Reclaimed Water Rulemaking - Formal Comment Period August 23 - October 13, 2017

26 results

 Submitted By:  

Comment from: Sammamish Plateau Water (John C.Krauss)
10/23/17 12:00 AM   |  
 
 
Comment from: IDEXX Water (PatsyRoot)
10/17/17 11:21 AM   |  
 
 
Comment from: David Batts
10/14/17 12:16 AM   |  
 
 
Comment from: Andrew Austreng
The rule's intent to authorize recovery of reclaimed water stored in a geologic reservoir (i.e., through aquifer storage and recovery [ASR]) is unclear. If the intent of the rule is to permit only the recovery of recharged water molecules (e.g., through chemical fingerprinting and "breakthrough curves"), most ASR projects that would incorporate reclaimed source water will be rendered economically nonviable due to simple commingling of recharged water and native groundwater. Further, using water quality to determine recoverable quantities would not allow recharge and recovery to occur at separate locations. Provisions for recoverable quantities should be based on water budget impacts and on impairment to existing rights, as is the case for other water rights permitting decisions. The draft rule should explicitly require that the water budget impact of a proposed project be evaluated from water levels and hydrogeologic modeling when the storage duration (recovery period) is determined, as described in sections 173-219-210(2)(v) and 173-219-270(7) of the draft rule. Water quality impacts should not be a consideration for determining recoverable quantities, since criteria are established in Chapters 172-200 and 172-219 WAC to preserve groundwater quality for the highest beneficial use, which apply regardless of whether any recharged water is ever recovered. The Purple Book should be modified to clarify that the recoverable quantity will be based on analysis of water budget impacts. The draft language in Section 12.3 of the Purple Book currently states "Recovery of reclaimed water stored in an aquifer (aquifer recovery) is exactly that, recovery of the reclaimed water that has been stored in an aquifer". As written, this statement is ambiguous and could apply to either a recharged volume of water, or on a chemical fingerprint of recharged water. If the Department adopts the position that chemical fingerprinting (e.g., "breakthrough curves") will determine recoverable quantities, few ASR projects will ever come to fruition using reclaimed water.
10/13/17 11:59 PM   |  
 
 
Comment from: Gray and Osborne (Jay Swift)
1. In previously submitted comments, Gray and Osborne recommended that under WAC-173-219-340 Disinfection Process Standards, Section (1a) be changed to reflect free chlorine disinfection and adequate detention time for 4-log virus removal. In addition, the section should note that these requirements could potentially be relaxed on a case by case basis by Ecology when adequate virus removal is thoroughly documented, and adequate safeguards are provided, upstream of the disinfection process, for instance, through a membrane bioreactor. 2. For UV Disinfection, it appears that the State is not requiring checkpoint bioassays on-site. It is recommended that, at plants where checkpoint bioassays are not completed, that a field commissioning checklist be completed and signed by both the manufacturer and engineer, at a minimum, to ensure that hydraulics and construction tolerances, etc., are within specification to provide the necessary pathogen inactivation. In lieu of the field commissioning checklist, or as specifically required by Ecology, the checkpoint bioassay could be conducted. See attachments.
10/13/17 4:55 PM   |  
 
 
Comment from: City of Arlington Public Works (JamesKelly)
The City of Arlington Public Works Department is submitting comments on the proposed Reclaimed Water Rule (WAC 173-219) in the attached letter and exhibits. The City of Arlington is a member of the Washington Water Utilities Council and appends the WWUC comment letter by reference.
10/13/17 4:34 PM   |  
 
 
Comment from: WA State Chapter Sierra Club (ElainePackard)
10/13/17 4:05 PM   |  
 
 
Comment from: Muckleshoot Indian Tribe (CarlaCarlson)
10/13/17 2:08 PM   |  
 
 
Comment from: Ilene Le Vee
I think a significant contributing factor to groundwater/in-stream flow loss is directly attributable to the amount and degree to which individuals/families choose to build/live in unincorporated areas adjacent to timber/forested lands. Additionally, as our weather/climate continues evolving, naturally and through human activity, we'll see increasing need for reclaimed water to address wildfires and agricultural/concentrated uses ie., large feedlots/dairies. It is my personal preference, as a ranch/farmland owner in Klickitat and Clark Counties, that development of any RCW/WAC on this subject be as directive as possible and as quickly as politically feasible. I offer the following article as a supporting argument in this vein. http://www.factcheck.org/2017/10/warming-blame-western-wildfires/. Thank you for considering my input. Ilene Le Vee Olympia, WA
10/13/17 1:56 PM   |  
 
 
Comment from: LOTT Clean Water Alliance (LisaDennis-Perez)
10/13/17 1:13 PM   |  
 
 
Comment from: James Kimball
As a member of the Advisory committee I want to thank DOE for their efforts to consider all sides of the Reclamation issue. I would like to expand on the comment in the October 10, 2017 DOH letter "Reclaimed Water can extend water supplies for drinking water where aquifers are declining faster than being recharged". The current Water Right mitigation program does not provide any special recognition of public water supplies that derive their water from declining aquifers. A recent example of an attempt to mitigate water rights that depended on the recent increase in flow of a river from a WWTP discharge. The increase in flow is derived from a declining aquifer. It appears that many of the significant water rights have not been used for over 10 years. Ecology should take the lead in vacating the water rights that have not been utilized for over 5 years.
10/13/17 1:07 PM   |  
 
 
Comment from: PUD #1 of Clallam County (TomMartin)
Please see uploaded attachment.
10/13/17 12:01 PM   |  
 
 
Comment from: Northeast Sammamish Sewer and ... (AnonymousAnonymous)
10/13/17 11:49 AM   |  
 
 
Comment from: Van Ness Feldman LLP (CaraTomlinson)
On behalf of the Washington Water Utilities Council, Cascade Water Alliance, The Washington Association of Sewer and Water Districts, the Washington Public Utility Districts Association, and Seattle Public Utilities, please see attached comments.
10/13/17 10:51 AM   |  
 
 
Comment from: Van Ness Feldman LLP (CaraTomlinson)
On behalf of the Washington Water Utilities Council, please see attached comment.
10/13/17 10:44 AM   |  
 
 
Comment from: Gray & Osborne, Inc. (KennethAlexander)
We were disappointed to see that a number of Gray & Osborne's previous comments we not addressed in the proposed rule. Below are our outstanding comments with a few new ones to address typos we found. We hope they will be considered. We feel this rule is needed to provide clear standards and procedures for implementing water reuse projects in the State of Washington. Our experience has been that without consistent state-wide rules and technical guidance that inconsistent practices and enforcement standards are applied, which is both confusing and unfair to the regulated community as well as consultants who assist them in the planning and design of water reclamation and reuse facilities. We have found that such inconsistency is particularly prevalent around the issues of filtration and disinfection system design and groundwater recharge standards. 1. Lack of consistency when referring to the "Orange Book" and "Purple Book." For example, WAC 173-219-220(1)(c) refers to the "Purple Book" for reclaimed water facilities commissioning plans. Elsewhere, references for treatment processes are to the "Orange Book" (i.e. WAC 173-219-340(1)(b) for UV design guidelines), with the understanding that the "Purple Book" would be reserved for reclaimed water distribution and use not treatment. 2. WAC 173-219-310 Cross-Connection Control: We suggest paring back the level of detail in WAC 173-219-320 and relying more on references to other WAC rules and cross-connection control manuals. 3. WAC-173-219-320 Class A and B Reclaimed Water: In the previous (2015) draft, there was an option to produce Class A reclaimed water with direct filtration (without coagulant addition) provided a disinfection dose sufficient for 5-log virus removal (instead of 4-log if coagulants are added) is provided downstream. This option should be restored to the Rule. 4. WAC 173-210-330 - Table 1. Minimum Biological Oxidation Performance Standards: a. Biological Oxidation: Per footnote 1, these parameters must be measured at the end of the unit process. We suggest retaining the exception in previous drafts of the Rule that permittees can request to measure BOD5, CBOD5, and TSS in the final effluent instead of directly after the secondary clarifier, with a limit of 10 mg/L. Otherwise multiple sampling points must be maintained, which may be impractical at small facilities, and in some processes such as MBRs, it is physically impossible to sample effluent between the biological process and filtration. 5. WAC-173-219-340 Disinfection Process Standards: a. Under (1) subtitle: Remove the words Class B. This entire section applies only to Class A reclaimed water. Perhaps include in new subsection with general requirements for Class B disinfection, such as less stringent disinfection dose and residual requirements for chlorine disinfection. b. Under (1a) - Change this section to say: "Where chlorine is used as the disinfectant in the treatment process a minimum chlorine residual of at least 1 mg/L, measured as free chlorine, after a T10 contact time of at least thirty (30) minutes at design peak day flow is required." The basis of the contact time needs to be defined. For example, in the Orange Book, for secondary effluent disinfection a contact time of 20 minutes at peak day flow is required. We recommend that a 30 minute contact time be required at the design peak day flow for reclaimed water disinfection. c. We also recommend that the T10 time be defined in the rule as the time at which at least 90% o the water flowing through the reactor are kept in contact with the disinfectant residual. T10 is determined as the time at which 10% o the volume of the slug of tracer passes the basin exit. 6. WAC 173-210-390 - Table 3. Use-Based Performance Standards: a. Row 5, Public Contact (including public water features): Delete this row and merge into Row 2, Commercial, industrial and institutional uses with public contact. No unique requirements are provided for Row 5. b. Row 8, Irrigation of Food crops: Add the words "Unless otherwise specified" to the row title, since Rows 9, 11 and 12 are also about irrigation of food crops. c. Row 10, Irrigation of nonfood crops: Suggest deleting this row, since it is duplicated by Rows 13 and 14 and provides no unique requirements. d. Row 11, Irrigation of orchards or vineyards: Add a note that the Class B irrigation water must not touch the fruit. Otherwise, Row 8, Irrigation of food crops (Class A), will apply. e. Row 12, Process Food Crops: Add a definition of processed food crops to the "Additional Requirements" column or as a table footnote. f. Row 19, Depressional Wetlands: Add the net environmental benefits and effluent quality language from Rows 17 and 18, unless the intent is that nutrient removal is not required for depressional wetland uses. Where are (1) and (2) of this section? g. Row 21: Delete the words "Class A or" if Class B is acceptable. h. Row 22, Surface Water Augmentation: Suggest dividing this into two categories, one for (a) general surface water augmentation and one for (b) direct augmentation of potable water supply impoundments. For (a), require Class B reclaimed water with case-by-case evaluation for compliance with Surface Water Standards (but not Drinking Water MCLs). For (b), require Class A reclaimed water with case-by-case evaluation for compliance with Surface Water Standards and Drinking Water MCLs. i. Row 23, Indirect Groundwater Recharge: Delete the words "Class A or" if Class B is acceptable. Remove the reference to Drinking Water MCLs; Groundwater Quality Standards are sufficient for this use. j. Row 25, Recovery of Reclaimed Water stored in an aquifer: This row should be deleted and the text should be a footnote applied to Rows 23 and 24. k. Footnote 3 does not apply and should be revised; it was copied from Table 2. Also, where are footnotes (1) and (2)?
10/13/17 8:45 AM   |  
 
 
Comment from: Coalition for Clean Water (RobinZukoski)
10/13/17 12:00 AM   |  
 
 
Comment from: Andrew Austreng
10/13/17 12:00 AM   |  
 
 
Comment from: Washington Association of Sewe... (JamesKuntz)
Please see attached.
10/12/17 2:58 PM   |  
 
 
Comment from: King County Department of Natu... (JacqueKlug)
10/12/17 2:41 PM   |  
 
 
Comment from: Department of Health (ClarkHalvorson)
10/12/17 10:55 AM   |  
 
 
Comment from: Scott Hemingway
Draft Reclaimed Water Facilities Manual Section 7.7.1 Operator Certifications If you are going to require that Distributors have a BAT you should also require that Generators have a BAT also. Generators are going to have a number of backflow assemblies within their facility to protect the reclaimed water from lower quality water and to protect the potable water system from reclaimed water. The level of protection at the source of the reclaimed water (Generator) should be equal to the distribution system.
10/12/17 7:46 AM   |  
 
 
Comment from: Scott Hemingway
Wac 173-219-310 6(ii) States "Ensure that the assembly will not become submerged due to weather-related conditions such as flooding." This does not ensure that backflow assemblies will not become submerged by sewage. My experience is that many assemblies are currently installed in basements or indoors below ground. This would protect the assembly from "weather-related conditions", but does not protect them from being submerged by sewage. If recent events at the West Point and Bellingham wastewater treatment have shown, basements are flooded by sewage when there are equipment failures at the plant. One suggestion is to change the language to "assemblies may not be installed below ground, or below 100 year flood level"
10/12/17 7:26 AM   |  
 
 
Comment from: Olympic Environmental Council (Darlene Schanfald)
10/08/17 9:51 PM   |  
 
 
Comment from: PNW Section WateReuse (ChristopherStoll)
10/04/17 4:11 PM   |  
 
 
Comment from: Nickie Davis
My neighborhood on San Juan Island in Washington has a five year old reclaimed water system that has been never been able to be put to use, although the water always tests clean. If this rule could be passed so we could use our reclaimed water in our toilets and underground irrigation system, that would be awesome. Thank you for your hard work and consideration.
8/23/17 7:24 PM   |  
 
 

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