Water Reuse

Recommendations for Federal Regulations

Currently there are no federal regulations that govern water reuse. The US EPA has produced some guidance and there are some federal regulations that certainly have some relevance to reuse situations, but the current federal regulatory environment may not be sufficient.

Non-potable Reuse
National regulations governing non-potable reuse should be developed. While EPA's "Guidelines for Water Reuse" document is extensive and informative, the instructions contained within it are merely recommendations. Full federal regulations should be developed in order to establish uniform compliance with a national standard. While local control and flexibility is desirable, it is important to set minimum national standards for these activities. This will ensure a national minimum level of public health protection and increase public confidence in what for many is a very new technology.

Potable Reuse
The area of potable reuse, both direct and indirect, requires additional federal attention as well. One area of particular concern for reclaimed potable water is the risk to public health from microbial contaminants. Currently there are several federal regulations on the books that address microbial contamination. These regulations were developed at a time when reuse was not considered as a viable option, and therefore they did not take into account the possibility of reuse. These regulations need to be reexamined in order to determine if any adjustments should be made for situations that involve reclaimed water.

There are several questions that need to be answered. Does a direct potable reuse source fall into the category of surface water, groundwater, or should a third category be invented? Do aquifers that have received recharge from wastewater treatment facilities have the same level of safety as those that haven't, and if not, does the Ground Water Rule adequately account for these differences? Do current disinfection processes under the Disinfection By-Products rules need to be adjusted when treating reclaimed water? Finally, are all potential public health risks from reclaimed water captured by the current list of regulated contaminants or should other substances, such as pharmaceuticals and personal care products, be regulated as well? These questions are only examples of the many complex issues that must be addressed in order for confidence in potable reuse to be established. Only a thorough review of all regulations in the context of water reuse situations will make this possible.