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I have had several discussions with people who are concerned about proposed water conservation legislation in California and the city of Los Angeles. The proposals are currently going through the legislative process. The concerns are related to water quality issues and requirements for all new construction located near existing municipal recycled or reclaimed water lines shall be connected to those water sources for flushing toilets, urinals and for irrigation purposes.
One such piece of proposed legislation is a revision to California Assembly Bill, AB 2282, which is part of the California Building standards dealing with reclaimed (recycled) water systems. The other concern was a proposed ordinance for Los Angeles with similar requirements.
There is concern because there does not seem to be a thorough understanding of all of the issues by the water conservation proponents and many of the people that will be voting on the legislation and ordinances. The main focus seems to be on saving water and energy with no consideration for the health and safety effects. Water conservation efforts such as these cause reduced water flows in the public drinking water supply and will allow water treatment chemicals to dissipate down to levels that are ineffective at fighting legionella, E.coli, cryptosporidium and other bacteria and organisms in the water supply. Reduced water flows will also create problems with drain line transport of solids. To date, there has not been a comprehensive study of drain line transport that includes disposable wipes and feminine hygiene products which are problematic in drains with lower flows. Recent PERC studies revealed there is no standard for toilet paper and the brand or strength of the toilet paper can have a significant impact on drain line transport.
Another issue is the water quality for reclaimed or recycled water systems. For example, there are many terms and many different definitions for reclaimed water systems, recycled water systems, water reuse systems, gray water systems, filtered water systems, rainwater collection systems, cisterns, etc. The terms have not been standardized so the water quality for what we will call a reclaimed or recycled water system can vary from one location to another. An industry standard for all the types of reclaimed or recycled water systems in needed.
Different geographical locations around the country allow different recycled or reclaimed water quality based upon their own localized understanding of the intended use of the water. Some locations allow lesser treatment so that the treatment system installation maintenance and operating costs can be kept reasonable. This produces inconsistent water quality from one location to another.
One person was concerned because he was potentially going to have to use the recycled water, as was proposed in this ordinance, to flush his water closets with bidet seats. He asked, what happens if he installs one of the new toilet seats that washes your private parts, and then blow dries you afterward. He said many of these toilet seat conversion kits, allow the purchaser to convert a water closet into a bidet. The unit has a fitting that connects to the water supply shut-off valve for the fixture and two flexible supplies; one to the water closet tank fill connection and one to the seat connection. The seats also have a small water heater reservoir to allow warm water to be sprayed on your private parts while using the fixture. If the water supplied is municipal water meeting the requirements of the EPA Safe Drinking Water Act, then the warm water would be reasonably safe. But, if an unsuspecting homeowner has recycled water piped to their water closet and a municipality allows a lower water quality, “because recycled water is just used for flushing,” how is a homeowner to know if the water system is safe and free from communicable diseases and will not grow bacteria? There appears to be no consistent industry standard for the water quality levels for these recycled/reclaimed water systems that can assure control of bacteria in the water supplied to the spray on the toilet seat or any other fixture using recycled or reclaimed water.
There are concerns about poorly maintained, reclaimed or recycled water systems leading to the spread of communicable diseases and bacteria growing in the recycled water system that was formerly waste water. There are some local ordinances that address the issue of water quality, but not an industry standard. If you would like to participate, please contact the California Building Standards Commission by telephone at (916) 263-0916, or online at www.bsc.ca.gov.
The proposed timeline for the California Assembly Bill (AB 2282) activities called for the first stakeholder meeting June 14, to allow for introductions, regulatory outline, legislative mandate, timeline, application and scope, request for cost analysis and other info for the ISOR by appropriate stakeholders. Other stakeholder and subcomittee meetings owudl take place each month, until December, when State Agencies would make the initial submittal of proposed code changes due to BSC, including AB 2282 recycled water regulations (prior to Code Advisory Committees). Finally, in June 2017, the BSC meeting would take place to adopt Intervening Code Supplement, including recycled water regulations pursuant to AB 2282.
We have the technology, but many people may not have a full understanding and the knowledge of the hazards associated with the quality of the water and potential hazards. The cost of implementing recycled water systems will be significant, cost comes from a duplicate gray water waste system to collect graywater waste and deliver it separate from the sanitary waste system. The cost also includes a water treatment system of an undetermined level of quality and a separate recycled/reclaimed water storage and booster pumping system and separate dedicated recycled/reclaimed water supply and distribution piping system. There are also increased maintenance costs and costs associated with litigation that must be considered in the life cycle cost of these systems. These reclaimed water/recycled water systems are being mandated without proper and comprehensive research and industry standards in place to assure proper water quality and the effects of a given water quality on various uses. In some locations spraying (aerosolization) or recycled/reclaimed water is not allowed because of Legionella and other bacteria and pathogen hazards drip irrigation is all that is allowed. In other locations, spray irrigation is allowed.
Water conservation is a noble cause, but it is not a simple subject. These systems have the potential to make many people sick and cause drain flow problems. This is not a subject that should be taken lightly or rushed into without any data. I am all for water conservation, but I think we need to understand the hazards before introducing bacterial hazards into the plumbing systems. We need to “Save Water Wisely” without the heat of the moment decisions or emotional legislation that is not based on science or engineering.
The EPA needs to take the lead in researching these important issues now before thousands of people are sickened or killed by well-intentioned, yet unwise, water conservation efforts that cause bacteria to grow in our water systems due to reduced flows and dissipating chlorine levels. The EPA has taken the first step toward doing research on the effects of water conservation program effects on water quality. The EPA research will cover issues of water quality and availability related to distribution systems and premise plumbing systems under lower-flow conditions associated with water conservation programs. This research is just beginning and may be several years away from completion.
We need to look at what the long term solutions are. Consider the following:
California is facing a significant water shortage, even during drought years, because tree farms are drawing water out of the rivers. There needs to be more regulations controlling agricultural development in arid regions that will rely on irrigation water resources. Restricting agriculture and development in arid regions would make good policy sense to preserve water usage for existing water users. This would be a better place to cut water use than reducing flushes and fixture flow rates to unsustainable levels.
I have come to the conclusion that there needs to be a government agency or water resource agency that has input on new development in watershed areas with limited water resources. The committee should be made up of a diverse group made up of plumbing, agricultural and other professionals that review any new proposals before enacting any legislation out of emotion. We need to base the decisions to alter the design and performance of plumbing systems on science not emotion.
Ron George, CPD, is president of Plumb-Tech Design & Consulting Services LLC. He can be reached at: office 734-322-0225; 755-1908; and website www.Plumb-TechLLC.com.
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