Getting NJDEP Approval
Client: Bio Clean Environmental Services, Inc. (BCES)
Problem: BCES wanted to follow the “New Jersey Department of Environmental Protection Laboratory Protocol to Assess Total Suspended Solids Removal by a Filtration Manufactured Treatment Device” (2013) in order to get NJDEP certification for the Kraken®. NJDEP requires New Jersey Corporation of Technology (NJCAT) verification of a stormwater treatment technology performance before they will certify the technology. Getting NJDEP is a challenge because you have to provide independently verified test data and that takes significant time and money. A lack of experience in testing can lead to mistakes which can take up more time and expense.
Solution: GHL produced a Quality Assurance Project Plan (QAPP) in consultation with BCES and Dr. Richard Magee, Executive Director of NJCAT. This enabled the QAPP to address some of the issues that are not entirely clear in the protocol. For example, how to deal with drain down between runs.
Steps Taken: In most filters, the drain down opening will clog over time so the drain down time will vary and eventually get very long. Before starting the test, it is important to determine how long to wait between samples and between runs.
The consultative process allowed the QAPP review to proceed quickly. The process went so smoothly it prompted Dr. Magee to comment to BCES, “It appears that you have chosen well with GHL.”
Once the QAPP was approved, the testing was straightforward. The client visited GHL at the commencement of testing to ensure that the unit was installed correctly and to observe the testing process. This is not essential but it is highly recommended. Samples were sent out for analysis daily so that decisions could be made based on results. This allowed some mishandled samples to be replaced by their duplicates before their storage time expired.
Regular communication was maintained throughout the testing in order to address any unforeseen issues. For example, they had a good problem, in that the Kraken® clogged very slowly. This is good because it suggests a long maintenance interval but it is a problem because it meant the test could run for many days. BCES decided to end the test at a certain mass loading amount rather than keep running until bypass since it was not clear when bypass would occur. Since the mass loading rate and flow rate depend on the treatment area, there is little benefit in increasing one without the other after a certain level.
The full round of testing took two weeks from the start to finish. Report writing took another three weeks after that. The public comment period attracted only two comments and no re-work was required.
Result: The Kraken® is now NJDEP certified and GHL added NJDEP filter testing to its list of accomplishments.