1. Water JAM 2010 Managing Risks in Water Reuse: Intersection of Policy and Science Mary E. Sadler, PE Benjamin Stanford, PhD WaterJAM® 2015 Virginia Beach, VA September 14-17

2. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction Water Reuse

3. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction Potable Reuse Is Happening in the U.S. and Abroad

4. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

5. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction 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

6. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction Urban Use Wastewater Treatment Advanced Treatment 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

7. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction Engineered Storage Urban Use Wastewater Treatment Advanced Treatment 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

8. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction

9. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

10. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

11. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

12. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

13. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

14. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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)

15. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

16. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction State IPR Regulated DPR Regulated Reuse Regulation Reuse GuidanceTreatmentStorage GeorgiaXPX UtahXX ArizonaXXX CaliforniaXPXXX OklahomaXP MassachusettsXX WashingtonXXX VirginiaXXX North CarolinaXX (legislation) X PennsylvaniaXXX New MexicoPPXX FloridaXX TexasXX P = Pending

17. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction Operations, Training, & Certification 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

18. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction 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 PublicConvincing Regulators TOOLS:

19. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

20. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction 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 1 2 3 4 5 6 7

21. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction 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

22. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction 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 Contaminants/ Hazardous Events Treatment Barriers Monitoring Operating Response Focus is on health relevant contaminants

23. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction 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.

24. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction 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

25. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction Establish Critical Limits: Pathogen Removal through Multiple Processes – MF-RO-UV/AOP-Chlorine Increasing Risk  Concentration Treatment goal (e.g., < 10 -4 Risk) Raw Water Pathogen (e.g., Giardia at 10 5 /L) Post-MF Post-RO Post- UV/AOP Post- Cl 2 Quantitative evaluation (Monte Carlo simulations) allows us to define critical limits to achieve water quality goals

26. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction 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)

27. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction Operations – Striking the Right Balance OPERATING RISK OPERATING COST Chemicals and Energy Operator Effort Asset Replacement Production Quality Public Health

28. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction 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

29. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction Reuse Training and Certification Not Yet Well Covered Water Reuse IPR DPR Wastewater Drinking Water

30. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

31. Water JAM 2010 NC AWWA WEA 2011 Risk Assessment Summary Operation And Response State Regulatory Approaches Introduction  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

32. Water JAM 2010Water JAM 2011 Questions? msadler@hazenandsawyer.com bstanford@hazenandsawyer.com