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Public Comment Invited for Water Recycling Criteria for Direct Potable Reuse

Client Alert

Public agencies have been invited to submit public comments to the State Water Resources Control Board on a draft report on direct potable reuse by October 25, 2016.

Direct Potable Reuse

Direct potable reuse is the planned introduction of recycled water either directly into a public water system or into a raw water supply immediately upstream of a water plant.  Unlike indirect potable reuse, direct potable reuse does not benefit from a meaningful environmental buffer between the discharge point of the recycled water and the extraction point. Without an environmental barrier, direct potable reuse is more dependent on engineered barriers to provide an equivalent level of public health protection. There are no regulations for direct potable reuse.

Feasibility of Developing Uniform Water Recycling Criteria

The State Water Board asked an expert panel and an advisory group to address the feasibility of developing uniform treatment water recycling criteria for direct potable reuse. The expert panel, with input from the advisory group, found it is feasible to adopt uniform criteria and that the criteria could provide public health protection equivalent to conventional water sources.

The expert panel identified reliability features that need to be provided. Those features include: 1) providing multiple, independent barriers; 2) ensuring the independent barriers represent a diverse set of processes; 3) benefits of using parallel independent treatment trains; 4) providing diversion of inadequately-treated water; 5) providing a final treatment step to “average” out any chemical peaks; 6) incorporating frequent monitoring of surrogate parameters at each step to ensure treatment processes are performing properly; and 7) developing and implementing rigorous response protocols, such as a formal Hazard Analysis Critical Control Point system.

The State Water Board plans to fill additional knowledge gaps with concurrent research on issues unique to direct potable reuse before completing the criteria.

Public Comment

Comments on the draft report may be sent to Commentletters@waterboards.ca.gov by noon on October 25, 2016.  A link to the report is below:

http://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/RecycledWater.shtml   

For further information, please contact your Aleshire & Wynder attorney or Christine Carson from Aleshire & Wynder, LLP’s Water Law Practice Group at (949) 223-1170.

Disclaimer:  Aleshire & Wynder, LLP legal alerts are not intended as legal advice.  Additional facts or future developments may affect subjects contained herein.  Please seek legal advice before acting or relying upon any information in this communication.