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Discussion of the Approach for Developing the Florida DPR Regulatory Guidance

Jeff Mosher

• Florida Potable Reuse Regulatory Guidance

• Purpose and approach

• “Guidance Document”

• Sources of information

• Research studies

• National scientific committees

• State-sponsored guidance

Two Items

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

Overarching Goals

• Develop science-based recommendations

• Protect public health

• Provide a regulatory path for DPR projects in Florida

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

Potable Reuse Commission will rely on

stakeholder involvement and expertise in

developing an approach for potable reuse

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

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.

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

Apr May June/July Aug/Sept Oct/Nov Dec

Guidance Activities

Workshop

#1 (April 6)

Workshop

#2 (mid-

summer)

Finalize

report

Develop draft

report

Input on

topics and

identify

questions

Develop draft

recommendations

Workshop

#3 (Fall)

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 (2012-2016).

• 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-15-01 (2016)

• In the past 15 years, supported expert panels for over 12 potable reuse projects in CA, AZ, TX, NV, WA, NM, and VA.

Guidance

Document

Proposed

Organization

Chap. 1: Introduction

overview

Water reuse in FL

Nonpotable reuse

Planned potable reuse

Potable reuse

• IPR

• DPR

Terminology

studies

NRC Report 1998

NRC Report 2012

Risks from microbial

and chemical

constituents

Etc.

organization

Chapter summaries

Recommended

resources

Chap. 2: Public Health Considerations

overview

Public health

considerations

Drinking water

regulations

pathogens

Pathogen reduction

criteria:

• TX approach

• CA IPR approach

chemicals

Targets:

• MCLs

• Trace organics

• TOC

• 1,4-dioxane and

NDMA

• DBPs

Chapter 3:

Potable Reuse Recommendations

Organized by Topic

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

Framework for DPR

• Published by WateReuse (2015)

• Sponsors:

WateReuse, AWWA, and WEF

• Developed by an NWRI Expert

Panel

• Available at:

www.nwri-usa.org/directpotable.htm

http://www.nwri-usa.org/directpotable.htm

Texas projects• DPR projects

• Direct Potable Reuse

Resource Document (2015)

• Groundwater replenishment (final

in 2014)

• Surface water augmentation (final

in 2018)

• Expert Panel Report on Feasibility

of Developing DPR Criteria for

California (2016)

California regulations

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…”

National Research Council –

1998

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”)

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

World Health Organization Potable Reuse

Guidance (2017)

U.S. EPA Potable Reuse

Compendium (2018)

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

Guidance Doucment –Topics for Discussion

1. General Topics

2. Technical Topics

3. Management Topics

4. Other Topics

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.

Regulation Permit Guidance

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.

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

1. General Topics

The Water Cycle Gives Us Access to Water

1.1 DPR Background Information

Source: AWWA Potable Reuse 101

De Facto or Unplanned Water Reuse

De Facto Water Reuse in the US

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 11099–11105)

The downstream use of surface water as a source of drinking

water that is subject to upstream wastewater discharges.

http://pubs.acs.org/author/Rice,+Jacelyn

http://pubs.acs.org/author/Wutich,+Amber

http://pubs.acs.org/author/Westerhoff,+Paul

Direct

potable

reuse

Wastewater Treatment

Advanced Water Treatment

Urban Water Use

Water Treatment

Environmental Buffer

Key components of DPR

Technical

Regulatory Outreach

Technical, Operational, and Management

Barriers

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

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

Important considerations for DPR

1. Consistent with current

regulations in Florida 5. DPR lacks an environmental barrier

2. Terms and definitions6. 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

1.2 Build on current regulations in Florida

• Florida IPR regulations – 62-610 Part V (F.A.C.)

• Two levels of treatment (62-610.563)

• Principal Treatment and Disinfection

• Full Treatment and Disinfection

• Discharge to Class I Surface Water (62-610.554)

• Discharge to Other Surface Waters (62-610.555)

• Groundwater Recharge by Injection (62-610.560)

• Salinity Barrier Systems (62.510.562)

• Definitions – 62-610.200

(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 – 62-610.310

(1) In accordance with the requirements and provisions of Chapters 62-

600 and 62-620, 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.

Full Treatment and

Disinfection (62-610.563)

• 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

Full Treatment and Disinfection (62-610.563)

• 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.” (62-610.560c3)

Other 62-610 Part V requirements

• Pilot testing (62-610.564)

• “Pilot testing is required for all projects that are required to

provide full treatment and disinfection”

• Require?

• Reliability and staffing (62-610.567)

• Monitoring (62-610.412)

• Operating protocols (62-610.310, 62-610.568, and 62-610.613)

• General Technical Guidance, Related Rules, and Forms (62-610.300)

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”

1.4 Public Outreach

Is “public

attitude” the

biggest

challenge to

potable reuse?

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)

StronglyFavor

SomewhatFavor

SomewhatOppose

StonglyOppose

Unsure0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

10%

16%

19%

45%

10%

35%33%

12% 11%9%

36% 37%

12%11%

4%

2004

2011

2012

Use Advanced Treated Recycled Water as an Addition to Drinking Water Supply

48

Public Tours of Facilities Help Educate the Consumer

Public Outreach: Key Activities

Outreach Activity Purpose

Provide a rationale for the need for DPR

Raise public confidence of the benefits and value of the DPR project to the community.

Identify public perception challenges to the DPR project

Use to assist in the development of strategies to alleviate these concerns and improve public perception.

Develop a DPR Communication PlanProvide 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.

Develop and disseminate communications materials on the DPR project

Provide objective, accurate, and timely information to raise awareness of the DPR project and address public concerns.

Connect with outreach staff at other AWTFs

Gain practical information and lessons learned from the real-world experiences of other potable reuse public outreach efforts.

Prepare a participation program for source control

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.

1.4. Outreach• What? Outreach programs are strategic, transparent, and thorough.

• Why? Public confidence and support is critical to the implementation of

potable reuse projects.


• 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.


1.5 DPR and Environmental Buffer

Wastewater

treatment

Advanced

water

treatment

Surface

water

treatment

Drinking

water

distribution

system

The Gap

No environmental

buffer

Maintain functionally of environmental buffer:

• Additional treatment

• Additional monitoring requirements

• Additional “engineered” storage

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

1.7 Multiple Barriers

• Drinking water concept

• Multiple treatment barriers for pathogens and chemicals

• Increases resiliency of treatment

• 62-610.563 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?

2. Technical Topics

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

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

2. Technical Topics

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

Direct potable reuse (first type)

producing advanced treated water

Wastewater

treatment

Advanced

water

treatment

Surface

water

treatment

Drinking

water

distribution

system

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

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)


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

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

2.2 Source control• 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.


• Understand the sewershed and sources of chemicals.

• Minimize discharge of harmful or difficult to treat chemicals.

• Improve wastewater water quality. Provide public with confidence.


2.3 Potable Reuse Water Quality and Human Health Risks

Microbial risk (mostly acute)̶ Virus̶ Protozoa̶ Pathogenic Bacteria

Chemical risk (mostly chronic)̶ Natural and synthetic compounds̶ Regulated and Unregulated

Microbial and chemical risks exist with both conventional drinking water and potable reuse sources but differ in degree of source vulnerability

NDMA

2.3 Public health protectionWhat? 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)


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.


• 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.


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%



• 10-log reduction = 99.99999999%

• 12-log reduction = 99.9999999999%

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.


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.


DPR Log10-Reduction Values

(WRRF 11-02)

Example Pathogen Log Reduction Credits (Tchobanoglous et al., 2015)

Process MonitoringLog Reduction Credits

NotesV G C

Secondary treatment

Study needed 0 - 1.9 0 - 0.8 0 - 1.2 “0” is the default.

MF or UF Daily PDT 0 4.0 4.0Pressure decay test (PDT) should be done daily to verify proper performance.

RO Online EC 1.5 1.5 1.5Electrical conductivity (EC) should be monitored in RO influent and effluent. Log reduction in system control must be based upon measured values.

UV-AOPIntensity sensors

6 6 6UV sensors should be calibrated per U.S. EPA (2006).

ESB with free chlorine, CL2,

Online Cl2 6 3 0System control is based on maintaining a minimum free residual of 0.4 mg/L.

Total 13.5 14.5 11.5

Filen

am

e.p

pt/

72

Altamonte Springs FL – DPR Pilot

Filen

am

e.p

pt/

73

Pilot

Sample Point

1 2

3 4 5 6

3

Ozone

(Xylem)Biofiltration

(Xylem)

GAC Filtration

(Calgon)UV AOP

(Trojan)

Secondary

Filtered

Effluent

Ultrafiltration

(Toray/BiWater)

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

Antibiotic:

Treats/prevents

infections

CECs, PPCPs, PFCs are Removed Through the Pilot

O₃+BAF

CECs, PPCPs, PFCs are Removed Through the Pilot

Chemical ControlRegulation Permit Guidance

• 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.


• 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.

Total Organic Carbon Concentration In

Product Water Meets Florida IPR Regulations

Chemical ControlA 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


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.


• 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.


• 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

2.4 Wastewater Treatment

5 Steps in the Wastewater Treatment Process

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.


• 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.


Wastewater optimizationPossible 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.


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.


• 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

treatment).


Example DPR treatment trains

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

RO + UV Achieves Removal of CECs

0

1

10

100

1,000

10,000

100,000

ng/L

RWPF Influent

RO Feed

AOP Feed

Product Water

Removal of Chemicals through DPR Processes (RO)

Reuse-14-12 Enhanced Pathogen and Pollutant Monitoring at Big Spring, TX (Eva Steinle-Darling, Carollo)

88

Disadvantages of O3-BAC

Disinfection byproducts

No TDS reduction

Higher product water TOC

Advantages of O3-BAC

Excellent CEC removal

Eliminates RO concentrate

Reduces capital and O&M costs

Alternative Approaches for Potable Reuse

MF O3 BAC UV

MF RO UV/H2O2

Alternative

based on

O3-BAC

Full

Advanced

Treatment

Source: Trussell Technologies

Differences

in Effluent

Quality

Between

Advanced

Water

Treatment

Processes

2.6 Treatment performance• What? Process control and monitoring

• Why? Document system performance and monitor chemical and pathogen

reduction or measure specific criteria.


• 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


2.7 Long-term monitoring

• What? Performance monitoring.

• Why? Demonstrate continuous production of high-quality water

protection of public health.


• Online where possible.

• Rapid surrogate measures.

• Assure log-removal targets are met.

• Develop periodic sampling requirements.

• Use of alarms, shutdowns, and flow diversions.


Performance Monitoring: Example Online and Calibration Sampling (Tchobanoglous et al., 2015)

Process Test Type and Frequency of Sampling

Secondary effluentTurbidity and microbial indicators

Turbidity: online (continuous) and grab (weekly); microbial: grab (weekly)

Ammonia, TSS, and BOD Grab (weekly)

MF or UFPDT Offline testing (daily)

Turbidity Online (continuous) and grab (weekly)

RO Influent and effluent EC and TOC Online (continuous) and grab (weekly)

UV-AOP

UV sensorsOnline (continuous) and verification (weekly)

Influent UVT Online (continuous) and grab (weekly)

Influent and effluent chloramine Online (continuous) and grab (weekly)

ESB with free chlorination

Effluent free chlorine residual Online (continuous) and grab (weekly)

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.

Engineered Storage Drinking Water Plant or Distribution

H2O2 UV Chlorine

Stabilization

NDMA Control

Wastewater Treatment Plant

Strainer

Acid/AntiscalantChloramine

MicrofiltrationReverse Osmosis

Microorganisms

Microorganisms &

Chemicals of ConcernMicroorganisms

Microorganisms &

Chemicals of Concern

Lead/copper leaching in

distribution system

Critical Control Points in Reverse Osmosis (Reuse-13-03)

Example: Control Control Points

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

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)


• Steps:

• Identify hazards

• Identify CCPs

• Identify monitoring procedures

• Identify corrective actions and procedures


Human Cell Line Bioassays

• Estrogen like chemicals

• Glucocorticoid/ progesterone like chemicals

• Androgen like chemicals

• Dioxin like chemicals

• Genotoxicity

• Cytotoxicity

• 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

Bioassays Indicate Bioactivity of Hormones/Chemicals is

Eliminated Through the Pilot Processes

Estrogen like chemicals

• 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

2.8 RO Concentrate

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.


• Commissioning and initial start up

• Shutdown plan

• O&M Plan (critical item)

• Operator Training and Certification

• Reporting


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 maintenanceof 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

2.10 Potential Water Quality Impacts of Blending Purified Water

Disinfection stability and DBPs

Temperature

Aesthetics

Corrosively

101

• Drinking water treatment counts towards DPR

treatment requirements (e.g., pathogen credits)

• Must meet all SDWA requirements for SWTP

2.11 Drinking Water Treatment Plant


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

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


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

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.


• Build on existing capacity develop program for PWSs

• Expand current TMP program to address DPR

• Ability to review small systems (less than 10,000?)


• 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

•

3.3 Permitting

• Need for trained operators of advanced treatments

• Create certification level for operators of advanced

treatments?

• Number and certification of operators

3.4 Operator Training and Certification

Operator Training and Certification

Risk Management

Risk Management

Processes

Operational Risk

Assessment

Water Quality Risk

Assessment

CCPs

Critical Control

Point Selection

Critical Control

Point Management

Communication

Operating Interfaces

Preventative and

Corrective Actions

Operator Skills and

Training

Operational

Monitoring

Validation and

Auditing

Asset Management

and Maintenance

Managing Incidents

and Emergencies

Operating

Procedures

Roles and

Responsibilities

Operations Management

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

• Potable reuse certification may be an

supplement to existing frameworks

• CA/NV AWWA developing a program

Operator Training: Materials currently

being developed (Reuse-15-05)

Potable Reuse Operations Management Plan (Reuse-13-13)

• Include “alternatives provision” in regulations

• Purpose: Allow a utility to propose an alternative

approach to any DPR requirements in the regulations

3.5 Alternavites Provision

4. Other Topics

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

• 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

4. Other Topics

• Rapid monitoring of contaminants

provides more time to respond to

treatment upsets

• 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)

Potable Reuse Monitoring

Integration

from sample pretreatment

and concentration to

sensing system

Cost-effectiveness

Activation,

Regenerations, &

Calibration

of sensing probes

High-throughput

by distribution of miniaturized

sensors

Practical Application

What is the Ideal Sensor? (Reuse-11-01)

Resilience: The ability of a

treatment train to successfully

adapt to failure

• Treatment processes are

interdependent from the

collection system to advanced

treatment and the tap (Reuse-

14-13)

Reliability: The ability to

provide water that consistently

meets or exceeds the public

health protection

Resilience and Reliability of DPR Treatment

Reverse Osmosis fault tree highlighting primary qualitative and quantitative process failures (Reuse-14-

16)

NEXT

CONCEPT

Apr May June/July Aug/Sept Oct/Nov Dec

Guidance Activities

Workshop

#1 (April 6)

Workshop

#2 (mid-

summer)

Finalize

report

Develop draft

report

Input on

topics and

identify

questions

Develop draft

recommendations

Workshop

#3 (Fall)

Thank You!

discussion of the approach for developing the florida dpr ...€¦ · develop a dpr communication...

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