United States
                     Using DWSRF Funds to  Comply with
                             Fj|ter  Backwasn  Recycling  Rule
The Drinking Water State Revolving Fund (DWSRF) program was established by the 1996 Safe Drinking Water Act
(SDWA) Amendments and authorizes grants to states to capitalize revolving loan funds. The states provide low-
interest loans to eligible systems for infrastructure improvements needed to ensure compliance with the SDWA and
protect public health.  The DWSRF program can play a significant role in helping systems, especially small systems,
to meet the challenges of complying with new drinking water standards.

The Environmental Protection Agency (EPA) published the Filter Backwash Recycling Rule (FBRR) in 2001. The
FBRR improves public health protection by requiring systems to assess and change, if necessary, recycle practices to
control risks from microbial contamination. The FBRR will impose a financial burden on some water systems. The
DWSRF can provide assistance to systems to help ease this burden, increase compliance, and  protect public health.

The 1996 SDWA Amendments required EPA to promulgate a regulation which "governs" the recycling of filter
backwash water within the treatment process of public water systems. The FBRR requires that recycled filter back-
wash water, thickener supernatant, and liquids  from dewatering processes be returned to a location such that all
processes of a system's conventional or direct filtration are  employed.  Systems may apply to the state for approval to
recycle at an alternate location. By establishing the FBRR, EPA hopes to improve public health performance at
conventional and direct filtration plants by reducing the likelihood that recycling practices would allow microbes,
such as Cryptosporidium, to pass through to finished drinking water. The FBRR will help ensure that the microbial
removal improvements of the Interim and Long Term 1 Enhanced Surface Water Treatment Rules  are not compro-
mised by backwash recycling practices.

The FBRR applies to all systems that use
surface water or ground water under the
direct influence of surface water
(GWUDI), practice conventional or
direct filtration, and recycle spent filter
backwash, thickener supernatant, or
liquids from dewatering processes.
                                     Surface Water  v
                                     Ground Water
                                      GWUDI    /
  CWSs    /
 TNCWSs   /
                                                                         Population Type
   < 10,000    /
10,000-100,000  /
   > 100,000    /

December 8, 2003
June 8, 2004
June 8, 2006

States submit FBRR primacy revision application to EPA (triggers interim primacy).
Submit recycle notification to the state.
Recycle flows must be returned through the process of a system's existing conventional or direct
filtration system or at an alternate recycle location approved by the state (unless granted a 2-year
extension by the state). Collect recycle flow information and retain on file.
Complete all capital improvements associated with relocating recycle return location (if necessary).
Primacy extension deadline - states with extensions must submit primacy revision applications to EPA.
June 8, 2003

June 8, 2005

                                                Figure I: TOTAL FBRR PRICE TAG
                                                 (in thousands of January 1999 $)
                                                Capital Costs
                                                for Recycle       $45,207
                                                Return Provision
                   Total Capital Costs by System Size
                     for Recycle Return Provision
                                                Annual O & M Costs
                                                Recycling Reporting
       < 100
    > 100,000
 $1,41 I
Total capital costs for the rule are estimated to
be over $45 million.  In addition, the annual
O & M and reporting costs will be more than
$2.5 million. Most of the capital costs will fall
on the shoulders of systems serving more than
100,000 people (see Figure 1). Only a very
small percentage of transient noncommunity
water systems (TNCWSs) and nontransient
noncommunity water systems (NTNCWSs)
will be subject to the FBRR because most of
these systems are ground water systems and
very few use conventional or direct filtration.

Of the 4,650 systems subject to the FBRR, the EPA estimates that fewer than 400 systems are expected to require
capital improvements to modify the location of their recycle return (the remainder are subject to the reporting require-
ments only).  Generally, systems affected by the FBRR will not be required to make significant modifications to their
treatment processes to meet the rule's requirements. The majority of systems that will have to modify the location of
their recycle return serve less than 50,000 people  (see Figure 2).

Figure  3 shows the average annualized capital and O & M costs for systems that must install a new recycle return
location. For most of these systems, the annual capital and O & M costs will be under $5,000. Although a fewer
number of systems serving more than  10,000 people will face capital costs from the FBRR, the costs per system will
be much more expensive (almost $50,000 on average).

EPA estimates that the total annual cost per household will be less than $1.70 for 99% of the 31.4 million households
potentially affected by the FBRR. The remaining 1% of affected  households will experience a range of costs between
$1.70 and $100 per year.  Costs for the FBRR will place a slightly more significant burden on small systems because
costs must be paid from a much smaller revenue base.
 Figure 2: Number of Systems That Will Need to Modify
 Location or Request Alternate Location
                    1,000    3,300  9,999   50,000  100,000

                        Population Served
Figure 3: Average Annual Costs for Installing New
Recycle Return Location (in thousands of 1999 $)
                    1,001-    3,301-    > 10,000
                    3,300     9,999
                   Population Served
    Note: Costs based on total costs amortized over 20 years at a
    3% discount rate.

During routine filter operation, particles such as metals, coagulants, and pathogens become trapped within system
filters. The process of backwashing filters removes these particles and is crucial in the proper operation of conven-
tional and direct filtration plants. The FBRR will ensure that the resulting spent filter backwash, if recycled, is
handled with at least the same level of multi-barrier treatment as raw source water.
The FBRR addresses spent filter backwash and two additional recycle flows  thickener supernatant and liquids from
dewatering processes.  Recycle streams may contain significant concentrations of pathogens, such as Cryptosporidium,
and pose a significant public health threat if not treated appropriately (see Exhibit 1). Under the rule's first provision,
systems are required to return their recycle flows through all processes of a system's existing conventional or direct
filtration system.  By passing the recycle flows through all treatment processes at the facility, the FBRR helps to ensure
the integrity of the chemical treatment.
Systems facing infrastructure improvements to
redirect recycle flows to pass through the
processes of a system's existing conventional or
direct filtration may require additional piping
and pump capacity. O & M costs for such
infrastructure improvements include the annual
cost of painting the pipes, replacement of pipe
sections and fitting, and pump and motor
Exhibit 1: Recycle Flows Most Likely to Contain
Untreated Spent Filter Backwash Water - Water used for
filter backwash which has not received treatment to remove
oocysts from the waste stream.

Gravity Settled Spent Filter Backwash Water - Filter
backwash in which gravity settling has been used to remove
solids prior to its return to the primary treatment process.

Combined Gravity Thickener Supernatant -  A combination of
the supernatant from spent filter backwash water and a gravity
thickener.  A gravity thickener removes water from the
sedimentation and filtration backwash sludge mass.

Gravity Thickener Supernatant from Sedimentation Solids -
This potential recycle flow is similar to that for  the combined
gravity thickener supernatant, but includes only the supernatant
from a gravity thickener.

Mechanical Dewatering Device Liquids - Liquids resulting
from devices used to mechanically separate water treatment
plant residuals (usually thickened sludge) into solids and water.
Devices used to mechanically dewater thickened sludge
include belt filter presses, centrifuges, filter presses, and
vacuum filters.
The EPA acknowledges the value of having the
recycle flows pass through all treatment pro-
cesses. However, the Agency also recognizes
unique site-specific conditions.  As a result, the
FBRR's recycle return provision provides
flexibility by allowing the state to approve an
alternate recycle  return location for systems on a
case-by-case basis.

Under the FBRR, systems are required to notify
states that they recycle. In addition, systems
must provide information that the state can
utilize to evaluate a system's susceptibility to
hydraulic disruptions as a result of recycling.
Accordingly, systems must provide the state with
a plant schematic showing the origin of all
recycle flows, the hydraulic conveyance used to transport them, and the location where they are recycled back into the
plant. They must also provide a typical recycle flow in gallons per minute (gpm), highest observed plant flow experi-
enced in the previous year (gpm), design flow for the treatment plant (gpm), and, if applicable, the state-approved
operating capacity for the plant.

Systems are also  required  to collect and maintain information for review by the state. After evaluating the informa-
tion, states may require a system to modify its recycle location or recycle practices.

States use DWSRF capitalization grant monies to
provide low-interest loans to publicly- and privately-
owned public water systems for infrastructure
improvements needed to continue ensuring safe
drinking water. States may offer principal forgive-
ness, reduced interest rates, or extended loan terms
to systems identified by the state as serving disad-
vantaged communities. States also have the ability
to reserve a portion of their grants (i.e., set-asides) to
finance activities that encourage enhanced water
system management and help to prevent contamina-
tion problems through source water protection
measures. Based on the fiscal year 2002 appropria-
tion of $850 million, capitalization grants ranged
from $8.0 million to $82.4 million per state.

Most capital projects  including installing new
piping and upgrading existing technologies 
needed to comply with the new FBRR standards are
eligible for funding under the DWSRF (see Exhibit
2). States can use set-aside funds from the DWSRF
to assist systems directly as well as to enhance their
own program management activities.

A state may use set-asides to make administrative
improvements to the entire drinking water program,
which faces increased costs in implementing the
FBRR.  States can provide training to systems on
meeting the requirements of the FBRR as well as
technical assistance in identifying appropriate
recycle locations.  In addition, states can provide assistance to small systems to cover the costs of project planning and
design for infrastructure improvements.

Since the DWSRF program is managed by states, project and set-aside funding varies according to the priorities,
policies, and laws within each state.  Given that each state administers its own program differently, the first step in
seeking assistance is to contact the state DWSRF representative which can be found on the EPA DWSRF website.
Exhibit 2: Projects/Activities Eligible for
Funding to Comply With the FBRR
Tvoe of Project/Activity ENgible Under ENgible Under
lype or project/Activity infrastructure Fund Set-Asides
Install piping to move Y
recycle to headworks
Upgrade backwash Y
pumping capacity
Planning & Design Activities Yes
Recycling Reporting No
System Administrative Improvements
Hire Staff No
Staff Training No
Public Outreach No
Monitoring No
Rate Increase Process No
State Administrative Improvements
Hire Staff No
Staff Training No
Public Outreach No
Compliance Oversight No
Enforcement No
Pilot Studies No
                                              *For small systems only.
      DWSRF and FBRR
 DWSRF Website:
  FBRR Website:
      General Information
SDWA Hotline
EPA's Ground Water & Drinking
Water Website:
Office of Ground Water and
Drinking Water (4606M)


June 2002
Printed on Recycled Pape