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Arizona Advanced Water Purification Rules (A.A.C. R18-9-A801)
Overview of Terminology
The term “direct potable reuse” does not appear in the Arizona Administrative Code. Rather, Arizona has established rules for “Advanced Water Purification.” The meaning at A.A.C. R18-9-A801.6 states:
“Advanced Water Purification” or “AWP” means the treatment or processing of treated wastewater to advanced treated water standards for the purpose of delivery to a drinking water treatment facility or a drinking water distribution system.”
The Arizona Advanced Water Purification Program includes:
- Facility planning
- Public outreach
- Permitting
- Piloting
- AWP-specific operator certification
- Chemical control
- Pathogen control
- Monitoring and reporting.
Title 18, Chapter 9, Article 8 Structure A.A.C. Title 18, Chapter 9, Article 8 is composed of six parts.
Part A. General Provisions (AAC R18-9-A801. et. seq.)
- Definitions
- Program Review
- Applicability of the Safe Drinking Water Act
Part B. General Program Requirements
- Advanced Water Purification (AWP) Operator Certification
- AWP Responsible Agency (AWPRA) – the utility proposing the AWPF project and obtaining/complying with the AWP Permit
- Inspections, violations, and enforcement
- Recordkeeping
- Construction and compliance with plans
- Record drawings
- Outreach; public communications plan
Part C. Pre-Permit and Permit Requirements
- Pre-Application activities
- Applicant pathways depending on National Pretreatment Program applicability
- Initial source water characterization
- Pilot study
- Permit application
- Demonstration permit
- Compliance schedule
Part D. General Permit Requirements
- Public notice
- Public participation
- Permit amendments
- Permit term; permit renewal
- Permit suspension, revocation, denial, or termination
Part E. Constituent Control, Monitoring, and Reporting
R18-9-E824 – Enhanced Source Control
Treated wastewater used as a source for an AWP project must come from a reclamation facility with an authorized enhanced source control program. Enhanced source control is an expansion of National Pretreatment Program requirements.
Requirements to obtain a localized enhanced source control program include:
- Enforcement authority
- Addressing constituents of concern
- Summary of local limits
- List of potentially impactful non-domestic dischargers
- Map of collection system
- Activities to protect WRFs and AWTFs from interference or pass-through
- Implementing an early warning system to obtain advance notice of a constituent of concern
- Response plan to address exceedances
- List of prohibited discharges
- Preparation of an annual report
R18-9-E.825 - Tier 1 Chemical Control; Maximum Contaminant Levels
Tier 1 chemicals are those that have National Primary Drinking Water Regulations (NPDWR) MCLs. References:
- Federal NPDWR: 40 CFR Part 141 at (Can be found at eCFR :: 40 CFR Part 141 — National Primary Drinking Water Regulations.)
- Arizona Safe Drinking Water regulations: 18-04.pdf.
R18-9-E826 - Tier 2 Chemical Control; (AWP-Specific Chemicals)
Advanced water purification-specific chemicals are established through various analyses and sources. They may include:
- Chemicals from non-domestic dischargers to the collection system (identified through the Enhanced Source Control Program);
- Chemicals from lists of drinking water standards and health advisories.
- Drinking water notification levels from other states.
- Arizona Department of Environmental Quality health advisory levels.
- Chemicals with a Reference Dose (RfD) or Cancer Slope Factor (CSF) in peer-reviewed literature or state or Federal databases.
- The utility proposing the Advanced Water Purification Facility (called the Advanced Water Purification Responsible Agency – AWPRA) would then need to establish action and alert levels for these chemicals that would be incorporated into the AWP Permit.
See details on page 176 at 18 A.A.C. 9.
R18-9-E827 - Tier 3 Chemical Control; (Performance-Based Indicators)
Performance-based indicators are used to establish the ability of the treatment processes to remove the contaminants to acceptable levels or to detect a process failure. Performance-based indicators may be selected from pre-existing chemicals identified in the treated wastewater or introduced by the AWPRA applicant. AWPRA applicants may use surrogate parameters to represent performance-based chemicals if it is demonstrated, through testing, that they correlate with the concentration of the chemicals and removal capability of the treatment processes.
The AWPRA applicant shall designate critical control points where monitoring will be performed to demonstrate performance of each process in the treatment train.
See details on page 177 at 18 A.A.C. 9.
R18-9-E828 - Pathogen Control
Pathogen control is based on demonstrating LRVs for surrogate pathogens:
- Enteric viruses
- Giardia lamblia cysts
- Cryptosporidium oocysts
Site-Specific LRVs (minimum):
- 8-log viruses
- 6-log Giardia lamblia cysts
- 5.5-log Cryptosporidium oocysts
Critical control points must be designated for pilot and full-scale systems.
Operations Plans must include:
- Process failure response times
- Operator response times
- Automatic shutdown procedures
See details on page 178 at 18 A.A.C. 9.
R18-9-E829 - Ongoing Monitoring Requirements
Once the Advanced Water Purification Facility (AWPF) is in full-scale operation ongoing monitoring must be conducted as follows:
- Pathogen Control Monitoring is performed at critical control points using validated operational parameters (e.g. turbidity).
- Tier 1 Chemical Monitoring: Conducted quarterly for all Tier 1 chemicals (NPDWR MCLs), except Nitrite, Nitrate as Nitrogen, and TOC, which are continuously monitored.
- Tier 2 Chemical Monitoring: Conducted monthly for treated wastewater and advanced treated water.
- Tier 3 Chemical Monitoring: Conducted at all designated critical control points as approved by ADEQ.
- Ammonia and Nitrite and Nitrate as Nitrogen: Shall be conducted continuously using online analyzers. Monitoring shall be conducted at the treated wastewater influent and advanced water effluent.
- Total Organic Carbon Monitoring: Shall follow the requirements in R18-9-E834 Total Organic Carbon Management. Management may be accomplished using the Standard Approach or Limit, or a site-specific approach. The standard approach requires the AWPRA to meet a TOC limit of 2 mg/L in the advanced treated water. The site-specific approach requires the AWPRA to conduct a Trace Organics Removal Procedure and Disinfection Byproducts Precursor Reduction Procedure to establish a TOC limit.
See details on page 179 at 18 A.A.C. 9.
R18-9-E830 - Reporting Requirements
The AWPRA must conduct the following reporting:
- Pathogen Reporting
- Tier 1 Reporting
- Tier 2 Reporting
- Tier 3 Reporting
- Ammonia and Nitrite and Nitrate as Nitrogen reporting
- TOC reporting
- Water Reclamation Facility Operational Parameters Reporting
See details on page 181 at 18 A.A.C. 9.
R18-9-E831. Annual Report
The AWPRA shall prepare a comprehensive annual report and submit to the Arizona Department of Environmental Quality postmarked no later than March 30th.
See details on page 181 at 18 A.A.C. 9.
Part F. Technical and Operational Requirements
- Minimum Design Requirements
- Technical, Managerial, and Financial Demonstration
- Total Organic Carbon Management
- Full Scale Verification
- Operations Plan
- Vulnerability Assessment
See table below for a Summary of Arizona’s Advanced Purified Water Specifications.
Staying Ahead of Arizona’s Advanced Water Purification (AWP) Requirements
As Arizona’s Advanced Water Purification (AWP) regulations continue to evolve, maintaining compliance depends on precise recordkeeping, reliable monitoring, and timely, accurate reporting. SAMS streamlines this entire process by centralizing your operational data, automating routine compliance tasks, and organizing all required documentation—including chemical monitoring logs, source control records, pathogen verification data, operational plan components, and annual reports for ADEQ. With these workflows already built into the system, you don’t have to determine which reports you need or how to structure them—SAMS has you covered. As your dedicated compliance partner, SAMS helps ensure your facility remains fully prepared and aligned with state requirements today and well into the future. Book a demo to see how SAMS supports comprehensive water purification compliance.
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About The Author
At NJBSoft, we’re proud to collaborate with experts like Robert Hollander, P.E., whose extensive experience in water quality and regulatory compliance allows us to design SAMS in order to meet industry needs. Bob’s leadership and deep industry knowledge supports utilities in staying organized, compliant, and focused on protecting public health every day.
Robert Hollander
- 45 years of experience in water quality, regulatory compliance, and utility management
- President of Hollander Consulting Services
- Held senior roles at the City of Peoria, City of Phoenix, and the Arizona Department of Environmental Quality
- Served as President of the AZ Water Association and the Western Coalition of Arid States
- Licensed Professional Engineer in Arizona with multiple Grade 3 operator certifications
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