Water Reuse Interagency Workgroup March Stakeholder Meeting

Transcription

1 Water Reuse Interagency Workgroup March Stakeholder Meeting Date: March 13, 2017 Contents Water Reuse Interagency Workgroup March Stakeholder Meeting... 1 Meeting Summary... 2 Discussion Questions... 2 Liability... 2 Risk Management... 2 Wastewater/Graywater... 3 Plumbing Code... 3 Stakeholder Feedback... 4 Liability... 4 Risk Management... 4 Wastewater/Graywater... 5 Plumbing Code... 5

2 Meeting Summary 2 WATER REUSE- MARCH STAKEHOLDER MEETING The Water Reuse Interagency Workgroup invited over 75 individuals or organizations to participate in the third stakeholder meeting in March of The Workgroup is developing recommendations for water reuse policy and practices and has established stakeholder meetings to solicit feedback from people who have an interest in water reuse. Others beyond the invite list were welcome to attend. This stakeholder meeting took place on Monday, March 13, 2017 in St. Paul, Minnesota. Around 45 people attended. At the meeting Anita Anderson from the Minnesota Department of Health and Workgroup chair, presented on risk management and water reuse. The presentation outlined the concept of risk for water reuse and identified a log reduction target approach to manage water reuse risk. Stakeholders then self-selected into four small groups focusing on key topics where the Workgroup was interested in obtaining feedback. The four topic areas included: plumbing, liability, wastewater/graywater, and risk management. Each small group held two sessions so stakeholders could rotate between them and provide a wealth of information. Each small group was moderated by a Workgroup member who asked a series of questions regarding the topic. The following are the questions the moderator could ask by topic. Discussion Questions Liability What recommendations does the reuse workgroup need to make in regards to liability and reuse? How does the liability with water reuse compare to traditional water, wastewater and food services (e.g. waterborne outbreaks, foodborne outbreaks, Legionella, etc.)? Are there supplier/user contracts for these services that can be used as models? Would regulatory agencies hold an industry that is receiving reuse water for use in their industry responsible for constituents in the reuse water that they have no control over? What parts of water reuse liability should be covered in contract language vs. law or rule? Is reuse water treated as a good or a service? What role does common law play? How is liability assigned? Distributor, producer, end-user (option to transfer, each partner taking responsibility for their part?) What characterization of wastewater is needed beyond current monitoring? Is there a concern with pollutant transfer out of normal discharge area? Need clarity on permitting and need for backup supply. Risk Management Is the contaminant reduction (treatment technique) approach understandable? Does it interfere with any existing regulatory or guidance frameworks?

3 What resources would be needed to implement? (log reduction credit tables, design manuals, etc.) Review details of log reduction targets. Do they fit MN? Do we have any data we aren t utilizing? How to incorporate into permits, plumbing code, reclaimed wastewater guidance, stormwater guidance or others? Who can provide ongoing oversight of monitoring and operations? Wastewater/Graywater 3 Introductions what s your role and involvement in wastewater/graywater engineering? Are you aware of MPCA guidance on wastewater reuse? Wastewater: What types of reuse would you like to encourage? What are the barriers? Are you aware of any interest in potable reuse? Graywater: What s the scale and level of interest that you re aware of? In remote locations? Domestic scale or community-scale? Institutional, commercial buildings? What are the barriers to graywater reuse? Is Leadership in Energy and Environmental Design (LEED) certification an incentive? Have you had experiences with the DLI variance process? Do we have the expertise to design decentralized graywater systems? What should the standards be? Where can these systems be most feasible and cost-effective? Would a wiki-type manual be a useful tool? Do we have information that could be used to populate it? Is it the best use of resources? What are the unintended consequences of graywater/wastewater reuse? Plumbing Code Are you familiar with the contents of the current Plumbing Code regarding rainwater reuse? How s the new plumbing code working regarding reuse? (Current systems don t require a lot of maintenance; DLI doesn t have authority to set up specified reporting) How should we manage reuse through the plumbing code? Review the alternate sources chapter of the Uniform Plumbing Code (current Chapter 16) what s in, what s not? How does it address graywater, wastewater, indoor stormwater? Should water treatment standards, water quality parameters, be part of plumbing code or remain separate, as they are at present? If the alternate sources fell under plumbing code, installation and repair and maintenance would require a licensed plumber what are the pros and cons of that approach. How much interest do you see in various types of reuse? How much interest in decentralized systems? Is the current variance system sufficient to handle new applications? Are local authorities willing to take over responsibility for oversight and management, after systems have been installed? Can a decentralized system be designed properly to meet water quality standards?

4 What would be steps needed to include stormwater, graywater and wastewater reuse in the plumbing code? What level of resources would be needed for agencies to undertake this effort? Stakeholder Feedback Each small group had rich, thoughtful discussions. These discussions will be taken into account as the workgroup completes the recommendations. The following is a summary of the common themes from the discussions on each topic. They include: Liability There were different takes on liability from people with different risk perceptions. Some didn t worry about liability. Others wanted more standards in place from the state so they have something to work towards to reduce their liability. The group seemed to favor policies (i.e., rules, not statutes) that would be created under one agency and that could be flexible and amended relatively easily when needed. There is interest in a permit shield approach the permit requires you to build to a set of standards; if you demonstrate you met the standards, it then shields you from liability to some extent. Operations & Maintenance (O & M) are critical in ensuring that systems function properly. Some people think we should set up standards to be clear about how to meet standards. Others said that requiring O & M will raise costs and make reuse cost-ineffective. The group still hasn t heard from the general public, who might be affected by some of these projects. The group didn t focus on specific sources or uses for all questions. They discussed reuse as a whole part of the time, so some may have been thinking about graywater while others were thinking about stormwater. At other times, comments were focused on specific sources and uses, or more broadly defined point and non-point sources. Generally, participants believed liability would vary by source and end use. For example, stormwater used outside should have different requirements than if used inside. A licensed operator of stormwater systems would not be needed (when end use is outdoors). Risk Management Risk management and treatment are complex, and there are many details to work out. How can people be involved in working out the details? People on the wastewater side understand regulations, and are used to doing water quality monitoring. They saw a need for treatment and monitoring. People on the stormwater side had questions about the levels of risks, and about the information available about the quality of stormwater. They were less ready to do monitoring or treatment, and asked if education can suffice instead of requirements. They wondered whether the group had considered the risk-benefit equation carefully. 4

5 More data on water quality is being collected. How do we incorporate new information into the process? Some see any requirements as a barrier to reuse, while some see consistent requirements as providing direction and ensuring safety. There was a question of what will happen with projects that have already been installed. If the state is going to do regulation, they would want it done sooner rather than later so they can adjust new projects now and not have to redo them later. There is also a need to consider risks such as chlorides, which may come into play before health risks. There is a need to have incentives for reuse. Wastewater/Graywater 5 The concept of resilience was discussed systems with reuse options can be more resilient in the face of future water shortages. The group, like others, differed on the need for regulation. Options discussed included direct potable use (considered a long-term option in Mankato) and reuse of splash pad water, which can be very wasteful if discharged but expensive to retrofit for reuse. People who work on decentralized systems in other states have a different perspective that is more favorable toward graywater reuse. Home water softeners are a barrier to graywater reuse. Much of what is built in today s market is developer-driven. Home builders are not promoting dual piping that would allow reuse. However, contractors are saying they can put in graywater systems through permitting at the city level; this might be happening in Minneapolis. For wastewater reuse, the key problem is that moving water is expensive, so proximity of source to end use is important. Different certifications like LEED, Living Building Challenge, Envision, and Sustainable Sites might drive reuse. Plumbing Code Most stakeholders agreed the state should be more proactive. They all agreed that the state doesn t have a water quantity issue now, but they wanted to be ready for when we do have one. There were concerns about homeowner ability to maintain reuse systems. Stakeholders were concerned about Operations & Maintenance, and were not opposed to training and certification of operators, especially for graywater. They discussed the need for oversight and who would do oversight, and how it will scale up over time for safe systems. For example, St. Paul already inspects systems twice a year. How do they adjust oversight when the number of projects increases? Will they charge fees? They discussed having reuse stay in the plumbing code. They discussed guidance for design review and meeting water quality standards.

6 Minnesota Department of Health PO Box St. Paul, MN /13/2017 To obtain this information in a different format, call: ###-###-####. Printed on recycled paper. 6