Date
Tuesday, July 29, 2025
Time
10:30 AM - 11:00 AM
Location Name
Room 301A
Name
Non-Potable Reuse of Municipal Wastewater in Lieu of Discharge
Track
Water Resource Recovery
Description
With xAI intending to build Colossus, the world’s largest supercomputer in Memphis, questions arose as to where the vast amount of cooling water needed for the project would come from. Concerns arose regarding the use of the Memphis Sand Aquifer and the potential depletion and adverse impacts on Memphis’ sole drinking water source. As such, xAI turned to the City of Memphis seeking approximately 13 MGD of treated wastewater to be used as cooling water. All of this occurred on the heels of Tennessee’s promulgation of its Non-Potable Reuse rules. xAI intends to design and construct the Colossus Water Recycling Plant (“CWRP”) which would provide additional treatment (beyond that provided by Memphis) to meet the reuse standards. Furthermore, xAI intends to provide its treated reuse wastewater to other downstream industrial users. In such case, xAI, not Memphis, would be the provider of reuse wastewater. Process wastewater from the CWRP would be discharged back to Memphis and subject to Memphis’ pretreatment program requirements. This scenario presents the unusual situation where the initial recipient of wastewater would be providing treatment to meet the reuse standards. Although inapplicable in this situation, Tennessee, by statute, requires applicants for a new or expanded wastewater discharge to surface waters to consider alternatives to discharge, including land application and beneficial reuse of treated wastewater. Regardless, there is a general consensus about the environmental benefit of using the City’s treated wastewater for cooling water purposes, thus resulting in the City, xAI, TDEC and environmental groups working towards a common objective. This paper will discuss practical, programmatic, and legal considerations associated with a municipality providing non-potable wastewater to be treated and reused by another entity. This includes, among other things, working through a set of rules that were not developed with these specific circumstances in mind, and addressing various implications associated with participation in such arrangements.