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Assessment of Approaches to Achieve Nationally Consistent Reclaimed Water Standards

Project: 08-01
Type: White Paper
Year Released: 2010

Program: Principal
Total Investment: $26,191.90 (Cash)

Principal Investigators: Margaret H. Nellor, P.E., Nellor Environmental Associates, Inc., and
Roberta Larson, Somach, Simmons & Dunn

Background

Water reuse practitioners around the world need and want a set of universal standards or criteria on which they can rely when designing a water reuse facility/project. There are currently no national standards in the U.S. Individual state regulations govern the design of various reuse facilities, although not all states have adopted standards. For states with standards, they do not necessarily cover all types of reuse applications. The level of stringency of state standards varies from state to state. California’s Title 22 regulations are typically viewed as the most stringent.

At international conferences, such as the October, 2007 water reuse conference in Antwerp, Belgium sponsored by the International Water Association (IWA), California’s Title 22 regulations are frequently referenced by presenters from around the world as the common standard for projects. The Environmental Protection Agency’s (EPA’s) Guidelines for Water Reuse is also cited. At the Antwerp conference, several speakers often erroneously referred to the EPA’s “Guidelines” document as if it had the force of law. As the name indicates, this document contains “guidelines” and bears little resemblance to a regulation, which is a legally enforceable standard. At this same IWA conference, a number of presenters also referred to the Green Buildings Council’s Gold Seal program, which contains a section dealing with water efficiency and use of wastewater for sustainable building supply and construction, but which has no direct links to recycled water regulation.

Goals and Objectives

The project assesses potential alternatives to achieve national consistency in the quality and safety of reclaimed water produced through reuse, including regulations/criteria, guidelines, industry “standards” or voluntary standards of practice, and other options. The objectives of the white paper are to identify and assess possible alternatives, their advantages and disadvantages, how they would be implemented, potential implementation obstacles, and stakeholder views on the alternatives.

Research Approach

The white paper does not attempt to develop regulations/guidelines, but is simply a feasibility study that presents recommendations on alternatives for further consideration by the water reuse community. The genesis for the project is the desire for the development of a consistent and accepted treatment and/or monitoring scheme that, if reliably applied, provides enhanced public confidence that a water reuse project is safe.

Findings and Conclusions

The feasibility assessment conducted for the white paper is limited to regulations/guidelines for non-potable irrigation uses (landscape and food), commercial uses (laundromats, car washes, dust control, etc.), and indirect potable reuse (groundwater recharge, seawater barriers, and reservoir augmentation). For irrigation projects and indirect potable reuse (IPR) projects, it is important to remember that under the current framework of state water quality standards, states have the obligation to protect all designated uses of groundwater, some of which may not be related to protection of public health, and thus may be obligated to apply additional requirements beyond those for water recycling.

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