fees. The cost to haul one truckload of wastewater per week to NewStream is $104,000 per year. In this case, the cost-benefit is clearly in favor of trucking, especially since the success of the new product line was not yet known and the company was hesitant to make the long-term investment in waste treatment equipment. Appendix 1 – Photos Texas Instruments – 1953
Outdoor Equalization Tanks
Inside overhead view
Inclined Plate Clarifier
Clarifier Effluent
Indoor holding tanks
Lab
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