Advancing Safe And Sustainable Water Reuse In Minnesota

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Advancing Safe and Sustainable WaterReuse in Minnesota2 0 1 8 REP ORT OF THE I N TERAGEN CY WORK GROU P ON WATER REU SE

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAAdvancing Safe and Sustainable Water Reuse in MinnesotaMinnesota Department of HealthEnvironmental Health DivisionPO Box 64975St. Paul, MN mn.uswww.health.state.mn.us/waterreuseAs requested by Minnesota Statute 3.197: This report cost approximately 50,000 to prepare, including staff time,printing and mailing expenses.Upon request, this material will be made available in an alternative format such as large print, Braille or audiorecording. Printed on recycled paper.1

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAContentsAdvancing Safe and Sustainable Water Reuse in Minnesota . 0Figures . 4Tables . 5Acronyms . 6Report Contributors . 7Executive Summary. 8Introduction . 9Why Consider Water Reuse in Minnesota? . 9Increasing Interest in Reuse. 10Benefits, Costs and Risks of Water Reuse. 12Workgroup Establishment/Goal, Objectives, and Activities. 14Definition of Successful Water Reuse. 16State Agencies’ Current Roles in Water Reuse . 16I.Recommendations . 21Recommendation a. Create an expanded workgroup with practitioners, advisors andstakeholders. 23Recommendation b. Prioritize research needs and integrate ongoing research. 23Recommendation c. Define roles and responsibilities . 24Recommendation d. Establish an information and collaboration hub on the web . 25Recommendation e. Develop a risk-based management system . 26Recommendation f. Develop water quality criteria for a variety of reuse systems based onthe log reduction target approach for pathogens . 29Recommendation g. Resolve unique issues related to graywater reuse . 30Recommendation h. Provide education and training. 31II. Water Reuse in Minnesota. 32Wastewater Reuse . 33Stormwater and Rainwater – Outdoor Reuse . 39Stormwater and Rainwater – Indoor Reuse . 43Graywater Reuse. 45Additional Reuse Categories . 47Variances for Indoor Stormwater, Wastewater and Graywater Reuse. 50Funding Sources for Reuse. 512

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAIII.Water Reuse in other Jurisdictions . 53States. 53Counties and Municipalities. 56International . 57IV.Managing the Human Health Risks of Nonpotable Water Reuse . 59Reasons to Consider Human Health . 59An Approach for Addressing Human Health Risk . 60Applications of the Log Reduction Approach . 60What the Log Reduction Approach Looks Like to End Users. 62Protecting Health through Proper Storage and Distribution. 64References. 65Resources . 67US Resources. 68International Resources . 70Other Jurisdictions in the US (States, Counties, and Municipalities) . 70Appendix A. Surveys. 73Minnesota Technical Assistance Program Survey . 73Municipal Separate Storm Sewer System (MS4) Survey . 73Water Reuse Interagency Workgroup Survey . 73Appendix B. Stakeholder Participation . 88Stakeholder List. 88Stakeholder Meeting Summaries. 89Appendix C. Liability Risks. 96Insurance Companies. 96Attorney Perspective . 96States and Local Governments . 963

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAFiguresFigure 1. Some Factors to Consider in Exploring Reuse. 12Figure 2. Potential Exposure Pathways. 14Figure 3. Common types of water reuse projects in Minnesota by source and end use(estimations) . 33Figure 4. Treated wastewater used for golf course irrigation, Shakopee Mdewakanton SiouxCommunity. 34Figure 5. Nonpotable Wastewater Reuse: Current Regulatory Path. 36Figure 6. Stormwater irrigation system for residential landscape irrigation in city of Carver,Carver County. Homeowners’ association will manage system. . 40Figure 7. Large stormwater pond in Waconia will serve new commercial lots along Highway 5 aspart of a regional reuse system the city will manage. Water will also be used for streetsweeping. . 42Figure 8. Schematic of rainwater/stormwater harvesting system from Minnesota StormwaterManual . 44Figure 9. Shower building at Lake Vermilion State Park. Photo: SRF Consulting . 46Figure 10. Dewatering mine pit in Hibbing . 49Figure 11. Log Reduction. 61Figure 12. County project is located in . 74Figure 13. Year project was implemented. 75Figure 14. Which permits were obtained for the project? . 77Figure 15. Source of water reused. 78Figure 16. Is there a backup water source? . 78Figure 17. What is the backup water source? . 79Figure 18. Primary uses of reused water in reported projects. 80Figure 19. Types of water reuse irrigation projects reported . 80Figure 20. Distribution of project capital costs. 81Figure 21. Distribution of project annual operating and maintenance costs. 81Figure 22. Types of monitoring reported. 82Figure 23. Conducting public outreach for water reuse project . 83Figure 24. Difficulties in project implementation . 84Figure 25. May we contact you? . 874

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTATablesTable 1. State Water Management Agencies’ Roles, Statutory Authorities, and GuidancePertaining to Water Reuse. 18Table 2. Reuse Regulation or Guidance by Water Source . 20Table 3. Recommendation Time Frames and Dependencies . 22Table 4. Potential Risk Management Categories in Minnesota. 27Table 5. Potential Reuse Scenarios by Risk Category and Roles. 285

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAAcronymsThe following names are used toreference certain reports in the text:BMPsBest Management PracticesBWSRBoard of Water and Soil ResourcesCSWConstruction StormwaterDLIDepartment of Labor and IndustryDPRDirect Potable ReuseDNRMinnesota Department of NaturalResourcesFSMAFood Safety Modernization ActIPRIndirect Potable ReuseISWIndustrial StormwaterMDAMinnesota Department of AgricultureMDHMinnesota Department of HealthMPCAMinnesota Pollution Control AgencyMS4Municipal Separate Storm Sewer SystemNPDESNational Pollutant Discharge EliminationSystemO&MOperation and MaintenanceRMEResponsible Management EntitySDSState Disposal SystemSDWASafe Drinking Water ActSWCDSoil and Water Conservation DistrictUMNUniversity of MinnesotaUSDAU.S. Department of AgricultureUSEPAU.S. Environmental Protection AgencyWE&RFWater Environment & Reuse Foundation 1“Australian Guidelines” - AustralianGuidelines for Water Recycling:Managing Health and EnvironmentalRisks 2006 (Phase 1) and AustralianGuidelines for Water Recycling:Managing Health and EnvironmentalRisks (Phase 2) Stormwater Harvestingand Reuse, 2009 (Natural ResourceManagement Ministerial Council,Environment Protection and HeritageCouncil, & Australian Health MinistersConference)“National AcademiesGraywater/Stormwater Report” - UsingGraywater and Stormwater to EnhanceLocal Water Supplies: An Assessment ofRisks, Costs, and Benefits (NationalAcademies of Sciences, Engineering, andMedicine)“USEPA 2012 Guidelines” - 2012Guidelines for Water Reuse (U.S.Environmental Protection Agency)“WE&RF Report” - Final Report: RiskBased Framework for the Developmentof Public Health Guidance forDecentralized Non-Potable WaterSystems (published by the WaterEnvironment & Reuse Foundation)1The Water Environment & Reuse Foundation is undergoing a mergerand will be called “The Water Research Foundation” in the future.6

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAReport ContributorsThe Minnesota Legislature directed the Minnesota Department of Health to “prepare acomprehensive study of and recommendations for regulatory and non-regulatory approachesto water reuse for use in the development of state policy for water reuse in Minnesota,” withfunding through the Clean Water Fund of the Clean Water, Land and Legacy Amendment. Thelist below includes Water Reuse Interagency Workgroup representatives.Minnesota Department of HealthRandy Ellingboe, Jim Kelly, Anita Anderson (Project Manager), Nancy RiceBoard of Water and Soil ResourcesSuzanne Rhees (Technical Writer), Marcey WestrickDepartment of Labor and IndustryJim Lungstrom, Cathy Tran, Bob Johnson, John Parizek (Minnesota Plumbing Board)Department of Natural ResourcesJulie Ekman, Dan MillerMetropolitan CouncilBrian Davis, Deborah ManningMinnesota Department of AgricultureDan Stoddard, Ron Struss, Jan KellyMinnesota Pollution Control AgencyScott Fox, Randy ThorsonUniversity of Minnesota Water Resources CenterFaye Sleeper, Sara HegerCharlie Petersen and Kristina Krull of Management Analysis and Development - MinnesotaManagement and Budget facilitated the project. Emmy Waldhart of the Minnesota Departmentof Health copyedited the report.7

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAExecutive SummaryWater reuse will be an increasingly important part of managing Minnesota’s water resources asdemands on our water supplies continue to grow due to population increases, urbanization,climate change, increased irrigation and industry growth. Water reuse is happening acrossMinnesota. Despite increasing interest in water reuse, there is no comprehensive statewideguidance or policy on water reuse. In 2015, the Minnesota Legislature directed the MinnesotaDepartment of Health to:“Prepare a comprehensive study of and recommendations for regulatory and nonregulatory approaches to water reuse for use in the development of state policy for waterreuse in Minnesota” (Session Law 2015, 1st special session, Chapter 2, Article 2, Section 8).The Clean Water, Land and Legacy Amendment provided funding for this project. In response tothe Legislature’s directive and funding, the Water Reuse Interagency Workgroup (“Workgroup”)formed including representatives from the Departments of Agriculture, Health, Labor andIndustry, and Natural Resources, the Minnesota Pollution Control Agency, Board of Water andSoil Resources, Metropolitan Council and the University of Minnesota Water Resources Center.The Workgroup: Defined successful water reuse.Collected and assessed information on 1) water reuse in Minnesota, 2) water reuse in otherstates and nations and 3) ways to manage human health risks posed by water reuse.Sought stakeholder perspectives through surveys and meetings.The Workgroup used the information to develop Minnesota-specific recommendations for stateand local governments, non-governmental organizations, businesses and industries to considerin developing regulations and guidance for water reuse. The recommendations are:a. Create an expanded workgroup with practitioners, advisors and stakeholders to continuedevelopment of standards and programs.b. Prioritize research needs and integrate ongoing research to address questions about reuse.c. Define roles and responsibilities to oversee and monitor water reuse.d. Establish an information and collaboration hub on the web to share information andresources.e. Develop a risk-based management system to determine if regulation or guidance isneeded.f. Develop water quality criteria for a variety of reuse systems based on the log reductiontarget approach for pathogens to manage human health risks.g. Resolve unique issues related to graywater reuse to determine the feasibility of expandinggraywater reuse.h. Provide education and training to support water reuse.This research, report and recommendations can help assist decision makers and stakeholders insetting a course of action to advance safe and sustainable water reuse in Minnesota.8

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAIntroductionWhy Consider Water Reuse inMinnesota?DefinitionsThere are many definitions of water reuse and thesources of water for reuse. The definitions below wereselected by the Workgroup primarily because they areconsistent with Minnesota’s system of watermanagement.Minnesota has historically been known as awater-rich state, with a substantial supply ofgroundwater, many lakes and rivers, andfrequent rainfall. However, there are limits tothose water supplies.Reuse: The capture and use of stormwater,wastewater and subsurface water to meet waterdemands for intentional and beneficial uses.Three of four people in Minnesota get theirdrinking water from groundwater sources(1.1 million private well users and 2.9 millionon public water supplies). Groundwater is notevenly distributed across the state, and someareas are beginning to feel stress fromquality and/or quantity issues ̶ such as thesouthwest and Twin Cities Metropolitan area.Minnesota increased its groundwater use by35 percent over the past 25 years, and usecontinues to increase (MinnesotaEnvironmental Quality Board, 2015). Changesin weather patterns, increased population,increased irrigation demands and growth inindustries that require high water input havestarted to stress Minnesota’s waterresources. Depletion of groundwaterreserves in some locations has focusedattention on the need for more efficient useof water.Categories of Source Water:Stormwater: Water generated by rainfall or snowmeltthat causes runoff. 2Rainwater (subset of stormwater): Water generatedby rainfall or snowmelt that can be collected directlyfrom roof surfaces.Wastewater: Used or discharged water from homes,institutional or public buildings, commercialestablishments, farms or industries.Domestic wastewater (subset of wastewater): Usedwater from bathing, laundry, toilet, kitchen or similarsources.Graywater (subset of wastewater): Wastewatersegregated from a domestic wastewater collectionsystem, typically from laundry and bathing waterIndustrial process wastewater (subset ofwastewater): Wastewater generated by industrialprocesses, including backwash water and condensate.Subsurface water: Water collected from below theground surface to maintain the structural integrity of abuilding, discharged through dewatering, or pumpedfor pollution containment.In addition to reducing groundwater use,water reuse offers multiple other benefits ̶such as managing stormwater ̶ as discussedfurther below.Categories of End Uses:Nonpotable uses: flushing, irrigation, cooling,washing, industrial processesPotable uses: drinking, culinary and bathingStormwater withdrawn from constructedmanagement facilities is exempt from DNR waterappropriation permitting.29

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAIncreasing Interest in ReuseIn the past decade, interest in water reuse has rapidly increased. Municipalities, watersheddistricts and watershed management organizations, businesses, industries and developers haveinstalled projects or are considering doing so. A survey conducted by the Workgroup in summerof 2016 (Water Reuse Interagency Workgroup Survey) indicated that 22 out of 31 projects hadbeen installed between 2010 and 2016.Despite the increased interest in reuse, Minnesota, like many other states, lacks acomprehensive, statewide approach to guide municipalities, industries and other partiesinterested in implementing water reuse. Various Minnesota agencies, including the MPCA, DNR,DLI, BWSR and MDH, all play a role in water reuse. Agencies oversee and regulate managementand discharge of wastewater and stormwater, water appropriations, water and wastewaterinfrastructure, protection of public health and safety, standards for contaminants ingroundwater or surface water and standards for water used in food production and processing.However, for most types of reuse, clear guidance on best practices and an understandableregulatory path are lacking.A number of reports and workshops have pointed to the need for better guidance.The UMN Water Resources Center produced the Minnesota Water Sustainability Framework in2011 to guide the work of the Clean Water Fund. The framework called on state agencies toplan for water reuse. Specifically, the recommendations were that the state agencies, inconsultation with outside experts, should: Identify and evaluate all water reuse strategies and applications.Recommend applications relevant to Minnesota’s seasons, geographical water use, soiltypes, and rainfall.Recommend an implementation strategy.The framework also called for the MPCA and MDH to work together to set appropriatestandards for water reuse applications identified in the recommendations.The Environmental Quality Board’s 2015 Water Policy Plan, “Beyond the Status Quo,”recommends the following regulatory solution:“Update plumbing codes and treatment standards to allow for safe and practical water reuse.Water withdrawn from Minnesota aquifers, streams and lakes is rarely reused, even thoughthe water (or treated wastewater) remaining after use is clean enough to be reused forindustrial and agricultural purposes. This single-use habit puts unnecessary pressure on watersupplies.” (EQB, 2015, p. 9)The Freshwater Society convened a workshop on reuse in May 2016. Attendees were asked toidentify barriers to rainwater and wastewater reuse. A summary of the top five responses isbelow (Freshwater Society, 2016, p. 13).Rainwater1.2.Cost is high, and potable water is inexpensive.Lack of state or national policies/guidelines for oversight and management of decentralizednon-potable water systems.10

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTA3.4.5.Lack of water quality/performance standards for decentralized water systems.Water appropriations permits and reporting processes are discouraging.Not enough public health or risk data.Wastewater1.2.3.4.5.Cost is high, and potable water is inexpensive.Treatment requirements are not in line with use.High chlorides in treated wastewaters is a challenge for industrial reuse.Lack of state or national polices/guidelines for oversight and management of decentralizednon-potable water systems.Lack of water quality data on alternate water sources.The Metropolitan Council developed one of the first guidance documents specifically forstormwater reuse in Minnesota. The 2011 Stormwater Reuse Guide includes case studies, a“toolbox” of resources and worksheets and links to other resources.In 2016, the MPCA worked with consultants and an advisory group to update the MinnesotaStormwater Manual and expand the section on stormwater harvest and reuse. The sectionexpansion included a thorough review of benefits and other considerations, an overview of thefour phases of project development (feasibility, pre-design, design and implementation) andguidance on water quality standards. The manual states that Minnesota-specific water qualityguidelines for stormwater reuse for irrigation are to be “determined at a later date.”Groups working on stormwater management, such as the Minimal Impact Design Standards(MIDS) workgroup, asked MDH to recommend water quality standards for nonpotableapplications. In addition, the Minnesota Plumbing Board (which was in the process of adoptingthe Uniform Plumbing Code for use in Minnesota) had an interest in adopting chapters onalternate sources of water, especially harvested rainwater and also asked MDH’s opinion onwater quality standards.MDH was asked to participate in national groups to develop the Blueprint for Onsite WaterSystems: A Step-by-Step Guide for Developing a Local Program to Manage Onsite WaterSystems and the WE&RF report. Additionally, MDH, the Metropolitan Council and the City ofEagan are members of the National Blue Ribbon Commission for Onsite Non-potable WaterSystems. Since 2016 the commission has been serving as a forum for collaboration andknowledge exchange. Projects have included: A model state guidance and policy framework for distributed non-potable water programs.Resources for water utilities based on best practices and lessons learned in the design,development, integration, and operation of Onsite Non-potable Water Systems (ONWS).Identification of additional research needs in the field.To gain a better understanding about potential health risks from water reuse systems, MDHcontracted with UMN to study the microbial water quality of two water reuse systems: astormwater irrigation system and a rainwater collection system used for flushing toilets in abuilding. Air samples were also collected from the irrigation system while it was in operation. AMDH document Water Reuse System Sampling Results Summary summarizes initial results, andmore detailed information will be available in 2018.11

ADV ANCING SAFE AND SUSTAINABLE WATER REUSE IN M INNESOTAA UMN study funded by the Legislative-Citizen Commissionon Minnesota Resources, Maximizing the Benefits of WaterReuse, is currently underway to assess the water quality ofreuse systems. The goal of this project is to provide pathogendata needed to properly assess the risks of water reuse.Figure 1. Some Factors toConsider in Exploring ReuseBenefits, Costs and Risks of Water ReuseThe increasing interest in implementing water reuse projectshas sparked discussions in the water reuse community aboutthe benefits, costs and risks of water reuse. The followinginformation provides a brief overview of some of the benefits,costs and risks discussed by the Workgroup and stakeholders.BenefitsWater reuse can reduce demands on Minnesota’s groundwaterand surface water supplies. Reuse - along with other water conservation strategies - can saveenergy, improve water quality and reduce the impacts of land use and development on lakes,streams and groundwater. Reuse can also help meet some water demands locally, such asdemands for irrigation, reducing the need to expand centralized water utilities.Stormwater reuse for irrigation is one of the most common reuse scenarios currently beingimplemented in Minnesota. Examples of stormwater reuse projects developed in the pastdecade can be found in the Minnesota Stormwater Manual. The Minnesota Association ofWatershed Districts Water Reuse Benefits Information Sheet (2017) cites the benefits ofstormwater reuse for irrigation:“Stormwater reuse irrigation projects reduce the amount of stormwater that flows out of awatershed by capturing and distributing it over a vegetated surface through irrigation. Thisreclaimed water evaporates during irrigation, evapotranspirates through plants, or percolatesthrough the soil where it has the potential to replenish local groundwater supplies. Reuseirrigation projects benefit groundwater resources by reducing consumption of availablegroundwater supplies. Properly designed stormwater reuse systems can meet a significantportion of annual irrigation demand.”Cities and watershed districts are generally required to reduce the volume of stormwaterleaving a development site, as required by MS4 or CSW permits. Reuse of stormwater has beenan effective strategy for managing stormwater discharges. In areas where infiltration ofstormwater is impractical due to tight or waterlogged soils, reuse of stormwater is often theonly practical option. Reuse also allows for shallow recharge of local groundwater throughirrigation, or conservation of potable water supplies through indoor uses such as vehiclewashing or toilet flushing.CostsThe economic feasibility of reuse projects is often unclear, due to costs of energy, installation,O & M of infrastructure and equ

Guidelines for Water Recycling: Managing Health and Environmental Risks 2006 (Phase 1) and Australian Guidelines for Water Recycling: . regulatory approaches to water reuse for use in the development of state policy for water reuse in Minnesota" (Session Law 2015, 1st special session, Chapter 2, Article 2, Section 8).

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