Water Reuse Interagency Workgroup Meeting Summary August 10, :30 am 12:00 pm Minnesota Pollution Control Agency

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1 Water Reuse Interagency Workgroup Meeting Summary August 10, :30 am 12:00 pm Minnesota Pollution Control Agency Present Members: Anita Anderson, Randy Ellingboe, Julie Ekman, Scott Fox, Jan Kelly, Deborah Manning, Rhees, Nancy Rice, Faye Sleeper, Dan Stoddard, Ron Struss, Randy Thorson, Cathy Tran Other Attendees: Anne Gelbmann, Carrie Jennings, Tim Power, Shane Symmank, Michael Nguyen Management Analysis & Development Staff: James Collins and Charlie Petersen Welcome, Agenda Review, and Updates Charlie welcomed members to the eighth meeting of the Water Reuse Interagency Workgroup. The focus for today s meeting is challenges to water reuse. Ron Struss introduced Jan Kelly, a new member of the group from the Dept. of Agriculture. Jan works in Food and Feed Safety Division and manages the manufactured food program. Jan is based in Southwestern Minnesota. The group introduced themselves and the group approved the July meeting notes pending Randy Thorson s updates. Updates: The Freshwater Society report is now available. and Anita said the six month update should be released online soon. It has gone through the communications office. It s the group s intent to send the first GovDelivery update soon to a broader mailing list. At the moment the list has approximately 160 contacts. WateReuse is hosting a conference in Kansas City soon, but no one plans to go. Gold n Plump had a stakeholder tour of their purified water pilot project on August 2nd and Anita and attended. Sponsor Check-in and Update Anita summarized the group s work to date for the agency sponsors. The group has developed a definition for success, a work plan, and a six month update. She referred them to the update for more details. This meeting included updates from the workgroup s sponsors. Sponsors noted: 1

2 Dan Stoddard: MDA didn t initially realize how involved they should be, so they are working on allocating additional resources to this effort in order to more fully participate. The issue of water reuse is important and the interagency coordination team devotes attention to it. Randy Ellingboe: There is a lot of interest in water reuse within and external to the Department of Health. The fact that the state is dealing with these regulatory barriers and having these conversations regarding uncertainties is important and a step forward. Are there assistance, guidance or insights that we as sponsors can provide? Are there any resource issues that are important as we move forward particularly if there are resource issues that may serve as a barrier to teams moving forward? Julie Ekman: I want to address existing legislation that eliminates water fee for those reusing stormwater. DNR is working with several Metro cities and watershed districts who are interested in streamlining or eliminating permit requirements for stormwater use. We are working on developing a general permit for stormwater that would require less time to review. In response, the group noted that there may be a need for additional administrative rulemaking down the road, especially in the areas of graywater and stormwater. Although there is a good framework for recycled wastewater, it is less practical to do much with that at this point. The group noted that the stakeholder process could uncover needs not currently acknowledged. The group noted that there will be a need for management level review for recommendations and each agency all the way up to the commissioner s office will probably want to weigh in and it would be helpful to have the support of sponsors during that process. Much of the assembly of the recommendations might be happening this spring, during the legislative session. It might be difficult to get sponsors attention but it is incumbent on workgroup members to keep their managers abreast of updates and recommendations. As far as other resources that may be required, it might be helpful to think through resources during the stakeholder input time but it may be too early to talk about resources required to address challenges. Legislative proposals may pop up this fall, if workgroup members become aware of any legislative proposals, members are requested to make the larger group aware. Challenges Pre-Discussion As a precursor to the larger challenges discussion, the group made some initial comments regarding challenges that have been uncovered. Challenges uncovered as of now include: The DNR sees a misunderstanding that when agencies want something to occur, that they will they stop regulating that activity, but this is not true. The DNR needs to convey the message that regulation isn t a bad thing and that it s necessary for the protection of resources. 2

3 Permitting process formats do not speak to water reuse and leave local inspectors confused as to how they should address reuse issues. Water reuse projects are relatively new and they take longer to evaluate. From a utility point of view, there is interest and concern about wastewater reuse, and the science isn t where we d like it to be in order to make the best regulatory decisions. What do we do when there are questions that science hasn t caught up with yet? Many of these reuse systems are new. Initial installations may get reviewed, but the challenge is long-term operation of the systems. There s little long-term planning for maintenance and operations of these individual systems. Stormwater Reuse Update Presentation Anne Gelbmann from the MPCA s Stormwater Section presented the group with information on the Stormwater Reuse Survey findings as well as how information is being updated in the MPCA s Stormwater Manual. Anne reported that many communities in Minnesota are implementing rainwater/stormwater harvest and use systems. In , MPCA staff identified and interviewed 177 entities that are regulated under the Municipal Separate Stormwater Sewer System (MS4) permit and their conversations revealed that: There are approximately 60 irrigation practices, four facilities that are using rainwater for toilet flushing and four facilities using rainwater for vehicle washing 54 respondents indicated they are planning a reuse project in the future 24 systems are using some sort of treatment 14 systems are being monitored for various pollutants 30 respondents indicated they have experienced difficulties implementing a reuse system Respondents voiced hesitations to implementing a reuse system. These hesitations include: DNR appropriations permit Funding Meeting plumbing code requirements Concerned that ponds would dry out Chloride concerns for irrigating golf courses Confusing regulatory frameworks Bacteria exposure concerns Availability of good guidance Lack of a cost benefit analysis Specific difficulties with reuse systems that respondents have experienced include: Sprinkler heads clogged Plumbing not installed correctly 3

4 Undersized pump Constant need for repairs Algae blooms Maintaining water intake as pond levels fluctuate Lack of understanding of how to maintain these systems In addition to reviewing these research findings, Anne presented how the team at the MPCA is updating the Stormwater Reuse Section of the Minnesota Stormwater Manual. They have divided their work into the following sections: Overview Design Elements Construction Sequence Operation and Maintenance Water Quality Considerations Environmental Costs Credit Calculators The content is being developed by Emmons and Olivier Resources with the guidance of a diverse group of stakeholders and the manual wiki has gotten more than 6 million hits. Challenges Discussion Through discussion, the group identified broad categories of challenges: Information/Education/Public Awareness Wide Variety of Sources and Applications, Infrastructure Integration Code/Regulatory Inspection and Ongoing Maintenance Guidance, Planning, and Assessment Risk/Benefit: Health, Stewardship, Economic, Liability Funding/Cost The group will work to develop recommendations to address these barriers. noted the value in thinking about challenges by using a matrix framework because the challenges can vary depending on the water source. Team Updates Charlie handed out the stakeholder advisory team list and workgroup members volunteered to take responsibility for some stakeholders who had yet to receive a workgroup member contact. Workgroup members will reach out to identified stakeholders and will request for them or their organization to commit to coming to the stakeholder meetings. Anita raised the point that this is probably a biased group of pro-reuse interests and asked the question if we needed to cast a wider net. Faye suggested the group reach out to the Water Cluster or perhaps to those who might bear an unfair economic burden as reuse develops. 4

5 Regulatory: Deb has been able to provide staff resources who have created a helpful table that matches elements of California regulations with what may or may not be in Minnesota code. The next step is to try to apply that technique to other source waters. The team has used the EPA guidance documents for wastewater as a framework. The team knows what s existing and now can compare with this framework, and that comparison will provide insights. There are gaps in these regulations and there is considerable discussion around how California delegates to a governing authority to fill in the gaps in guidance and regulation. Carrie Jennings noted that she looks to Denmark for examples of water reuse. There is a similar geography, ground water reuse practices, and population to Minnesota. Also, Carrie noted that Denmark is not water starved, so some of their approaches are more transferrable to our environment. Anita noted that Australian references also have some good insights. Outreach: Scott reminded the group that the last meeting there was not yet agreement on whether this is an internal tool or for the public as part of our final report. As far as a working tool, the team is researching the websites to identify what guidance and outreach material may be presented. Risk: The team has been looking at health and liability risks, but is wondering if they should start to develop a report that covers these subjects. The group developed a consensus that a summary of the findings is helpful to the technical writer to compile the material. Water Projects: The team had about responses to their survey and they are in the process of analyzing the responses. Responses include information on water source, use, level of treatment, storage, building types, permitting challenges, level of concerns, etc. The team will report their findings upon completion of their analysis. Next Steps The rest of the meeting was reserved for the teams to meet. MAD will out the notes for group members to review. 5

6 Handout: Group Workplan Activity Actor Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Define water reuse, prioritize scope Define success Generate and review stakeholder lists Teams complete work Draft 6 month update Review 6 month update Generate recommendations Stakeholder meetings Review, revise and prioritize recommendations Write report Draft 6 month update Review 6 month update Group reviews report Agency management reviews products Public and stakeholders review report Group reviews stakeholder feedback Final edits to report Send report to Legislature Teams Teams Anita 6

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