Discussion of the Approach for Developing the Florida DPR Regulatory Guidance. Jeff Mosher

Transcription

1 Discussion of the Approach for Developing the Florida DPR Regulatory Guidance Jeff Mosher

2 Two Items Florida Potable Reuse Regulatory Guidance Purpose and approach Guidance Document Sources of information Research studies National scientific committees State-sponsored guidance

3 Purpose of Guidance Doucment: Primary focus: Direct Potable Reuse Provide recommendations regarding the development of DPR regulations in Florida Scope of Work: Based on input from stakeholders, develop a document that provides specific recommendations on the range of topics needed for implementing DPR in Florida

4 Overarching Goals Develop science-based recommendations Protect public health Provide a regulatory path for DPR projects in Florida

5 Why now? Florida Potable Reuse Commission DPR is a viable option Strong experience with indirect potable reuse One Water concept We need the water New Information Available Research and technology have moved forward Experience in other states State, Federal, National, and International efforts

6 Potable Reuse Commission will rely on stakeholder involvement and expertise in developing an approach for potable reuse

7 Approach to develop the guidance doucment Identify initial topics Collect input at stakeholder workshops Develop a public review draft Guidance Doucment Finalize Guidance report for PRC

8 Approach PCR reached out to Water Research Foundation Non-profit research organization credible and scientific WRF experienced in technical/scientific reviews 3 one-day interactive workshops Provide opportunities for stakeholder to present questions or concerns. Approach: Workshop #1: WRF would provide a recommended list of topics and options Workshop #2: WRF would provide a summary of recommendations based on stakeholder input and current state-of-science. Workshop #3: Review and comment on Draft Report of recommendations.

9 Scope and Outcomes Potable Reuse Commission (PRC) Framework Outcomes Develop recommendations for legislation, rule development, and incentives for potable reuse WRF Scope Working with PRC and stakeholders, develop a list of recommendations on DPR regulations Technical, managerial, and operational topics Outcome Written report documenting recommendations. PCR would use recommendations to inform the implementation of potable reuse in Florida which could include formal DPR regulations by the state

10 Guidance Activities Apr May June/July Aug/Sept Oct/Nov Dec Workshop #1 (April 6) Workshop #2 (midsummer) Workshop #3 (Fall) Input on topics and identify questions Develop draft recommendations Develop draft report Finalize report

11 Project Team Julie Minton, Project Manager Director of Strategic Initiatives, WRF. Program Director for WRF Water Reuse Issue Area. Project Manager on $24M DPR Research Initiative ( ). Former Director of Research for WateReuse Foundation. In the past 9 years, Project Manager on over 15 water reuse projects. Jeff Mosher, Facilitator Former Director of Research for WRF. Former Executive Director of National Water Research Institute. Former Director of Research for WateReuse Foundation. In the past 14 years, managed expert panels for over 12 potable reuse projects in CA, AZ, TX, NV, WA, NM, and VA. Worked on IPR and DPR regulatory development in CA, AZ, NM, CO, and NV. Gina Vartanian, Writer and Editor Communications Manager for NWRI Co-author of Guidance Framework for DPR in Arizona (2018) Co-Principal Investigator of Potable Reuse Research Compilation: Synthesis of Findings WRRF (2016) In the past 15 years, supported expert panels for over 12 potable reuse projects in CA, AZ, TX, NV, WA, NM, and VA.

12 Guidance Document Proposed Organization

13 Chap. 1: Introduction overview studies organization Water reuse in FL Nonpotable reuse Planned potable reuse Potable reuse IPR DPR Terminology NRC Report 1998 NRC Report 2012 Risks from microbial and chemical constituents Etc. Chapter summaries Recommended resources

14 Chap. 2: Public Health Considerations overview pathogens chemicals Public health considerations Drinking water regulations Pathogen reduction criteria: TX approach CA IPR approach Targets: MCLs Trace organics TOC 1,4-dioxane and NDMA DBPs

15 Chapter 3: Potable Reuse Recommendations Organized by Topic

16 sources of information

17 DPR Key Questions Treatment requirements Need for criteria for pathogen and chemical control On-line monitoring Performance monitoring Treatment technologies Defining reliability Source control Managing the collection system Operations and operators Response time (respond to off-spec water) Public acceptance 17

18 Framework for DPR Published by WateReuse (2015) Sponsors: WateReuse, AWWA, and WEF Developed by an NWRI Expert Panel Available at:

19 Texas projects DPR projects Direct Potable Reuse Resource Document (2015)

20 California regulations Groundwater replenishment (final in 2014) Surface water augmentation (final in 2018) Expert Panel Report on Feasibility of Developing DPR Criteria for California (2016)

21 1998 National Research Council Report (National Academy of Sciences) Topics: Chemical and microbial contaminants Methods of assessing health risks Health effect studies Reliability and quality assurance The committee views the planned use of reclaimed water to augment potable water supplies as a solution of last resort 1998 National Research Council

22 2012 National Academy of Sciences Report Treatment, Monitoring, and Operations: A range of treatment options exits Treatment reliability and robustness Monitoring and operational plans Assessment of Risks: Methods to assess risks exist An occurrence of a contaminant does not necessarily post a significant risk Compare risk of potable reuse with current supplies ( risk exemplar )

23 California Recycled Water Panel on CECs (January 31, 2018 DRAFT Report) Update to 2010 report Use of risk-based screening framework Revised list of CECs for monitoring Recommends two bioassays for screening purposes Discusses the use Non-Targeted Analysis

24 U.S. EPA Potable Reuse Compendium (2018) World Health Organization Potable Reuse Guidance (2017)

25 Guidance Framework for DPR in Arizona (2018) Developed for WateReuse AZ Provided recommendations on DPR in AZ Informed a State effort to develop DPR regulations Based on stakeholder involvement

26 Guidance Doucment Topics for Discussion 1. General Topics 2. Technical Topics 3. Management Topics 4. Other Topics

27 Regulation Permit Guidance X. Key What? What is the topic. Why? Why are we interested in this topic for DPR. Specific recommendations: List of specific recommendations for guidance document.

28 1. General Topics Review topics and concepts that support the development of potable reuse regulations. That is, review of concepts that are useful to understand the implemetion of potable reuse.

29 1. General Topics 1.1 DPR background information 1.2 Build on current regulations in Florida 1.3 Terminology 1.4 Public outreach 1.5 Environmental buffer 1.6 Blending 1.7 Multiple Barriers

30 1.1 DPR Background Information The Water Cycle Gives Us Access to Water

31 De Facto or Unplanned Water Reuse Source: AWWA Potable Reuse 101

32 De Facto Water Reuse in the US The downstream use of surface water as a source of drinking water that is subject to upstream wastewater discharges. Assessment of De Facto Wastewater Reuse across the U.S.: Trends between 1980 and 2008 Jacelyn Rice, Amber Wutich, and Paul Westerhoff (Environ. Sci. Technol., 2013, 47 (19), pp )

33 Direct potable Urban Water Use Wastewater Treatment reuse Water Treatment Environmental Buffer Advanced Water Treatment

34 Key components of DPR Technical Regulatory Outreach

35 Technical, Operational, and Management Barriers

36 Types of Barriers Technical barriers (which also can be viewed as physical barriers) Barriers that can be credited with treatment performance Operational barriers Include operations and monitoring plans, failure and response plans, and operator training and certification

37 Types of Barriers Management barriers Policy and maintenance plans key to the proper functioning and oversight of technical and operational barriers in DPR projects Can be applied from the source of supply through treatment Provide guidance for staff to make critical decisions e.g., when to shut down the process if water quality data are questionable or treatment performance is compromised

38 Important considerations for DPR 1. Consistent with current regulations in Florida 5. DPR lacks an environmental barrier 2. Terms and definitions 6. Multiple barrier approach (drinking water concept) to control pathogens and chemicals 3. Regulations or permitting or guidance 7. Technical, operational, and managerial barriers 4. Regulatory flexibility (alternatives provision) 8. Protective of public health

39 1.2 Build on current regulations in Florida Florida IPR regulations Part V (F.A.C.) Two levels of treatment ( ) Principal Treatment and Disinfection Full Treatment and Disinfection Discharge to Class I Surface Water ( ) Discharge to Other Surface Waters ( ) Groundwater Recharge by Injection ( ) Salinity Barrier Systems ( )

40 Definitions (27) Indirect potable reuse means, for purposes of this chapter, the planned discharge of reclaimed water to surface waters to augment the supply of water available for drinking water and other uses. Indirect potable reuse is contrasted with direct potable reuse which involves the discharge of reclaimed water directly into a drinking water treatment facility or into a drinking water distribution system. Engineering Report (1) In accordance with the requirements and provisions of Chapters and , F.A.C., an engineering report shall be submitted in support of permit applications for new or expanded reuse or land application projects. The engineering report will serve as the preliminary design report for reuse and land application projects.

41 Full Treatment and Disinfection ( ) Meet Primary Drinking Water Standards (MCLs) Multiple barriers for Organic compounds Pathogens Secondary Drinking Water Standards TOC = 3 mg/l TOX = 0.2 mg/l

42 Full Treatment and Disinfection ( ) Multiple barriers for Organic compounds and Pathogens The treatment processes shall include processes which serve as multiple barriers for control of organic compounds and pathogens. Secondary Drinking Water Standards Is TDS of 500 mg/l an issue? TOC = 3 mg/l Is this needed? TOX = 0.2 mg/l Needed? Additional reductions of pollutants which otherwise would be discharged in quantities which would reasonably be anticipated to pose risk to public health because of acute or chronic toxicity shall be required. ( c3)

43 Other Part V requirements Pilot testing ( ) Pilot testing is required for all projects that are required to provide full treatment and disinfection Require? Reliability and staffing ( ) Monitoring ( ) Operating protocols ( , , and ) General Technical Guidance, Related Rules, and Forms ( )

44 1.3 Terminology Certain terms must be defined in regulations Many terms that may be best addressed in policy, guidance, and/or permitting, which allows for flexibility Terms used for outreach and communication purposes Purified water Trend towards using just potable reuse for both IPR and DPR California legislation specifies terms for DPR: Raw water augmentation Treated drinking water augmentation

45 1.4 Public Outreach Is public attitude the biggest challenge to potable reuse?

46

47 Psychology of Water Reuse Human Reactions to Water Reuse (WateReuse Foundation 2004) Workshop with psychologists Law of Contagion Once in contact always in contact Not fully subject to logic and science Address through framing Process to categorize and ignore parts of reality Frame things out of awareness Not think about where something has been (restaurant forks and plates)

48 Use Advanced Treated Recycled Water as an Addition to Drinking Water Supply 45% 45% 40% 35% 35% 36% 33% 37% 30% 25% 20% 15% 10% 10% 16% 19% 12% 12% 11% 11% 10% 9% % 4% 0% Strongly Favor Somewhat Favor Somewhat Oppose Stongly Oppose Unsure 48

49 Public Tours of Facilities Help Educate the Consumer

50 Public Outreach: Key Activities Outreach Activity Provide a rationale for the need for DPR Identify public perception challenges to the DPR project Develop a DPR Communication Plan Develop and disseminate communications materials on the DPR project Connect with outreach staff at other AWTFs Prepare a participation program for source control Purpose Raise public confidence of the benefits and value of the DPR project to the community. Use to assist in the development of strategies to alleviate these concerns and improve public perception. Provide strategies to communicate about the DPR project to the public, elected officials, and others, with the goal of building public confidence in and support of the DPR project. Provide objective, accurate, and timely information to raise awareness of the DPR project and address public concerns. Gain practical information and lessons learned from the realworld experiences of other potable reuse public outreach efforts. Engage industrial and commercial dischargers, as well as the public, on means to eliminate or control the discharge of constituents into wastewater that can impact the production of ATW.

51 1.4. Outreach Regulation Permit Guidance What? Outreach programs are strategic, transparent, and thorough. Why? Public confidence and support is critical to the implementation of potable reuse projects. Specific recommendations: Not the role of regulators. Start early. Continue throughout project. Terminology is important. Use proven techniques. Develop consistent messages. Use of a communications plan. Prepare for tough questions. Build relationships.

52 1.5 DPR and Environmental Buffer No environmental buffer Wastewater treatment Advanced water treatment The Gap Surface water treatment Drinking water distribution system Maintain functionally of environmental buffer: Additional treatment Additional monitoring requirements Additional engineered storage

53 1.6 Blending Really talking about dilution Require dilution of the advanced treated water? Or limit the amount of advanced treatment water? Big Spring, TX limits advanced treated water to no more than 50% of water to the water treatment plant Alternative: Require a back up source of water if DPR facility is down or there is off-spec water

54 1.7 Multiple Barriers Drinking water concept Multiple treatment barriers for pathogens and chemicals Increases resiliency of treatment FAC: The treatment processes shall include processes which serve as multiple barriers for control of organic compounds and pathogens. Define in regulations? With approach in guidance?

55 2. Technical Topics Review topics including water quality, treatment, and enginieering concepts that relate to the safety and production of potable reuse.

56 2. Technical Topics 2.1 Applications (Types of DPR) 2.2 Public health protection (pathogen and chemical control) 2.3 Source control 2.4 Wastewater treatment 2.5 Advanced water treatment 2.6 Treatment performance 2.7 Monitoring and instrumentation 2.8 Residuals management (including concentrate) 2.9 Facility operation (O&M) 2.10 Blending 2.11 Drinking water treatment

57 2.1. Potable Reuse Applications Groundwater Replenishment Spreading Injection Surface Water Augmentation Reservoirs, lakes, and water conveyance structures. Direct Potable Reuse With a surface water treatment plant Direct into a drinking water distribution system

58 Direct potable reuse (first type) producing advanced treated water Wastewater treatment Advanced water treatment Surface water treatment Drinking water distribution system

59 Direct potable reuse (second type) producing finished drinking water Wastewater treatment DPR facility: Advanced water treatment that meets SDWA requirements for Surface Water Treatment Plant Drinking water distribution system

60 Regulation Permit Guidance 2.1 Potable reuse applications Direct Potable Reuse With a surface water treatment plant (produces advanced treated water) Without a surface water treatment plant (produces finished drinking water)

61 2.2. Source Control Program Program to reduce chemicals in the wastewater collection system that impact treatment and/or final water quality Source control programs are essential for DPR Build on Federal Pretreatment programs Working with dischargers and residents (voluntary) Realistic expectations are needed Not possible to eliminate all hazardous chemicals Additional Benefit: Component of public outreach 61

62 Source Control Program Modify the pretreatment program so it is suitable for DPR Identify constituents in wastewater that may be very hazardous, difficult to remove, or are precursors to disinfection byproduct formation Inventory the sources and concentrations of selected constituents Include commercial and industrial entities Develop a program to inform consumers of best practices for home waste disposal

63 2.2 Source control Regulation Permit Guidance What? Control of the discharge of constituents (chemicals) into a wastewater collection system that: 1. Can impact wastewater treatment. 2. Are difficult to treat. 3. May impair the water quality entering an advanced treatment facility. Why? Beneficial, efficient, and cost effective strategy for managing chemicals by keeping them out of the wastewater system. Specific recommendations: Understand the sewershed and sources of chemicals. Minimize discharge of harmful or difficult to treat chemicals. Improve wastewater water quality. Provide public with confidence.

64 2.3 Potable Reuse Water Quality and Human Health Risks Microbial risk (mostly acute) Virus Protozoa Pathogenic Bacteria Chemical risk (mostly chronic) Natural and synthetic compounds Regulated and Unregulated NDMA Microbial and chemical risks exist with both conventional drinking water and potable reuse sources but differ in degree of source vulnerability

65 Regulation Permit Guidance 2.3 Public health protection What? Demonstrate public health protection through appropriate pathogen and chemical control based on treatment technologies, treatment performance, and monitoring. Why? Potable reuse involves a highly impaired source wastewater. Regulators require that a certain level of risk protection is achieved and the public will need confidence. Specific recommendations: Pathogen control (viruses, protozoa, and bacteria) Chemical control (regulated and unregulated) Treatment technologies and monitoring (indicators and surrogates)

66 Regulation Permit Guidance Microbial control What? For DPR, public health protection requires that pathogens in wastewater be removed or inactivated. Why? Pathogens in recycled water include bacteria, viruses, and protozoan parasites. Pathogenic microorganisms present significant acute risks to the consumer and are the most important design and operating concern for DPR systems. Specific recommendations: An appropriate goal is 1 in 10,000 annual risk of infection. A log removal target approach (including a log removal credit system) is needed since it is not possible to measure directly.

67 Log Removal Log reduction relates to the percentage of pathogens physically removed or inactivated by a treatment process Under SDWA, treatment for surface water requires a 3-log removal for Giardia and 4-log removal for viruses. 1-log reduction = 90% removal and/or inactivation 2-log reduction = 99% 3-log reduction = 99.9% 4-log reduction = 99.99% 5-log reduction = % 10-log reduction = % 12-log reduction = %

68 Regulation Permit Guidance Log Removal Targets Comply with the following minimum log removals (including SWTR credits for the drinking water plant) starting from the raw wastewater (California): 12-log reduction of enteric virus, 10-log reduction of Giardia cysts, and 10-log reduction of Cryptosporidium oocysts Log removals can be adjusted based on an approved pathogen removal study of the wastewater treatment plant that assigns conservative log reduction credits (Texas) Apply credits to wastewater facility, advanced water treatment facility, and drinking water facility based on regulatory review.

69 Regulation Permit Guidance Log Removal Credits CA has assigned maximum credits at unit processes at IPR projects. Specific unit processes with LRVs are (V/C/G): Wastewater (2/1/1) Microfiltration/ultrafiltration (0/4/4) Reserve osmosis (1.5/1.5/1.5) Advanced oxidation process (6/6/6) Chlorination (6/3/0) Process monitoring is needed for verification.

70 DPR Log 10 -Reduction Values (WRRF 11-02)

71 Example Pathogen Log Reduction Credits (Tchobanoglous et al., 2015) Process Monitoring Log Reduction Credits V G C Notes Secondary treatment Study needed is the default. MF or UF Daily PDT RO Online EC UV-AOP Intensity sensors Pressure decay test (PDT) should be done daily to verify proper performance. Electrical conductivity (EC) should be monitored in RO influent and effluent. Log reduction in system control must be based upon measured values. UV sensors should be calibrated per U.S. EPA (2006). ESB with free chlorine, CL 2, Online Cl System control is based on maintaining a minimum free residual of 0.4 mg/l. Total

72 Filename.ppt/72 Altamonte Springs FL DPR Pilot

73 Filename.ppt/73 Pilot Secondary Filtered Effluent Ozone (Xylem) Biofiltration (Xylem) Ultrafiltration (Toray/BiWater) GAC Filtration (Calgon) UV AOP (Trojan) Sample Point

74 Pathogen Log Reduction Credits for a Ozone-BAF Based Treatment Train for Direct Potable Reuse Unit Process Virus Giardia Crypto Ozone 5-log - - BAF Ultrafiltration (UF) + 4-log 4-log Granular Activated Carbon (GAC) UV AOP 6-log 6-log 6-log Engineered Storage with Chlorine 4-log 3-log - Total 15-log 13-log 10-log + indicates some removal expected - indicates no removal anticipated

75 CECs, PPCPs, PFCs are Removed Through the Pilot Antibiotic: Treats/prevents infections

76 CECs, PPCPs, PFCs are Removed Through the Pilot O₃+BAF

77 Regulation Permit Guidance Chemical Control What? Chemicals in wastewater must be removed to appropriate levels. Why? Chemicals in recycled water include both regulated and unregulated chemicals. Chemicals are typically chronic (nitrate is a notable exception). Trace organics (e.g., CECs) are often discussed. Specific recommendations: Meet all MCLs and any additional state requirements (regulated chemicals) Meet relevant health criteria established for unregulated chemicals. Monitor for surrogates and indicators of treatment (performance monitoring) and water quality (verification monitoring). Possibly use TOC as a measure for unknown chemicals.

78 Total Organic Carbon Concentration In Product Water Meets Florida IPR Regulations

79 Regulation Permit Guidance Chemical Control A tiered approach for chemical criteria based on the type of monitoring: Tier 1: Regulated chemical constituents, including DBPs MCLs, other state requirements Tier 2: Unregulated chemical constituents with public health interest Including CECs based on public health Tier 3: Unregulated chemical constituents that provide information on the effectiveness of treatment Including CECs Detected frequently and at sufficient concentrations to make them useful measures of the removal of health-significant organic chemicals

80 Regulation Permit Guidance Chemical Control - Salinity What? TDS and individual constituents. Why? Salinity is not a public health issue, but salinity must be managed to maintain acceptable aesthetics and for recycled water quality. Individual constituents (chloride, bromide, etc) are also important. Specific recommendations: Salinity is often a regional issue. Include salinity as a consideration in planning and design. Understand the long-term changes in salinity. Removing salinity requires advanced treatments such as RO.

81 2.4 Wastewater Treatment Differences between different secondary treatment processes. Issues related to the use of conventional wastewater treatment in potable reuse applications. Benefits of using a higher quality efflue1.1 DPR background information

82 5 Steps in the Wastewater Treatment Process

83 Regulation Permit Guidance Wastewater treatment What? Provide a consistent, high-quality effluent. Why? As a source water for DPR, WWTPs should produce an effluent optimized for further processing by Advanced Water Treatment Plant. Specific recommendations: Source control Minimum treatment requirement Assignment of log removal credits There are benefits with using a higher quality effluent in a potable reuse treatment train. As a result, enhancements should be considered.

84 Regulation Permit Guidance Wastewater optimization Possible measures to improve performance and enhance reliability: Enhanced screening process and, possibly, fine screening. Influent flow and load equalization. Elimination (or equalization) of untreated return flows. Operational mode for biological treatment process to improve reliability and produce an effluent of consistent quality. Improved disinfection while preventing DBP formation. Post-treatment filtration (remove suspended solids). Improved online and offline process monitoring.

85 Regulation Permit Guidance 2.5 Advanced water treatment (AWT) What? Involves unit processes (a range exists) for treating wastewater effluent to produce a drinking water source of supply. Why? Must meet regulatory review (pathogens and chemicals) and public scrutiny. Specific recommendations: Define the objectives (pathogen log removals and chemical control). Do not list specific treatment trains (avoid the notion of prescribed trains). Instead, provide lists of advanced treatments and the capabilities. Use of pilot testing and/or demonstration studies. Final water quality will vary based on the treatments employed. Track research and field experience. Understand reliability (performance of

86 Example DPR treatment trains From the draft Expert Panel Report on the Feasibility of Developing DPR Criteria for Calif. (2016)

87 Removal of Chemicals through DPR Processes (RO) RO + UV Achieves Removal of CECs 100,000 10,000 1,000 RWPF Influent RO Feed AOP Feed Product Water ng/l Reuse Enhanced Pathogen and Pollutant Monitoring at Big Spring, TX (Eva Steinle-Darling, Carollo)

88 Alternative Approaches for Potable Reuse Full Advanced Treatment MF RO UV/H 2 O 2 Alternative based on O 3 -BAC MF O 3 BAC UV Advantages of O 3 -BAC Excellent CEC removal Eliminates RO concentrate Reduces capital and O&M costs Source: Trussell Technologies Disadvantages of O 3 -BAC Disinfection byproducts No TDS reduction Higher product water TOC 88

89 Differences in Effluent Quality Between Advanced Water Treatment Processes

90 Regulation Permit Guidance 2.6 Treatment performance What? Process control and monitoring Why? Document system performance and monitor chemical and pathogen reduction or measure specific criteria. Specific recommendations: Automated system control Start-up performance Performance monitoring (long-term monitoring; surrogate and indicator monitoring) Frequency, locations, regulatory vs. process, online vs. periodic Use of Critical Control Points

91 Regulation Permit Guidance 2.7 Long-term monitoring What? Performance monitoring. Why? Demonstrate continuous production of high-quality water protection of public health. Specific recommendations: Online where possible. Rapid surrogate measures. Assure log-removal targets are met. Develop periodic sampling requirements. Use of alarms, shutdowns, and flow diversions.

92 Performance Monitoring: Example Online and Calibration Sampling (Tchobanoglous et al., 2015) Process Test Type and Frequency of Sampling Secondary effluent MF or UF Turbidity and microbial indicators Ammonia, TSS, and BOD PDT Turbidity Turbidity: online (continuous) and grab (weekly); microbial: grab (weekly) Grab (weekly) Offline testing (daily) Online (continuous) and grab (weekly) RO Influent and effluent EC and TOC Online (continuous) and grab (weekly) UV-AOP UV sensors Influent UVT Online (continuous) and verification (weekly) Online (continuous) and grab (weekly) ESB with free chlorination Influent and effluent chloramine Effluent free chlorine residual Online (continuous) and grab (weekly) Online (continuous) and grab (weekly)

93 Treatment Reliability Critical Control Points CCPs are points in the treatment process that are specifically designed to reduce, prevent, or eliminate a human health hazard and for which controls exist to ensure the proper performance of that process. Wastewater Treatment Plant H 2 O 2 UV Chlorine Microorganisms & Chemicals of Concern Critical Control Points in Reverse Osmosis (Reuse-13-03) NDMA Control Chloramine Stabilization Strainer Microorganisms Microfiltration Microorganisms Acid/Antiscalant Engineered Storage Microorganisms & Chemicals of Concern Reverse Osmosis Drinking Water Plant or Distribution Lead/copper leaching in distribution system

94 Example: Control Control Points From the draft Expert Panel Report on the Feasibility of Developing DPR Criteria for Calif. (2016)

95 Regulation Permit Guidance Critical Control Points What? Point in the treatment train (i.e., a unit treatment process) that is designed to reduce, prevent, or eliminate a human health risk and for which controls exist to ensure the proper performance of that process. Why? Systematic approach to inform the effective operation of AWTF through performance-based monitoring (augment end-of-pipe monitoring) Specific recommendations: Steps: Identify hazards Identify CCPs Identify monitoring procedures

96 Human Cell Line Bioassays Used for years in pharmaceutical field Measures bioactivity of a chemical class Ability to measure for unknown chemicals Ability to measure mixtures Use as a screening tool and for benchmarking Estrogen like chemicals Glucocorticoid/ progesterone like chemicals Androgen like chemicals Dioxin like chemicals Genotoxicity Cytotoxicity

97 Bioassays Indicate Bioactivity of Hormones/Chemicals is Eliminated Through the Pilot Processes Estrogen like chemicals

98 2.8 RO Concentrate Issue for inland communities If RO is used in the treatment train, the management of RO concentrate is a major consideration. A number of RO concentrate disposal options are available, though cost is a factor

99 Regulation Permit Guidance 2.9 Facility Operation What? Operation and maintenance (O&M) for DPR system to operate consistently and reliably. Why? Appropriate O&M is needed to ensure that all public health objectives are met. Specific recommendations: Commissioning and initial start up Shutdown plan O&M Plan (critical item) Operator Training and Certification Reporting

100 Components of an O&M Plan for a DPR System (Tchobanoglous et al., 2015) Staffing (i.e., for daily operations and emergencies) Operator training and certification Checklists for operations procedures (daily, weekly, and monthly) Routine maintenance of equipment Critical spare parts and failure training Control system (e.g., SCADA, shutdown procedures, and alarms) Process monitoring and control Regulatory compliance Frequency of monitoring Distribution System Response time to treatment failures or non-compliant water quality

101 2.10 Potential Water Quality Impacts of Blending Purified Water Disinfection stability and DBPs Temperature Aesthetics Corrosively 101

102 2.11 Drinking Water Treatment Plant Drinking water treatment counts towards DPR treatment requirements (e.g., pathogen credits) Must meet all SDWA requirements for SWTP

103 3. Management Topics Review technical topics including water quality, treatment, and enginieering concepts that relate to potable reuse.

104 3. Management Topics 3.1 Utility collaboration 3.2 Technical, Managerial, and Financial (TMF) Capacity (Small Systems) 3.3 Permitting 3.4 Operator training and certification 3.5 Alternatives Provision

105 3.1 Utility Collaboration Address inter-jurisdictional issues: Collaboration is needed. How different agencies will work together. Interagency cooperation and responsiveness plan Should be developed between the entities operating the WWTP, AWTF, and DWTF to ensure pretreatment and source control are conducted effectively Memorandum of Understandings MOUs or inter-governmental agreements are needed to define the roles and responsibilities of multiple utilities and/or jurisdictions. These agreements can describe the methods that the utilities and/or agencies would use to work together and implement the DPR project. 105

106 Regulation Permit Guidance 3.2 TMF Capacity What? Technical, Managerial, and Financial Capacity ability of a water utility to provide safe and dependable water (required by SDWA) Why? Regulators can assess a utilities potential or existing weaknesses to provide safe and reliable advanced treated water. Specific recommendations: Build on existing capacity develop program for PWSs Expand current TMP program to address DPR Ability to review small systems (less than 10,000?)

107 3.3 Permitting Best Practice: Have frequent meetings with regulators Best Practice: Work in collaboration with regulators Are changes needs to clarify roles and responsibilities for the regulators for: Permitting of potable water reuse projects, Improving the management of potable water facility monitoring data Reporting of potable water operations to the public

108 3.4 Operator Training and Certification Need for trained operators of advanced treatments Create certification level for operators of advanced treatments? Number and certification of operators

109 Operator Training and Certification Certification Programs: Most existing certifications are generalist and may not be representative of what is needed to perform a specific task related to potable reuse Risk Management Risk Management Processes Potable Reuse Operations Management Plan (Reuse-13-13) CCPs Critical Control Point Selection Operations Management Roles and Responsibilities Operational Monitoring Potable reuse certification may be an Water Quality Risk Assessment Critical Control Point Management Operating Procedures Operator Skills and Training supplement to existing frameworks CA/NV AWWA developing a program Operational Risk Assessment Managing Incidents and Emergencies Preventative and Corrective Actions Operator Training: Materials currently Asset Management and Maintenance Operating Interfaces being developed (Reuse-15-05) Validation and Auditing Communication

110 3.5 Alternavites Provision Include alternatives provision in regulations Purpose: Allow a utility to propose an alternative approach to any DPR requirements in the regulations

111 4. Other Topics Review topics on emerging concepts that may need to be addressed during the framework development.

112 4. Other Topics Antibiotic resistant bacteria and genes Integrating real-time sensors and rapid monitoring of contaminants Failure response times Reliability, robustness, resiliency, and redundancy Use of expert panels for projects or state efforts Research

113 Potable Reuse Monitoring Rapid monitoring of contaminants provides more time to respond to treatment upsets What is the Ideal Sensor? (Reuse-11-01) High-throughput by distribution of miniaturized sensors Real-time sensors generate large amounts of data and are only effective if data can be understood and acted upon in a timely manner (Reuse-14-01) Integration from sample pretreatment and concentration to sensing system Activation, Regenerations, & Calibration of sensing probes Practical Application Cost-effectiveness

114 Resilience and Reliability of DPR Treatment Resilience: The ability of a treatment train to successfully adapt to failure Reverse Osmosis fault tree highlighting primary qualitative and quantitative process failures (Reuse-14-16) Treatment processes are interdependent from the collection system to advanced treatment and the tap (Reuse ) Reliability: The ability to provide water that consistently meets or exceeds the public health protection

115 NEXT CONCEPT

116 Guidance Activities Apr May June/July Aug/Sept Oct/Nov Dec Workshop #1 (April 6) Workshop #2 (midsummer) Workshop #3 (Fall) Input on topics and identify questions Develop draft recommendations Develop draft report Finalize report

117 Thank You!