FREQUENTLY ASKED QUESTIONS

1) QUESTION - The requirements laid out in the manual can have the force of regulation without having gone through a formal public comment process pursuant to Administrative Procedures Act. Shouldn’t this document have to follow the same procedures?

1) ANSWER - The RWBR Technical Manual is a guidance document to assist facilities interested in implementing a RWBR project. The guidance document is based on successful Water Reuse programs across the USA as well as EPA guidance and is an excellent resource for Water reuse implementation. Should the RWBR manual be reference by rule/statute, then it will be subject to the Administrative Procedures Act.
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2) QUESTION - The RWBR manual provides guidance for a Water Allocation Permittee on how to complete a Reuse Feasibility Study (“RFS”) analysis. The guidelines require an economic, environmental and technical feasibility evaluation as part of the RFS. Doesn’t this place a heavy burden on the utility for information that the Department should already have?

2) ANSWER - Each RFS analysis should be unique to the local in which the facility resides, thus it is important that each facility evaluate the economic, environmental and technical feasibility. The Department certainly has information that may be incorporated into the RFS and can be accessed from the Department at the request of the person completing the RFS.
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3) QUESTION - The RWBR Technical manual states that RWBR Ponds must be isolated from a stormwater pond system. Are there any situations in which a RWBR Pond could be part of a Stormwater Pond system on a golf course for example?

3) ANSWER - If the facility implementing Reuse can establish and provide, in writing to the Department, an Operations Protocol that ensures there will be no discharge fromthe Stormwater System except in the event of a 100 year storm event combined with the RWBR entering the pond, then the Department may authorized such a RWBR type pond.
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4) QUESTION - The 10 mg/L Total Nitrogen limit for public access spray irrigation cannot be met by my Wastewater treatment plant without significant upgrades. Are there any exceptions to the 10 mg/L total Nitrogen limit.

4) ANSWER - The are many instances where a Vegetative Uptake Calculation Analysis was completed by a consultant or an organization such as Rutgers Agricultural Coop Extension, that demonstrated uptake of Total Nitrogen by the vegetation at the spray site, such that the 10 mg/L limit was not required. The Department suggests you complete a Vegetative Uptake Calculation Analysis for your spray site. The Department can incorporate the Total Nitrogen uptake limit into the RWBR modules in your NJPDES permit upon satisfactory review of the Vegetative Uptake calculations .
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5) QUESTION - Since water meeting the public access criteria for RWBR does not need a NJPDES discharge permit, can the transmission of public access RWBR occur to it’s ultimate destination through perforated piping, such as an existing stormwater drain?

5) ANSWER - No. RWBR transmission lines must be managed similar to any other type of irrigation or similar delivery pipe. RWBR should be considered as a resource and not something to be disposed to the subsurface environment through perforated piping. The only exceptions would be an RWBR dispersal system used for shallow subsurface irrigation such as subsurface drip irrigation systems.
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6) QUESTION - Can RWBR that will be discharged to a stormwater basin use the existing stormwater conveyance piping to transmit the RWBR to that basin?

6) ANSWER - No. There are two issues that prohibit this practice. First, existing stormwater piping is sized to handle the stormwater flows generated from the drainage area and the additional flow of RWBR could impact that system’s ability to adequately handle the stormwater flows. Secondly, to ensure the quality and quantity of RWBR reaching it’s identified reuse or reuse storage location, RWBR must be conveyed directly to that location.
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7a) QUESTION - Could the Department clarify when a Treatment Works Approval (TWA) is required for RWBR projects?

7a) ANSWER - The general philosophy of when a TWA is required or not involves discerning when the water is wastewater or effluent and when it becomes RWBR quality non-potable water supply. If any treatment or conveyance facilities are treating or conveying the wastewater or effluents a TWA is required. Once the water has reached the permitted RWBR quality a TWA is not necessary for any conveyance lines of the RWBR water or for any additional treatment facilities required by the end user. Conveyance and treatment facilities should be designed to professional engineering standards and must not allow the RWBR to be distributed in a manner or to a location that is not identified by the NJPDES Permit that authorizes the RWBR.
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7b) QUESTION - RWBR is coming to my site from the local MUA. It goes into my irrigation pond and is pumped into my sprinkler system. Does the MUA need a TWA for the pipe to my facility or do I need one for my pond and sprinkler system?

7b) ANSWER - If the non-potable water leaving the MUA meets the public access RWBR requirements, no TWA is needed for the conveyance to the facility. The only piping that would require a TWA is that which is used to convey raw or partially treated wastewater and is treated further at your site. This treatment facility would also require a TWA. This practice is sometime referred to as “wastewater mining” which draws raw wastewater from a sewer main line and treats the wastewater onsite or close by (to the end user). No TWA would be required for the basin or distribution (sprinkler) system.
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8) QUESTION - Is an areawide Water Quality Management Plan (WQMP) amendment required for RWBR projects?

8) ANSWER - RWBR activities must be identified in the areawide WQMP, but this is typically done through an administrative correction or revision to that plan, not an amendment. Facilities that receive RWBR on a consistent basis, such as irrigation and cooling water, will be identified in the plan through a revision. Activities such as dust control, street sweeping, fire protection and sewer jetting, may be identified under the permitted entity’s description in the WQMP.
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9) QUESTION - The Department’s Guidance Manual references a document for designing RWBR disinfection using ultraviolet radiation. Where can I get a copy of that document.

9) ANSWER - Copies of the document can be ordered at: www.nwri-usa.org/
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