water jam 2010 managing risks in water reuse: intersection of policy and science mary e. sadler, pe...
TRANSCRIPT
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Managing Risks in Water Reuse: Intersection of Policy and Science
Mary E. Sadler, PE
Benjamin Stanford, PhD
WaterJAM® 2015Virginia Beach, VASeptember 14-17
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Risk
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State Regulatory
ApproachesIntroduction
Water Reuse
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Potable Reuse Is Happening in the U.S. and Abroad
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No federal jurisdiction for water reuse
States have jurisdictional authority over how water is reclaimed
Differing state statutes and rules
EPA does not have a plan for applying federal regulation to water reuse
EPA has published technical guidance (2004 and 2012)
Attempt to aid states that do not have regulation or require assistance
No federal jurisdiction for water reuse
States have jurisdictional authority over how water is reclaimed
Differing state statutes and rules
EPA does not have a plan for applying federal regulation to water reuse
EPA has published technical guidance (2004 and 2012)
Attempt to aid states that do not have regulation or require assistance
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Water Reuse Practice of recovering wastewater and purifying it for
various community applications Water reuse water recycling, recycled water,
reclaimed water
Non-Potable Reuse All applications of recycled water for purposes other
than producing drinking water or augmenting drinking water supplies
Landscape irrigation, agricultural irrigation, indoor toilet flushing, industrial uses
De Facto Reuse Situations where an upstream treated wastewater
effluent provides a portion of available raw water supply
Not officially recognized as providing supply
Water Reuse Practice of recovering wastewater and purifying it for
various community applications Water reuse water recycling, recycled water,
reclaimed water
Non-Potable Reuse All applications of recycled water for purposes other
than producing drinking water or augmenting drinking water supplies
Landscape irrigation, agricultural irrigation, indoor toilet flushing, industrial uses
De Facto Reuse Situations where an upstream treated wastewater
effluent provides a portion of available raw water supply
Not officially recognized as providing supply
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Urban UseWastewater Treatment
AdvancedTreatment Environmental Buffer
Water Treatment
Indirect Potable Reuse (IPR) Planned, intentional, and recognized augmentation of a drinking water
source (surface or groundwater) with purified recycled water followed by an environmental buffer preceding drinking water treatment
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Engineered Storage
Urban UseWastewater
TreatmentAdvancedTreatment
Water Treatment
Direct Potable Reuse (DPR) Introduction of purified water directly into a drinking water treatment
plant, with or without blending with a raw water supply, or directly into a drinking water distribution system
Direct Potable Reuse (DPR) Introduction of purified water directly into a drinking water treatment
plant, with or without blending with a raw water supply, or directly into a drinking water distribution system
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Georgia EPD guidelines on reclaimed water IPR allowed via surface water augmentation
Metro water districts allowing planned IPR EPD developing DPR guidelines
Urban water reuse may be used in lieu of potable water for:
Agricultural irrigation (feed crops), residential / commercial landscape irrigation, dust control, etc.
Georgia EPD guidelines on reclaimed water IPR allowed via surface water augmentation
Metro water districts allowing planned IPR EPD developing DPR guidelines
Urban water reuse may be used in lieu of potable water for:
Agricultural irrigation (feed crops), residential / commercial landscape irrigation, dust control, etc.
Utah reuse governed by regulation IPR allowed via groundwater injection
Class 5 water use includes recharge wells to replenish an aquifer
No specific water quality requirements for IPR
Issues with reuse conflicting with water rights
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Arizona allows IPR via surface water augmentation and groundwater recharge
Regulation governing reclaimed water 5 designated classes of reclaimed water
Reuse discharge must not exceed any aquifer water quality standard at a Point of Compliance in aquifer
Wastewater treatment must employ Best Available Demonstrated Control Technology
Arizona allows IPR via surface water augmentation and groundwater recharge
Regulation governing reclaimed water 5 designated classes of reclaimed water
Reuse discharge must not exceed any aquifer water quality standard at a Point of Compliance in aquifer
Wastewater treatment must employ Best Available Demonstrated Control Technology
Virginia reuse regulated via Chapter 740 Sections 10‐210
DPR prohibited IPR allowed with advanced treatment
Limit of Technology, or LOT
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California legislation passed new statutes January 2011 Stipulated that CDPH must adopt uniform water recycling criteria
for indirect potable reuse Title 22 CCR amended in June 2014 for IPR via groundwater
replenishment by surface and subsurface application Surface water augmentation by 2016 Assess feasibility of direct potable reuse in 2016
Surface water application: Reduction of 12-log enteric virus, 10-log Giardia cyst, 10-log
Cryptosporidium Three separate wastewater treatment processes Groundwater retention time estimates
Subsurface application: Full advanced treatment to include reverse osmosis and an
oxidation process Log-removal of indicator compounds 12-10-10 log removal of pathogens
California legislation passed new statutes January 2011 Stipulated that CDPH must adopt uniform water recycling criteria
for indirect potable reuse Title 22 CCR amended in June 2014 for IPR via groundwater
replenishment by surface and subsurface application Surface water augmentation by 2016 Assess feasibility of direct potable reuse in 2016
Surface water application: Reduction of 12-log enteric virus, 10-log Giardia cyst, 10-log
Cryptosporidium Three separate wastewater treatment processes Groundwater retention time estimates
Subsurface application: Full advanced treatment to include reverse osmosis and an
oxidation process Log-removal of indicator compounds 12-10-10 log removal of pathogens
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Oklahoma reuse governed by regulation IPR not specifically allowed DPR regulations in development stages
However, IPR and DPR projects are evaluated on case-by-case basis
State may issue permits for POTW discharges into public water supply
Oklahoma reuse governed by regulation IPR not specifically allowed DPR regulations in development stages
However, IPR and DPR projects are evaluated on case-by-case basis
State may issue permits for POTW discharges into public water supply
Massachusetts allows IPR via groundwater recharge Reuse governed by state regulation 314 CMR 5.00
Treatment must meet drinking water standards and high level disinfection
Emerging contaminants and additional pollutants on a case-by-case basis
DPR not currently allowed Regulatory requirements for POTW discharges upstream of public
water supply source
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Washington 1997 guidance “standards” Quasi-regulation 4 classes of reuse water New reclaimed water rule anticipated in 2015
IPR via groundwater recharge allowed AKART standards must be met
All Known, Available, and Reasonable methods of control and Treatment Minimum required treatment:
Oxidation, coagulation, filtered, reverse-osmosis, disinfection
Washington 1997 guidance “standards” Quasi-regulation 4 classes of reuse water New reclaimed water rule anticipated in 2015
IPR via groundwater recharge allowed AKART standards must be met
All Known, Available, and Reasonable methods of control and Treatment Minimum required treatment:
Oxidation, coagulation, filtered, reverse-osmosis, disinfection
Texas regulates reuse via 30 TAC 210.3 IPR is not currently allowed via regulation DPR allowed but not officially regulated
Case by case basis Colorado River Municipal Water District
Microfiltration, reverse osmosis, UV disinfection
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North Carolina Senate Bill 163 Local water system may combine reclaimed water with
source water to provide potable water supply
Conditions: All reclaimed water treatment requirements must be met 5 days of storage with mixing prior to treatment Maximum blend of 20% average day flow of source water
over a 24 hour period Water conservation and efficiency must be implemented
North Carolina Senate Bill 163 Local water system may combine reclaimed water with
source water to provide potable water supply
Conditions: All reclaimed water treatment requirements must be met 5 days of storage with mixing prior to treatment Maximum blend of 20% average day flow of source water
over a 24 hour period Water conservation and efficiency must be implemented
Pennsylvania has reuse guidance manual with stated purpose of offsetting demand on potable water supply
Class A+ water requires advanced treatment ENR, coagulation, filtration, reverse osmosis, disinfection Any other treatment type must meet water quality requirements
IPR allowed via groundwater recharge direct injection (Class A+ water)
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New Mexico 2007 reuse guidelines 4 classes of water No IPR uses in guidelines
DPR regulation pending, but allowed on a case-by-case basis
DPR treatment to meet or exceed SDWA standards Example: DPR project in Cloudcroft, New Mexico
MBR, chloramine disinfection, reverse osmosis, UV/AOP, blending, ultrafiltration, chlorine disinfection
December 2015 anticipated completion
New Mexico 2007 reuse guidelines 4 classes of water No IPR uses in guidelines
DPR regulation pending, but allowed on a case-by-case basis
DPR treatment to meet or exceed SDWA standards Example: DPR project in Cloudcroft, New Mexico
MBR, chloramine disinfection, reverse osmosis, UV/AOP, blending, ultrafiltration, chlorine disinfection
December 2015 anticipated completion
Florida regulates IPR via Regulation 62-610 IPR uses include groundwater recharge to Class F-1,
G‐1, or G-II groundwater Direct injection Rapid rate land application Discharge to surface waters connected to Class F-1, G-1, or G‐
II groundwater
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StateIPR
RegulatedDPR
RegulatedReuse
RegulationReuse
Guidance Treatment Storage
Georgia X P X
Utah X X
Arizona X X X
California X P X X X
Oklahoma X P
Massachusetts X X
Washington X X X
Virginia X X X
North Carolina X X (legislation) X
Pennsylvania X X X
New Mexico P P X X
Florida X X
Texas X X
P = Pending
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Operations, Training,
& Certificatio
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Assess Risks
Identify Critical Control Points
Validate CCPs &
Set Limits
Validate Monitors
Develop Response
Procedures
Can we trust the technology?
Hazard Analysis and Critical Control Point (HACCP) methodology
Reliability of critical control points (CCPs)
Reliability of monitoring devices (Risk Priority Number approach)
Can we trust operations? Reliability and training of
operations staff
Theme: Building Confidence and Trust in DPR
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DPR – Raising the Stakes
Can We Trust the Technology?
Can We Trust Operations?
Trust but Verify
WRRF 13-03
Critical Control Point Assessment to Quantify Robustness and Reliability of Multiple Treatment Barriers of a DPR Scheme
WRRF 13-13
Development of Operation and Maintenance Plan and Training and Certification Framework for Direct Potable Reuse (DPR) Systems
Convincing a Skeptical Public Convincing Regulators
TOOLS:
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Hazard Analysis and Critical Control Point (HACCP) History
Systematic preventative approach to Food Safety
Focus on barriers – not end of pipe treatment
Conceived in 1960s by Pillsbury for NASA
Defined in ISO 22000 – Food Safety
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The 7 HACCP Principles
Conduct a Hazard Analysis
Determine Critical Control Points
Establish Critical Limits
Establish System to Monitor the
Control of a CCP
Establish Corrective Action to be Taken When
Monitoring a CCP is Not Under Control
Establish Procedures for Verification to Confirm that HACCP System is working
effectively
Establish Documentation Concerning All Procedures and Records Appropriate to These Principles and Their
Application
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Identify Hazardous Events
Accidental contamination of the
catchment
Disease outbreak – high pathogen load
Failure of biological processes
High rainfall event – bypassed treatment
Catastrophic membrane integrity
breach
Formation of DBPs in the process train
Overdosing, underdosing, or contamination of
chemicals
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What Does the CCP Approach Provide?
Review and Manage Risks to Protect Public Health
What are the risks?
Holistic Review / Robust Methodology – Source Water to Distribution
What are the right
technologies?
How are we sure they are
working?
How do we respond if a barrier fails?
Contaminants/Hazardous
Events
Treatment Barriers
MonitoringOperating Response
Focus is on health relevant contaminants
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Focus of CCPs is on Health-Relevant Contaminants
Assists in decision making: Which contaminants are of concern for a given source water/distribution system?
Determines clear requirements for treatment barriers.
Ensures appropriate barrier design/operation.
Assists with permitting/ regulation – focuses on important requirements for public health.
Is transparent and can be externally audited.
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Selecting CCPs – Methodology to Control Hazards
Three Basic Questions: Is there a hazard at this step?
Can it be controlled by this step in the process train?
Is this step intended to eliminate or reduce the risk?
Not to be confused with Critical Operating Points (production focused)
Classic example: Bar Screen
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Establish Critical Limits: Pathogen Removal through Multiple Processes – MF-RO-UV/AOP-Chlorine
Increasing Risk
Co
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ntr
atio
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Treatment goal (e.g., < 10-4 Risk) Raw Water
Pathogen (e.g., Giardia at 105 /L)Post-MFPost-RO
Post-UV/AOP
Post-Cl2
Quantitative evaluation (Monte Carlo simulations) allows us to define critical limits to achieve water quality goals
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Is Operations Ready for DPR?
Can We Trust Operations?
Convincing a skeptical public Convincing regulators
“Eighty percent of the failures recorded were not due to failures of technology … but were due to human error”
Professor Don Bursill, the CEO of the Cooperative Research Centre for Water Quality and Treatment, Australia 2007 (The Age June 5, 2007)
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Operations – Striking the Right Balance
OPERATING RISK OPERATING COST
Chemicals and
Energy
Operator Effort
Asset Replacemen
t
Production
Quality
Public Health
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DPR Operations Management Plan
Risk Management CCP Operations Management
Operating Interfaces
Validation and Auditing
Operational Monitoring
Non Conformances Corrective/
Preventative Actions
Managing Incidents and Emergencies
Asset Management
and Maintenance
Operator Skills and Training
Risk Management Process
Operational Risk Assessment
Water Quality Risk Assessment
Critical Control Point Selection
Operating Procedures
Roles and Responsibilities
Critical Control Point Management
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Reuse Training and Certification Not Yet Well Covered
Reuse Training and Certification Not Yet Well Covered
Water Reuse
IPR
DPR
Wastewater Drinking
Water
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CCP provides a valuable means to focus evaluation, design, and operation of DPR facilities
HACCP can provide a means of validating specific processes and water quality goals
HACCP integrated into operations and response
Provides confidence to regulators that the proposed process scheme will provide public health protection
CCP provides a valuable means to focus evaluation, design, and operation of DPR facilities
HACCP can provide a means of validating specific processes and water quality goals
HACCP integrated into operations and response
Provides confidence to regulators that the proposed process scheme will provide public health protection
Key Message: Safety and Reliability in DPR with the HACCP Method
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Hazen and Sawyer – Troy Walker, Aaron Duke, Allison Reinert, Meric Selbes
WateReuse Research Foundation Project 13-03 and 13-13
University of New South Wales – Stuart Khan
University of Arizona – Shane Snyder & Ricardo Valerdi
Headstart Development, Pty Ltd – Cedric Robillot
SPI – Jim Vickers
Utility Partners: OCWD, WINGOC, West Basin, AWRCoE, Scottsdale, Other Anonymous Partners
Hazen and Sawyer – Troy Walker, Aaron Duke, Allison Reinert, Meric Selbes
WateReuse Research Foundation Project 13-03 and 13-13
University of New South Wales – Stuart Khan
University of Arizona – Shane Snyder & Ricardo Valerdi
Headstart Development, Pty Ltd – Cedric Robillot
SPI – Jim Vickers
Utility Partners: OCWD, WINGOC, West Basin, AWRCoE, Scottsdale, Other Anonymous Partners
Acknowledgements
