TCEQ Trade Fair

Joel KlumppTexas Commission on Environmental Quality

TCEQ Review Process for Innovative Water Treatment

Technologies

Drinking Water OnlyDrinking Water Only

• This presentation is focused on Drinking Water approval processes, NOT:• Wastewater

• Air

• Water Rights

• Anything else

DESALINATIONDESALINATION

In the Distant Past (2012)In the Distant Past (2012)

• Currently TCEQ has design requirements in rule• Exception process for anything not in

the design rule

• Desalination and membrane processes not in the rule, thus require an exception.• And require a pilot study

MissionMission

• To identify a solution to streamline the TCEQ drinking water processes involving approval of brackish groundwater desalination while assuring the required quality and quantity of drinking water. To work with a balanced group of stakeholders to identify potential alternatives to pilot studies for membrane filtration that provide solutions in developing new water supplies for the state and gather necessary information to support the regulatory program requirements.

Stakeholder Process GoalsStakeholder Process Goals

• A new staff guidance document for a streamlined approval process

• New process finalized by January 1, 2013

• Posted to TCEQ’s web page

Stakeholder Process ResultsStakeholder Process Results• Staff guidance document with approval

process posted on TCEQ’s webpage at:

www.tceq.texas.gov/goto/desal

• To further assist drought stricken communities, the TCEQ will offer concurrent reviews of plans, specifications and exception requests for brackish groundwater RO plants

But we didn’t stop there…But we didn’t stop there…

• TCEQ initiated new rules which are slated for adoption on July 1, 2015

• These rules include design criteria for reverse osmosis and nanofiltration for the removal of salts or inorganic contaminants

• Once adopted, public water systems will no longer need an exception but will still need plan approval

The proposed rules:The proposed rules:

• Allow for computer model results in lieu of pilot testing to demonstrate that treatment for chemicals will be effective

• Cannot be used for approval of pathogen treatment

• Allow for treatment process approval for primary contaminants such as Arsenic, Fluoride, and Nitrate

You may not need a pilot…You may not need a pilot…

• There are other options besides pilot studies:• Alternative site data

• Pilot in place • for systems already using the water

• Full-scale verification study

• Contact us!

REUSEREUSE

Wastewater ReuseWastewater Reuse

• Wastewater reuse as a water management and conservation tool. Reuse activities include:

• Irrigation

• Industrial processes

• Hydraulic fracturing

• Fire protection

• Construction: dust suppression/soil compaction

• WWTP on-site use

• Potable Reuse

Potable Reuse

Figure taken from 2012 EPA Guidelines for Water Reuse

DefinitionsDefinitions

• De facto reuse: A situation where reuse of treated wastewater is, in fact, practiced but is not officially recognized

• Direct Potable Reuse (DPR): The introduction of reclaimed water (with or without retention in an engineered storage buffer) directly into a drinking water treatment plant, either collocated or remote from the advanced wastewater treatment system

• Indirect Potable Reuse (IPR): Augmentation of a drinking water source (surface or groundwater) with reclaimed water followed by an environmental buffer that precedes drinking water treatment

Potable Reuse in TexasPotable Reuse in Texas

• Two plants in operation

• One plant with construction approval

• One PWS preparing to pilot test their proposed treatment process

• Many other PWSs have expressed interest…

TCEQ ApproachTCEQ Approach• Case-by-case basis• Drought response• Require a pilot study (or verification test)• Start counting credits after WWTP• Sum of removal and inactivation credits

must meet or exceed minimum treatment required

• No requirement for storage• No pathogen treatment credit for RO

Factors to ConsiderFactors to Consider• Water Rights

• No real-time pathogen monitoring

• Brine management of RO waste stream

• Public acceptance

Current Status of DPR Current Status of DPR Projects in TexasProjects in Texas

• CRMWD at Big Spring• Start date: April 2013• Status: operational

• Wichita Falls Emergency Temporary DPR Project• Start date: July 2014• Status: operational

• City of Brownwood• Start date: construction approval + full-scale

verification granted December 2012; no decision to begin project at this time

• El Paso Water Utilities DPR• Start date: unsure at this time; currently preparing

to pilot test their proposed treatment process

The Future of Reuse in The Future of Reuse in TexasTexas

• We expect to see more DPR proposals, especially if the drought continues

• Lessons learned so far:• PWSs should evaluate all sources of

water before moving forward with a reuse project

• The multiple barriers required for reuse projects are expensive and require experienced operators

The Future of Reuse in The Future of Reuse in TexasTexas

• Lessons learned continued:• DPR Projects include innovative

treatment technologies which require either a pilot study or a full-scale verification test

• Due to the innovative nature of these projects, TCEQ review of DPR projects takes more time than other projects; public water systems considering DPR should factor in adequate review time

Questions?Questions?

Joel Klumpp

TCEQ

Joel.Klumpp@tceq.texas.gov

512.239.4453