No Cause For Alarm? How What is Not Covered in the MFGM Can Impact MF/UF Plant Operations and Control System Set Points

This paper and associated presentation explores these areas of regulatory discretion under the Long-Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) membrane regulatory framework, discussing the impact of different approaches both qualitatively (i.e., from a policy perspective) and quantitatively (i.e., using a sensitivity analysis applied to the LRV equations). The objective of this work to help microfiltration (MF) / ultrafiltration (UF) system operators and regulators understand some of the important practical nuances of Membrane Filtration Guidance Manual (MFGM) implementation and, subsequently, develop policies that protect public health and regulatory compliance while maintaining smart, efficient plant operation. Accordingly, this work also discusses appropriate alarms and control system set points that will help operators facilitate these objectives. Examples from the Olivenhain Municipal Water District?s (California) David C. McCollom Water Treatment Plant, featuring a 34 MGD GE submerged UF system, will be provided to demonstrate the practical impact of these considerations on a functioning plant.