Water Services National Training Group

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Water Services National Training Group

• 12th Annual Conference
• 11th September, 2008

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Water Services National Training Group

• Drinking Water Safety Licensing

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Safety Security of Water Supplies

• Brendan Wall
• Senior Inspector
• Environmental Protection Agency

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Presentation

• Overview of role of EPA
• Drinking Water Regulations
• Enforcement Notifications/Audits
• Case Studies
• Drinking Water Booklets

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EPA Structure

• Office of Environmental Enforcement
• Role of the OEE
• Water Enforcement Team
• DW Enforcement
• Reporting

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Some Key points of 2007 Regs

• Water supplier must supply water that is
  wholesome and clean
• Standards for 2 Microbiological, 26 Chemical and
  20 Indicator parameters
• Meets the quality standards and is free from
  microorganisms or substances which constitute a
  potential danger to human health
• Focus is on human health and corrective action to
  be taken in the event of a non-compliance

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EPA Enforcement

• LAs must notify the EPA when health risk or
  breach of quality standard
• EPA to investigate and can issue direction to LA
  if appropriate
• EPA can prosecute if LA fails to comply with
  Direction

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Enforcement Overview

• Regulation 9 public health
• Regulation 10 non-compliances

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Enforcement Overview

• No of Notifications 326 (225 in 2008)
• No of Audits 75 (47 in 2008)
• No of Directions 37 (15 in 2008)
• No of Prosecutions 1 in 2008
• up to end of August

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Safety and Standards

• Standards were the main way to measure safety
• Examples have not demonstrated this
• Another approach is needed
• Walkerton

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Walkerton

• Walkerton, Ontario, Canada
• www.attorneygeneral.jus.gov.on.ca/english/about/pu
  bs/walkerton/
• May 2000 contaminated with bacteria, primarily
  Escherichia coli O157H7.
• Seven people died and more that 2300 ill
• Inquiry into the incident
• Entered system through a well
• Primary source of contamination was manure spread
  on land near the well. Famer not to blame.
• Would have been prevented by the use of
  continuous chlorine residual and turbidity
  monitors at the well

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Auditing of Water Supplies

• Regulation 17 of DW Regs
• Each supervisory authority must audit water
  suppliers.
• Frequency of auditing should be based on risk
  criteria but should also include provision for
  unscheduled audits
• EPA audits will be based on notificaitons
  received and scheduled audits

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Focus of EPA Enforcement

• Source protection
• Disinfection system monitors/alarms
• Management of filters
• Effectiveness of chemical dosing
• Overall management Water Safety Plan Approach

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1. Source Protection

• Routine monitoring of the raw water to
  characterise water (incl. E. coli)
• Catchment surveys should be conducted on high
  risk activities
• Trends in RW quality should be conducted to
  determine the optimum treatment conditions.
• Actions must be taken to reduce risk of
  contamination of supply

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2. Disinfection

• Disinfection must be complete and verifiable
• WHO Guidelines for Disinfection must be met
• gt 0.5 mg/l Cl2 during the whole contact period
• At least 30 mins contact time
• Turbidity of lt1.0 NTU
• pH lt8
• Disinfection system monitor and alarm (for Cl2
  and UV)
• Duty and standby dosing systems with automatic
  changeover
• Flow proportional dosing of disinfectant
• EPA Circular issued in August 2008

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Chlorine Monitor
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3. Management of Filters

• Minimum design depth for media
• Flow rates must not be excessive
• Appropriate control over backwashing of filters
• Turbidity monitors after each filter
• First run of water through filters run to waste
• Media examination for problems (e.g. cracks,
  boils, poor backwash arrangements)
• EPA Water Treatment Manual Filtration

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Uneven Backwash
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Even Filter Backwashing
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Turbidity spikes when filter brought back into
service
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RGSF Boils , cracks, algae
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RGSF Preferential Flow
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4. Chemical Dosing

• Characterisation of raw water to determine
  treatment and dose
• Must be capable of treating water under all
  conditions (shut off may be needed)
• Duty/standby dosing pumps with automatic
  changeover
• Regular jar tests under different conditions
• Linking dose to online raw water monitors e.g.
  colour analysers or algorithms
• Online and visual monitoring of process (e.g.
  floc blanket formation, residual coagulant)

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Colour analyser
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Duty/Standby Dosing Points
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5. Water Safety Plan Approach

• From the 70s to 90s, drinking water quality
  guidelines kept adding more parameters or lowered
  limits or both
• The premise being that water quality limits
  alone, assured safe water
• Countless examples like Walkerton (and Galway!!)
  have shown this premise to be untrue
• Treated Water Monitoring Does Not Assure Safety
• All of the WSP approach is good practice and much
  should be in place already
• http//www.who.int/water_sanitation_health/dwq/gdw
  q3rev/en/index.html

x
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Water Safety Plan Approach

• Basic Development and Implementation of the
  approach involves
• Identification of all hazards from catchment to
  the consumers tap
• Assessment of the risk presented by each hazard
• Consideration if controls or barriers are in
  place and if these are effective
• Identification where improvements are needed
• Implementation of an improvement plan, where
  necessary
• Demonstration that the system is consistently
  safe
• Regular reviews of the hazards, risks and
  controls
• Keeping of accurate records for transparency and
  justification of outcomes

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Water Safety Plans
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2008 Activities

• Drinking Water Meetings with every local
  authority
• Respond to Notifications
• At least one audit in every local authority
• Remedial Action List (339)
• Set out proposed solution and timeframe
• Establish Network group from CCMA, DEHLG, HSE and
  EPA
• RAL
• Safe and Secure Approach
• Foster links with WFD

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Weather in August

• 20 boil water notices/restrictions of use put in
  place following heavy rainfall in August (44 for
  2008 to date)
• Over 87,000 persons affected
• E. coli the main reason (9), then coliforms (4),
  discoloured water (7)
• Some treatment plants could not cope with heavy
  rainfall and poor raw water quality

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Lessons Learned

• Plants must be designed to cope with all raw
  water conditions
• Treatment must be appropriate
• Treatment must be able to respond (e.g. automated
  chemical dosing, intake shutdown etc)
• Security of water supply must be robust enough to
  cope with challenges

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Case study 1

• Supply originates from a river and is treated by
  pressure filters (occasionally alum is added)
• Treatment plant inadequate (serves 500 people)
  and due for replacement
• E. coli failure (140/100ml) on 9th July 2007
• EPA HSE notified
• Chlorine cylinder had run empty and supply was
  not being chlorinated
• No standby cylinder with automatic changeover
• No chlorine monitor and alarm
• Disinfection process not secure

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Case study 1

• EPA Direction (August)
• Install chlorine monitor and alarm within 2
  months
• Review practices in relation to
  inspection/replacement of chlorine cylinders
• Council response indicated no chlorine monitor
  was to be installed as plant was to be replaced
  in Feb 08
• EPA audit in November found that
• Supply was inadequately treated
• Inadequate process monitoring
• Inadequate disinfection no chlorine monitor
  installed

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Case study 1 Outcome

• Summons issued in February for failure to install
  a chlorine monitor and alarm
• County Council pleaded guilty and were prosecuted
  in April.
• Fines of 4,000 and costs of 5,500 awarded
• Alarm fitted in May 2008
• Source now discontinued.

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EPA Guidance

• Water Treatment Manuals
• Disinfection
• Filtration
• Coagulation, Flocculation and Clarification
• European Communities (Drinking Water)
  Regulations, 2000 A Handbook on Implementation
  for Sanitary Authorities

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EPA Guidance Booklets

• Booklet No 1. Guidance for Local Authorities on
  Regulation 9 and Regulation 10 of the European
  Communities (Drinking Water) (No. 2) Regulations
  2007 (SI No. 278 of 2007).
• Booklet No 2. Annual reporting of drinking water
  monitoring results.
• Booklet No 3. Guidance for local authorities on
  the development of a remedial action list for
  public water supplies.
• Booklet No 4. Risk screening methodology for
  Cryptosporidium.
• Working on three new booklets - To Issue
• Booklet No 5. Auditing of water supplies by
  supervisory authorities.
• Booklet No 6. Exempted drinking water supplies.
• Booklet No 7. Monitoring function of local
  authorities.

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Environmental Enforcement Network
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FAQs
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Advice and Guidance
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Booklet No. 5

• Audit of Water Supplies by Supervisory
  Authorities
• Binding guidelines under Reg 17
• Preparation of Annual Drinking Water Audit Plan
• Risk based approach to auditing supplies
• Guidance on frequency and content

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Booklet No. 6

• Exempted Drinking Water Supplies
• Binding guidelines under Reg 14
• Those served by exempted supply must be
• Made aware that Regs do not apply to them
• Made aware of actions they can take to protect
  their supply
• This should be done by
• Local ads
• Leaflets
• Liaison with local community groups

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Booklet No. 7

• Monitoring Function of Local Authorities
• Guidelines under Reg 7
• Monitoring programmes should be documented
• Require review and approval of the EPA
• Guidelines in EPA Handbook apply

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Water Services National Training Group

• 12th Annual Conference
• 11th September, 2008