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HomeMy WebLinkAboutWRRF Response to June 12, 2014 Expert Panel Report California Direct Potable Reuse Initiative Response to June 12, 2014 Expert Panel Report July 21 , 2014 1 WRRF is grateful for the CDPH Expert Panel Final Report dated June 12, 2014 responding to the March 5 conference call where the WRRF presented on our DPR research portfolio. WRRF appreciates the comments and input on our existing research and identificatio n of added research opportunities. The purpose of this document is to respond to the Comments Section (3), outlining where WRRF existing research will support Expert Panel comments and where added research opportunities may lie. WRRF will assemble our Res earch Advisory Committee (RAC) on September 6, 2014 to expand our 2014 DPR program in response to th is June 12 Expert Panel report. 3. C OMMENTS ______________________________________________________________________________ 3.1 General Comments • The Panel w ould like to receive copies of reports completed by WRRF on DPR -related topics (PDF files are preferred, when possible ). We will provide this on our dropbox page: Click here to view DPR Folder . Currently the following final reports are available: o Utilization of HACCP Approach for Evaluating Integrity of Treatment Barriers for Reuse (WRRF -09 -03) o Demonstrating the Benefits of Engineered Direct versus Unintended Indirect Potable Reuse System s (WRRF -11 -05) o Evaluation of Risk Reduction Principles for Direct Potable Reuse (WRRF -11 -10) • The Panel would also like t o receive a copy of Policy M emorandum 97 -005 on “extremely impaired water s ourc es ” (as mentioned by Bob Hultquist of CDPH ). • The Panel encourages the development of a web site to provide the Panel with useful presentations and deliverables. o Currently the Foundation shares material through dropbox : Click here to view DPR Folder • The Panel noted that the formal reports from new ly awarded and future research project s may not be available in time to be use ful toward the Panel review process ; yet, in many cases, significant work may be completed or underway. T he Panel is inte rested in finding an effective way to include an up -to -date understanding of this ongoing research in its deliberations. The P anel discussed receiving periodic updates, e arly materials , or presentations at future Panel meetings. o We will provide quarterly updates on our DPR projects, providing a paragraph update on each. Quarterly progress reports and other important documents (scope of work, presentations, workshop summaries, etc) are located on dropbox if more information is desired. If there ar e specific questions, please direct them to Julie Minton. Also we’d like to have an opportunity for our PIs to present at Expert Panel meetings to provide more information on their WRRF project. 2 • The Panel would like to receive information regarding out -of -spec behavior reported for IPR projects and drinking water treatment plants throughout the State. The Panel is particularly interested in incidences of compromise in the removal of pathogens, including the process used to discover breakthrough (if any). Such information could be provided in the form of a summary or in the form of case studies that include information like the process train used, type of incident or compound, response and response time, information provided to the public, public reaction, overall costs, and other relevant factors (such as risk factors, detection methods, potential surrogates, response measures, public outreach, and so on ). Where IPR p rojects are specifically concerned, an example might be the Orange County Water District’s response to the occurrence of N - Nitrosodimethylamine (NDMA), 1,4 -dioxane , tritium , and acetone. o WRRF -13 -03 and 13 -13 are not surveying out of spec results, but rather investigating the operational response and developing robust procedures to manage it. o WRRF -12 -06 is looking at statistical variation in water qua lity from IPR facilities; findings will be shared once they come. • The Panel notes that p eer -review ed publications have greater credibility than industry research reports and encourages WRRF and its p rincipal i nvestigators (PIs) to consider producing peer -reviewed publications . o We have encouraged our PIs to submit peer -reviewed publications. 3.2 CDPH Mandate and Panel Process • The Panel would like clarification of certain terms, which appear to b e key elements of the State’s mandate, including : “adequately protect ive of public health ,” “feasibility ,” “acceptable risk,” and “DPR.” T he Panel would like to address these issues in detail at the next meeting , and would appreciate a presentation from CDPH discussing their perspective . o WRRF would be happy to support this effort. • Regarding surface water augmentation criteria, the Occoquan Reservoir Project operated by UOSA in Virginia and the Lake Lanier Project operated by the F. W ayne Hill Water Resources Center near Atlanta , Georgia, are other projects of interest. Information on the status of DPR projects elsewhere, particularly Windhoek, Namibia, and Big Spring , Texas , would also be useful to the Panel . The Pa nel would like to hear a presentation addressing th ese projects . o A project has been added to our DPR portfolio, ‘Enhanced Pathogen and Pollutant Monitoring of the Colorado River Municipal Water District Raw Water Production Facility at Big Spring Texas ’ (WRRF -14 -10), led by Eva Steinle - Darling at Carollo. We can arrange a pres entation on this work as early as September when the first round of testing is complete (WebEx or in Dallas at WRA Symposium?). • As the Panel understand s it, the purpose of the Advisory Committee is to provide insight and support to the Panel. To facilitate productive interaction , the Panel recommends that 3 a liaison from the Advisory Committee, such as the Committee Chair, be invited to attend the public portions of future Panel meetings. A direct dialogue between the Panel an d the Advisory Committee may also prove useful in the future . 3.3 Comments about the Research Plan The Panel would like to commend WRRF and WateReuse California for their efforts with the DPR Initiative. Overall, the research plan is comprehensive and thorough , especially in regards to addressing r eg ulatory and utility concerns about DPR . The results of these research projects are highly anticipated. 3.3.1 General • T he feasibility of DPR depends, in part , on how it fits with other alternatives to expand the S tate’s water resources through recycling of municipal wastewater effluent s . o WRRF -14 -03 • It is not clear to everyone that DPR must be pursued to meet the S tate’s water resource needs. The Panel requests a review of the data that provide the basis for a water resource economic case of DPR for the State of California. o WRRF -14 -08 • Doing away with the environmental buffer in potable reuse projects may represent a significant change . River flow and movement through the ground are both effective in removing many contaminants from water . o WRRF -12 -06 • Reaction times and processes involved in the environment may be quite different from those in conventional treatment processes . Environmental buffers do not just create a barrier, but they can also be an effective treatment process for some contaminants . This issue needs consideration when evaluating the feasibility of DPR. o WRRF -12 -06 • A comparison of the long -term impacts on water resources is needed between a few large IPR plants that redirect water back into the overall California raw water supply versus a smaller number of DPR plants built across the s tate . o A challenging endeavor - t o be considered post implementation of DPR plants. 3.3.2 Research on P athogens In potable reuse projects, as wastewater sources and finished drinking water become close r together (in either time or space ), the concern about protec tion from momentary lapses in pathogen control becomes increasingly important . • The Panel suggests that the following questions about pathogen control, as provided by CDPH, become the subject of a future study: 4 o Is the available monitoring (including perhaps of surrogates) sensitive and rapid enough to tell us when the organism reduction goal is not being met?  WRRF -11 -01, 14 -01 , 12 -06 o How do we quantify the overall reliability of the treatment scheme?  WRRF -11 -01, 11 -02 , 12 -06 , 13 -03, WRF 450 8 o How consistently must the treatment meet the organism log -reduction goal?  WRRF -14 -02 o Multiple redundant barri ers minimize the chance of a complete failure of treatment. How do we determine the necessary number and capability of the redundant barriers?  WRRF -13 -03 o Are there Critical Control Points for key pathogens that can be identified and monitored?  WRRF -13 -03 • Information on pathogen levels in raw wastewater is limited. I ndustry surveys should be conducted using peer -reviewed methods and techniques to characterize the pathogen levels in raw sewage, in different populations, throughout the seasons , and during local episodes of illness. New technology that provides high throughput, multiple pathogen identification, detection of emerging pathogens , an d/or better quantification may be valuable in achieving this objective . o WRRF -14 -02 o Explore alternative to current CA model of credits starting at raw water (Texas approach is documented in WRRF -12 -06) o University of Arizona has extensive data on pathogens in raw sewage (influent) and after treatment (affluent), including viruses. Current studies are evaluating treatment efficacy at a new 21 st Century WWTP (Agua Nueva – commissioned in January 2013) (per Ian Pepper) • Research needs to be conducted to document and quantify the removal of pathogens in different biological wastewater treatment processes. In the absence of that research, many advanced water treatment plants will likely be buil t with more treatment than is needed to establish removal credi ts. o WRRF -14 -02 • A better understanding of the microbial com munity that exists in advanced treated water is needed, and how a stable microbiological community can be maintained throughout the distribution system when DPR is employed. It is important to ens ure that new ecological niches are not being created for the proliferation of opportunistic pathogens. Emerging methods for measuring, monitoring, and managing the microbial community during storage and distribution of recycled water should be evaluated. o WRF Project 4536 (Blending project) is exploring post treatment microbiological issues, including corrosion, antibiotic resistance, and opportunistic pathogen work o University of Arizona is planning to do next generation sequencing on sewage as it is treated (per Ian Pepper) 5 3.3.3 Research to Address Regulatory Concerns O ther key difference s between IPR and DP R are the consequences of process failures. Therefore , both failure analysis and reliability analysis will be important. • There is a need to define and describe the concept of “safe .” The wor d “safe ” has different meaning s to members of the community than it does to engineers who design facilities. Regulators often end up in the middle, making judgments about what is safe. The P anel sees the potential for a research project on better defining, communicating , and describin g the concept of “safe .” Will an annual risk of infection of 10 -4 for potable water (for example , for pathogens ) be the goal or are more safety factors necessary? o WRRF -11 -02 placed much effort into defining the treatment necessary to protect public health. “Safe” might be better replaced with “protective of public health”. o “The Panel sees the potential for a research project on better defining, communicating, and describ ing the concept of “safe.” – communication to public: WRRF -13 -02 o WRF 4508 • R egardless of how effective, reliable, robust, redundant , and resilient the system is , we should be prepared for circumstances where it fails. Certainly , every precaution should be take n to prevent failure, but work is needed on what should be done in light of failure when it does occur (e.g., h ow to identify it, how will we respond to it , and how it will be communicated ?). Simply put, t his consideration needs to be more explicitly addressed in the research. o WRRF -11 -10 o Communication: WRRF -13 -02 Phase II - In the recommendations for Phase II of WRRF 13 -02 the team has recommended a state level Rapid Response Plan that addresses what happens if there is a technical failure, or reporte d illness and what would be the communications process for informing media and the public. o WRRF -13 -03 and 13 -13 • The concept of “resilience ” has not been formally developed in potable reuse . Indications are this will be addressed by additional redundancy (e.g., log removals) in the treatment system to mitigate the effects of system failures. A rational basis is needed for determining how much redundancy is required , or systems will be predictably over - engineered with attendant costs in terms of redundant or substitute unit processes and space within a treatment plant to accommodate redundant systems. Therefore, a methodology based upon experience with the failure of unit processes in potable reuse syst em needs to be developed. T here is a wealth of exper ience with the unit processes used in IPR (which are, for the most part, identical with those anticipated for use in DPR). If sufficient data are available from this experience, it should be straightforward to collect the data and develop a generic model (i.e., one that can be adapted to any given treatment train) for use in assessing the actual need for redundant treatment systems to maintain the accepted risk reduction goals through failures of different extents, durations, and severity. If the data are not available, it can be generated. Although likely more important for microbial agents, such a model should be useful for defining the flexibility 6 of treatment processes to remove specific compounds of proven health concern. In both cases, it should be possible to determine the response time for bringing redundant treatment online in the case of failures. Some problems will be small enough to address by taking the malfunctioning component offline, while others may require shutting down a significant fr action of unit processes required for a particular treatment. Whatever the degree of treatment failure that entails should include documentation of critical questions relating to the degree of impairment and variation in time required to make appropriate repairs, as well as the extent to which key components of established health concern in a particular water source are not being removed. This will allow a clear documentation of the extent to which public health protection may be diminished during failure s in the treatment process that are inevitable. The impacts on risk are likely to be minimal for documentable health risks, and are unlikely to be remedied by arbitrarily increasing the assignment of additional logs of removal to a treatment train. o We re cognize the importance of this work, and much of our existing research will touch on this (WRRF -11 -02, 11 -10, 12 -06, 13 -09 Indirect Potable Reuse Investigation in Tucson, AZ , 14 -03 and 14 -08 cost analysis) o The Australian W ater R ecycling C entre of E xcellent (AWRCoE) is working on a resilience model of IPR/reuse plants which would be valuable information also. The WRRF -13 -03 team is worki ng to bring this into that project . o WRRF -14 -12 (San Diego demo) will illustrate full concept of resilience o Exploratory proj ect : Additional research may be needed and several opportunities are broached here to be explored at RAC meeting in September.  Evaluate different components of train and independence of unit processes – what happens when one fails? Are they truly independe nt and is process resilient? • A key component of defining the “consistency of treatment” is to understand the variability that occurs within each unit process in a treatment train and incorporate this variability into a quality assurance analysis. The WRR F 13 -03 Project on “Critical Control Point Assessment to Quantify Robustness and Reliability of Multiple Treatment Barriers of DPR Scheme” is expected to compile data from actual facilities on the variability of an entire treatment train. The Panel would like to receive more information about this new project, including the experimental plan. o WRRF -13 -03 - dropbox includes scope of work and PRs. The team would be happy to present project plan via a WebEx or at next meeting. o WRF 4508 • At present, as an industry, we do not understand what makes a barrier redundant or indepen dent. It is a research need. Full -scale monitoring should assess what makes it redundant for contaminants of interest. o This fits with Exploratory project above. o WRRF -11 -02, 14 -12 (San Diego demo) • What treatment trains are co nsidered equivalent to full advanced treatment (FAT)? It i s un clear to the Panel if other treatment trains are being considered by CDPH or if FAT is 7 the gold standard. Also, what type s of scale should these sc hemes have (e.g., oversight, financial, etc.)? o Two trains in WRRF -11 -02, 13 -03 • The Panel suggests examining the experiences of the food industry . o WRRF -11 -10 examines other industry (structural and aviation), WRRF -13 -03 HA C CP concept originated in food industry • A more thorough evaluation may be warranted of the experience s of other DPR schemes (like Windhoek ) and their response strategies. It may be useful to expand this effort to include s urface w ater treatment plants using source water that receive a significant a mount of wastewater discharge . o WRRF -14 -10 3.3.4 Research to Address Utility Concerns • A more comprehensive economic analysis of potable reuse is needed. This analysis should consider factors such as the drought -proof nature of potable re use and benefits of a diversified water supply portfolio . Research may exist to help assess when DPR projects should be selected over traditional water supply projects . o WRRF -14 -03 , 14 -08 • The Panel anticipates that i ssues pertaining to energy, such as costs, conservation, and recovery, may be adequately addressed in the upcoming WRRF 14 -03 project titled “Developing Method ology of Comprehensive (Fiscal/Triple Bottom L ine) Analysis of Alternative Water Supply Projects Compared to DPR.” Keeping the Panel updated on the progress of this project will be helpful. o WRRF -14 -03 • The Panel would like to see more information regarding requirements and the need for providing blending for DPR and surface water augmentation projects that might differ from CDPH’s grou ndwater recharge draft regulations (i.e., source water used for blending, location of blending, accounting [the recycled water contribution concept averaged over several years ]). o WRF4536 • The Panel would like more information regarding the potential of non ‐reverse osmosis (RO) treatment options being suggested to eliminate the need for brine disposal. RO removes a significant number of contaminants from water. Would DPR without RO eliminate a n important barrier? o WRRF -11 -01 , WRRF -13 -10 Controlling Trace Organic Contaminants using Alternative, Non -FAT Technology for Indirect Potable Water Reuse 8 3.3.5 Research to Address Community Concerns The Panel would like to provide the following suggestions to broaden the “Community Concerns” portion of the DPR re search effort , increase transparency, and address information gaps: • W e need to consider how other industries (like air travel , food processing , and nuclear power) have addressed questions about safety and confidence with the public . What systems have the se industries created to ensure quality ? Can we modify or apply them to DPR ? o This is an excellent idea but beyond the current scope of WRRF -13 -02; this will be explored further. • I t will be important to discuss openly with the public other water supply options that may be available besides DPR (e.g., IPR, desalination, tradeoffs with agricultura l , etc.). o WRRF -13 -02 • Selecting straightforward , transparent terminology to describe the DPR process is a step in the right direction . However, a more comprehensi ve plan is needed to address the concerns of opponents and community members who feel alienated ; terminology alone will not be enough to lessen their fears . o WRRF -12 -06, o WRRF -13 -02 explored thi s further in focus grou ps and telephone surveys in two model CA communities (SD & SCVWD). The results and findings and key messages will be in the final report later this year. • T he composition, disposal, and environmental impacts of RO reject probably warrant furth er consideration as well. o Seawater desal and DPR have some of the s ame challenges . o WRRF -13 -10 Controlling Trace Organic Contaminants using Alternative, Non -FAT Technology for Indirect Potable Water Reuse for no -RO schemes • Some speak as if treated d rinking w ater is sterile , whereas in reality , it contains varying concentrations of microorganisms , most of which are believed to be benign . This misperception will need to be addressed when commu nicating the safety of DPR projects to the public and stakeholders. The concept of the “water microbiome ” may provide a means of underst anding and communicat ing this idea o W RF 4536 • Clarification is needed as to how the products of th e research to address community concerns will be used and by whom. For instance, will a rapid response team be necessary for DP R projects ? In recent times, we have seen the emergence of pathogens and chemicals (e.g., Giardia, Cryptosporidium, Legionella, HIV, prions, emerging disinfection byproducts , etc.) that have been of concern to health professionals and the community. Some of these have been serious problems , while others have posed little, if any, risk to water supplies. Consideration should be given to developing a mechanism for addressing process treatment failures, community outbreaks of illness, newly 9 identified chemi cal contaminants and pathogens , and social issues in a timely manner. Developing this mechanism might require maintaining a list of on -call experts in a variety of fields , as well as deciding which agency or group should be responsible for coordinating th e rapid response team. o WRRF -13 -02 Phase II includes description and funding for developing a Rapid Response Plan that addresses what happens if there is a technical failure, or reported illness and what would be the communications process for informing med ia and the public . 3.3.6 Health Research M ore effort should be devoted to health research. Suggestions include: • A first priority should be the design of study(s) to assess changes in infectious disease rates when DPR is initiated . An approach has been suggested by other NWRI P anels for various IPR projects. Generally, such studi es should be set up with county or state health departments in areas where activities may be ongoing. Ongoing standard surveillance activities should be leveraged to esta blish baseline rates of illness (e.g., hospital visitations, emergency room visits, school absenteeism , and calls to nurse hotlines). The DPR system should not be the sole focus of investigation, but rather tied in with a broader surveillance of disease o utbreaks in the area. It should also be integrated into these projects as one of the variables examined. A pilot project should be funded that investigates the feasibility of such an effort with the appropriate public health authorities in areas where DP R is likely to be initiated. It is important that actual studies be initiated prior to the introduction of DPR. o We agree this work is important and would be open to discuss how we can support this work. • Efforts on diseases that might result from chemic al exposure are also possible, but would require much more work in designing an approach. The k ey to how such studies can be conducted is t he select ion of appropriate health endpoints. This may mean some divergence from studying classical health endpoint s, but focusing on biomarkers that are dependable indicators of increased risk for such endpoints o WRRF -10 -07 • Public health surveillance is a key component of any IPR or DPR project and should be adequately addressed. During the Ci ty of San Diego Health Effects Study (c.1992 ), a baseline was developed on pertinent morbidity and mortality data so that a basis of comparison would be available to the City if potable reuse became a reality. The Panel can be provide d relevant historical background work from S an Diego , if needed . A lso, taste and odor complaints should be tracked, monitored, and evaluated. o We agree this work is important and would be open to discuss how we can support this work. 10 3.3.7 Chemicals of Emerging Concern (CECs) WRRF and WRF have do ne extensive research in CEC in reuse and drinking water, and we can share that work if desired. • It appears that several of the proposed DPR Initiative projects imply that additional bio - analytical screening assays are needed for CECs. The DPR Initiative team should dialogue with staff from both the Southern California Coastal Water Research Project (SCCWRP) and San Francisco Estuary Institute (SFEI) regarding ongoing research in California involving the use of such assays for certain CECs. In addition, other organiz ations and agencies, such as the State Water Resources Control Board, are involved with research projects to evaluate bio -analytical tools. These outside efforts should be incorporated into the Panel’s review process and DPR Initiative (for instance, incl ude a presentation on the results of these projects at a future Panel meeting). o WRRF -10 -07 (included 2 collaborative workshops with SCCWRP on their similar project) o WRF 4508 will recommend appropriate analytical methods and testing for CEC’s as part of a DPR monitoring framework • The Panel encourages the DPR Initiative team to read the brief review on antibiotics and antibiotic resistance in the April 2012 SCCWRP report on Monitoring Strategy for Chemicals of Emerging Concern (CECs) in California Aquatic Ecosystems: Recommendations of a Science Advisory Panel (see Section 4.3 and Appendix F of the report, which can be found on the SCCWRP website 1 ). o We are supporting WERF lead project: Occurrence, Proliferation and Persistence of Antibiotics and Antibiotic Resistance during Wastewater Treatment o WRF 4536 will include testing for antibiotic resistance 3.3.8 Hazard A nalysis and Critical Control P oints (HACCP ) The Hazard Analysis and Critical Control Points (HACCP) framework deserves consideration . As follow up: • The Panel would like to receive more information about the ongoing WRRF 13 -03 Project on “Critical Control Point Assessment to Quantify Robustness and Reliability of Multiple Treatment Barriers of DPR Scheme.” It is understood that the project is in the early stages and the first progress report is pending. In the meantime, the Panel would find it helpful to receive the experimental plan for WRRF 13 -03. o WRRF -13 -03 • Th ough some Panel members have concerns about validation and calibration, the Panel is also interested in the workshop results for the WateReuse -10 -07 Project on “Bio - A nalytical Techniques to Assess the Potential Human Health Impacts of Reclaimed Water .” o WRRF -10 -07 1 http://www.sccwrp.org/ResearchAreas/Contaminants/ContaminantsOfEmergingConcern/EcosystemsAdvisoryPane l.aspx 11 3.3.9 Application of Research The Panel would like to learn more about the plan to transition the results from research to application. How will operators make the tools work? W ill the tools be practical? Will the test results provide usable information (quality of information) that is a reliable guide to whether treatment needs to be improved (if possible) or water wasted ? Can the results be interpreted or explained to the public ? o We are aware of this need and how critical it is to implement the results. Where appropriate, teams d evelop non -traditional deliverables such as tools, guidelines, outreach materials, etc . to foster dissemination and usability. This will be a work in progress, and we encourage recommendations/collaboration to ensure success. 1.4 Panel’s Response to Research Plan Questions 1. Does the Research Plan appropriately define the needed DPR research? The Panel believes that t he DPR Research Plan is comprehensive and thorough, especially in regards to addressing regulatory and utility concerns about DPR. The results of the research projects will assist in providing regulators and utilities with the information they may need as they consider implementing DPR . The comments provided in this Panel Report are intended to help strengthen the Research Plan. 2. Is the framew ork presented in the Plan appropriate (i.e., regulatory, utility, and community concerns)? The Panel believes that the framework summarized in the DPR Research Plan for addressing regulatory, utility, and community concerns is suitable for the intended purpose. The Panel provided additional comments in this Panel Report on areas in the Research Plan that may need to be strengthened , such as focusing on health research . 3. Can the Panel identify any substantial gaps in the research framework, including the current research and proposed future research? In the time allotted for the current review, the Panel was un able to conduct a comprehensive analysis of gaps in the propo sed research framework or list of current and future projects. The comments above provide a preliminary assessment of gaps and suggestions for additional research. The Panel suggests that the status of current research efforts be reviewed at Panel meetin gs with research organizations to maintain a dialogue on current and future research efforts. 4. Does the Panel have other comments for W RRF and WateReuse California as it implements the Plan? In addition to the comments provided in this Panel report, t he Panel woul d like to learn more about the p lan to transition the results from research to application. How will 12 utilities make use of the results and tools? The interpretation indicators and surrogates (either as water parameters or as indicators of heal th risk) must be specified, justified, and validated. Prioritization is also of interest. What should be done first? Why? And h ow? Pilot and field studies are an essential component of translational science for the water industry , and that type of fol low up might be needed. Work in progress – conversation to be continued. 5. How would the Panel like to be updated in the future on the status of the research efforts? The Panel would benefit from update s on current or upcoming research efforts, including early materials (as discussed in Section 3.1 of this report). Perhaps there could be a briefing or summary of the conference call meetings held between WRRF and its project PIs for the DPR Initiative. P resentation and important project material will be in dropbox .