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U.S. EPA Finalizes the Clean Water Rule

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By Claudio Ternieden, Kristina Twigg, and Seth Brown

On May 27, the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (USACE) finalized the Clean Water Rule (, which EPA and the USACE believe, ensures that waters protected under the Clean Water Act are more precisely defined and predictably determined, making permitting less costly, easier, and faster for businesses and industry,

The rule, published in the Federal Register on June 29, is expected to become effective August 28, depending on the outcome of some lawsuits filed by a number of states seeking to stop the rule from going into effect. The rule is grounded in law and the latest science, according to an EPA fact sheet (, and it received substantial  public input from more than 400 stakeholder meetings and more than 1 million public comments. EPA and USACE also maintain that the rule creates no new permitting requirements for agriculture and maintains all previous exemptions and exclusions, including dredged or fill requirements.

Stormwater controls not affected

In general, the Clean Water Rule clarifies which bodies of water are classified as “waters of the United States,” thereby requiring federal pollution controls. The Rule maintains the current status of municipal separate storm sewer systems (MS4s) and encourages the use of green infrastructure to protect water quality. Specifically, the final rule states:


(2) The following are not “waters of the United States” even where they otherwise meet the terms of paragraphs (1)(iv) through (viii) of this section.


(vi) Stormwater control features constructed to convey, treat, or store stormwater that are created in dry land.


By using the terms “constructed” “in dry land,” the new rule allows EPA to assert jurisdictional authority over the natural lakes, ponds, wetlands, rivers, and streams while not impacting MS4 elements. This section should help to exclude urban stormwater control measures in most cases, as the rule also stresses in the preamble: “This exclusion responds to numerous commenters who raised concerns that the proposed rule would adversely affect municipalities’ ability to operate and maintain their stormwater systems, and also to address confusion about the state of practice regarding jurisdiction of these features at the time the rule was proposed.”

Existing jurisdictional determinations and permits are valid until they expire. By promoting more consistent and effective implementation of Clean Water Act regulatory programs, the rule sets the stage for permit streamlining during implementation.

Some areas may be challenged

However, questions remain about the rule’s definition of tributaries and when that definition applies to ephemeral or intermittent streams — which would make them jurisdictional. According to EPA, 60% of U.S. stream miles flow only seasonally or after rain, and 1 in 3 Americans rely on these sources for drinking water.  According to some environmental attorneys, the tributary definition is the part of the rule most likely to be challenged. Based on the rule, a tributary must possess the physical characteristics of a bed, bank, and an ordinary high water mark as well as evidence of the frequency, duration, and volume of flow characteristic of a tributary. Further, to be considered jurisdictional, tributaries must significantly affect the health of downstream waters. Based on these definitions, tributaries primarily include headwater streams. Erosional features and ditches with intermittent flow specifically are excluded along with ditches draining into wetlands.

The final rule also further defines adjacent open waters and wetlands as jurisdictional if they are within 100 feet of the ordinary high water mark of a jurisdictional water or within the 100-year floodplain and within 1500 feet of the ordinary high water mark of covered waters. Certain isolated waters also could fall under the scope of the Clean Water Act based on both their connectivity and proximity to traditional navigable waters, interstate waters, and territorial seas. A significant nexus determination is based on the isolated water’s effects on the physical, biological, or chemical integrity of jurisdictional waters, such as through an exchange of pollutants, flow, or organisms. Additionally, scientific analyses assessing connectivity will consider how isolated waters affect the nearest jurisdictional water as a group rather than individually.

That analysis will be informed by EPA’s final report published last January, Connectivity of Streams and Wetlands to Downstream Waters: A Review and Synthesis of the Scientific Evidence (, where it summarized current understanding about the connectivity and mechanisms by which streams and wetlands affect the physical, chemical, and biological integrity of downstream waters. The report serves as the technical backbone of the final Clean Water Rule.  Even if an excluded ditch falls within the defined limits of adjacent waters, an exclusion will trump an inclusion, said Ken Kopocis, deputy assistant administrator of EPA’s Office of Water, in a recent webcast about the rule.

Other clarifications

In addition to the issue of defining tributaries, EPA and USACE say the Clean Water Rule:

  • Protects prairie potholes, Carolina and Delmarva bays, pocosins, western vernal pools in California, and Texas coastal prairie wetlands when they affect downstream waters.
  • Focuses on streams, not ditches. The rule limits protection to ditches that are constructed out of streams or function like streams and can carry pollution downstream. Ditches not constructed in streams and that flow only when it rains are not covered.
  • Significantly limits the use of case-specific analysis by creating clarity and certainty on protected waters and limiting the number of similarly situated water features. Previously, almost any water could be put through a lengthy case-specific analysis, even if it would not be subject to the Clean Water Act.
  • Only protects the types of waters that have historically been covered under the Clean Water Act. It does not regulate most ditches and does not regulate groundwater, shallow subsurface flows, or tile drains. It does not make changes to current policies on irrigation, water transfers, or erosion in a field. The Clean Water Rule addresses the pollution and destruction of waterways, not land use or private property rights.

The Water Environment Federation will continue to follow the developments related to this rule and provide analysis and information.

Claudio Ternieden is the director of government affairs and Kristina Twigg is the associate editor of World Water: Stormwater Management at the Water Environment Federation (WEF; Alexandria, Virginia). Seth Brown, P.E., is a WEF senior adviser on stormwater issues and is the principal/founder of Storm and Stream Solutions, LLC (Springfield, Virginia).


“The information provided in this article is designed to be educational.  It is not intended to provide any type of professional advice including without limitation legal, accounting, or engineering. Your use of the information provided here is voluntary and should be based on your own evaluation and analysis of its accuracy, appropriateness for your use, and any potential risks of using the information.  The Water Environment Federation (WEF), author and the publisher of this article assume no liability of any kind with respect to the accuracy or completeness of the contents and specifically disclaim any implied warranties of merchantability or fitness of use for a particular purpose. Any references included are provided for informational purposes only and do not constitute endorsement of any sources.”

Help for States Considering Direct Potable Reuse

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Framework provides guidance on program development and costs, federal regulations, and public outreach

By Justin Mattingly


As interest in direct potable reuse (DPR) has grown, so has the need to ensure water quality and safety. State regulators and local government and water utility decision-makers must make water supply decisions, but without specific criteria or guidelines, excessive treatment redundancies may result that impede or slow down projects, causing high costs, project delays, and public distrust.

As a result, a framework is being developed that outlines the most important issues that states will need to address as they develop DPR guidelines. This framework, which will be released in the fall, will focus on two forms of DPR, the first of which is defined as introducing highly treated wastewater effluent — with or without an engineered storage buffer — into the intake water supply upstream of a drinking water treatment facility. Another form introduces highly treated wastewater effluent directly into a drinking water distribution system. The framework is the culmination of a DPR framework project being developed by the WateReuse Research Foundation (Alexandria, Virginia) in coordination with the Water Environment Federation (WEF; Alexandria, Virginia) and the American Water Works Association (Denver).


What the framework will include

DPR projects are not necessarily new; Windhoek, Namibia, has been operating one since 1967 that introduces water directly into the drinking water distribution system. In the United States, permitted operational DPR projects add highly treated wastewater ahead of a water treatment facility. Currently, only Wichita Falls and Big Spring in Texas have operational DPR facilities, but DPR is currently under consideration in California, New Mexico, and several other states.

The framework will summarize Texas’ experience in implementing DPR and California’s creation of regulations for groundwater recharge indirect potable reuse projects. This framework also will cover a broad spectrum of issues in DPR implementation, including

  • a background on DPR as well as the cost of implementing a DPR program compared to other water resource options;
  • public health protection and how DPR may be affected by existing federal statutes such as the Clean Water Act and Safe Drinking Water Act;
  • source water control programs, wastewater treatment, advanced wastewater treatment, residuals management, and monitoring and control strategies; and
  • system operation to ensure that utilities have sufficient staff training and resources to properly operate these systems, which in many cases are more advanced than traditional wastewater or drinking water treatment facilities.


Managing public perception

Water treatment technology and operations are an ever-evolving process, and technology and regulatory needs for DPR may require future development. In addition, public perception is important in any statewide or local discussion of implementing a DPR program. Community organizations need to be engaged early to ensure that the public understands the DPR concept to dispel fears about using recycled water as a source of drinking water. The framework will include information on public outreach including the key factors that should be included in a communication plan, communication tools, as well as examples of successful DPR outreach programs.

The framework effort is part of a WateReuse Research Foundation Direct Potable Reuse initiative that has already allocated $5.8 million to fund 34 research projects. The National Water Research Institute (Fountain Valley, California) expert panel developing this framework is chaired by George Tchobanoglous of the University of California-Davis along with Joseph Cotruvo of Joseph Cotruvo & Associates, Jim Crook, Ellen McDonald of Alan Plummer Associates, Adam Olivieri of EOA Inc., Andrew Salveson of Carollo Engineers, and R. Shane Trussell of Trussell Technologies Inc.

The framework directly addresses a key theme of found in EPA’s Water Technology Innovation Blueprint. The Blueprint outlines the business case for investment in new tools in the 10 most promising market opportunities in the water quality sector, one of which is “Conserving and Eventually Reusing Water.”  Intended to be released by WEFTEC 2015 (September 26–30, 2015) in Chicago, the framework will be featured at the WEFTEC Innovation Pavilion discussion “Overcoming Barriers to Water Reuse.”

Justin Mattingly

Justin Mattingly is a research manager at the WateReuse Research Foundation. He can be reached at

“The information provided in this article is designed to be educational.  It is not intended to provide any type of professional advice including without limitation legal, accounting, or engineering. Your use of the information provided here is voluntary and should be based on your own evaluation and analysis of its accuracy, appropriateness for your use, and any potential risks of using the information.  The Water Environment Federation (WEF), author and the publisher of this article assume no liability of any kind with respect to the accuracy or completeness of the contents and specifically disclaim any implied warranties of merchantability or fitness of use for a particular purpose. Any references included are provided for informational purposes only and do not constitute endorsement of any sources.”



presentation FI

PWC: Call for Abstracts

The Hawai‘i Section of the American Water Works Association and the Hawai‘i Water Environment Association are proud to announce the third annual joint conference now known as the Pacific Water Conference at the Hawai‘i Convention Center from February 2 – 4, 2016.  Our joint conference committee is hard at work to bring you an exciting, fun, and educational conference.

The Conference officially opens on Wednesday, February 3 and lasts through Thursday, February 4.  Join us in the Convention Center Exhibit Hall to cheer on this year’s operator competitions featuring HWEA’s Operations Challenge and AWWA’s Pipe Tapping and Top Ops events.  Remember to check out the exhibitors showcasing the newest and latest products in the industry.  With up to 6 technical session tracks to choose from, there’s sure to be one that piques your interest.   The conference golf tournament will be held on Friday, February 5 at the Hawai‘i Prince Golf Course, and the community service event will take place on Saturday, February 6.

Registration, hotel information, and other details will be posted on the conference web site after August 1. Check the web site after August 1 for more information.

If you are interested in presenting at this year’s conference, please CLICK HERE for the Call for Abstracts, and email them to  You can also contact the Technical Program Chairs: Jordan Fahmie (808) 529-7272 and Susan Mukai (808) 203-2667.


We look forward to seeing all of you at the Conference!

Jay Stone | Scott McAdam | Trevor Inouye | Puna Kaneakua
2016 Conference Chairs


Missouri WEFMAX Report

Summary of Events & Takeaways

by: Lance Manabe

WEFMAX 2015 – Kansas City, Missouri was a great opportunity to hear from the following member associations:

Ohio WEA                            Pennsylvania WEA          Georgia AWP

Nebraska WEA                  North Carolina WEA       Indiana WEA

Rocky Mountain WEA    Kansas WEA                       Iowa WEA

Chesapeake WEA             Illinois WEA                       New England

Arkansas WEA                  Missouri WEA                    South Dakota



There were many great sessions, the following are summaries of the points I took away from this WEFMAX.


Ohio WEA’s Presentation on MA Financial Stability included some interesting concepts:

Executive Committee consists of the following positions:

President, President-Elect, Vice President, Secretary/Treasurer, Senior Delegate, Junior Delegate and Past President.  Making their board eight (8) members.

Sponsor Program

They changed from an event based solicitation to an annual sponsor program campaign in 2012.  Companies received award points based on sponsor level.  Eight (8) levels from $7,500 to $250.  Example a company that donates $7,500 would receive 60 points that could be used on the following:



Chesapeake WEA’s Presentation on Membership & Retention included interesting points:

Understanding you MA’s Profile


Chesapeake’s focus was on:

  • Increase Membership Retention
  • Develop New MA Website
  • Create New MA Logo (More Contemporary, relevant, eye catching

(Note:  WEF helped Chesapeake with the Logo Redesign with their graphics team which is also available to us)

  • Involvement from YP and Student Activities Committees to Provide valuable experiences for younger members. Membership value to their careers.



Illinois WEA’s Presentation on Retaining Student Chapters included interesting points:

  • Strong Committee (5-10 individuals for 3 universities)
  • Strong School Contacts



  • Programming includes Plant Tours, Evening with Industry, Meeting with CEO’s of companies, round table discussions and scholarships.




North Carolina AWWA-WEA’s approach to Leadership – Selecting, Shaping, Sustaining.

  • Revised organization structure


  • How Leadership Skills are Identified
    • No “entitlement” to lead – we seek the best match of capabilities to requirements of the task: Knowldege, Skills, Abilities, Experience.
  • Sustaining Leadership
    • Training – top to bottom
    • Access to current information – inside and out
    • Skill Development
    • Recognition

Pennsylvania WEA’s Presentation focus was on Leadership Development – Questions and How to’s.

  • Succession/Leadership Planning – a process for identifying and developing persons with the potential to fill key leadership positions within an organization.
  • Does your MA have “Ready Now” candidates to replace key leaders?
  • Without a solid plan, the future continuity and performance of you MA is at risk.
  • What is you MA’s current leadership plan?
  • PWEA leaders and Section leaders meet at Annual Joint Summit Meeting to identify and promote leadership development (mini WEFMAX)
  • PWEA has a detailed written list of requirements and responsibilities of leadership positions.
  • PWEA holds yearly Executive Officer orientation/transition meeting at annual conference.

2015 Biosolids and Stormwater [Photo Gallery]



Operations Study Session Program

When: Saturdays, 8AM-10:30AM.
See HWEA Schedule for any changes. No class Saturday June 27th 2015.
Where: Sand Island Upstairs Large Conference Room
Who Should Attend: Operators or anyone who require CEUs and would like to learn!
Continuing Education Unit Information: 0.1 CEUs per Class




A volunteer based program to develop the critical thinking skills and the ability to learn within wastewater operators in order to work through written problems and absorb knowledge logically.


Main Objectives:

  1. Have operators learn the basics of math, physics, chemistry and microbiology
  2. Have operators learn to think and work through word and logic problems
  3. Integrate engineers and operators in a comfortable and casual environment where they will be able to collaborate and learn from one another.

Secondary Objectives:

  1. Focus on passing the Operators Licensing Exam I-II
  2. Develop stronger engineer and operator relationships
  3. Minimal amount of CEU credits to promote self-study, requesting 0.1 CEUs per 2-4 hour session, dependent on course work.

Future Objectives

  1. Operator Licensing Exams 2-4
  2. Additional Classes
  3. A slow introduction and testing ground for a full-fledged bootcamp program


Passing rates for the Operator Licensing Exam is devastating low in the state of Hawaii. Between 2007 and 2012, an average of 55%, 42%, 29%, and 15% passing for Grades 1, 2, 3 and 4 respectively. Failure to obtain licensure within 2 years from being hired results in termination (Young & Babcock Jr., 2013). About half of the work force is gone and 2 years of training money has now been lost. Out of 117 examinees in 2014, 27 of the operators passed the exam, for an overall passing rate of 23%.The certification requirements are only rising as time goes on, with the complexity of wastewater systems increasing as technology develops. Along with low passing rates, the workforce is getting older. In a survey done in 2012, the average age of operators was approximately 50.5 years with an average retirement age of 64. 72% of surveyed operators expect to retire within the next 15 years.



A three month volunteer based program beginning in June 2015. Every Saturday morning between 9AM-11AM, basic math, physics, chemistry and microbiology are discussed at the Sand Island Training Center or Conference Room. These classes/study sessions are free for attendees and will help them develop a method of thinking in order to think though exam problems. Wastewater related sample exam problems will be used in class, as well as given as take home problems for discussion the next week.

We will the use of webinars from WEF, and WEF’s knowledge center. WEF is preapproved for 13 courses in 13 states for the courses below:

  • Purpose & Fundamentals of WW Treatmentis approved for 1.3 Contact Hour.
  • Primary Treatmentis approved for 2.3 Contact Hours.
  • Fixed Film Systemsis approved for 1.1 Contact Hour.
  • Natural Treatment Systemsis approved for 2.6 Contact Hours.
  • Solids Handlingis approved for 5.2 Contact Hours.
  • Activated Sludgeis approved for 5.7 Contact Hours.
  • Wastewater Treatment Plant Hydraulics:  The Fundamentalsis approved for 2 Contact Hours.
  • Another 100-Year Stormis approved for 2 Contact Hours.
  • Collection System Evaluation, Rehabilitation, and Performance Assessmentis approved for 2 Contact Hours.
  • Sewer Cleaning and Managing Grease Blockagesis approved for 1.5 Contact Hours.
  • Modeling 101:  How to Use Simulators in the Designis approved for 1.5 Contact Hours

Total Contact Hours: 27.2 Contact Hours

Other Courses include:

  • Basic Wastewater Treatment Series Course Bundle Suggested 4 Contact Hours
  • Fundamentals of Disinfection Suggested 3 Contact Hours
  • Fundamentals of Preliminary Treatment Suggested 3 Contact Hours
  • Wastewater Treatment Plant Hydraulics – The Fundamentals Suggested 2 Contact Hours

Total Contact Hours: 12 Contact Hours

Note that if the individual or Board of Certification requires WEF sponsored CEUs, each individual must pay the $895 for the Wastewater Treatment Subscription through WEF.

Other courses to consider include free webcasts which cover topics from biosolids, nutrients, utility management and wastewater treatment.

Verification of Attendance:

Each Operator or Operator in Training must sign in and out of the class verifying their attendance. The Hawaii Water Environment Association (HWEA) shall have an officer-in-charge to also verify attendance. Continuing Education Unit (CEU) credits for this specific program shall be tracked by the HWEA officer-in-charge, and certificates shall be given/mailed per completion of a course. If a webinar is missed within that course, it must be made up on the Operator’s own time during another study session or scheduled with the officer-in-charge.


Emily Dong, P.E.
(808) 768-8752
Hawaii Water Environment Association – President
City & County of Honolulu – Civil/Environmental Engineer

HWEA 5-S Chapter

Membership in the HWEA Select Society of Sanitary Sludge Shovelers (also known as the “5-S Chapter”) is bestowed on individuals in recognition of outstanding service to the association or to WEF.  The original chapter was established in 1940 by theArizona Water and Pollution Control Association.  The idea was conceived by A.W. “Dusty” Miller and F. Carlyle Roberts, Jr. to recognize the fact that many members do not receive the coveted Bedell Award or become Association President, but nevertheless contribute in some outstanding measure to the affairs and success of an Association.

You CANNOT join the Society – you must be “selected” – on the basis of merit.  The HWEA Select Society of Sanitary Sludge Shovelers is one of many 5-S chapters established in member associations across the country, Canada, and Europe.  5-S members can be identified by a lapel pin of a golden shovel (pictured above) which must be worn by all members at official HWEA events.

The HWEA 5-S Chapter was established in 1982.  There are six basic criteria for qualification to membership in the HWEA 5-S Chapter:

  • Service to HWEA as President;
  • Service to HWEA as Annual Conference Chair;
  • Service to HWEA as National Director;
  • Recipient of either the William D. Hatfield or Arthur Sidney Bedell Award;
  • A “founding father” of HWEA; or
  • Outstanding contribution to HWEA or WEF

Click on the thumbnail on the left to see a larger image of the 2006 inductees into the HWEA 5-S Society.  All members of the HWEA Select Society of Sanitary Sludge Shovelers are listed below in chronological order.  Members with an asterisk (*) next to their name are former Presidents of HWEA.




1 William A. Bonnet * 1982
2 Michael J. Chun * 1982
3 Gordon L. Dugan * 1982
4 Christopher G. Hong * 1982
5 Maurice K. Kaya * 1982
6 Wally Miyahira 1982
7 Frank G. Stone, Jr. * 1982
8 Albert M. Tsuji * 1982
9 Vernon K. Yamamoto * 1982
10 Spencer Yim 1982
11 Reginald H.F. Young * 1982
12 Lawrence K. Agena * 1983
13 Clay Harrison 1983
14 Kenneth T. Ishizaki * 1983
15 James S. Kumagai * 1983
16 L. Steven Lau 1983
17 B.J. McMorrow* 1983
18 Martin McMorrow* 1983
19 Charles Saiki 1983
20 Ben Taguchi * 1983
21 Albert Q.Y. Tom * 1983
22 Robert Barletta 1984
23 Brian Gray 1984
24 Victor D. Moreland * 1984
25 David R. Yogi, Jr. * 1984
26 David B. Bills* 1986
27 Joe Hanna 1987
28 Lee A. Mansfield * 1987
29 Clement K. Souza * 1987
30 Horace Batezel * 1988
31 Dennis Tulang * 1988
32 Roger S. Fujioka * 1989
33 Ivan K. Nakatsuka * 1989
34 Robert Purdie, Jr. 1990
35 Jeff Howard 1991
36 Roy Abe * 1992
37 James K. Honke * 1992
38 Nick Musico 1993
39 Andrew L. Amuro 1994
40 Michael M. Miyahira 1994
41 Myron H. Nomura * 1994
42 Audrey Yokota 1994
43 Steven Y.K. Chang * 1995
44 Vijay Kumar 1995
45 Russell Okita 1995
46 Westley Chun 1996
47 Edith Eldeen 1996
48 June Nakamura 1996
49 Tina Marie C.D. Ono * 1996
50 Allen Perry 1996
51 Ian Kagimoto * 1997
52 Debra L. Leigh 1997
53 Lance Manabe * 1997
54 Peter Ono * 1997
55 Suzette Hokama 1998
56 Guy Moriguchi 1998
57 Linda Uchima 1998
58 Dina Ueoka Lau 1998
59 Walter Billingsley 1999
60 Leighton Lum * 1999
61 Pamela R. Tsugawa 1999
62 Lori Kajiwara * 2000
63 Kevin Nakamura 2000
64 Audrey Uyema Pak 2000
65 Leanne Watanabe 2001
66 Greg Chung 2001
67 Steve Parabicoli * 2002
68 Dwight Nakao 2002
69 John Katahira 2002
70 Tina Nakasone * 2003
71 Lisa Kimura 2003
72 Ian Arakaki 2003
73 Eassie Miller 2003
74 Anna Lee 2004
75 Paulette Chang 2004
76 Jon Kawamura 2004
77 Kristie Ching * 2005
78 Jay Stone 2005
79 Travis Hylton 2005
80 Greg Arakaki 2006
81 Dan Clark 2006
82 Wynn Miyamoto 2008
83 Dawn Barsana 2008
84 Shannon Holman 2009
85 Scott McAdam 2009
86 Lori Kahikina-Moniz 2010
87 Mark Goodrowe 2010
88 Lori Nishida 2011

(1) * – Denotes Past President
(2) List Current as of March 2007


Biosolids & Stormwater Workshop Presentations

Here at the Hawaii Water Environment Association, we want to give a huge thank you to all of the presenters at the Biosolids and Stormwater Workshop at the Japanese Cultural Center. The event was such a success because of the great men who helped organize the event, Jay Stone, Greg Arakaki & Brad Takenaka. Please see the below links for the presentations:



Lauren Roth Venu, Roth Ecological Design Intl.
– From Grey to Green Infrastructure

Rob Anderson, RJR Engineering & EnviroCert International
– An Overview of Trends in Stormwater and Stormwater Industry

Bob Bourke, Oceanit
– Wetlands for Control of Stormwater Runoff Pollutants

Norm Schofield, Hawaiian Dredging and Construction Company
– SWPPP Sotrm Water Pollution Prevention Plan

Randall Wakumoto, City and County of Honolulu
– Update on the City’s NPDES MS4 Permit Program

Darryl Lum, State DOT
– Protecting State Waters: The NPDES MS4 Program

Randal Leong, State DOT
– HDOT – Harbors Storm Water Program

Dawn Easterday & Jay Stone, Belt Collins Hawaii LLC
– Low Impact Development Integrated Management Practices

Ross W. Dunning, Kennedy/Jenks Consultants
Floating Plants & Boxes of Dirt, The Future of Stormwater Treatment



Libby Stoddard, DOH
State of the State’s Sludge

Barry Ayers, City of San Diego
17 Years of Operating the Metro Biosolids Center

Jordan Fahmie, AECOM
Honolulu’s Biosolids Master Plan

Steve Wirtel, Ostara
Beneficial Reclamation of Struvite

Mike Joyce, Kennedy/Jenks Consultants
Compressed Natural Gas as an Alternative to Cogeneration

Lori Kahikina
H-Power Sludge Disposal System

Mike Elhoff and Mack MacPherson
Comparison of Dewatering Technologies 

Jerry Szofer
Solids Pumping Alternatives

Flushables-Toilet-Trash FI

The State of the Flush!

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The State of the Flush!
Better product guidelines, marketing standards for pipe-clogging “flushables” are on the way

By Brianne Nakamura, Program Manager in the Water Science & Engineering Center at the Water Environment Federation (Alexandria, Va.).

Flushable wipes: To flush or not to flush?

While the average consumer might wash their hands of the matter without a thought, for those in the wastewater industry, the nightmares of clogged pumps and sanitary sewer overflows (SSOs) come to mind. Recently, the topic of “flushable” wipes has become front and center within the wastewater industry, as more consumers are turning to a wet wipe rather than the common dispersible toilet paper.

While flushable wipes have been on the market for years, the question of their degradability has been garnering more attention in the media and prompted state-level responses, such as the recently proposed bill in Maine requiring that products labeled “flushable” live up to their claim.

Advertising versus reality

According to the current Association of Nonwoven Fabrics Industry (INDA; Cary, N.C.) guidelines (GD3, June 2013), a “flushable” is “any product that is marketed as ‘flushable’ [that] can be flushed into the wastewater system without adversely impacting plumbing or wastewater infrastructure and operations.” Under voluntary INDA guidelines, a product must pass seven assessment tests or be clearly labeled with the “Do Not Flush” logo.

These tests include a toilet and drain-line clearance test, disintegration “slosh box” test, household pump test, settling column test, aerobic test, anaerobic test, and municipal pump test. According to INDA guidelines, if a product passes all seven tests, it should not “under normal circumstances” block toilets, drainage pipes, water conveyance, and treatment systems or become an aesthetic nuisance in surface waters. But testing and real life can have different outcomes, especially under “normal circumstances.” The U.S. Federal Trade Commission (FTC) recently announced its tentative agreement with wipe manufacturer Nice-Pak Products Inc. (Orangeburg, N.Y.), that might further define some of these issues.

Problems can’t be wiped away

For wastewater utilities, these “nondispersibles,” or anything other than human waste and toilet paper flushed down the toilet, are problematic throughout the treatment process. They cause ragging in pipes and lift stations and get caught in screens, pumps, and settling basins.

Nondispersibles wreak havoc in rainy and dry climates alike. They clog collection systems during storms and cause SSOs or, in a drought-ridden area (we’re looking at you, California), the lack of water velocity in collection systems prevents wipes from breaking down. In extreme and highly publicized cases, the accumulation of wipes and other nondispersibles can cause the formation of “fatbergs,” such as those weighing as much as 15 tons in London sewers.

Industry response to the flushables flood

Although recent media attention has increased awareness of the consequences of convenient-yet-clog-causing wipes (and other nonflushable materials), wastewater utilities throughout the country have responded with their own public education campaigns, such as “What2Flush” in California and “Don’t Flush Baby Wipes” in Maine. These initiatives, as well as the wastewater industry’s “Three P’s (Pee, Poop, and “Toilet” Paper) standard, have been informing homeowners and renters about what’s OK to flush and to not use toilets as trash cans.

The Water Environment Federation (WEF; Alexandria, Va.) has also been involved in the initiative to improve flushability requirements and educate the public. In 2010, the WEF Collection Systems Committee formed a Flushables Task Force in response to the growing concern about wipes-related problems. The WEF House of Delegates (HOD) followed suit in 2012 to involve Member Associations with the formation of the HOD Non-Dispersible Work Group.

To create a singular message, the WEF Flushable Task Group, formed in 2014 and currently chaired by Scott Trotter, has worked on several initiatives including a 2013 billing stuffer campaign with the tagline, “It’s a Toilet, Not a Trashcan!” The group also advocated for collaborative studies conducted by the Water Environment Research Foundation (Alexandria, Va.).

More recently, the Task Group, as a representative of WEF, is collaborating with four other associations representing the water sector and the nonwoven fabrics industry: INDA, the National Association of Clean Water Agencies (Washington, D.C.), the American Public Works Association (Kansas City, Mo.), and the Canadian Water & Wastewater Association (Ottawa, Ontario). The goal is to develop a new, fourth edition of guidelines (GD4) that will influence product design and support the marketing of nonwoven products as “flushable.” The guidelines are scheduled to be released in July 2016.

In addition, the collaborative effort is behind the Product Stewardship Initiative to increase public and consumer awareness about the proper disposal of wipes. The initiative seeks to improve the labelling of both flushable and nonflushable products, as well as increase the industry’s responsibility over the downstream impacts of flushable products.

WEF has been heavily involved in both GD4 and the Product Stewardship Initiative. As the awareness of the problems of flushable wipes continue to increase, both in the media and within the wastewater industry, WEF continues to support the initiatives of the Flushables Task Force. While we can’t stop consumers from flushing things down their toilets, we can stem the tide with better education and incentives for corporate responsibility.

Brianne Nakamura is a Program Manager in the Water Science & Engineering Center at the Water Environment Federation (Alexandria, Va.). She is the staff liaison for the Collection System Committee and can be contacted at

BNakamura Flushables-Toilet-Trash-Bill-Stuffer.jpg

Photo caption: The WEF Flushable Task Group, formed in 2014 and currently chaired by Scott Trotter, has worked on several initiatives for better public awareness about nondispersibles, including this 2013 billing stuffer campaign.