Discussion of the Approach for Developing the Florida DPR Regulatory Guidance
Jeff Mosher
Developing the Florida DPR Regulatory Guidance Jeff Mosher Two - - PowerPoint PPT Presentation
Discussion of the Approach for Developing the Florida DPR Regulatory Guidance Jeff Mosher Two Items Florida Potable Reuse Regulatory Guidance Purpose and approach Guidance Document Sources of information Research
Discussion of the Approach for Developing the Florida DPR Regulatory Guidance
Jeff Mosher
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
in Florida
Overarching Goals
recommendations
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
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Identify initial topics Collect input at stakeholder workshops Develop a public review draft Guidance Doucment Finalize Guidance report for PRC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
stakeholder input and current state-of-science.
Scope and Outcomes
potable reuse
regulations”
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)
Proje ject Team
Julie Minton, Project Manager
Initiatives, WRF.
Water Reuse Issue Area.
DPR Research Initiative (2012-2016).
for WateReuse Foundation.
Manager on over 15 water reuse projects.
Jeff Mosher, Facilitator
for WRF.
National Water Research Institute.
for WateReuse Foundation.
expert panels for over 12 potable reuse projects in CA, AZ, TX, NV, WA, NM, and VA.
regulatory development in CA, AZ, NM, CO, and NV.
Gina Vartanian, Writer and Editor
for NWRI
Framework for DPR in Arizona” (2018)
“Potable Reuse Research Compilation: Synthesis of Findings” WRRF-15-01 (2016)
supported expert panels for over 12 potable reuse projects in CA, AZ, TX, NV, WA, NM, and VA.
Guidance Document
Proposed Organization
Water reuse in FL Nonpotable reuse Planned potable reuse Potable reuse
Terminology
studies
NRC Report 1998 NRC Report 2012 Risks from microbial and chemical constituents Etc.
Chapter summaries Recommended resources
Public health considerations Drinking water regulations
pathogens
Pathogen reduction criteria:
chemicals
Targets:
NDMA
Chapter 3: Potable Reuse Recommendations
Organized by Topic
sources of information
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DPR – Key Questions
Need for criteria for pathogen and chemical control
Performance monitoring
Defining reliability
Managing the collection system
Framework for DPR
WateReuse, AWWA, and WEF
Panel
www.nwri-usa.org/directpotable.htm
Texas projects
Resource Document (2015)
in 2014)
in 2018)
California (2016)
California regulations
1998 National Research Council Report (National Academy of Sciences)
“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
not necessarily post a significant risk
current supplies ( “risk exemplar”)
California Recycled Water Panel on CECs
(January 31, 2018 DRAFT Report)
framework
screening purposes
Analysis
World Health Organization Potable Reuse Guidance (2017) U.S. EPA Potable Reuse Compendium (2018)
Guidance Framework for DPR in Arizona (2018)
DPR in AZ
develop DPR regulations
involvement
Guidance Doucment – Topics for Discussion
1. General Topics 2. Technical Topics 3. Management Topics 4. Other Topics
Regulation Permit Guidance
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
The Water Cycle Gives Us Access to Water
1.1 DPR Background Information
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.
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
Types of Barriers
questionable or treatment performance is compromised
Important considerations for DPR
regulations in Florida
control pathogens and chemicals
permitting or guidance
(alternatives provision)
1.2 Build on current regulations in Florida
(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.
(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)
Standards (MCLs)
Standards
Full Treatment and Disinfection (62-610.563)
multiple barriers for control of organic compounds and pathogens.”
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
provide full treatment and disinfection”
1.3 Terminology
and/or permitting, which allows for flexibility
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)
Strongly Favor Somewhat Favor Somewhat Oppose Stongly Oppose Unsure 0% 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
48Public 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 Plan Provide 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
potable reuse projects.
Regulation Permit Guidance
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:
1.6 Blending
more than 50% of water to the water treatment plant
there is off-spec water
1.7 Multiple Barriers
multiple barriers for control of organic compounds and pathogens.”
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
2.1. 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
water)
drinking water)
Regulation Permit Guidance
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
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.
chemicals by keeping them out of the wastewater system.
Regulation Permit Guidance
2.3 Potable Reuse Water Quality and Human Health Risks
Microbial risk (mostly acute)
̶
Virus
̶
Protozoa
̶
Pathogenic Bacteria
Chemical risk (mostly chronic)
̶
Natural and synthetic compounds
̶
Regulated and Unregulated
Microbial and chemical risks exist with both conventional
drinking water and potable reuse sources but differ in degree
NDMA
2.3 Public health protection
What? 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:
Regulation Permit Guidance
Microbial control
wastewater be removed or inactivated.
protozoan parasites. Pathogenic microorganisms present significant acute risks to the consumer and are the most important design and
needed since it is not possible to measure directly.
Regulation Permit Guidance
Log Removal
inactivated by a treatment process
and 4-log removal for viruses.
Log Removal Targets
for the drinking water plant) starting from the raw wastewater (California):
study of the wastewater treatment plant that assigns conservative log reduction credits (Texas)
and drinking water facility based on regulatory review.
Regulation Permit Guidance
Log Removal Credits
(2/1/1)
(0/4/4)
(1.5/1.5/1.5)
(6/6/6)
(6/3/0)
Regulation Permit Guidance
DPR Log10-Reduction Values (WRRF 11-02)
Example Pathogen Log Reduction Credits (Tchobanoglous et al., 2015)
Process Monitoring Log Reduction Credits Notes V G C Secondary treatment Study needed 0 - 1.9 0 - 0.8 0 - 1.2 “0” is the default. MF or UF Daily PDT 4.0 4.0 Pressure decay test (PDT) should be done daily to verify proper performance. RO Online EC 1.5 1.5 1.5 Electrical conductivity (EC) should be monitored in RO influent and effluent. Log reduction in system control must be based upon measured values. UV-AOP Intensity sensors 6 6 6 UV sensors should be calibrated per U.S. EPA (2006). ESB with free chlorine, CL2, Online Cl2 6 3 System control is based on maintaining a minimum free residual of 0.4 mg/L. Total 13.5 14.5 11.5
Altamonte Springs FL – DPR Pilot
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
+ + + Ultrafiltration (UF) + 4-log 4-log Granular Activated Carbon (GAC)
6-log 6-log 6-log Engineered Storage with Chlorine 4-log 3-log
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
CECs, PPCPs, PFCs are Removed Through the Pilot
Chemical Control
Regulation Permit Guidance
unregulated chemicals. Chemicals are typically chronic (nitrate is a notable exception). Trace organics (e.g., CECs) are often discussed.
and water quality (verification monitoring).
Total Organic Carbon Concentration In Product Water Meets Florida IPR Regulations
Chemical Control
A tiered approach for chemical criteria based on the type of monitoring:
useful measures of the removal of health-significant organic chemicals
Regulation Permit Guidance
Chemical Control - Salinity
to maintain acceptable aesthetics and for recycled water quality. Individual constituents (chloride, bromide, etc) are also important.
Regulation Permit Guidance
processes.
treatment in potable reuse applications.
background information
2.4 Wastewater Treatment
5 Steps in the Wastewater Treatment Process
Wastewater treatment
treatment train. As a result, enhancements should be considered.
Regulation Permit Guidance
Wastewater optimization
Possible measures to improve performance and enhance reliability:
produce an effluent of consistent quality.
Regulation Permit Guidance
2.5 Advanced water treatment (AWT)
produce a drinking water source of supply.
scrutiny.
treatment).
Regulation Permit Guidance
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
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
reduction or measure specific criteria.
Regulation Permit Guidance
2.7 Long-term monitoring
protection of public health.
Regulation Permit Guidance
Performance Monitoring: Example Online and Calibration Sampling
(Tchobanoglous et al., 2015)
Process Test Type and Frequency of Sampling Secondary effluent Turbidity and microbial indicators Turbidity: online (continuous) and grab (weekly); microbial: grab (weekly) Ammonia, TSS, and BOD Grab (weekly) MF or UF PDT Offline testing (daily) Turbidity Online (continuous) and grab (weekly) RO Influent and effluent EC and TOC Online (continuous) and grab (weekly) UV-AOP UV sensors Online (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/Antiscalant Chloramine Microfiltration Reverse Osmosis Microorganisms Microorganisms & Chemicals of Concern Microorganisms Microorganisms & Chemicals of Concern Lead/copper leaching in distribution systemCritical 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
is designed to reduce, prevent, or eliminate a human health risk and for which controls exist to ensure the proper performance of that process.
through performance-based monitoring (augment end-of-pipe monitoring)
Regulation Permit Guidance
Human Cell Line Bioassays
like chemicals
field
chemical class
chemicals
benchmarking
Bioassays Indicate Bioactivity of Hormones/Chemicals is Eliminated Through the Pilot Processes
Estrogen like chemicals
RO concentrate is a major consideration.
available, though cost is a factor
2.8 RO Concentrate
2.9 Facility Operation
consistently and reliably.
Regulation Permit Guidance
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 maintenance
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
treatment requirements (e.g., pathogen credits)
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
utility to provide safe and dependable water (required by SDWA)
to provide safe and reliable advanced treated water.
Regulation Permit Guidance
for the regulators for:
monitoring data
treatments?
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 ManagementCertification Programs: Most existing certifications are generalist and may not be representative of what is needed to perform a specific task related to potable reuse
supplement to existing frameworks
Operator Training: Materials currently being developed (Reuse-15-05)
Potable Reuse Operations Management Plan (Reuse-13-13)
approach to any DPR requirements in the regulations
3.5 Alternavites Provision
Review topics on emerging concepts that may need to be addressed during the framework development.
contaminants
provides more time to respond to treatment upsets
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, & CalibrationWhat is the Ideal Sensor? (Reuse-11-01)
Resilience: The ability of a treatment train to successfully adapt to failure
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)
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!