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Hydrovac Slurry ManagementRick Berkenbosch
Land PolicyAlberta Environment and Parks
Environmental 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% solids.
So, 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.
• High potential for degradation of groundwater and surface water bodies.
• Potential to contaminate lands
What Does the Rule Book Say?
Waste Control Regulation– [s.1(mm)] ‘waste’ – any solid or liquid material or product or
combination of them that is intended to be treated or disposed of or that is intended to be stored and then treat or disposed of, but does not include recyclables
Environmental Protection and Enhancement Act (EPEA)– [s.1(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 apple is not a waste until there is no one or thing that can use the apple, or no one that wants the appleanymore. The owner of the apple must 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 apple and all the other apples (odours, liquids from decomposition, solid residuals, etc.) can be risk managed.
• Now replace apple with ‘hydrovac slurry’…
Back to the Rule Book
Environmental Protection and Enhancement Act (EPEA)
– [s.176] 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 Director.
What Does Being a ‘Waste’ Mean
• Slurry taken offsite must be managed at an authorized waste management facility
• Waste characterization criteria applies: – Alberta User Guide for Waste Managers NOT Tier 1– TCLP BTEX and TCLP Metals NOT total 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 (e.g. 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. – 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?
• 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 liquids.
What 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
contaminants
The Problem
• Current waste management infrastructure developed for solids or liquid waste
- Slurry is too wet for direct landfill disposal. - 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 clarity
What 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.
• March 2017 – May 2017:– On March 23, 2017 interim guidance was distributed to the
industry & a FAQ followed. • Jan 2018:
– Hydrovac Fact sheet• http://aep.alberta.ca/waste/legislation-and-
policy/documents/HydrovacWaste-Jan29-2018.pdf
SolutionsWhere 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 infastucture
Facility Type Type Restrictions / Notes #Regional Waste Landfills
Non-hazardous
Phase separation and disposal of solids into landfill
4
Hazardous Waste Management Facilities
Hazardous and Non-hazardous
Phase separation and disposal of solids into landfill
14
Storage Sites
Non-hazardous
Phase separation and disposal of solids into landfill.
3
Wastewater treatment Facilities
Phase separation and disposal of solids into landfill
NOTE: Land applications of biosolids may be restricted due to hydrovac presence
1
HydroVac Treatment Facility
Non-hazardous waste only
Gravel reused, water sold back to hydrovac companies and fines are sent to landfill for daily cover
1
On-site Onsite management
First Party solids treatment and de-watering
-
Total 23
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 Facilities
Moving 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 (i.e. non-structural fill)–Onsite management or via a facility approval
• CAUTION using Tier 1 – do not create “pollute-up-to” situations: 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 approvals
Moving ForwardOn-Site Drying Application
This 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 process
Moving 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)– Snow Disposal Guidelines for the Province of Alberta (1994)
• Constant themes of the above policies:– GW monitoring; minimum distance to GW table; setbacks to water
bodies; minimum liner specifications; run-on & run-off controls; storm event protection; sampling ……..
Questions?
Rick BerkenboschWaste Management Specialist
Land Policy Branch780-644-2310
James JorgensenEnvironmental Protection Officer – Inspector
Compliance Assurance Lead403-297-6035
