Operators Learn About Latest Water and Wastewater Regulations

Operators from across Florida came to the conference to learn about pertinent issues to use in their careers. On Thursday, some attended the Operators Showcase to have a beer and hear about new regulations.

The showcase is sponsored by the Florida Water and Pollution Control Operators Association (FWPCOA), and this year the discussion was moderated by Tom King, who chairs and is a member of several FWPCOA committees.

The session had three presenters:

S Chris Owen, associate vice president and director of water and reuse innovations with Hazen and Sawyer in Tampa.

S Carlyn J. Higgins, Ph.D., P.E., an engineer with Hazen and Sawyer in Tampa.

S John O’Brien, a licensed operator with Seacoast Utility Authority in Palm Beach Gardens.

What Does the Per- and Polyfluoroalkyl Substances Regulatory Future Look Like and What Does It Mean for Your Utility?

Owen spoke about the effects of perand polyfluoroalkyl substances (PFAS) chemicals on the water utility industry. She discussed the following:

S PFAS background

S The proposed new maximum contaminant levels (MCLs)

S Proposed compliance schedules

S Treatment approaches

S Funding opportunities

S Communication tools

The (Expanding) World of PFAS Compounds

A large, complex group of synthetic chemicals, PFAS have been used in consumer products around the world since about the 1950s. They are ingredients in various everyday products that are used to keep food from sticking to packaging or cookware, make clothes and carpets resistant to stains, and create firefighting foam that is more effective. There are more than 4,000 compounds that make up PFAS.

The PFAS molecules have a chain of linked carbon and fluorine atoms. Because the carbon-fluorine bond is one of the strongest, these chemicals do not degrade easily in the environment.

People are most likely exposed to these chemicals by consuming PFAS-contaminated water or food, using products made with PFAS, or breathing air containing PFAS. Because PFAS break down slowly (if at all), people and animals are repeatedly exposed to them, and blood levels with PFAS can build up over time.

The most commonly studied PFAS are perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS). The next most commonly studied are perfluorohexane sulfonic acid (PFHxS), and perfluorononanoic acid (PFNA). The PFAS molecules have a chain of linked carbon and fluorine atoms that provide their chemical and thermal stability, as well as their water- and oil-repellent characteristics.

The U.S. Environmental Protection Agency (EPA) recently finalized the human health toxicity assessment for hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt, which are also known as “GenX chemicals” because they are the two major chemicals associated with the next generation of processing technology used to make highperformance fluoropolymers without the use of PFOA.

The adverse health effects of PFAS exposure include:

S Increased cholesterol levels

S Decreased vaccine response in children

S Changes in liver enzymes

S Increased risk of high blood pressure or preeclampsia in pregnant women

Small decreases in infant birth weights

Scientists are still learning about the health effects of exposures to mixtures of different PFAS.

Maximum Contaminant Levels

In March of this year, EPA proposed new MCLs for a group of PFAS contaminants. These new MCLs will be finalized at the end of 2023 (or the beginning of 2024) and utilities will need to take action as a result, including monitoring, public notification, and treatment if levels exceed the new MCLs. Utilities will have three years to implement treatment.

Attention from the Media

All forms of media (print, electronic, social) are now reporting on PFAS, which means that water and wastewater utility customers are more aware of the issue. The potential health risks surrounding PFAS have created an environment where communities are asking utilities and regulators to quickly find solutions to address, remove, and destroy these contaminants.

Managers and operators at water utilities must educate themselves on PFAS, build trust with their communities, and juggle evolving regulations, while also simultaneously planning for and funding new treatment systems.

Regulatory Timeline

The U.S. government has been aware of PFAS for some time and EPA set a regulatory action timeline to deal with them: 1998 - EPA first alerted to risks.

2000 - Environmental Science & Technology (ES&T) article on global PFAS distribution is published.

2006 - Manufacturers phase out chemicals via participation in EPA’s stewardship program.

2016 - EPA published health advisories for PFOA and PFOS.

2019 - Federal legislation (Senate Bill 1507) is enacted, which requires the EPA administrator to promulgate certain limitations with respect to preproduction, plastic pellet pollution, and for other purposes.

2020 - Preliminary regulatory determination is made for PFOA/PFOS; various state regulatory action and monitoring also established.

2022 - New health advisory levels (HALs) announced.

2023 - Unregulated Contaminant Monitoring Rule (UCMR) 5 begins and EPA proposes

PFAS National Primary Drinking Water Regulation (NPDWR).

Comprehensive Environmental Response, Compensation, and Liability Act

The EPA has extended its estimated publication of a final rule designating certain PFAS (PFOA and PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). It pushed the timeline for the final rule on PFAS CERCLA designation from August 2023 to February 2024.

The CERCLA establishes liability for current and former owners and operators of facilities where hazardous wastes were released or disposed, generators and arrangers of disposal or transportation of hazardous substances, and transporters of hazardous substances. As such, any entity that handles designated PFAS—not solely PFAS manufacturers—could become liable for the recovery and remediation costs of PFAS releases or threatened releases and would need to comply with federal law on transportation and disposal of hazardous waste. Owners of land contaminated with a hazardous substance are considered potentially responsible parties and are jointly and severally liable for response costs.

The CERCLA also imposes retroactive liability; prior owners of contaminated land may be held liable under the statute. The manufacturing of PFAS began in the United States in the 1930s and the extent of contamination at manufacturing sites and places of use is still unknown. Prospective owners can avoid liability only by qualifying for a CERCLA defense, exemption, or liability protection.

Liability under CERCLA creates a significant risk for passive receivers who don’t contribute to PFAS contamination and merely receive materials and substances that contain PFAS. Water and wastewater utilities are particularly vulnerable to CERCLA liability due to their role in receiving and filtering PFAS out of drinking water and wastewater.

Treatment technologies that can remove PFAS from source water—granular activated carbon (GAC), anion exchange resins, and membrane systems (reverse osmosis [RO] and nanofiltration)—result in PFAS-filled contaminated media or concentrate that must be disposed of carefully. The most effective known method of destroying PFAS is incineration, but the capability is not widely deployed and it still requires consolidation of media containing PFAS. Transporting and disposing of spent media risks subjecting utilities to significant legal consequences.

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Wastewater utilities also must contend with both industrial and residential contributors of PFAS, the latter of which poses unique challenges due to the prevalence of PFAS in many consumer products. Wastewater utilities also face uncertainty over regulation of biosolids, a beneficial byproduct of treatment that supports agriculture.

Treating PFAS Current Technologies

Many water agencies have already begun to address PFAS in their water supplies. Treatment solutions include GAC adsorption, ion exchange (IX) resins, and nanofiltration (NF) and low-pressure RO membrane treatment processes.

The utilities that use these treatments can expect varying levels of PFAS “removal” ranging from less than 50 percent to more than 95 percent with RO membranes. More advanced treatment options are needed.

Control and Management Approach

Utilities should determine the presence and composition of PFAS in their facilities and intercept and treat them from multiple sources, as shown in Figure 1.

Water treatment plants (WTPs) and water resources reclamation facilities (WRRFs) are only receivers of PFAS and DO NOT produce PFAS, but the transformation of precursors makes it appear that PFAS are “generated” at WRRFs. The reality is that many precursors aren’t detected in current screening methods and caution must be used when performing mass balances at a facility.

A utility’s sampling approach for PFAS should consider total organofluorine contributions. Source control may be a very effective strategy for reducing these chemicals in WRRF influents.

Innovation Technologies and Approaches Under Consideration

New technologies to treat PFAS include:

S Novel adsorbents

S Coagulant aids

S Pretreatment with GAC

S Nanobubbles for foam fractionation

Cost of Treatment

Water agencies have played no role in producing PFAS, yet they are the ones who are facing the burden of removing these contaminants from their water supplies. As water providers discover these contaminants in their supplies, the demand (and cost) for treatment technologies and infrastructure upgrades are likely to rise.

The bipartisan Drinking Water and Wastewater Infrastructure Act of 2021 includes a comprehensive package that will invest billions of dollars in drinking water and wastewater infrastructure to address PFAS and other unregulated contaminants. The funds, however, come with restrictions on what they can be used for and exclude the long-term operation and maintenance costs of running these facilities.

Unless the manufacturers responsible for this pollution are held accountable, the billions of dollars to clean the contaminated water will be a burden borne by rate payers, who have also likely been exposed to the toxic chemicals.

Over the past two decades, litigation has helped expose not only the dangers of these chemicals, but how much the manufacturers knew and withheld information about those dangers. In past cases pursued against PFAS manufacturers, an enormous amount of evidence was produced demonstrating wrongdoing on the part of those manufacturers, making litigation a good option for water providers to consider.

What are Additional Challenges for Utilities?

A gap exists between what affects humans versus what can be measured, and there are limitations of analytical methods.

The challenges regarding PFAS include:

S Inconsistent regulatory actions over the past 10 years

S Lack of testing/monitoring methods for HALs and MCLs

S Communicating complicated information to customers and other stakeholders

The challenges associated with quantifying the full diversity of PFAS present in environmental samples and the lack of toxicity data highlight the need for information and tools to better understand new and emerging fluorinated compounds. Further, there are no current data for approximately 100 million Americans who obtain their water from small public water supplies serving less than 10,000 individuals and private wells, representing a critical research need for the future.

It’s also a challenge to get the public to understand scientific issues when the “experts” don’t know the full extent of exposure and how to mitigate the danger.

What Communication Tools do Utilities

Have in the Light of Recent PFAS Developments?

Utilities can adopt the following communication strategies:

Communication Support

Develop communication materials that are informative and educational. Crafting public notification strategies specific for stakeholders, including customers, board members, elected officials, and the media, will go a long way to educate these audiences.

Staff Training

Prepare staff with training designed to address PFAS implications throughout the agency, including the operations, customer service, engineering, management, and board levels. Provide staff with key messages they can readily share with customers.

Monitoring Advice and Results Interpretation

Identify resources that can provide guidance on sample collection, methods selection, laboratory identification, and data analysis for understanding and communicating results. National organizations have prepared educational materials and templates that are generally open to all to use.

Proactive Treatment Assessments

Begin sampling and planning discussions to address PFAS occurrence and treatment effectiveness.

Any communication to any audience regarding PFAS should include the “4 Cs”:

S Control – determine the message and seek out opportunities to interact with various audiences

S Clarity – no jargon

S Competence – be informed and knowledgeable

S Concern - acknowledge customer fears and issues

As more information comes to light about the impact of these chemicals, it will continue to draw the attention of water customers; local, state, and federal regulators; legal professionals; environmental groups; and the public.

Direct Potable Reuse in Florida: What It Means for Operators

John O’Brien

O’Brien is an instructor in the utility field and is chair of the new Direct Potable Reuse Operator Certification Committee for FWPCOA. He gave an overview of direct potable reuse (DPR) in Florida.

What is Direct Potable Reuse?

Potable reuse is the process of using treated wastewater for drinking water and provides another option for expanding a region’s water supply portfolio. As planned potable water reuse, DPR uses advanced ultratreated reclaimed water for potable purposes without an environmental buffer, such as surface water or an aquifer. Wastewater may be conveyed to a municipal wastewater treatment plant for treatment to reclaimed water standards, and then further treated to protective drinking water levels for distribution as potable water.

This water is treated to levels that protect public health and is tested before entering a drinking water distribution system. Advanced treatment is used, which consists of multiple treatment steps that are specifically engineered to treat any anticipated pollutants or contaminants in reclaimed or wastewater. The processes are constantly monitored and tested at every necessary treatment step to protect public health. Contingency plans are also in place to ensure that DPR water is further treated when necessary. In addition, DPR facilities must comply with regulations mandated by the Safe Drinking Water Act (SDWA).

Another Source of Water for Florida

As an alternative, sustainable supply of water, DPR can help Florida meet its projected water needs. By 2035 the state is forecast to require an additional 1.1 billion gallons of fresh water per day to help meet supply. With fresh groundwater supplies becoming limited, reusing water for potable uses has become a proven method across the United States to augment water supplies.

Technology advancements have made the costs of treating potable reuse competitive with other alternative water supply sources, such as seawater and brackish desalination.

Outreach to the Public

Public acceptance is crucial to the success of any water reuse project and it’s influenced by many factors, such as the perceived value of water, the history of the water to be reused, trust in the entities promoting the reuse project and in the technologies used to purify the reuse water, education on fundamental water concepts that apply more specifically to water reuse, the timing of the proposed reuse project with local circumstances (e.g., drought), and inclusion of information on pilot projects.

Despite research demonstrating that DPR can be safe, one of the most significant issues surrounding implementation is public opposition. Because the public has rejected many reuse projects in the past, there is a substantial body of work on public perceptions of, and attitudes toward, water reuse, along with recommendations for effective public education and outreach related to water reuse projects. Most of this work, however, is based on experiences with nonpotable reuse, or indirect potable reuse (IPR).

For the public to feel comfortable about DPR, it needs to know that the technology is advanced enough to ensure the purity of the water and that the utility personnel using the technology have been adequately trained.

Operators and Direct Potable Reuse

Most of the existing operator training and certification doesn’t cover reuse well, especially when it comes to licensing.

The FWPCOA has assisted the WateReuse Association in developing a survey to collect data from water and wastewater operators and other members of the industry about advancing the concept of DPR and IPR treatment licensing in the state of Florida. WateReuse has created the Potable Reuse Commission (PRC) to assist in promulgation of a joint position for Florida.

The U.S. Environmental Protection Agency (EPA) is working on a discussion framework for a draft water reuse action plan (WRAP). One recommendation is the introduction of an advanced water treatment license. While FWPCOA endorses EPA’s development of the WRAP, the survey will gather information to share with the PRC, which it can use to guide the Florida Department of Environmental Protection (FDEP) and other water sector stakeholders in amending the future licensing certification program.

The FWPCOA is also creating a manual on DPR that can be used by operators.

Plant City Potable Reuse: Data Collection, Operator Training, and Operator Certification

Carlyn Higgins

Higgins presented information on the City of Plant City’s potable reuse water pilot project.

Background

The City of Plant City (city) is located about 50 miles inland of Florida’s west coast and is known for agriculture and its annual Strawberry Festival. The city owns and operates a water reclamation facility (WRF) and four water treatment plants (WTPs).

The city considered potable reuse for several reasons:

Florida Senate Bill 64 requires certain domestic wastewater utilities to submit to the Florida Department of Environmental Protection (FDEP), by a specified date, a plan for eliminating nonbeneficial surface water discharge within a specified timeframe.

The city’s current stormwater system is experiencing flooding and treatment challenges.

S The city needs more drinking water supply due to population growth.

S The city is located in the Dover Southern Water Use Caution Area, which creates additional challenges to permit additional groundwater for drinking water supplies.

Potable reuse would then give the city the following advantages:

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S Reduce reliance on surface water discharge by diverting highly treated effluent to McIntosh Park, which would in turn hydrate wetlands, mitigate flooding, promote a healthy ecosystem, preserve the beauty of the passive recreational park, and recharge the aquifer.

S Implement potable reuse—either indirect potable reuse (IPR) or direct potable reuse (DPR)—to augment the city’s provide water supply and flood protection to the city. It has the following components:

S Stormwater treatment through expanded wetland treatment systems.

S Localized flooding mitigation by adding more than 100 acres of wetlands and pond systems.

S Increased water supply through investigating potable reuse.

S Creation of a natural habitat park with walking trails, education boards, and a nature preserve.

Potable Reuse Requirements

Some key questions that the city considered when evaluating potable reuse for its utility were:

The integrated water management plan for McIntosh Park is a collaborative project to enhance park recreational opportunities and

S How much additional potable water is needed?

S Would IPR or DPR be more feasible for the city given the current state of the city’s water needs and draft potable reuse regulation?

S What potable reuse treatment trains should be utilized?

S How can it demonstrate performance while the rule making process is ongoing?

The current regulations in Florida require a pilot program to demonstrate the performance of reuse treatment intended for drinking water supplies. The pilot consisted of the components shown in Figure 1.

Pilot Goals and Objectives

The city’s potable reuse pilot had the following goals:

S Meet current regulatory requirements

S Establish design and operating criteria for a full-scale process

S Develop and execute an engagement program

S Provide operator training for operation and maintenance

To achieve the pilot goals, a membrane filtration (MF), reverse osmosis (RO), and ultraviolet/advanced oxidation process (UV/ AOP) pilot was procured and installed in series to represent advanced potable reuse treatment. Each pilot unit was prefabricated by a vendor and contained appropriate meters, gages, valves, instrumentation, etc., required to monitor and adjust performance. The pilots also have sample panels to appropriately collect samples as water goes through each treatment stage.

The process mimics that of a potential full-scale purification facility, but is scaled down to receive only a fraction of the flow. In this application, the wastewater treatment plant diverts approximately 40 gal per minute (gpm) of wastewater effluent from the city’s sand filter effluent to the pilot process.

Pilot Results

The comparison of pilot finished water to current potable water quality is shown in Table 1.

As shown in Table 2, no viable pathogens were detected in the finished water.

More than 400 organic compounds and constituents of emerging concern were analyzed in reclaimed water and pilot finished water.

S 18 constituents were detected in the reclaimed water (N-Nitrosodimethylamine [NDMA], 1,4-dioxane, per- and polyfluoroalkyl substances [PFAS], sucralose, hexazinone [herbicide], testosterone [hormone], erucamide, phenanthrene [industry])

S Seven constituents were detected in the UV/AOP finished water (disinfection byproducts [DBPs] at less than 5 ug/L, sucralose at less than 10 ng/L)

No constituents, however, exceeded maximum contaminants levels (MCLs) or health advisory levels (HALs).

Pilot performance monitoring and optimization have helped inform design criteria, as shown in Table 3.

Public Outreach Program

The city has engaged in a comprehensive public outreach program to educate the surrounding community about the future of its water supply. The efforts were developed with the goal of increasing public acceptance of potable reuse by educating stakeholders on the quality and safety of alternative potable water supplies.

Components of the program included:

S Project branding

S Creation of educational materials

S An inaugural ribbon-cutting event

S Public tours

S Video development

S Collaborative beverage making with Keel Farms

Operator Training and Certification

Hands-on training opportunities for

Potential Option 1

Potential Option 2

Potential Option 3 operators exposed them to potable reuse treatment technologies and included:

S Classroom educational sessions

S Process monitoring

S Sampling procedures

S Maintenance activities

The city’s pilot was extended for three months to allow for operator exposure and public outreach. Continued on page 30

As the regulation is still in the draft phase, the avenue of operator certification is still up for discussion. Potential certification options include:

S New license

S Dual licensing

S Potable reuse operator certification

S Certificate on water or wastewater license

Several options are available:

• Potential Option 1: A separate potable reuse (PR) operator certification program (source: California Urban Water Agencies, 2016)

• Potential Option 2: A supplement to a current drinking water or wastewater license (source: California Urban Water Agencies, 2016)

• Potential Option 3: Hybrid added onto either drinking water or wastewater license (source: California Urban Water Agencies, 2016)

Other questions to consider concerning operator certification are:

S Is there a large enough market to support a certification program?

S Could the approach limit the existing pool of existing operators?

S What level of experience would be acceptable to operate a potable reuse facility and sit for an exam?

S Would a specific certification avenue result in knowledge gaps?

If both drinking water and wastewater operators are used, would senior supervisors be experienced enough to manage a diversity of staff backgrounds?

Other challenges exist:

Implementation of resources to run the

Mobility, career path, pay implications, and job descriptions

Boundaries: what to test and not to test; what to test at different levels of an exam

The Path Forward

To assist with operator training, FWPCOA is creating study materials on potable reuse. There is also the potential to leverage training materials from other states, associations, and water-related organizations. It’s important to keep the conversation going and include operators in any decisionmaking processes. S