<-xml:namespace prefix = st1 ns = "urn:schemas-microsoft-com:office:smarttags" />09 October 2007

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Valerie Rourke

Commonwealth of Virginia

Department of Environmental Quality

629 East Main St.

P.O. Box 1105

Richmond, Virginia 23218

Re:       9 VAC 25-740 Draft Regulation for Wastewater Reclamation and Reuse

Dear Ms. Rourke,

The City of Norfolk Department of Utilities performed a review of the draft water reclamation and reuse regulations and submits the following comments:

Section 100 Application For Permit

• Par. C.1. – Add a statement that the Reclaimed Water Management Plan shall be the responsibility of the generator not the distribution system only owner.  Proposed statement can read, “For reclaimed water distribution system only owner, the RWM shall be submitted by the reclaimed water generator, not the distribution system owner.”  This statement can be inserted after the first sentence in that paragraph.

Section 110 Design Criteria

• Par. C.1. – Add a statement that the storage requirement is the responsibility of the generator, not the distribution system only owner.  Proposed statement can read, “Reclaimed water system storage is the responsibility of the reclaimed water generator, not the distribution system owner.”  This statement can be inserted as the first sentence in that paragraph.

Section 120 Construction Requirements

• Par. B.1. – Add a statement that the Certificate to Construct (CTC) and Certificate to Operate (CTO) will not be required for distribution system only owner.  Proposed statement can read, “A CTC and/or CTO shall not be required for a reclaimed water distribution system only owner.  The certificates shall be obtained by the reclaimed water generator.”  This statement can be inserted as the last sentence in that paragraph.

Section 170 Use Area Requirements

• Par. A. – Add a statement that in the event of a distribution system only owner, the generator is responsible for providing the education and notification program.  Proposed statement can read, “For reclaimed water distribution system only owner the education and notification program shall be developed and maintained by the reclaimed water generator.  The distribution system only owner can develop and maintain one on a voluntary basis.”  This statement can be inserted as the last sentence in that paragraph.
• New Par. L. – Provide clarification on handling requirements for reclaimed water flushed from the distribution system or in the event of a distribution main break.  Proposed new paragraph can read, “L. Reclaimed water flushed from the distribution system or lost in the event of a distribution main break or leak shall not be considered a sanitary sewer overflow.”  This new paragraph can be inserted after paragraph K.

Section 200 Reporting

• Par. B. – Provide clarification on requirements for reclaimed water flushed from the distribution system or lost in the event of a distribution main break.  Proposed statement can read, “Reclaimed water flushed from the distribution system or lost in the event of a distribution main break or leak shall not be considered a sanitary sewer overflow.”  This statement can be inserted as the second sentence in that paragraph. 
• Par. C. – Add a statement that for a distribution system only owner, the generator is responsible for providing that information to the distribution owner.  Proposed statement can read, “For reclaimed water distribution system only owner the reclaimed water generator shall provide the information required in paragraphs 2 and 3 below.”  This statement can be inserted as the second sentence in that paragraph. 

If you have any questions feel free to contact me at 757-664-6701.  Thank you.

Sincerely,

Kristen M. Lentz, PE

Director