PFAS Discharges into Sand Creek from Suncor’s Denver Refinery Must Stop

Suncor Refinery alongside Sand Creek - Photo by Hyoung Chang, Denver Post

I have been stewing over whether to do a post on an article I saw in the Denver Post on July 27, 2023, regarding discharges of PFAS from Suncor’s refinery in the Denver area into Sand Creek which eventually makes its way to the South Platte.  For years I have been hearing local news stories of concerns from nearby communities about air emissions from the refinery and allegations of exceeding EPA and Colorado Department of Health and Environment (CDPHE) permit levels. I have wondered if Suncor has been given some slack due to its position as a major fuel supplier in the region. Whenever the refinery is offline due to maintenance, etc., fuel prices spike which impacts the wider community’s hip pocket (does anyone keep their wallet in their hip pocket anymore?). Is that allowing Suncor some leverage over CDPHE’s permitting process? According to the Denver Post article, Suncor had been operating on an air quality permit from 2006 that is supposed to be updated every 5 years. The permits for water and stormwater discharges were last updated in 2012.  Of course, having a permit does not mean Suncor adheres to it and there have been reported incidences of benzene spills into Sand Creek over the years as well as air permit exceedances.

South Platte’s PFAS Problem

Being in the water industry and seeing the great expense many water utilities and communities are facing to meet upcoming PFAS regulations, when I read about how such high levels are being discharged from Suncor into a drinking water source used by so many Coloradans it really hit a raw nerve for me. Pretty much any water treatment system taking water from the South Platte in the Denver Metro Area and East, including nearby wells, will have to implement some sort of treatment for PFAS removal. The cost for treatment is in the millions to tens of millions of dollars each, depending on system size. While the drinking water PFAS regulations are still being finalized, many water systems are already making plans to install treatment, since it can take years to get the funds and construct the required treatment equipment (typical solutions are GAC, Ion Exchange or Reverse Osmosis).

Suncor’s source of PFAS is likely firefighting foams used onsite, although I’m not familiar with refining to know if any raw materials contain PFAS also. This contaminates groundwater under the refinery and according to the Denver Post, Suncor treats this groundwater before releasing to Sand Creek, although obviously it not treated for PFAS removal yet. Admittedly, PFAS has only been identified as a concern in drinking water relatively recently (since 2016) and drinking water regulations are still being finalized. But Suncor was issued a draft permit by CDPHE in 2020 to release no more than 70 parts per trillion into Sand Creek. Note in June 2023 Suncor reported to the CDPHE a discharge level of 2,675 ppt…this is after Suncor apparently installed in interim treatment system to reduce PFAS to 70 ppt in early 2022.

The Denver Post article reported that Suncor estimated it would take 3 years and millions of dollars to build a permanent system to remove PFAS from wastewater before discharge into Sand Creek. Suncor also said PFAS removal is extremely difficult and treatment technologies are still in development. These statements really raise my hackles. First of all, established treatment technologies for PFAS are available now – Reverse Osmosis, Granular Activated Carbon (GAC) and Ion Exchange are well proven and already in use for PFAS removal by water utilities. Secondly, if the stormwater is already being collected for treatment, a lot of the hard work is already done and it would not be difficult to add GAC or ion exchange to the treatment train. Much larger treatment systems have already been installed on contaminated Californian ground water supplies in a quick response to the detection of PFAS and the interim regulations. So don’t try to say the technologies are not yet developed! Locally, there are also treatment systems installed at water utilities south of Colorado Springs where they detected PFAS in the ground water supply originating from a local military base.

While Suncor continues to discharge PFAS into Sand Creek, communities downstream are paying the price with their health and their money where the local water treatment plants must pay for treatment.

The article in the Post was written in late July, so Suncor may very well have accelerated installing treatment for PFAS removal since then, since the media is quick to report a violation but often slow to report on a resolution. If so, then I retract some of my vitriol for Suncor not taking action.

The comments and opinions in this post are my own and not those of my employer.

“So your saying there’s a chance” - Dumb Bid Evaluation Processes

 I saw a bid evaluation process recently for membrane equipment that I hadn’t seen in about 10 years. I thought this type of evaluation had seen its last days with the demise of the bids that only allowed the ‘big-three’ proprietary system suppliers (Pall, Memcor, Zenon). I guess there are some engineers/owners still living in the past who don’t realize that bidding processes of the old days are not relevant for evaluating between todays’ membrane system suppliers (MSSs).

This particular bid process required bidders to provide in one envelope (#1) a technical proposal, including qualification and experience criteria, and in the other envelope (#2) the pricing and other commercial information. The owner and/or owner’s engineer would review the technical proposal and select the best qualified submission and only open the pricing proposal for that bidder. If the price met budget they would start negotiations to award to that bidder without looking at pricing for any other bidders. Out of the four MSSs invited to bid, one of these was one of the big-three and would clearly have the most references and be chosen as having the best score out of the technical proposals. So why would the other three bother bidding? Maybe some would hope the favorite in the race did not turn up for some reason?

In the old days, the big-three would bid nearly everything to try get market share in a fast growing and evolving market. Well hello, the MF/UF market is now quite mature, MSSs are often bidding with the same membranes supplied by independent vendors and decisions on whether to bid or not are based on whether the project can be profitable rather than buying market share. So, if you don’t have an open and fair bidding process, there may be only one bidder, which does not look good for the writer of the specifications.

This bidding situation had the look of the engineer/owner really wanting to select one manufacturer while keeping that manufacturer’s price honest. As long as the price is within budget, that manufacturer’s price could be higher than all others and the owner would never know. These days for MF/UF system procurement it is common to see a prequalification stage where a short list is made of manufacturers based on experience, company financial stability, references, local service, etc and then these bidders have a competitive bid based on price. That way the owner and engineer are happy with the quality of the bidders and the owner gets the best price from these bidders.

Another bidding process that is a combination of the above has a scoring matrix where price (or NPV) is say 40-60 points out of 100, with the rest of the points spread across reference installations, local service capabilities and other factors. This evaluated bid process can still allow the engineer/owner to pick the MSS they prefer using the subjective scoring factors, as long as the pricing of the preferred vendor is not too high. But at least all bidders will get their prices considered and therefore more MSS’s will likely bid, even those scoring lower on the non-price factors. As Lloyd said in Dumb and Dumber “So your saying there’s a chance”. I still think this bid process is not ideal, but if it is an open bid with no favorite, I’ll take this this type of evaluated bid over the two-envelope lucky draw...

Of course, if I am in the shoes of the preferred manufacturer with the best experience, I’ll take the ol’ two envelope bid process but sooner or later when this process yields only one bidder, somebody will end up looking dumb…

The comments and opinions in this post are my own and not those of my employer.

Gasson Spices up Membrane Technology Conference Opening Session

(Not one of the keynote speakers)

This year’s Membrane Technology Conference (MTC) in Knoxville TN, February 20-23, saw a spike in attendance, almost back to pre-covid levels, with a definite buzz around the presentations and exhibit hall where attendees were excited to be back networking with colleagues and technology suppliers.

Christopher Gasson, Publisher of Global Water Intelligence, was a keynote speaker for the Opening General Session, along with Harry Seah, CTO of PUB. Christopher’s ‘State of the Global Membrane Industry’ presentation certainly provided a spicey opening to the conference with his description of ‘What’s Hot and What’s Not’. Some exhibitors in the audience that were on Christopher’s ‘Not Hot’ list may have begged to differ. These included manufacturers and developers of ‘Fancy Membranes’ which I assume referred to new chlorine resistant membranes and fouling resistant membranes among others. From a global market share perspective, he is probably correct, but companies such as ZwitterCo are likely not trying to take the place of traditional RO membranes and are content targeting niche markets.

Other technologies or technological trends on the ‘Not Hot’ list included higher recovery for seawater, higher flux RO membranes and lower pressure desal membranes.

On the ‘Question Mark’ list included ceramic membranes and Universal/Open Platform low pressure systems.

During questions, Hary Seah agreed to disagree on the potential for ceramic membranes where PUB is a big advocate of ceramic membranes at its plants in Singapore. I’ve given my thoughts on the ceramic market previously and copped some flak for saying it is a niche technology, but I would agree with Christopher on his position.

I also agree that the Universal/Open Platform low pressure market may have cooled a little now that there are many direct replacement modules available for Asahi (Pall), Memcor, Toray and Dupont modules, which gives some flexibility for future membrane replacements without needing a membrane rack to accommodate modules of different configurations. Also, the proliferation of non-proprietary MF/UF systems using modules from Toray, Dupont and others has taken some steam out of the need for Universal racks. I will flesh this out further in a separate post.

 On the ‘Hot’ list were higher recovery RO in industrial applications (not seawater) which I assume is technologies such as CCRO, Pulse RO and FRRO, polymeric NF (NX Filtration), RO/NF membrane spacers, brine mining and digital monitoring (AI). Christopher pointed out that NX Filtration is capitalized at over €500M with revenues of €8M last year, having investment characteristics of a start-up tech company and a lot of pressure to perform.

I must admit I haven’t been to many opening sessions at MTC, but this one was very well attended, possibly in anticipation of the speakers’ topics. The audience was not disappointed, and Christopher’s thought-provoking statements provided a great catalyst for discussion afterwards and set the stage for a very lively conference.

The comments and opinions in this post are my own and not those of my employer.

Good Projects Spoiled by Bad Contractor Selection

 

Something that really perplexes me is how engineers and owners can put so much effort into the design of a plant, ensuring equipment vendors and components are well qualified and tightly specified, then the project is put out to bid and awarded to the contractor with the lowest price. Then it is a crapshoot if the contractor has the experience or capability to complete the project….

The contractor is the most important part of the project. They are responsible for taking the process equipment specified and all the surrounding infrastructure and turning it into a functioning water treatment plant. So why are there so many instances where unqualified, low-bid contractors win these projects?

When an incompetent contractor runs into trouble with schedule or budget when he/she missed something in the specifications, he is going to do what he can to deflect the blame to try keep the project profitable and avoid LDs. That often ends up in conflict with process equipment vendors to improve schedule to make up for poor project management, and drawn-out payments to vendors because the contractor can’t get approval for achieving project milestones. So many times I have heard the excuse from contractors that they can’t pay for start-up because they haven’t been paid for the practical completion milestone. That is compete BS when the equipment has been delivered and started up months ago and the contractor can’t get his s - it together to finish the landscaping or install the toilets… Just as frustrating is when start-up is delayed for months because the contractor is behind with installation, meanwhile the component vendors for the process equipment must be paid, so we go back to the old story of the process equipment vendor also acting as a bank for the project… (see previous post). All of this leads to conflict between the owner, engineer, contractor and OEMs and nobody feels good about the project.

Don’t get me wrong, I’m not out to bash all contractors. I have worked with a lot of very competent water treatment system contractors. And process equipment vendors are not always without blame for delays and missing items in the specifications. I have also seen specs where it wasn’t clear who was supposed to provide some items, so nobody had them, which is on the engineer who wrote the specs. My gripe is really with the process of not prequalifying contractors and ending up with a rudderless ship of a project. Similarly, process equipment vendors should be pre-qualified and most of the time they are, but when they are not it opens up the possibility of any garage integrator throwing in a price. Which takes me back to my original point – why spend so much time designing and specifying a plant and then leaving the execution in the hands of a random low bidding contractor?

Don't Blame the Pandemic

Admittedly, these days in some cases it has been hard to find contractors to bid projects. So, standards may be lowered to get competitive bids. Before a job goes out to bid, there has to be an awareness of what else is bidding locally that will cause contractors to pick and choose what to bid. I have seen bids delayed so as not to overlap with a larger project bidding in the region, which is smart. I have also seen cases where a bid is due just before a board meeting to approve the winning bidder, so there is no room to delay the bid for scope clarifications or to allow contactors more time to prepare, so bidders drop out. This happens so many times. An engineer spends a year or more pulling the spec together then allows 4-5 weeks for contractors to get a bid together and there is no flex in the bidding schedule to give contractors a few more weeks. Not smart!

 While recent years have made this situation worse with supply chain delays and a shortage of contractors to bid projects, unqualified contractors winning water treatment projects has been going on for years and is not a symptom of the pandemic. Engineers and owners need to put more thought into  the bidding process to ensure they get a competent contractor which will ensure a much more successful and harmonious project for all involved!