Non-potable Water Program Guidebook

A Guide for Implementing Onsite Non-potable Water Systems in San Francisco

San Francisco’s Non‑potable Water Program Opportunities to Reduce Potable Water Use

In September 2012, the City and County of San Francisco adopted the Onsite
Water Reuse for Commercial, Multi-Family, and Mixed-Use Development
Ordinance. Commonly known as the Non-potable Water Ordinance, it added
Article 12C to the San  Francisco Health Code, allowing for the collection,
treatment, and use of alternate water sources for non-potable uses in
buildings. Since 2012, the Non-potable Water Ordinance has been amended to
allow for district-scale projects, where two or more parcels can share alternate
water sources. In 2015, Article 12C became a mandatory requirement for new
development projects over 250,000 square feet of gross floor area to install
and operate an onsite non-potable water system.
Replacing the demand for toilet and urinal flushing with non-potable
water can offset approximately 25% of the total potable water use in
a residential building, and up to 75% in a commercial building. Other
potential non-potable demands include irrigation, cooling/heating
applications, process water, and clothes washing. Using onsite non-
potable water systems to meet these demands can further reduce
potable water demands by 50% to 90%.
Multi-Family Residential Water Use

Onsite non-potable water systems, also referred to as alternate water source Toilets and Urinals*

systems, provide a myriad of benefits such as reducing potable water use for Faucets

toilet flushing and irrigation, meeting Stormwater Management Ordinance Irrigation*

requirements, and helping San  Francisco achieve greater water supply Kitchen/Dishwashing
resiliency and reliability. The Non-potable Water Program was established to Cooling*
create a streamlined permitting process for onsite non-potable water systems
Leaks/Miscellaneous
and help designers and developers assess a project’s available alternate water
Showers
sources and non-potable demands. The program also supports San Francisco’s
Clothes Washing
OneWater approach of matching the right water source for the right use and
looking holistically at the utility’s services to develop programs and policies that Adapted from American Water Works Association; WaterSense

provide multiple benefits to conserve resources and promote ecosystem health.

This guidebook provides developers, architects, and engineers with the necessary
Commercial Water Use
steps to collect, treat, and use alternate water sources for non-potable uses. It
Toilets and Urinals*
also outlines the roles and responsibilities of each city agency involved in the
Faucets
approval and permitting process, including the San  Francisco Public Utilities
Commission (SFPUC), San Francisco Department of Public Health-Environmental Irrigation*

Health (SFDPH-EH), San Francisco Department of Building Inspection-Plumbing Kitchen/Dishwashing

Inspection Division (SFDBI-PID), and San Francisco Public Works (SFPW). Cooling*

Leaks/Miscellaneous

Adapted from WaterSense; EPA;

Australian Department of the Environment

* Non-potable water uses.

Published: January 2018

 Alternate Water Sources and End Uses

Commercial, mixed-use, and multi-family residential buildings

RAINWATER generate several types of non-potable water, or alternate water
sources. Rainwater, stormwater, foundation drainage, graywater,
and blackwater are the most common types of alternate water
Precipitation
collected from sources collected and treated by buildings in San Francisco. Other
roofs and above alternate water sources, such as condensate, and additional end
grade surfaces.
uses may be allowed if approved by SFDPH-EH.
BLACKWATER

In compliance with the SFDPH-EH Director’s Rules and Regulations

Regarding the Operation of Alternate Water Source Systems
Wastewater
from toilets, (Rules and Regulations), alternate water sources can be used to
dishwashers,
meet the following non-potable end uses:
kitchen sinks,
and utility sinks.
Indoor uses Outdoor uses

• Toilet and urinal flushing • Subsurface irrigation

• Priming drain traps • Drip or other surface

non-spray irrigation
GRAYWATER • Clothes washing
• Spray irrigation

Wastewater from
• Decorative fountains
clothes washers, and impoundments
bathtubs, showers,
and bathroom sinks. • Cooling applications

• Dust control/street cleaning

While the Non-potable Water Program provides a permitting

framework for larger commercial, mixed-use, and multi-family
STORMWATER developments, the SFPUC also encourages the use of alternate
FOUNDATION water sources in single-family and two-unit homes through its
DRAINAGE residential rainwater and graywater programs.
Precipitation collected
from at or below
Nuisance groundwater grade surfaces.
from dewatering
operations.

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 Requirements for Onsite Non-potable Water Systems

New development projects with 250,000 square feet or more of gross floor area that were issued a site permit after November 1, 2016, are required to install
and operate an onsite non-potable water system. The project must meet its toilet and urinal flushing and irrigation demands through the collection, treatment,
and use of available graywater, rainwater, and foundation drainage. While not required, projects may use treated blackwater or stormwater if desired.

Projects under 250,000 square feet may install an onsite non-potable water system to reduce the use of potable water and meet the requirements of
the Stormwater Management Ordinance. While not required to comply with Article 12C, these projects still need to meet the required water quality and
monitoring criteria. Notable differences in requirements for the two types of projects are summarized in the table below. New development projects

The Exploratorium (images courtesy of Amy Snyder © Exploratorium, All rights reserved)
between 40,000 and 250,000 square feet of gross floor area are required to submit a Water Budget Application and Water Use Calculator to the SFPUC
to assess the amount of available graywater, rainwater, and foundation drainage supplies for toilet and urinal flushing and irrigation.

Projects Not Required to Install an Onsite System Projects Required to Install an Onsite System

Requirements for alternate water
sources and non-potable end uses
Projects may use any approved alternate water
source for any approved non-potable end use in
accordance with the required water quality and
monitoring criteria
Projects must use available graywater, rainwater, and foundation drainage to meet
toilet and urinal flushing and irrigation demands in accordance with the required
water quality and monitoring criteria to the extent that:
• 100% of these demands are met, or
• 100% of the available graywater, rainwater, and foundation drainage
sources are captured and treated
Projects may also collect, treat, and use blackwater and stormwater

Projects are eligible for available grant funding Projects are not eligible for grant funding as the project is required to comply with
Eligibility for SFPUC grant funding
through SFPUC’s Non-potable Grant Program Article 12C

Subject to SFPUC water use allocation Projects are not assigned a potable water use Projects are assigned a potable water use allocation and are subject to excess use
program and excess use charges allocation and are not subject to excess use charges charges (more information is available on page 19)

Projects are eligible for adjusted water and

Eligibility for water and wastewater Projects are eligible for adjusted water and wastewater capacity charges (more
wastewater capacity charges (more information
capacity charge adjustments information available on page 18)
available on page 18)

Use of alternate water supplies, particularly rainwater, can reduce a project’s potable water footprint as well as provide a strategy to comply
with San Francisco’s Stormwater Management Ordinance. By considering compliance requirements for both non-potable water reuse and
stormwater management at the beginning of a project, it can lead to system sizing efficiencies and a more integrated design approach.

Download the Synergies for Compliance with the Non-potable Water Ordinance and Stormwater Management Ordinance Guidebook at
sfwater.org/np for assistance on how to optimally meet compliance with both ordinances.

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 8 Steps for Successful Implementation of an
Onsite Non-potable Water System

1 Submit a Water Budget Application to SFPUC

2 Submit a Non-potable Implementation Plan to SFPUC

(district-scale projects only)

The Exploratorium treats water from the San Francisco Bay for its heating and 3 Submit Engineering Report, Permit Application, and
Application Fee to SFDPH-EH
cooling system and uses rainwater for toilet and urinal flushing to meet the
Stormwater Management Ordinance.

4 Obtain Plumbing Plan Check and Permits from SFDBI

and Complete System Construction

5 Obtain Encroachment Permit from SFPW (if applicable)

6 Conduct a Cross Connection Test with SFPUC and

SFDPH-EH

7 Obtain a Permit to Operate from SFDPH-EH

8 Conduct Ongoing Monitoring, Reporting, and

Inspections

3
 1
The St. Anthony’s Dining Room and Mercy Housing joint project treats rainwater for
STEP Submit a Water Budget toilet and urinal flushing to reduce potable water use and comply with the Stormwater
Management Ordinance.
Application to SFPUC

Each project must first prepare a Water Budget Application.

The application provides an overview of the project’s onsite
non-potable water system and the available alternate water
supplies and proposed non-potable end uses.

Projects must submit either a single-building or district-scale

Water Budget Application prepared using the SFPUC Water
Use Calculator. The calculator incorporates detailed building
information such as square footage and number of residential
units, if applicable, to estimate the potential volume of
alternate water supplies for the selected non-potable uses.
The Water Use Calculator is available at sfwater.org/np.

The Water Budget Application and Water Use Calculator

must be approved by the SFPUC. Any modification to the
project’s proposed alternate water supplies or end uses
will require a resubmittal to the SFPUC. Upon approval of
the Water Budget Application, the SFPUC will inform the
project on the next steps for compliance under the Non-
potable Water Program and notify SFDPH-EH, SFDBI-PID,
and SFPW (if applicable) about the proposed project.
121 Golden Gate (image courtesy of David Wakely Photography)

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 2

Mission Rock (image coutesy of Steelblue and San Francisco Giants)

STEP
Submit a Non-potable Implementation
Plan to SFPUC (district-scale projects only)

Onsite non-potable water systems can be designed for a variety of scales,

including a single-building or district. A district is considered two or more
parcels within a development project. While sharing alternate water sources
within a district-scale development project can provide greater efficiencies for
onsite water reuse, projects are subject to additional requirements given the
complexity of design, phasing, and implementation.

Step 2 requires district-scale projects to submit a Non-potable Implementation

Plan to the SFPUC. This Plan must be prepared in accordance with the SFPUC’s
Checklist for the Non-potable Implementation Plan, which includes, but is not
limited to:
Large redevelopment projects are considering district-scale and
in-building non-potable water systems as a sustainable solution • Schematic layout of non-potable water system components
to reduce overall potable water use.
• Details on the non-potable water treatment system

• Estimated potable and non-potable water supplies and demands

• Estimated discharges to the sewer system

• Proposed ownership model and compliance plan

The following are commonly used terms for permitting • Operations and maintenance plan for non-potable water system
onsite non-potable water systems. Depending on the components
project configuration, the same entity may perform more
• Phasing for implementation of district-scale project
than one role.

Permittee: Property owner that holds a valid permit to With approval of the Non-potable Implementation Plan, the project may move
operate from SFDPH-EH and is responsible for ensuring forward to obtain additional approvals from SFDPH-EH, SFDBI-PID, and SFPW.
water quality, monitoring, and reporting requirements. District-scale projects must also execute an enforceable legal agreement that
Permittee is also referred to as Responsible Party in defines the roles and responsibilities of the supplier and user. Each property shall
Article 12C. designate a site supervisor to oversee operation and maintenance of their portion
of the district-scale project, including distribution and/or collection systems.
Supplier: Entity that supplies untreated non-potable
water to the district-scale system for treatment and reuse. Subject to SFPUC approval, district-scale projects may seek an alternative
compliance approach to Article 12C. For more information on alternative
User: Entity that accepts treated non-potable water 
compliance, visit sfwater.org/np.
for beneficial uses within their building or area.

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STEP
3 Submit Engineering Report, Permit
Application, and Application Fee to
SFDPH-EH
Projects must submit to SFDPH-EH an Alternate Water Source System Engineering
Report (Engineering Report) prepared by a qualified engineer licensed in California.
The Engineering Report must follow the instructions and template provided by
SFDPH-EH. In addition to the Engineering Report, an Application for Permit to
Operate an Alternate Water Source System and the appropriate fee must also be
submitted to SFDPH-EH.

The Engineering Report provides detailed information on the following

project elements:

• Alternate water sources collected and treated for non-potable end uses

• Entity or entities involved in the design, treatment, operation, and

38 Dolores Street (images courtesy of BAR Architects)

maintenance of the onsite non-potable water system

• Treatment system manager qualifications and responsibilities The Whole Foods mixed-use development project located at
38 Dolores Street uses rainwater for subsurface irrigation,
• Treatment processes used to meet required water quality criteria
reducing potable water for landscaping purposes and to
• Monitoring and reporting plan including information on operating comply with the Stormwater Management Ordinance.
conditions, continuous monitoring controls, and certified laboratory
for sampling analysis

• Cross-connection and backflow prevention measures

• Contingency plan and system bypass that will allow the system to
divert to the sewer

PERMIT EXCEPTIONS - Projects utilizing rainwater for subsurface irrigation

or surface non-spray irrigation (i.e. drip, bubblers) do not require a permit
under Article 12C. Additionally, projects using stormwater, graywater, or
foundation drainage solely for subsurface irrigation do not require a permit.

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 Onsite Non-Potable Water System Design Basics

Onsite non-potable water systems typically have the following major components: collection system,
equalization tank, treatment system, treated water storage, and non-potable water distribution system.
System designers should be mindful of water quality challenges associated with long periods of water storage
and are encouraged to efficiently size storage tanks to meet demands and include design and/or operation
features that minimize water age.

The sample schematic below features a 1-tank integrated configuration treatment system, which may be the
most efficient design with the fewest components and smallest overall storage volume. For more guidance
on system configurations, see the SFPUC’s Synergies for Compliance with the Non-potable Ordinance and
Stormwater Management Ordinance Guidebook available at sfwater.org/np.

Identification and Signage

RAINWATER

make-up water
line with air gap
Onsite non-potable water systems STORMWATER
first flush diverter
flow meter toilet/urinal
and their components must be equalization additional flushing
tank treatment
properly identified and labeled. (blackwater) (blackwater) filtration/
GRAYWATER
diversion disinfection diversion
valve
Non-potable water piping must be valve treated
rainwater/ water
purple and labeled as “non-potable” non-potable buffer
BLACKWATER
water cistern tank flow
meter
and must include arrows showing
bypass
direction of flow. All valves on the FOUNDATION bypass overflow to overflow irrigation
DRAINAGE
to overflow sewer
non-potable water distribution sewer sewer
system must be tagged.

Signage must also be installed in
restrooms where non-potable water
is used for toilet and urinal flushing.
Multi-family residential projects may
elect to place tags or signage inside
toilet tanks.
Signage is also required in equipment
rooms and on valve access panels.
Sites using non-potable water for
irrigation must post signs at site
entrances, along pathways, or as
otherwise determined by SFDBI-PID.
Periodically, onsite non-potable water systems will need to be taken offline for routine maintenance, inspections,
or other unforeseen conditions. It is critical that the system have a built-in bypass prior to the treated water tank
to direct non-potable water to the sewer system. All buildings must also have the ability to receive water from
the SFPUC in order to serve potable and make-up water for non-potable end uses. The connection to the make-
up water supply must be adequately protected by an approved backflow preventer. Additionally, the make-up
water supply must be plumbed downstream of the treatment system so that water can be supplied to the end
uses in the event the system is inoperable. Flow meters are required to track the system’s non-potable supplies
and potable make-up water.
Prior to commissioning an onsite non-potable water system, a shut-down test must be performed to ensure there
is no cross-connection between the potable and non-potable water systems. With the exception of rainwater
harvesting systems, a cross-connection test must be conducted at least once every four years thereafter. For
more information on backflow and cross-connection testing requirements, see Step 6 on page 15.

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 Treatment System Requirements

The Engineering Report must provide detailed information on the treatment processes used to meet the water quality criteria for allowed alternate water sources
and end uses. In addition to the physical and chemical water quality requirements, projects are required to demonstrate compliance with the log reduction
targets, or LRTs, listed below, which represent the minimum requirements for inactivation of pathogens including viruses, protozoa, and bacteria. To meet the
LRTs and other water quality requirements, projects should design an effective treatment train which may include the use of common treatment processes
such as microfiltration (MF), ultrafiltration (UF), membrane biological reactor (MBR), ultraviolet light (UV) disinfection, ozone disinfection, and chlorination. The
Engineering Report should detail how the treatment train will achieve pathogen reduction credits in order to meet the LRTs. Additionally, the Engineering Report
should address any validation, field verification, and ongoing monitoring requirements related to the treatment processes.

SFDPH-EH will review each project’s Engineering Report and accept pathogen reduction credits based on established crediting frameworks such as
those developed for drinking water, potable reuse, and non-potable reuse. Refer to the following pages for guidance on how to credit common treatment
processes, create effective treatment trains to meet the LRTs, and document the validation, field verification, and ongoing monitoring requirements in the
Engineering Report.

Log Reduction Targets for Onsite Non-potable Water Systems

Alternate Water Use Scenario Enteric Viruses Parasitic Protozoa Enteric Bacteria

Blackwater

Outdoor Use 8.0 7.0 6.0

Indoor Use 8.5 7.0 6.0

Graywater

Outdoor Use 5.5 4.5 3.5

Indoor Use 6.0 4.5 3.5

Stormwater or Foundation Drainage

Outdoor Use 3.0 2.5 2.0

Indoor Use 3.5 3.5 3.0

Rainwater

Outdoor Use N/A N/A 3.5

Indoor Use N/A N/A 3.5

8
The following table provides example pathogen reduction credits for common treatment processes. The associated documentation for each treatment
process must be submitted with the project’s Engineering Report. Other treatment processes may be used within the treatment train and SFDPH-EH
will assess pathogen reduction credits on a case-by-case basis.

Available Pathogen
Example Treatment Process Reduction Credits Example Information Included in an Engineering Report
Virus / Protozoa / Bacteria

Description and calculation of how the system defines an acceptable pressure decay test value per the
Microfiltration or Ultrafiltration 0/4/0
EPA’s Membrane Filtration Guidance Manual to detect 3.0 µm breach

Operation within the Tier 1 operating envelope as defined in the AWRCE Membrane bio-reactor, WaterVal
Membrane Biological Reactor 1.5 / 2 / 4
validation protocol

Demonstration of ability to meet salt rejection criteria and a description of surrogate parameter used to
Reverse Osmosis Up to 2 / 2 / 2
calculate pathogen reduction credits

UV reactor’s validation report following approved procedures or NSF/ANSI 55 Class A validation and
Ultraviolet Light Disinfection Up to 6 / 6 / 6
demonstration of ability of system to meet criteria to achieve specified UV dose

Demonstration of ability to achieve a target CT including description of contact basin, contact time
Chlorine Disinfection Up to 5 / 0 / 5
provided, and monitoring of chlorine residual

Demonstration of ability to achieve a target CT including description of contact basin, contact time
Ozone Disinfection Up to 4 / 3 / 0
provided, and monitoring of ozone residual

Chlorine Disinfection

Chlorine disinfection can be used to achieve pathogen reduction credits. To achieve credits, calculations must be shown in the Engineering Report
to demonstrate CT disinfection, where CT = Chlorine Residual Concentration x Contact Time. Specifics on how concentration and contact time is
determined should also be included in the Engineering Report. Contact time can be demonstrated via a tracer study or conservative assumptions.
Systems using free chlorine disinfection to achieve credit must have a chlorine dosing control system to ensure free chlorine residual in the presence
of ammonia in the feedwater. Additional chlorine residual sampling may be required at or near the point of use, such as toilets. To facilitate sampling,
installation of an inline chlorine residual monitor near the point of use should be considered during plumbing design and construction. Alternatively,
projects may consider using a handheld chlorine residual meter.

9
 UV Disinfection

UV disinfection is a critical treatment process to achieve the log reduction

targets. Pathogen reduction credits for UV are reactor-specific and dose
dependent. To achieve credits, the UV reactor must be validated using
one of the following guidelines, or have NSF/ANSI 55 Class A validation:

• EPA UV Disinfection Guidance Manual (USEPA 2006)

India Basin (image coutesy of Build Inc and Steelblue)

• German UV Devices for the Disinfection for Drinking Water
Supply Standard (DVGW 2006)

• NWRI UV Disinfection: Guidelines for Drinking Water and

Water Reuse, 3rd edition (NWRI 2012)

If UV is selected as a treatment process, the project’s Engineering Report

must include the UV validation report along with a letter demonstrating
that the report has been accepted by the California State Water Resources
Control Board, Division of Drinking Water.

Large redevelopment projects are evaluating compliance approaches

For a list of validated and accepted UV reactors, visit the Non-potable
to Article 12C, considering both fully private onsite non-potable water
Water System Resources List available at sfwater.org/np.
systems and public-private partnership opportunities.

Example Treatment Trains

Pier 70 (image courtesy of Design Distill)

The following pages provide example treatment trains to illustrate pathogen
reduction credits that can be achieved by each treatment process, as well
as the associated validation, field verification, and treatment requirements.
Also shown are the parameters that must be continuously monitored
at critical control points to ensure treatment system performance
and demonstrate the ability of each treatment process to achieve the
pathogen reduction credits. Treatment trains shown here are for planning
purposes only. An engineer licensed in California must be consulted to
design a treatment train necessary to meet SFDPH-EH water quality and
monitoring requirements. For additional example treatment trains, review
the non-potable program FAQ at sfwater.org/np.

10
 RAINWATER Example Rainwater Treatment System

UV

flow rate
UV transmittance
turbitidy

UV intensity

181 Fremont, Jay Paul Company, Heller Manus Architects, Image: Steelblue
UV Total Required

Virus 3.5 3.5 N/A

Pathogen
Protozoa 6 6 N/A
Crediting
Bacteria 3.5 3.5 3.5

UV

Validation and Field

Validation for dose of 80 mJ/cm2 per USEPA, NSF, or DVGW
Verification

Influent turbidity: 95% < 0.3 NTU; never > 1 NTU

Treatment System
Influent UVT > minimum validated value for UV reactor
Requirements
UV dose > 80 mJ/cm2

In a rainwater system, the only specified LRT is for bacteria. In this example, the use of
a validated UV reactor can achieve pathogen reduction credits based on the California
drinking water crediting framework and can meet the LRT for bacteria if it is operated
within its validated operating conditions. 181 Fremont Street, a new mixed-use building
in downtown San Francisco, collects and treats
Treatment systems with technologies that cannot meet the bacteria LRT are required to graywater and rainwater to meet nearly 100%
perform ongoing total coliform sampling to demonstrate the removal of bacteria. of their non-potable demands for toilet flushing
and irrigation. These onsite reuse strategies also
help the project comply with the Stormwater
Management Ordinance.
11
 GRAYWATER Example Graywater Treatment System Managing BOD
High concentrations of organics will be present in blackwater
and many sources of graywater. Reducing biological oxygen
MBR demand (BOD) is an important step in a well-designed
UV treatment train. Treatment trains for blackwater and graywater
must be able to reliably meet the treated water BOD limit
of 10 mg/L. Using biological treatment to reduce BOD and
suspended solids will help:

flow rate • Improve reliability of pathogen reduction performance in

UV transmittance downstream processes such as UV, chlorine, or ozone
Tier 1 operating envelope turbidity UV intensity
• Increase operational reliability of downstream processes
such as membrane filtration, reverse osmosis, or UV
MBR UV Total Required
• Minimize issues with aesthetics (color and odor)
Virus 1.5 6 7.5 6
Pathogen • Minimize regrowth of microorganisms (including
Protozoa 2 6 8 4.5 Legionella) in the distribution system
Crediting
Bacteria 4 6 10 3.5
The table below provides biological treatment technologies that
MBR UV can reduce BOD in an onsite blackwater or graywater system.

Validation for dose of

Validation and Field verification of Example Biological Treatment Technologies
150 mJ/cm2
Field Verification operation within Tier 1
per USEPA, NSF, or DVGW
Conventional Activated Sludge
UV dose > 150 mJ/cm2
Treatment System Effluent turbidity < 0.2 NTU Sequencing Batch Reactor
Requirements Operation within Tier 1 Influent UVT > minimum
validated value for UV reactor Membrane Biological Reactor

Engineered Wetland

In this example, the graywater system must meet the LRTs for indoor use.
Both MBR and UV are used to achieve the LRTs for graywater. The MBR
can receive credit for operation within the Tier  1 operating envelope. A
validated UV system providing a dose of 150 mJ/cm2 can receive credit
under the California drinking water crediting framework for the reduction
of virus, protozoa, and bacteria if it is operated within its validated
operating conditions.
Moving Bed Biofilm Reactor
Biofilter
An MBR can provide the dual-benefit of reducing organics
concentrations and providing pathogen reduction credit under
an existing crediting framework (see table on page 9).

12
BLACKWATER Example Blackwater Treatment System

MBR
UV Free chlorine

flow rate
Tier 1 operating UV transmittance
envelope turbidity UV intensity pH Free chlorine residual

MBR UV Free Chlorine Total Required

Virus 1.5 3.5 5 10 8.5

Pathogen Crediting Protozoa 2 6 0 8 7

Bacteria 4 3.5 5 12.5 6

MBR UV Chlorine

Validation and Field Validation for dose of 80 mJ/cm2

Field verification of operation within Tier 1 Tracer study or assumed baffling factor of 0.1
Verification per USEPA, NSF, or DVGW

UV dose > 80 mJ/cm2

Treatment System Effluent turbidity < 0.2 NTU CT no less than 10 mg-min/L
Requirements Influent UVT > minimum validated value with verified free chlorine residual
Operation within Tier 1 for UV reactor

In this example, the blackwater treatment system incorporates an MBR, UV, and free chlorine to meet the LRTs for blackwater for indoor use. The MBR is
credited per the Australian WaterVal validation protocol and must operate within the Tier 1 operating envelope. A validated UV system providing a dose
of 80 mJ/cm2 can receive credit under the California drinking water crediting framework for the reduction of virus, protozoa, and bacteria if it is operated
within its validated operating conditions. An additional 5-log credit for virus and bacteria can be achieved through the use of free chlorine if it is preceded
by either a membrane filter or MBR that meets the turbidity requirements. This system must have a chlorine dosing control system to ensure free chlorine
residual in the presence of ammonia in the feedwater.

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 STEP
4 Obtain Plumbing Plan Check and
Permits from SFDBI and Complete
System Construction

After approval of the Engineering Report by SFDPH-EH, the project must obtain
a plumbing permit from SFDBI. This requires contacting SFDBI-PID to conduct a
plumbing plan check to verify that the onsite non-potable water system meets the
State of California and San Francisco Plumbing Code requirements.

Once the system is constructed, a Construction Certification Letter must be submitted

SFPUC Headquarters
to SFDPH-EH certifying that the onsite non-potable water system was installed in
accordance with the approved Engineering Report. If system modifications were
made during construction, the letter must detail the changes. The Construction
Certification Letter must be provided on company letterhead, signed, and stamped
by a California licensed engineer.

At 525 Golden Gate Avenue, the San Francisco

Public Utilities Commission installed a Living
Machine™ to treat blackwater for toilet and urinal
flushing. The system has reduced the use of

5
potable water by 60% within the building.
STEP Obtain Encroachment Permit from SFPW
(if applicable)

Projects installing infrastructure in the public right-of-way (such as a sidewalk or

street) must be reviewed by SFPW for potential utility conflicts through the issuance
of an encroachment permit. As part of the streamlined permitting process under
San Francisco’s Non-potable Water Program, all projects requiring an encroachment
permit will be processed as a minor encroachment with no public right-of-way
occupancy assessment fee.

For more information on encroachment permit requirements, visit sfpublicworks.org.

14
 STEP
6 Conduct a Cross-Connection Test
with SFPUC and SFDPH-EH

Cross-Connection Test
Prior to commissioning any onsite non-potable water system, a cross-connection shutdown test shall be performed to ensure separation between the non-
potable and potable water systems. The test shall be conducted in the presence of a certified Cross-Connection Control Specialist authorized to work in
San Francisco and in coordination with SFPUC Water Quality Division and SFDPH-EH.

After the initial shut-down test, all onsite non-potable water systems, except rainwater harvesting systems, must undergo a cross-connection test at least
once every four years. Additionally, anytime a building’s plumbing system is altered, a cross-connection test must be performed. In fully occupied high-rise
buildings, cross-connection tests may be performed through a pressure differential test instead of a shut-down test. To facilitate the pressure differential
test, installation of a connection or fitting downstream of the main isolation valve on both potable and non-potable systems, in each pressure zone if
applicable, should be considered during plumbing design and construction.

Backflow Prevention
All buildings must have the ability to receive water from the SFPUC in order to serve potable uses and make-up water for non-potable end uses. Make-up
water must be supplied in a manner that protects the potable water system from potential backflow.

To protect the potable water system, properties that have onsite non-potable water
Market Street Place (image courtesy of CRP/Cypress Market Street, LLC)

systems must follow San  Francisco backflow prevention requirements listed below,
which are consistent with San  Francisco Health Code Article 12A and the State of
California and San Francisco Plumbing Codes.

Rainwater Harvesting

• Containment reduced pressure principle backflow prevention assembly (RP)

located within 25 feet of the building’s water meter

• Isolation RP or isolation air gap at the point of potable make-up to the non-
potable system

Blackwater, Graywater, Stormwater, and Foundation Drainage

• Containment RP within 25 feet of the building’s water meter

6x6, a six-level retail shopping center in downtown
San Francisco, will treat rainwater for cooling tower
• Isolation air gap at the point of potable make-up to the non-potable system
make-up and toilet and urinal flushing. Using rainwater
For more information, visit the SFPUC Cross-Connection Control Program website at
onsite also helps this project comply with the
sfwater.org/backflow.
Stormwater Management Ordinance.
15
 STEP
7 Obtain a Permit to Operate
from SFDPH-EH

Once steps 1 through 6 are completed, the project must submit a final operation
and maintenance manual, provide proof of a contract with a certified laboratory
(for necessary water quality analyses), provide documentation of an enforceable
legal agreement (applicable only to district-scale projects), and assign a qualified
treatment system manager that will operate and maintain the system. The project
must also obtain a Business Account Number through the San Francisco Tax Collector
and pay the annual license fee. Once the first license fee is paid, SFDPH-EH will issue

Moscone Convention Center (images courtesy of San Francisco Department of Public Works)

a permit to operate under two operational modes:

Conditional Startup Mode

Alternate Water Bypass Conditions Frequency of Total

Duration
Source (bypass to sewer) Coliform Sampling The Moscone Convention Center expansion project will treat
foundation drainage and rainwater for toilet flushing, cooling,
Rainwater,
Stormwater, 30 days None Weekly irrigation, and provide water for San Francisco Public Works street
Foundation Drainage cleaning vehicles. This project will significantly reduce the use
of potable water and meet the requirements of the Stormwater
Graywater 90 days 30 days Daily Management Ordinance.

Blackwater 180 days 30 days Daily

Final Use Mode

Alternate Water Bypass Conditions Frequency of Total

Duration
Source (bypass to sewer) Coliform Sampling

Rainwater, May be reduced or

Stormwater, eliminated upon
Foundation Drainage None, unless treated variance approval
Final Use Mode from SFDPH-EH if
non-potable water
applies as long as treatment system
does not meet
all permit conditions is continuously
Graywater specified water
are met monitored
quality requirements

Blackwater Daily

16
 STEP
8 Conduct Ongoing Monitoring, Reporting, and Inspections

To maintain a valid permit to operate, ongoing monitoring is required for all

onsite non-potable water systems to ensure systems are properly working Treatment Process Example Continuous Monitoring Methods

and continuously protecting public health. Monitoring of treatment

processes may include turbidimeters, UV transmittance meters, chlorine Microfiltration or • Daily pressure decay test
dosing control systems, and other instrumentation as needed. Ultrafiltration • Effluent turbidity

If a treatment process is being used to achieve log reduction targets,

continuous online monitoring of treatment process performance via Membrane
• Effluent turbidity
Biological Reactor
surrogate parameters is required. The table at the right highlights example
continuous monitoring methods for sample treatment processes.

All onsite non-potable water systems must conduct total coliform • Influent and effluent total organic carbon (TOC)
Reverse Osmosis
• Influent and effluent electrical conductivity
sampling during the Conditional Startup Mode.

Treatment system managers must report to SFDPH-EH at the following • Influent UV transmittance
frequencies: Ultraviolet Light • Influent turbidity
Disinfection • UV intensity
• Rainwater, graywater, stormwater, and foundation drainage systems • Flow rate

must submit monthly Discharge Monitoring Reports during

Conditional Startup Mode, and then annually thereafter • Chlorine residual
Chlorine Disinfection
• Flow rate
• Blackwater systems must submit monthly Discharge Monitoring
Reports in perpetuity

• All projects are required to submit a Non-potable Water System Ozone Disinfection
• Ozone residual
• Flow rate
Annual Report to SFDPH-EH that describes the system’s operation
during the calendar year

Lastly, in accordance with the approved operations and maintenance manual, the onsite non-potable water system must be regularly inspected and
tested to verify that the system is operating correctly, meets permit requirements, and remains physically separated from the potable water system.
Backflow prevention assemblies must be tested annually, and cross-connection tests must be conducted in accordance with Article 12A.

This concludes the 8-step permitting process for San Francisco’s Non-potable Water Program. Detailed information
about each permitting step as well as additional guidance and resources can be found at sfwater.org/np.

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 Capacity Charge Adjustments for Onsite Non-potable Water Systems

The SFPUC assesses a water and wastewater capacity charge prior to the issuance of a project’s site permit by SFDBI. One-time water and wastewater
capacity charges are designed to provide an equitable mechanism by which development projects that create new or additional demands on San Francisco’s
water and sewer system can pay their proportional share of the cost for the infrastructure required to serve them.

Understanding that onsite non-potable water systems provide many benefits, including reduced potable water use and discharges to the sewer system,
the SFPUC has implemented a capacity charge adjustment for development projects with onsite non-potable water systems. Effective February 1, 2017,
a project with an onsite non-potable water system will receive an adjusted water and wastewater capacity charge based on the size of the water meter
required to serve only the plumbing fixtures supplied with SFPUC water during normal building operation. This adjustment fairly assesses capacity charges
by only charging for the demand placed on SFPUC water and sewer systems.

The example below illustrates the potential savings from an adjusted capacity charge for a new building installing an onsite non-potable water system.
While the building is still required to install a water meter sized to meet 100% of the building’s water demands, the capacity charge is assessed based on
the size of the water meter required to serve only the fixtures supplied with SFPUC water during normal building operation. Note that actual cost savings
will differ depending on the meter size required for the project.

Example Capacity Charge Adjustment

Building without an onsite non-potable water system Building with an onsite non-potable water system
(assessed using potable and non-potable demands) (assessed using only potable water demands)

Size of Water Meter Installed 2” Size of Water Meter Installed 2”

Water Capacity Charge for 2” Meter $10,211 Water Capacity Charge for 1” Meter $3,192

Wastewater Capacity Charge for 2” Meter $34,744 Wastewater Capacity Charge for 1” Meter $10,857

Total Capacity Charge: $44,955 Total Capacity Charge $14,049

Capacity Charge Savings: $30,906

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 Water Use Allocation Program

In 2017, the SFPUC approved a water use allocation program and excess use charges for new development projects that are required to install an onsite
non-potable water system. The program was adopted to ensure that onsite non-potable water systems are continuously operated and maintained in
accordance with the requirements of the Non-potable Water Program. Using potable and non-potable water demands identified in the Water Budget
Application and Water Use Calculator, a monthly water use allocation will be assigned to each project.

The monthly water use allocation establishes the project’s maximum potable water use under normal building operations. Projects that exceed their
monthly allocation are subject to excess use charges, calculated at 300% (or “3x”) applicable water and wastewater rates. Excess use charges are applied
to the project’s monthly SFPUC bill, in additional to the normal water and sewer charges.

Excess use charges are applicable one year after a project receives its first water and sewer bill from the SFPUC to allow for commissioning of the onsite non-
potable water system. For example, a project that receives their first SFPUC bill in August 2017 will not be subject to excess use charges until August 2018.

The example below illustrates an excess use charge for a project that exceeded its monthly allocation by 50 billing units, also known as CCF or hundred
cubic feet (1 CCF = 748 gallons). The example project assumes a 95% flow factor, which represents the amount of water returned to the sewer. Water and
sewer rates are for illustrative purposes only.

Example Excess Use Charge

Potable water allocation for August 100 CCF

Example Water
Potable water consumption for August 150 CCF
and Sewer Rates
Excess water use 50 CCF

Water excess use charge ($21 x 50 CCF) $1,050 $7.00/CCF

Sewer excess use charge ($45 x 47 CCF) $2,115 $15.00/CCF

Total Excess Use Charge for August $3,165

If the project’s baseline allocation is incorrect, water use practices have changed, or if there is a change in building use, the SFPUC will consider
allocation appeals on a case-by-case basis.

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 Additional Resources

This guidebook serves as a resource to assist with San  Francisco’s permitting process
for onsite non-potable water systems. It is not intended as a substitute for a qualified
professional completing a comprehensive design process for your specific project.
Additional resources for San  Francisco’s Non-potable Water Program can be found at
sfwater.org/np, including:

• Case Studies of San Francisco Non-potable Water Projects

• Non-potable Water Program Factsheet

• Non-potable Water System Resources List

• San Francisco Department of Public Health Director’s Rules and Regulations

Regarding the Operation of Alternate Water Source Systems

• San Francisco Health Code, Article 12A, Backflow Prevention

• San Francisco Health Code, Article 12C, Non-potable Water Ordinance

• San Francisco Public Utilities Commission Rules and Regulations Governing

Water Service to Customers, Section G, Cross-Connection Control

• Stormwater Management Requirements and Guidelines

• Synergies for Compliance with the Non-potable Water Ordinance

SFPUC Headquarters
and Stormwater Management Ordinance Guidebook

• Water Budget Applications for single buildings and district-scale projects

• Water Use Calculators for single buildings and district-scale projects available for
download at sfwater.org/np

NON-POTABLE GRANT PROGRAM - The SFPUC periodically offers grant assistance to projects that implement an onsite non-potable water
system and are not subject to the mandatory requirements of Article 12C. The SFPUC’s Non-potable Grant Program encourages the voluntary
installation of onsite non-potable water systems to maximize the use of non-potable water for toilet flushing, irrigation, and other non-potable
uses. The grant program has limited funding and is awarded to qualified projects on a first-come, first-serve basis. For more information, contact
nonpotable@sfwater.org.

20
Advancing Onsite Non-potable Water Reuse

Since launching the Non-potable Water Program in 2012, San Francisco

has partnered with other local and state agencies to address the barriers,
opportunities, and research needs for onsite non-potable water systems.
With support from the Water Research Foundation (WRF) and Water
Environment Research Foundation, the SFPUC convened a coalition of
public health agencies and water utilities from across the country to
develop the Blueprint for Onsite Water Systems: A Step-by-Step Guide
for Developing a Local Program to Manage Onsite Water Systems.

The SFPUC, in partnership the coalition, led an effort to evaluate

existing water quality standards for alternate water sources, develop
recommendations to help regulators implement oversight and
management programs for onsite non-potable water systems, and
establish uniform standards among states. After a year-long research
effort, Risk Based Framework for the Development of Public Health
Guidance for Decentralized Non-potable Water Systems was published
by WRF and Water Environment & Reuse Foundation (WE&RF) to
provide regulators with an appropriate water quality framework and
monitoring regimes.

In 2016, the SFPUC partnered with the U.S. Water Alliance to convene
the National Blue Ribbon Commission for Onsite Non-potable Water
Systems. The Blue Ribbon Commission consists of 33 representatives
from public health agencies and water and wastewater utilities from 11
states and the District of Columbia and is funded by WRF and WE&RF.
In 2017, the Blue Ribbon Commission released the Guidebook for
Developing and Implementing Regulations for Onsite Non-potable
Water Systems, which includes model regulation and resources for states
and municipalities interested in establishing programs. Additional goals
of the Blue Ribbon Commission include identifying the benefits of onsite
non-potable water systems and identifying research needs to further
advance the field of onsite water reuse. For more information on the Blue
Ribbon Commission, visit sfwater.org/iuws.

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Non-potable Water Program Guidebook