On Wednesday the AB 547 Direct Potable Reuse (DPR) Expert Panel met to provide their recommendations on the draft DPR regulations released in August 2021 by the Division of Drinking Water (DDW) at the California State Water Resources Control Board. Below are some of the major recommendations from the Panel. - The Panel recommends that ozone and biological activated carbon (BAC) processes operate before the reverse osmosis (RO) process to manage low molecular weight (LMW) compounds.
- Alternative treatment trains should be approved through the Alternative Clause contained in the regulations.
- While the Panel agrees with DDW’s intent to keep the criteria broad enough to cover all forms of DPR, the Panel still believes that clearly defining Raw Water Augmentation in the criteria (or Statement of Reasons) is appropriate and necessary.
- The Panel recommends all notifications to the public and public agencies need to be consistent with those currently required as part of the California potable water regulations and the Safe Drinking Water Act, and references to existing potable water notification regulations should be included in the DPR criteria.
- The Panel recommends inclusion of a criterion that requires 24/7 operation for 12 months before considering a request for reducing the number of operators and/or unstaffed operations.
In response to these new recommendations, WRCA commented that agencies support the current draft regulations which provide more flexibility for the placement of ozone/BAC within the treatment train – as long as the project proponent can demonstrate the process is protective of public health. Currently there are no other processes that can manage the LMW compounds, but agencies and the industry will be conducting research to address this issue. While we appreciate the inclusion of the Alternative Clause in the regulations, allowing flexibility within the main body of the regulations will more easily allow the regulations to reflect changing technology and science of potable reuse. WRCA will be preparing a comment letter this and other recommendations from the Panel. The next Expert Panel meeting will be held February 28th. |