Using DWSRF Funds to Comply with

the Filter Backwash Recycling Rule

The Drinking Water State Revolving Fund (DWSRF) program was established by the 1996 Safe Drinking Water Act

(SDWA) Amendments and authorizes grants to states to capitalize revolving loan funds. The states provide lowinterest loans to eligible systems for infrastructure improvements needed to ensure compliance with the SDWA and

protect public health. The DWSRF program can play a significant role in helping systems, especially small systems,

to meet the challenges of complying with new drinking water standards.

The Environmental Protection Agency (EPA) published the Filter Backwash Recycling Rule (FBRR) in 2001. The

FBRR improves public health protection by requiring systems to assess and change, if necessary, recycle practices to

control risks from microbial contamination. The FBRR will impose a financial burden on some water systems. The

DWSRF can provide assistance to systems to help ease this burden, increase compliance, and protect public health.

WHY DID EPA CREATE THIS RULE?

The 1996 SDWA Amendments required EPA to promulgate a regulation which “governs” the recycling of filter

backwash water within the treatment process of public water systems. The FBRR requires that recycled filter backwash water, thickener supernatant, and liquids from dewatering processes be returned to a location such that all

processes of a system’s conventional or direct filtration are employed. Systems may apply to the state for approval to

recycle at an alternate location. By establishing the FBRR, EPA hopes to improve public health performance at

conventional and direct filtration plants by reducing the likelihood that recycling practices would allow microbes,

such as Cryptosporidium, to pass through to finished drinking water. The FBRR will help ensure that the microbial

removal improvements of the Interim and Long Term 1 Enhanced Surface Water Treatment Rules are not compromised by backwash recycling practices.

TO WHOM DOES THIS RULE APPLY?

The FBRR applies to all systems that use

surface water or ground water under the

direct influence of surface water

(GWUDI), practice conventional or

direct filtration, and recycle spent filter

backwash, thickener supernatant, or

liquids from dewatering processes.

Source Type System Type Population Type

 



 







Surface Water < 10,000

Ground Water 10,000 - 100,000

GWUDI > 100,000

CWSs

NTNCWSs

TNCWSs

FOR SYSTEMS FOR STATES

States submit FBRR primacy revision application to EPA (triggers interim primacy). June 8, 2003

December 8, 2003 Submit recycle notification to the state.

June 8, 2004

Recycle flows must be returned through the process of a system's existing conventional or direct

filtration system or at an alternate recycle location approved by the state (unless granted a 2-year

extension by the state). Collect recycle flow information and retain on file.

June 8, 2006 Complete all capital improvements associated with relocating recycle return location (if necessary).

Primacy extension deadline – states with extensions must submit primacy revision applications to EPA. June 8, 2005

CRITICAL RULE DEADLINES & REQUIREMENTS
HOW WILL THIS RULE IMPACT SYSTEMS?

Total capital costs for the rule are estimated to

be over $45 million. In addition, the annual

O & M and reporting costs will be more than

$2.5 million. Most of the capital costs will fall

on the shoulders of systems serving more than

100,000 people (see Figure 1). Only a very

small percentage of transient noncommunity

water systems (TNCWSs) and nontransient

noncommunity water systems (NTNCWSs)

will be subject to the FBRR because most of

these systems are ground water systems and

very few use conventional or direct filtration.

Of the 4,650 systems subject to the FBRR, the EPA estimates that fewer than 400 systems are expected to require

capital improvements to modify the location of their recycle return (the remainder are subject to the reporting requirements only). Generally, systems affected by the FBRR will not be required to make significant modifications to their

treatment processes to meet the rule’s requirements. The majority of systems that will have to modify the location of

their recycle return serve less than 50,000 people (see Figure 2).

Figure 3 shows the average annualized capital and O & M costs for systems that must install a new recycle return

location. For most of these systems, the annual capital and O & M costs will be under $5,000. Although a fewer

number of systems serving more than 10,000 people will face capital costs from the FBRR, the costs per system will

be much more expensive (almost $50,000 on average).

EPA estimates that the total annual cost per household will be less than $1.70 for 99% of the 31.4 million households

potentially affected by the FBRR. The remaining 1% of affected households will experience a range of costs between

$1.70 and $100 per year. Costs for the FBRR will place a slightly more significant burden on small systems because

costs must be paid from a much smaller revenue base.

Figure 1: TOTAL FBRR PRICE TAG

(in thousands of January 1999 $)

Capital Costs

for Recycle

Return Provision

Total Capital Costs by System Size

for Recycle Return Provision

< 100

101-500

$260

$713

$539

$1,411

$45,207

$2,487

$92

$2,284

$9,460

$30,540

501-1,000

1,001-3,300

3,301-10,000

10,001-100,000

>100,000

AnnualO&M Costs

Recycling Reporting

0

20

40

60

80

100

<100 101-500 501-

1,000

1,001-

3,300

3,301-

9,999

10,000-

50,000

50,001-

100,000

>100,000

Population Served

Request

Alternate

Location

Modify

Location

$49

$2 $3

$5

$0

$10

$20

$30

$40

$50

$60

<1,000 1,001-

3,300

3,301-

9,999

>10,000

Population Served

Figure 2: Number of Systems That Will Need to Modify

Location or Request Alternate Location

Figure 3: Average Annual Costs for Installing New

Recycle Return Location (in thousands of 1999 $)

Note: Costs based on total costs amortized over 20 years at a

3% discount rate.
WHAT TYPE OF TREATMENT WILL SYSTEMS HAVE TO PUT IN PLACE?

During routine filter operation, particles such as metals, coagulants, and pathogens become trapped within system

filters. The process of backwashing filters removes these particles and is crucial in the proper operation of conventional and direct filtration plants. The FBRR will ensure that the resulting spent filter backwash, if recycled, is

handled with at least the same level of multi-barrier treatment as raw source water.

The FBRR addresses spent filter backwash and two additional recycle flows – thickener supernatant and liquids from

dewatering processes. Recycle streams may contain significant concentrations of pathogens, such as Cryptosporidium,

and pose a significant public health threat if not treated appropriately (see Exhibit 1). Under the rule’s first provision,

systems are required to return their recycle flows through all processes of a system’s existing conventional or direct

filtration system. By passing the recycle flows through all treatment processes at the facility, the FBRR helps to ensure

the integrity of the chemical treatment.

Systems facing infrastructure improvements to

redirect recycle flows to pass through the

processes of a system’s existing conventional or

direct filtration may require additional piping

and pump capacity. O & M costs for such

infrastructure improvements include the annual

cost of painting the pipes, replacement of pipe

sections and fitting, and pump and motor

service.

The EPA acknowledges the value of having the

recycle flows pass through all treatment processes. However, the Agency also recognizes

unique site-specific conditions. As a result, the

FBRR’s recycle return provision provides

flexibility by allowing the state to approve an

alternate recycle return location for systems on a

case-by-case basis.

Under the FBRR, systems are required to notify

states that they recycle. In addition, systems

must provide information that the state can

utilize to evaluate a system’s susceptibility to

hydraulic disruptions as a result of recycling.

Accordingly, systems must provide the state with

a plant schematic showing the origin of all

recycle flows, the hydraulic conveyance used to transport them, and the location where they are recycled back into the

plant. They must also provide a typical recycle flow in gallons per minute (gpm), highest observed plant flow experienced in the previous year (gpm), design flow for the treatment plant (gpm), and, if applicable, the state-approved

operating capacity for the plant.

Systems are also required to collect and maintain information for review by the state. After evaluating the information, states may require a system to modify its recycle location or recycle practices.

Untreated Spent Filter Backwash Water - Water used for

filter backwash which has not received treatment to remove

oocysts from the waste stream.

Gravity Settled Spent Filter Backwash Water - Filter

backwash in which gravity settling has been used to remove

solids prior to its return to the primary treatment process.

Combined Gravity Thickener Supernatant - A combination of

the supernatant from spent filter backwash water and a gravity

thickener. A gravity thickener removes water from the

sedimentation and filtration backwash sludge mass.

Gravity Thickener Supernatant from Sedimentation Solids -

This potential recycle flow is similar to that for the combined

gravity thickener supernatant, but includes only the supernatant

from a gravity thickener.

Mechanical Dewatering Device Liquids - Liquids resulting

from devices used to mechanically separate water treatment

plant residuals (usually thickened sludge) into solids and water.

Devices used to mechanically dewater thickened sludge

include belt filter presses, centrifuges, filter presses, and

vacuum filters.

Exhibit 1: Recycle Flows Most Likely to Contain

Cryptosporidium
HOW CAN THE DWSRF ASSIST SYSTEMS?

States use DWSRF capitalization grant monies to

provide low-interest loans to publicly- and privatelyowned public water systems for infrastructure

improvements needed to continue ensuring safe

drinking water. States may offer principal forgiveness, reduced interest rates, or extended loan terms

to systems identified by the state as serving disadvantaged communities. States also have the ability

to reserve a portion of their grants (i.e., set-asides) to

finance activities that encourage enhanced water

system management and help to prevent contamination problems through source water protection

measures. Based on the fiscal year 2002 appropriation of $850 million, capitalization grants ranged

from $8.0 million to $82.4 million per state.

Most capital projects – including installing new

piping and upgrading existing technologies –

needed to comply with the new FBRR standards are

eligible for funding under the DWSRF (see Exhibit

2). States can use set-aside funds from the DWSRF

to assist systems directly as well as to enhance their

own program management activities.

A state may use set-asides to make administrative

improvements to the entire drinking water program,

which faces increased costs in implementing the

FBRR. States can provide training to systems on

meeting the requirements of the FBRR as well as

technical assistance in identifying appropriate

recycle locations. In addition, states can provide assistance to small systems to cover the costs of project planning and

design for infrastructure improvements.

Since the DWSRF program is managed by states, project and set-aside funding varies according to the priorities,

policies, and laws within each state. Given that each state administers its own program differently, the first step in

seeking assistance is to contact the state DWSRF representative which can be found on the EPA DWSRF website.

Type of Project/Activity

Eligible Under

Infrastructure Fund

Eligible Under

Set-Asides

Capital

Install piping to move

recycle to headworks

Y o es N

Upgrade backwash

pumping capacity

Y o es N

P s lanning & Design Activities Y * e Yes

Recycling Reporting N o o N

System Administrative Improvements

H o ire Staff N oN

S o taff Training N s Ye

P o ublic Outreach N s Ye

M o onitoring N oN

R o ate Increase Process N s Ye

State Administrative Improvements

H o ire Staff N s Ye

S o taff Training N s Ye

P o ublic Outreach N s Ye

C o ompliance Oversight N s Ye

E o nforcement N s Ye

P o ilot Studies N s Ye

Exhibit 2: Projects/Activities Eligible for DWSRF

Funding to Comply With the FBRR

Printed on Recycled Paper

FOR MORE INFORMATION...

DWSRF and FBRR General Information

DWSRF Website:

http://www.epa.gov/safewater/dwsrf.html

FBRR Website:

http://www.epa.gov/safewater/filterbackwash.html

SDWA Hotline

1-800-426-4791

EPA's Ground Water & Drinking

Water Website:

http://www.epa.gov/safewater/

Office of Ground Water and

Drinking Water (4606M)

EPA 816-F-02-006

June 2002

*For small systems only.