ENVIRONMENTAL PROTECTION  AGENCY  £. ?.A. :•::•;!•»' 4 '.


       "JUL   7 1972
WASHINGTON, D.C.  20460            .   ..   t     PM'7?
                                 JUL
    to
Attn of:
Subject:  EPA Policy Statement on Water  Reuse

   To:  All Regional Administrators
            The Office of Air  and Water  Programs  and the Office of Research
       and Monitoring have  jointly  prepared  the attached EPA Policy Statement
       on Water Reuse and the  accompanying Water  Reuse Background Statement.

            These documents are  for your guidance and for distribution as you
       see fit,,
                                             ~
                                               Robert I/. Sansom
                                            Assistant Administrator
                                           for Air and Water Programs
       Attachment

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                     EPA POLICY STATEMENT ON  WATER REUSE
The demand for water is increasing both through  population growth and changing
life styles, while the supply of water from nature remains basically  constant
from year to year.  This is not to imply that we are or will shortly  be  out
of water, although water shortages are of great  comcern in some  regions  and
indirect reuse has been common for generations.   Vfe must recognize the need
to use and reuse wastewater.  Therefore,

     1.  EPA supports and encourages the continued development and practice
         of .successive wastewater reclamation, reuse, recycling and recharge
         .as a major element in water resource management,  providing the  rec-
         lamation systems are designed and operated so as  to avoid health
         hazards to the people or damage to the  environment.

     2.  In particular, EPA recognizes and supports the potential for waste-
         water reuse in agriculture, industrial, municipal,  recreational and
         groundwater recharge applications.

     3.  EPA does not currently support the direct interconnection of waste-
         water reclamation plants with municipal water treatment plants.
         The potable use of renovated wastewaters blended  with other  accep-
         table supplies in reservoirs may be employed once research and
         demonstration has shown that it can be  done without hazard to health.
         EPA believes that other factors must also receive consideration,  such
         as the ecological impact of various alternatives, quality of avail-
         able sources, and economics.

     4.  EPA will continue to support reuse research and demonstration projects
         including procedures for the rapid identification and removal of  vi-
         ruses and organics, epidemiological and toxicological analyses  of
         effects, advanced waste and drinking water treatment process design
         and5operation, development of water quality requirements for various
         reuse opportunities, and cost-effectiveness studies.

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                              WATER REUSE
Background

While indirect and delayed reuse of water has many accepted applications,  the
direct application of measures to reuse wastewaters for constructive purposes
presents both new opportunities and new problems.  Direct reuse is currently
being conducted in a number of places for specific purposes; in fact, Cali-
fornia reported in 1969 over 200 non-potable reuse situations.  Reuse is
being applied for a number of purposes, including industrial use for cooling
purposes, for groundwater recharge to prevent salt water intrusion in coastal
areas; as a source for recreational waters; for irrigation and other agri-
cultural uses, not involving direct contact with food surfaces; and for other
uses.  An appendix is included for definition of direct and indirect reuse
and discussion of the differences related thereto.

The potential for water reuse, as a tool in broad water resources and water
quality  planning, is many times greater than current practice and should be
routine  y considered and developed to meet non-potable demands.  As could be
expected, activity with regard to reuse appears to be much intensified in
water-short areas of the country, for instance in the arid West.  The Water
Resources Council (WRC) report, "The Nation's Water Resources, 1968" cites
water shortage problems in 9 basins--Arkansas-White-Red; Texas-Gulf; Rio
Grande;  Upper Colorado; Souris-Red-Rainy; Missouri; Lower Colorado; Great
Basin; and California—and pointedly shows that these problems will worsen
by 2020  unless remedial measures are applied.

In addition to. reuse of wastewaters, attention is being given to weather
modification, desalination, water conservation, interbasin transfer, tap-
ping of  the geothermal deep-water reservoirs and other approaches to con-
serve existing as well as tap new sources.  Reuse should be considered in
the light of water quality, environmental, ecological and economic aspects
as well  as the public health aspects; it should provide a vital link in
meeting  needs in water short areas.
                                                                    \
                                                                    >
Reuse Application and Public Health Problems

Taking a national view of fresh water demands, it may be seen from the
1968 WRC report  that for 2020, electric power (cooling water) will be
first in demand  (410 BCD); self-supplied industrial, second (210 BCD); ir-
rigation, third  (161 BCD); and municipal, fourth (74 BCD); with minor residue
demands  for livestock and rural domestic.  Logically, one would expect that
priorities for reuse would pattern after demand with electric power (cooling)
first, industrial second, etc.  Such a pattern of application would ideally
suit health protection-water quality relationships since cooling and most
industrial uses would present low health risks; irrigation for some crops
would be potentially hazardous, but not for others; and municipal uses would
offer the greatest human contact and the largest potential danger.

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 The  problem may  not  be  handled  so  simply on gross utilization terms since each
 call for water reuse will  be  situational,  depending on geographic location,
 climate, public  attitudes,  the  availability of wastewater sources and of po-
 tential  water users, etc.   One  community may be non-conservative in utilizing
 its  fresh  waters and be willing to treat and recycle wastewaters in order to
 continue its  easy-water practices  while another community with a similar po-
 licy and. an abundant supply of  cheap water may be unwilling to treat and re-
 cycle wastewater just  to  conserve  water for use by others—for instance for
 irrigation or municipal purposes elsewhere.  In one case, a needy municipal-
 ity  may  be in a  position  to utilize, industrial wastewaters and in another
 case a needy  industry may  be  situated  so as to use municipal wastewaters.
 In any event  the technology is  available for the treatment and reuse of many
 wastewaters for  many purposes and  such reuse should be broadly considered
 in the management of water resources.

 Public health problems  do  occur and require attention as follows:

      1.  Industrial:   The  reuse of water by industry should be encouraged
         where it is technically and economically feasible.  Quality needs
         for  industrial uses  vary  so widely that it is not possible to
         generalize  on  this subject; however, except for food processing
         industries, they  are usually  lower than drinking water requirements.

      2.  Groundwater Recharge:   Groundwater recharge can be used to raise or
         maintain the  level of  groundwater and/or to prevent the intrusion of
          salt water.   For  most  recharge applications through spreading and
         percolation of reuse waters on the surface, quality requirements
/  .        for  health  protection  would be enhanced by natural filtering pro-
          cesses.  However,  percolation into a shallow basin used for drink-
          ing water supply  should receive careful attention and the recharge
         of reuse water by subsurface  injection should not be implemented
         without strict controls and a clear demonstration that such dis-
         posal will  not harm  present or potential subsurface water supplies
         or otherwise  damage  the environment.

      3.  Recreation:  Indirect  reuse of water for primary contact recrea-
          tional  purposes  is clearly recognized in the section on recreational
          uses  in Water Quality  Criteria  by way of the recommended limits for
          fecal  coliform organisms  and  the  recommendation that sanitary sur-
         veys  be conducted to determine the degree of threat of pathogens
          from specific sources.                                    •'

          The  hazards associated with direct contact recreation in waters re-
          ceiving inadequately treated  waste discharges are chiefly biological
          and  are usually  associated with the transmission of infectious di-
          seases  that may  enter  the body through the mouth or nasal passages
          or other portals  such as the eyes, and certain areas of the skin.
          Numerous examples may  be  given of both direct and indirect use of
          treated wastewaters  for recreational purposes and this appears to be

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         a valid practice where health requirements  can  be met.  However,
         much remains to te known about the  health relationships of water
         quality and recreational use.  For  example, water high in nutrients
         may serve as a culture for pathogenic  bacteria. Further research
         and epidemiological investigations  into water quality and health re-
         lationships are urgently needed.

     4.   Irrigation:  The reuse of waters  for irrigation is  and should be a
         satisfactory mode of reuse.  Water  quality  requirements for  crop
         protection relate primarily to salinity and toxic compounds.  For
         irrigation of non-food or shelled-food crops health considerations
         would be minimal but for irrigation of other food crops or of pas-
         turage for food-animals, the hazards are  significant unless  the
         water is adequately treated.  Much  study  and development of  safe-
         guards should precede this latter use.   :

     5.   Municipal:  The concurrent use of the  Nation's  rivers and lakes for
         both water supply and waste disposal has  been practiced for  many
         years in many areas of the country.  It is  estimated that 50% of
         the Nation's population now derives their water supply from  sur-
         face sources which have also received  a variety of  industrial wastes,
         untreated sewage, urban runoff and  effluent fron a  variety of sewage
         treatment plants.  Public health  officials  have relied upon  time of
         travel or storage and treatment to  protect  the  public against infec-
         tious diseases and toxic substances.   Water quality standards and
         treatment requirements applicable to surface sources used for water
         supply have permitted the discharge of relatively high quantities
         of wastes.  The continuing development of new advanced wastewater
         treatment technologies and implementation of.new standards will
         necessitate a reappraisal of historical philosophies.

         Indirect reuse for municipal public water supply is a fact of life;
         however, direct reuse is a new matter  requiring careful research and
         investigation before introduction.  Currently,  there is insufficient
         data to support safety of direct  interconnection of wastewater rec-
         lamation plants into municipal water supplies.   However, the direct
         connection of municipal renovated water to  supply industrial water
         needs is desirable and should be  exploited  where practical.

Health problems in a direct interconnection  or  in  a  recycling situation re-
late to viruses, bacterial build-up, chemical build-up,  the  possibility of
accidental spills or sabotage and a record of questionable reliability in
the operation of wastewater treatment plants.   Viruses are difficult  to
identify and measure and are more resistant  to  disinfection  than bacteria.
Carbon columns and other possible advanced waste treatment elements may har-
bor bacteria or their metabolites and contribute to  the  development of un-
healthful levels of bacteria in a recycling  situation.

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The direct introduction of chemicals from a waste-stream and their build-up
through potable system-waste system recycling can present increased long-
term chronic hazards, presently undefined.  Accidental-spills or sabotage
present an acute threat which cannot be disregarded, as anyone can throw any-
thing down the drain.  Because of these, even if orher.obiectionable problems
were solved, some system of holding and dilution, reservoirs  may inevitably
need to be provided between the reclamation plant and the potable water in-
take together with biological and chemical monitoring.  With regard to the
reliability of reclamation plant operation, studies  in California have shown
that 60% of wastewater treatment plants studied had some breakdown during the
year.  Observations of engineers and others confirm that reliability is a com-
mon problem in wastewater treatment plants; safeguards must be provided to
prevent the introduction of non-treated or poorly treated wastes into a potable
water system.

Conclusions                                   ,                     .    .

     1.  The purposeful reuse of treated wastewaters has a large potential
         in helping to meet water supply needs.   Expansion of reuse as a
         tool of water quality and water resources management should be
         encouraged as long as measures are taken to protect the public
         health.

     2.  We do not have the knowledge to support the direct interconnection
         of wastewater reclamation plants into municipal water supplies at
         this time.  The potable use of renovated wastewaters blended with
         other acceptable supplies in reservoirs may be employed once re-
         search and demonstration has shown that all of the following con-
         ditions would be met:                ...       .        ..

         a)  protection from hazards to health

         b)  offers higher quality than available conventional sources

         c)  results in less adverse ecological impact than conventional
             alternatives

         d)  is tested and supplied using completely dependable chemical
             and biological control technology

         e)  is more economical than conventional sources

         f)  is approved by cognizant public health authorities

     3.  An accelerated research and demonstration program is vitally needed to:

             Develop basic information and remedial measures with respect to •
             •viruses, bacteria, chemical build-ups, toxicological aspects and
             other health problems.  Develop criteria and standards to assure
             health protection in connection with reuse.

             Upgrade the treatment process design and operation so as to as-
             sure continuously safe service to the public.  Provide economic
             an'd other analyses to facilitate the planning and design of ef-
             fective regional solutions to problems of water-shortage and
             water quality.

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\J  Water Quality Criteria,  Report of the National Technical Advisory
  -  Committee to the Secretary of the Interior,  April 1,  1968.

2j  Ongerth,  H.J., Jopling,  W.F., and Deaner,  D.G.  Fitness  Needs for
    Wastewater Reclamation Plants, J. American Water Works Assn., Oct.,  1971,

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            APPENDIX: . DEFINITIONS AND DISCUSSION OF DIFFERENCES
                        FOR DIRECT AND INDIRECT REUSE
Definitions are derived from a report of the National  Water Commission,
"Wastewater Reuse," by Jerome Gavis,  July 1971,  as follows:

     1.  Direct Reuse:  is the direct routing of treated wastewater
         effluents to the point of use.

     2.  Indirect Reuse:  is the discharge of treated  wastewater where
         it is subjected to natural purification processes and dilution
         before being withdrawn for use.
Differences in the two types of reuse that must be considered in any
drinking water application are as follows:

     1„  Direct reuse is more vulnerable to sabotage, operational
         failure and the accidental spill of toxic or hazardous sub-
         stances into the water-wastewater system.  The provision of
         fail-safe equipment, processes and holding reservoirs may be
         necessary to meet this problem.

     2.  Direct reuse allows no margin for error in the destruction
         of pathogenic viruses, bacteria and other microorganisms.
         v*>     '•   ,
     3o  Direct reuse could result in the buildup of trace substances
         to many times their usual concentration; 'depending on the
         degree of reuse and the efficiency of treatment, the con-
         centration factor could run up to nine times.

Many of the factors influencing direct reuse may come into play for
indirect reuse.  If the time and dilution factors before indirect
reuse are small, the impacts of dilution and natural purification
may be minimal.  Yet the question of what time and dilution factors
are adequate cannot be answered on the basis of today's knowledge.
Research to acquire new basic knowledge  and common sense in the
application of today's limited knowledge  is essential.  Also, it
is essential that each reuse situation be treated on an individual
basis, taking into account all factors.

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