The State of Texas has taken a renewed interest in desalination of brackish water. Because the Texas population is expected to grow tremendously in coming decades, many municipalities and other water-supplying entities will need to supplement their current freshwater sources. Desalination of brackish water is high on the list of water-source alternatives for supplying some or all of the increased water needs in many communities. However, disposal of desalination concentrates may pose legal, technical, and economic barriers, especially for smaller communities with water supplies of less than one million gallons per day (MGD). In this report, we examine evaporation ponds and the possibility of incorporating a low-permeability layer (precipitant) into the pond-liner system as a liner component or possibly as the liner itself. One aspect of this analysis was to investigate the regulatory requirements and barriers of using self-sealing ponds, if this strategy proves to be a technically viable alternative to standard pond liners. Another part of the work consisted of understanding the favorable chemical conditions, natural or induced, for the precipitation of such a compound(s). The third and last facet of this work was to investigate the savings or extra costs of this approach.
The following observations characterize the regulatory issues relating to self-sealing pond liners.
(1) No significant regulatory barriers currently exist that would prevent the permitting of self-sealing evaporation pond-liner technologies at desalination facilities in Texas.
(2) No Federal authorizations are required, but a Texas Land Application Permit (TLAP) must be obtained from the Texas Commission on Environmental Quality (TCEQ) Water Quality Division.
(3) TCEQ has considerable latitude for approving alternative permit requirements for industrial permits. Rules for municipal wastewater treatment are used as guides for the evaluation of industrial evaporation ponds but do not impose strict regulatory requirements. Currently approved pond liners include a 3-foot-thick layer of in-situ clay or compacted clay (with a maximum hydraulic conductivity of 10-7 cm/s) or a geomembrane liner (polyvinyl chloride [PVC], high-density polyethylene [HDPE], butyl rubber, polypropylene, etc.) of 30 mils (0.76 mm) or more with leak detection monitoring. An alternative liner technology may be approved by TCEQ if it can be demonstrated to achieve and maintain equivalent containment capabilities to the pre-approved liners and that the resulting liner material(s) will not deteriorate because of reactivity with salinity or other compounds in the effluent stream or other ambient conditions. Supporting demonstration information may include previous research, pilot projects, and monitoring data from existing operational facilities currently utilizing the proposed technology. Regulatory processing for the permitting of an evaporation pond could be simplified if the self-sealing technology were recognized by the TCEQ as an accepted type of liner, equivalent to compacted clay or geomembrane liners. No statutory change or rulemaking would be required to revise the permit instructions to add self-sealing pond liners to the list of acceptable methods, although compelling scientific and engineering evidence would be necessary to justify such a modification.Bureau of Economic Geolog
