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Wednesday, August 11, 2021

Coming Down the Pipe: Direct Potable Reuse Rule Stakeholder Process

The stakeholder process is underway!

Resources:

On March 16, 2021 we ran an Aqua Talk article announcing our stakeholder process for Direct Potable Reuse (DPR). We are providing a brief update here with highlights of the project so far.

Since the previous article, we have accomplished the following key activities:

  • Hosted two kickoff stakeholder meetings, 
  • Formed workgroups to focus on key areas of the regulations:
    • Communications and outreach
    • Source water nexus - including pretreatment and wastewater treatment
    • Advanced drinking water treatment
    • Operations
    • Regulatory development
  • The workgroups met numerous times and produced several key decisions and draft materials
  • A midsummer update stakeholder meeting was held on July 14, 2021.

The stakeholder community has agreed generally about the definition of DPR. The definition will be important both for determining the applicability of the regulation and also establishing a new drinking water ‘source’ type. The definitions below reflect the current status of the stakeholder efforts and could change somewhat going forward.
  • “DIRECT POTABLE REUSE” means using a series of processes that produce finished water utilizing a source containing treated wastewater that has not passed through an environmental buffer.
  • “ENVIRONMENTAL BUFFER” means either a surface water or a groundwater aquifer that causes adequate dilution or natural attenuation of pathogenic and chemical contaminants. Treated wastewater from a permitted (e.g. Colorado Discharge Permit System) wastewater treatment plant that has been discharged to a surface water body is considered to have passed through an environmental buffer. 
  • “TREATED WASTEWATER” means any water source that originates at a wastewater treatment plant that has undergone biological nutrient removal that has reduced total nitrogen in wastewater. Treated wastewater is not required to pass through a disinfection step at the wastewater treatment plant.

The workgroups are on schedule and making progress with regulatory language, technical content, and additional policy concepts. Workgroups have agreed to the following requirements: 
  • Applies to drinking water utilities - as all drinking water regulations apply to drinking water utilities
  • Require advanced public outreach from the utility to the public about the intent to utilize DPR for drinking water.
  • Require the utility to ensure the wastewater collection system has proper controls in place to reduce the risk of contamination being introduced that will threaten public health or hinder the treatment process.
  • Require nitrification/denitrification at the wastewater treatment facility before water is sent to the advanced drinking water treatment process. 
  • Require a significantly higher level of treatment than treatment of lakes, streams, or reservoirs including:
    • Additional pathogen barrier(s)
    • Chemical treatment barriers - including treatment for trace pollutants and contaminants of emerging concern present in treated wastewater
    • Additional monitoring and reporting
  • Require operations plan to address overall process monitoring and plan for addressing wasting water that is off-specification.