docs2.health.vic.gov.audocs2.health.vic.gov.au/docs/doc... · Description of proposed regulation 1...

PROPOSED SAFE DRINKING WATER REGULATIONS

Key Stakeholder Consultation – Feedback template

Tim Harding & Associates

ABN 55 102 917 624

PO Box 5113,

Cheltenham East VIC 3192

In association with

2

Identifying advantages and disadvantages of the proposals

In Table 1 below, please identify any advantages or disadvantages from the following proposals for the Safe Drinking Water Regulations (SDWR), in

comparison to a base case of no regulations.

Stakeholder listed advantages and disadvantages of proposed reforms

Proposal

number

Description of proposed regulation1 Advantages of proposal Disadvantages of proposal

1 Water sampling localities (WSL)

1(a) Specify an area to be a water sampling locality taking into

consideration:

• the nature and design of the distribution system;

• the sources of the drinking water; and

• any other matter that the Secretary considers relevant.

Remove explanation on how this is to be specified.

(with reference to its boundaries using: geographic co-

ordinates; freeway; highway; road; street; other

thoroughfare; railway line; municipal boundary; physical

feature of terrain; waterway; or property boundary)

Retain gazettal mechanism in order to formalize this

process. (WSL referred to in drinking water quality

standards and sampling frequency regulations)

The proposed change will

reduce the administrative

burden of specifying water

sampling localities with

reference to boundaries.

Nil

1 Includes maintaining some current requirements.

3

Proposal

number


2 Water sampling points

2(a) Department to no longer approve water sampling points

within water sampling localities.

Water sampling points should be part of a water sampling

program incorporated in the RMP.

Distribution and appropriateness of water sampling points

to be checked during risk management plan audits.

These proposed changes will

allow greater flexibility with

sample point selection where

water supply networks are

constantly changing (i.e. in

the case of new

developments, new

distribution mains etc.).

This proposed new approach

will allow greater

consideration of risk, where

internal network expertise will

determine the

appropriateness of water

quality sample points.

Nil

4

Proposal

number


3 Required content of risk management plans

3(a)

3(b)

Names, contact details, positions held by persons

responsible for managing hazards and risks to water

quality identified in the risk management plan.

Details of the activities/measures taken to manage

hazards and risks including the method by which

effectiveness of activities/measures is verified.

• Outline the operational procedures and process

controls at each CCP (including determining the

critical limits and performance criteria for each

CCP, along with alarming, reporting and mitigation

procedures).

• Incorporate water sampling programs.

• Include details of the actions taken to improve

employee awareness and training, including

training of water treatment operators and water

sampling officers.

3a

Retention of this requirement

will maintain clear, defined

channels of communication

alongside the definition of

roles/responsibilities.

3b

Outlining critical limits and

CCPs would unlikely be an

onerous process as the

majority of water businesses

will have already undertaken

this process.

3a

This requirement may be onerous

where staff changes result in the

requirement to update details

regularly. Further, duplication will be

evident with existing emergency

management plans.

3b

A clear definition of CCPs and critical

limits is required to accurately

characterise cost and resource

implications. Also, given the high level

nature of the discussion paper, a

clearer understanding of what would

be expected in terms of verification is

required (cost estimates for additional

verification requirements are included

in Attachment 1).

5

Proposal

number


3(c)

3(d)

3(e)

3(f)

Details of the features of the system of supply designed

to assist in the management of risks to water quality

identified in the risk management plan, including

verification method for effectiveness of these features.

• Identify the critical control points (CCPs) within a

treatment plant.

For water supplier - details of the procedures for

consultation with water storage managers and other

water suppliers for the purpose of achieving agreement

on the hazards and risks to quality of the water supplied.

Details of procedures and management systems for:

- ensuring that amount/purity chemicals added to

drinking water does not adversely affect the quality of

that water/pose risk to human health; and

- controlling residue or chemical by-products imparted

to drinking water as a result of the addition of

chemicals

Details of emergency management

arrangements/procedures for dealing with an incident

(details of person and public communication information

dissemination method)

3c

Retention of this aspect of the

regulations is supported as it

provides a worthwhile

platform to document system

changes and allows for clear

identification and

documentation of CCPs.

The proposed changes will

allow for consistency of

approach across water

businesses.

3d

Not applicable to East

Gippsland Water

3e


existing regulations is

supported as its effectiveness

has been demonstrated.

3f




has been demonstrated.

3c

A clear definition of CCP is required

accurately evaluate cost and resource

implications.

3d

Nil

3e

Nil

3f

Some duplication will be evident with

existing emergency management

plans.

6

Proposal

number


3(g)

Must address the:

- risk to human health of pathogenic micro-organisms,

inorganic/organic chemicals, radiological parameters

and algal toxins in water; and

- risks from incident or event that may cause

pathogenic micro-organisms, inorganic/organic

chemicals, radiological parameters and algal toxins to

enter or be present; and

- risk of transfer of pathogenic micro-organisms,

inorganic/organic chemicals, radiological parameters

and algal toxins in water being supplied.

• Outline the steps that will be taken to quantify and

analyse the risk of each hazard identified in the plan.

3g

Retention of the existing

component of 3(g) is

supported and is likely to be

already undertaken by the

majority of water businesses.

3g

The additional paragraph, read in

conjunction with the technical report

and the discussion paper, raises a

number of questions that require

clarification before the

advantages/disadvantages can be

adequately assessed. East Gippsland

Water has made a number of

assumptions in order to assess the

costs involved in meeting the log

reductions presented in the technical

report. These assumptions, alongside

the operational and capital cost

implications of this item for East

Gippsland Water are presented in

Attachment 1.

4 Documents to be reviewed as part of a risk

management plan audit

4(a) The risk management plan.

Any document or operating manual, procedure or protocol

created pursuant to the risk management plan or

containing material relating to the content of the risk

management plan

The following is made redundant if listed as a

requirement of RMPs:

Any training and competency manual relating to the

responsibilities of the staff of the water supplier or water

storage manager

4a




has been demonstrated and

the approach is familiar to

water businesses.

4a

As outlined in the VicWater

submission, East Gippsland Water

notes that some of the wording in the

regulations (existing and proposed)

could be improved in terms of

simplicity and clarity. This section is

an example of where a plain English

re-write could be beneficial.

7

Proposal

number


5 Form and content of an audit certificate

See Addendum 1

Nil Nil

6 Approval criteria for risk management plan auditors

6(a) Applicant holds an accreditation by an institution which in

the opinion of the Secretary, make the applicant suitable

for approval as a risk management plan auditor.

Applicant demonstrates to the Secretary that he or she

has the experience, qualifications and skills necessary to

independently conduct audits of risk management plans.

Applicant must provide to the Secretary a written

declaration that he or she has no conflict of interest that

would impinge on their ability to objectively conduct an

audit of a risk management plan.

Nil Nil

7 Drinking water quality standards

7(a) Drinking water must not contain any algal toxin,

pathogen, substance or chemical, whether alone or in

combination with another toxin, pathogen, substance or

chemical, in such amounts that may pose a risk to human

health.

7a

Nil

7a

Nil

7(b)

Remove drinking water quality standards:

• bromate

• formaldehyde

• chloroacetic acid

• dichloroacetic acid

• trichloroacetic acid

• aluminium (acid soluble).

7b

The less prescriptive

approach to the proposed

drinking water quality

standards are supported. This

approach provides greater

flexibility for risk-based

7b

Nil

8

Proposal

number


7(c)

7(d)

Retain the following standards:

• E.coli

• Turbidity

• Total trihalomethanes

Alter the standards of the drinking water parameters to:

*Escherichia coli one sample per week - No E.coli per

100 millilitres of drinking water sampled in an

investigation.

*Proposed to encourage an approach that an initial

detection is investigated adequately to determine if the

suspected contamination is proved.

Turbidity one sample/week – Less than or equal to 5 NTU

monitoring. Further, potential

sampling and administration

cost savings may be realised

(pending risk assessment).

7c

Maintaining these standards

allows water corporations to

readily compare performance

and provides customer

confidence.

7d

E. coli

In essence, all water

businesses strive to achieve

zero E. coli.

Turbidity

Nil

7c

Turbidity is an aesthetic issue that

does not necessarily pose a direct

public health risk. Accordingly, its

inclusion as a standard is

questionable.

7d

E. coli

A single E. coli detection would result

in a non-compliance for that water

sampling locality. In reality, it may be

difficult to distinguish between a

genuine and spurious result.

Consequently, this may undermine

customer confidence. Clear

clarification on what constitutes a

genuine result must be provided.

Turbidity

There is no health driver for the

change of this standard from a

statistical to a maximum allowable

limit. This proposal may result in a

significant cost burden associated with

upgrades to plants, storages and

networks.

The operational and capital cost

9

Proposal

number


Trihalomethanes one sample/month – Less than or equal

to 0.25 milligrams per litre

THMs

Nil

implications of this item for East

Gippsland Water are presented in

Attachment 1.

THMs

It is important to note that the

maximum allowable limit of 0.25mg/L

is not reflective of the chronic health

risk posed by this parameter. A single

non-compliant THM result does not

pose an immediate health risk and

may consequently cause unnecessary

community concern.

8 Altering the frequency of sampling

8(a) The Secretary may vary the frequency at which samples

of drinking water are to be collected.

Determination of frequency may have regard to - the

number of persons taking water from the WSL; the need

to have a sufficient number of samples to ensure samples

are representative of the drinking water supplied;

chemicals and other substances used to disinfect or treat

the drinking water.

A notice must specify the water supplier, the relevant

WSL being supplied, the parameter specified and

frequency from schedule 2, the period for which the

frequency specified applies and the date the notice takes

effect



supported.

Nil

10

Proposal

number


9 Requirements relating to the analysis of water

samples

9(a) Every sample of drinking water collected within a water

sampling locality should be analysed for E. coli, turbidity

and THMs as per the standard

Nil As per the VicWater submission, East

Gippsland Water agrees that for clarity

this clause should be worded so as to

avoid the implication that every

physical sample must be tested

against all three parameters.

10 Reporting the results of the analysis of water

samples

10(a) Monthly reporting ceases and is replaced with an

exception reporting model.

(This could be achieved through reporting arrangements

under ss. 18 and 22 of the Safe Drinking Water Act 2003)



supported due to the reduced

reporting burden

(administrative saving).

Nil

11

Approval of water analysts

11(a) Remove the requirement to approve water analysts and

replace it with a generic requirement for water suppliers

to have their water samples analysed at a NATA-

accredited laboratory that holds accreditation for the

relevant parameters.



supported.

Nil

12 Content of annual reports

11

Proposal

number


12(a) For water suppliers

- Evidencing compliance or noncompliance with drinking

water quality standards and frequency of sampling.

- Actions taken when a drinking water quality standard

has not been met.

- Actions taken in respect of each emergency, incident or

event that has arisen that has affected the quality of

drinking water generally, where it has posed a risk to

health

- Analysis of water sample information, data and results

for quality of drinking water supplied and a comparison

with water sample information, data and results from the

previous 2 financial years.

-A summary of every:

• variation in aesthetic standards under S.19 and

conditions under S.20 of the Act.

• exemption from a water quality standard under

S.20 and conditions under S.21 of the Act.

• written undertaking under S.30 of the Act

- Summary of complaints with a summary of the

responses and any analysis of the issues arising from the

complaints.

- Summary of the process by which the drinking water

supplied is disinfected or treated and any other processes

applied to the water and any issues arising out of the

application of those processes.

- List of all the chemicals and other substances, and any

processes, used by the water supplier to disinfect or treat



supported due to familiarity

of approach where the

existing requirements are

carried over.

The reporting of CCPs and employee

training activities may not be

meaningful to customers. Inclusion of

employee training activities is not

supported as it does not add value to

the document (which is primarily for

the public).

Clarification is required regarding the

scope of CCP performance reporting

(i.e. full review or exception reporting

only).

Additional costs may be incurred in

the collation and presentation of CCP

performance in annual reports

(included in Attachment 1).

12

Proposal

number


the drinking water supplied by it.

- Steps taken to manage the aesthetic characteristics

including steps taken to manage the taste, odour, clarity

and pH of the drinking water supplied.

- Details of any regulated water supplied and the

declaration under S.6 of the Act in respect of that

regulated water.

- Details of the steps taken in accordance with S.25 of the

Act.

- Summary of the findings of the most recent risk

management plan audit and any issues that the approved

auditor raised during the risk management plan audit.

Include an annual review of the performance of CCPs.

Provide information on employee training activities.

12(b) For water storage managers

- Actions taken in respect of each emergency, incident or

event that has arisen that has affected the quality of

drinking water generally, where it has posed a risk to

health

- Any issues that may have arisen out of the actions.

Summary of:

• exemption under S.8 of the Act and any condition

imposed in relation to every exemption

• written undertaking under section 30 of the Act.

Not applicable to East Gippsland Water

13

Proposal

number


Summary of the process by which the water supplied is

disinfected or treated and any other processes applied to

the water and any issues arising out of the application of

those processes.

List of all the chemicals and other substances, and any

processes, to disinfect or treat the water supplied, or to

be supplied, by it for drinking purposes.

Summary of the findings of the most recent risk

management plan audit and any issues that the approved

auditor raised during the risk management plan audit

Include an annual review of the performance of CCPs.

Provide information on employee training activities.

14

ADDENDUM 1

Attachment 2 : Cost Estimate - SDWR Review Gap Analysis & NPV*Attachment 2 : Cost Estimate - SDWR Review Gap Analysis & NPV*Attachment 2 : Cost Estimate - SDWR Review Gap Analysis & NPV*Attachment 2 : Cost Estimate - SDWR Review Gap Analysis & NPV*

CapitalCapitalCapitalCapital Special O&MSpecial O&MSpecial O&MSpecial O&M Recurrent Recurrent Recurrent Recurrent Comments and JustificationComments and JustificationComments and JustificationComments and Justification

Quantifying the RiskQuantifying the RiskQuantifying the RiskQuantifying the Risk

Update Risk Management Plans (using BIN system) 0000 $60,000$60,000$60,000$60,000 Based on the requirement for an extra person's time for approximately one year.

Civil Works to address RiskCivil Works to address RiskCivil Works to address RiskCivil Works to address Risk

UV installation $865,000$865,000$865,000$865,000 $100,000$100,000$100,000$100,000

UV or microfiltration would be required at all sites to achieve the requisite microbial log reduction that is specified in the proposed

regulations; UV would be East Gippsland Water's preferred technology selection.

Chlorine $75,000$75,000$75,000$75,000 $20,000$20,000$20,000$20,000

Additional chlorination may be required at specific sites to achieve the requisite log removal that is specified in the proposed

regulations. Cost estimate includes: tank, pumps, analyser, installation.

Clear water storage installation/augmentation $3,250,000$3,250,000$3,250,000$3,250,000 $20,000$20,000$20,000$20,000

Several clear water storage storages would need to be augmented to ensure compliance with the proposed E. coli and turbidity

standards.

Specific sites would require significant raw and/or clear water storage upgrades to ensure compliance with the proposed regulations.

Raw water storage installation $250,000$250,000$250,000$250,000 $20,000$20,000$20,000$20,000 Due to land use in the catchment and raw water quality challenges, specific water treatment facilities would require raw water storage

capacity to ensure compliance with the proposed regulations.

Instrumentation/Monitoring improvementsInstrumentation/Monitoring improvementsInstrumentation/Monitoring improvementsInstrumentation/Monitoring improvements

Contact time monitoring (programming) $13,500$13,500$13,500$13,500 $0$0$0$0 Estimate includes programming costs for contact time monitoring online.

Treated water pH meter $14,000$14,000$14,000$14,000 $2,000$2,000$2,000$2,000 This is required for comprehensive contact time analysis as part of new regulations. Includes installation.

Treated water chlorine meter $13,000$13,000$13,000$13,000 $2,000$2,000$2,000$2,000 This is required for comprehensive contact time analysis as part of new regulations. Includes installation.

Treated water turbidity $32,000$32,000$32,000$32,000 $2,500$2,500$2,500$2,500 Extra monitoring required to ensure compliance with the proposed new turbidity regulations.

Treated water temperature monitoring $27,000$27,000$27,000$27,000 $2,000$2,000$2,000$2,000 This is required for comprehensive contact time analysis as part of new regulations. Includes installation.

Flow meters (filtered water flow) $45,000$45,000$45,000$45,000 $2,000$2,000$2,000$2,000 Required for comprehensive filter performance monitoring to ensure compliance with proposed turbidity regulations.

Filtered water to waste (civil and programming) $30,000$30,000$30,000$30,000 $0$0$0$0 Required for comprehensive filtered water turbidity monitoring and filter performance to ensure compliance with proposed turbidity

regulations

Reporting/AdministrationReporting/AdministrationReporting/AdministrationReporting/Administration $20,000$20,000$20,000$20,000

Savings from proposed regulation changesSavings from proposed regulation changesSavings from proposed regulation changesSavings from proposed regulation changes -$35,000-$35,000-$35,000-$35,000 Estimated savings from reduced schedule 2 parameters & administration/reporting

TOTAL COSTSTOTAL COSTSTOTAL COSTSTOTAL COSTS $4,614,500$4,614,500$4,614,500$4,614,500 $60,000$60,000$60,000$60,000 $155,500$155,500$155,500$155,500

*Please note, the cost estimates presented above are based on the current regulations versus the proposed regulations (i.e. incremental cost)

NPV based on these estimates is presented on following page

NPV Assessment - SDWR Review Gap Analysis*NPV Assessment - SDWR Review Gap Analysis*NPV Assessment - SDWR Review Gap Analysis*NPV Assessment - SDWR Review Gap Analysis*

6.8%6.8%6.8%6.8%

2015/162015/162015/162015/16 2016/172016/172016/172016/17 2017/182017/182017/182017/18 2018/192018/192018/192018/19 2019/202019/202019/202019/20 2020/212020/212020/212020/21 2021/222021/222021/222021/22 2022/232022/232022/232022/23 2023/242023/242023/242023/24 2024/252024/252024/252024/25

YearYearYearYear 1111 2222 3333 4444 5555 6666 7777 8888 9999 10101010

CAPEX 4,614,500$ -$ -$ -$ -$ -$ -$ -$ -$ -$

Special O & M 60,000$ -$ -$ -$ -$ -$ -$ -$ -$ -$

OPEX 190,500$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$

Replacement -$ -$ -$ -$ -$ -$ -$ -$ -$ -$

Total 4,865,000$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$ 190,500$

NPCNPCNPCNPC $5,727,810.29$5,727,810.29$5,727,810.29$5,727,810.29

Income -$35,000 -$35,000 -$35,000 -$35,000 -$35,000 -$35,000 -$35,000 -$35,000 -$35,000 -$35,000

Total with income 4,830,000$ 155,500$ 155,500$ 155,500$ 155,500$ 155,500$ 155,500$ 155,500$ 155,500$ 155,500$

NPVNPVNPVNPV $5,479,641.91$5,479,641.91$5,479,641.91$5,479,641.91

* over 10 years (based on proposed regulation changes)

docs2.health.vic.gov.audocs2.health.vic.gov.au/docs/doc... · Description of proposed regulation 1...

Documents

Transcript of docs2.health.vic.gov.audocs2.health.vic.gov.au/docs/doc... · Description of proposed regulation 1...