MEETING THE CHALLENGES IN APPLYING THE AUSTRALIAN GUIDELINES FOR WATER RECYCLING FOR REGIONAL NSW

Transcription

1 MEETING THE CHALLENGES IN APPLYING THE AUSTRALIAN GUIDELINES FOR WATER RECYCLING FOR REGIONAL NSW Nanda Altavilla 1, Annalisa Contos 2, Leonie Huxedurp 3 and Annette Davison 4 1. Department of Primary Industries, Office of Water, Parramatta, NSW 2. Atom Consulting, Sydney, NSW 3. City Water Technology, Sydney NSW 4. Risk Edge, Sydney NSW ABSTRACT The Australian Guidelines for Water Recycling, Phase , (NRMMC, EPHC & NHMRC) (AGWR) introduced a risk-based Framework to the management of recycled water schemes. The NSW Department of Primary Industries, Office of Water (the Office) has adopted the Framework approach and now requires utilities to have a Frameworkbased recycled water management system in place to achieve approvals from the Office. The Office has developed a Framework-based recycled water management guidance information for utilities. This paper outlines the process that was followed to ensure that the guidance and updated policy information communicated the key messages and addressed stakeholders needs and concerns, through consultation and targeted peer review. INTRODUCTION The implementation of the AGWR introduced a preventive risk management approach including robust, scientifically defensible health-based targets. This approach was a significant shift in guidance for the management of sewage treatment for the production of recycled water and was based on the Framework in the Australian Drinking Water Guidelines NHMRC, (2004) (ADWG). In contrast to the implementation of the ADWG, there had been limited direct consultation and exposure to the Framework for regional sewage management and operations in NSW. Historically in NSW, sewage effluent was disposed of either via land or water. Interest in the recycling of sewage effluent has grown as climate dependant water sources have become less reliable. Early guidance focussed on the management of environmental risks (e.g. DEC Environmental Guidelines: Use of Effluent by Irrigation 2004). Public health risks arising from the residential use of recycled water were managed through prescriptive treatment trains in the NSW Guidelines for Urban and Residential use of Reclaimed Water (NSW Recycled Water Coordination Committee 1993). Unlike the AGWR, these guidance documents placed a reliance on end point testing and monitoring rather than risk-based management of the whole system. Since 2007, the Department of Primary Industries, Office of Water (the Office) required that regional utilities develop, submit and implement a recycled water management plan addressing the 12 elements of the AGWR in order to be granted an approval under s60 of the Local Government Act 1993 (NSW) or s292 of the Water Management Act 2000 (NSW) for water recycling schemes. Considering that for many regional utilities the management of drinking water and sewage is overseen by different staff or that drinking water is provided by another party, the introduction in 2007 of approvals that needed to be consistent with the AGWR was met with apprehension by utilities that were unfamiliar with the preventive risk management approach and contributed to an extended approvals process. Stakeholders consequently expressed the need for more information and guidance. In order to streamline the approvals process and promote the preventive risk approach for the management of recycled water, the Office initiated Project Purple to update the policy for recycled water schemes, develop a suite of information sheets and a guidance document to support and assist utilities to develop and implement a recycled water management system. This paper outlines the process that was followed to ensure that the updated policy and documents communicated the key messages and addressed stakeholders needs and concerns through consultation and targeted peer review. PROCESS A multi-agency working party was established to guide the project which included officers from the Urban Water Branch of the Office, Water Unit of NSW Health and external consultants. All members had experience in the approval process, risk assessment, auditing and/or consultation for recycled schemes in regional NSW and were aware of the need to streamline the approval process and support regional utilities for the safe management of recycled water.

2 The working party directed the consultants in the development of the information sheets and guidance. The guidance document was based on the NSW Guidelines for Drinking Water Management Systems (NSW Health and NSW Department of Primary Industries - NSW Office of Water, 2013) in both the substance and style, to promote a whole of government approach to riskbased management for both drinking water and recycled water. The aim of the guidance document was to support utilities to develop a management system that is based on the AGWR that satisfies the requirements of the NSW regulatory regime. The information sheets were designed to be in a short format and more user friendly style than the guidance document. The information sheets aimed to promote and support aspects of guidance across various staff levels of the utility from management to operations. The sheets addressed the issues that required more background or clarity and ensured that the guidance document was kept succinct and communicated the key messages. Identification of AGWR Implementation Challenges Both internal and external stakeholder engagement opportunities were used to identify challenges for the application of the AGWR. Staff from the Office and NSW Health regularly engage with utilities in the risk assessment workshops, consultation and feedback during the application process. Over the last five years, staff consulted with over 40 utilities seeking approval for recycled water schemes of various scales and for a wide range of end uses. They observed that even for utilities that were familiar with the ADWG and preventive risk management approach, there were certain concepts in the application of the AGWR that remained vexed and warranted further clarification. In particular, the derivation and application of log 10 reduction values (LRV), assignation and monitoring of critical control points (CCPs), application of onsite controls and differences between validation and verification monitoring. Another major concern for utilities was how to manage recycled water schemes when third party (non-utility) recipients of were involved. The AGWR require management of the scheme from collection to end use and in many schemes, there are control measures that become the responsibility of the third party recipient. However, the regulatory reach of the approval is limited to the supply point or infrastructure that is owned by the utility. The project also considered stakeholder opinions on the approval process that were expressed in other water industry and regulatory reports. These included various reports issued by the Australian Water Recycling Centre of Excellence and the stakeholder consultation report for the Joint Review of the Water Industry Competition Act 2006 (NSW) and regulatory arrangements for water recycling under the Local Government Act 1993 (NSW), Metropolitan Water Directorate (2013). Stakeholders identified that the approval process was too long and that there was a need for more support and guidance on how to undertake the risk assessment and risk management process, how to establish the critical control points and how to develop the supporting procedures. Stakeholder Feedback The objectives of the workshops were to seek feedback on the draft guidance and information sheets to ensure that the documents are communicating the key concepts and providing relevant information. The working party invited participation and feedback from those utility staff closely involved with seeking approvals or involved in the planning, operation or maintenance of recycled water schemes. Staff included water and wastewater engineers and managers, environmental health officers or operational and technical staff. The majority of the 50 participants were from local water utilities, with 20 local water utilities represented mainly from non-coastal areas of central and southern NSW. Two one day workshops were held, one in Wagga Wagga and another in Orange to cater for additional demand. Participants were given copies of all draft guidance documents prior to the workshop in order to facilitate full participation in the activities and provide constructive feedback. During the workshop, participants were guided through a series of six hands-on group activities, applying the guidance and information sheets to case studies that were derived from recycled water schemes that were either planned or existing in the participant s area of operations. Activities covered: 1. Regulatory Pathways 2. Pathogen Log Reduction 3. Critical Control Points 4. Chlorination as a CCP 5. Monitoring 6. End User Agreements Feedback and comments were recorded by facilitators that were embedded with workgroups during the activity and in the discussions with the whole group after each activity. Participants also provided anonymous written feedback in the form of a questionnaire for both the process of the workshop and the content of the documents.

3 Development of the documents was undertaken as an iterative process, with feedback from the first workshop incorporated into the next iteration of the documents prior to the second workshop for further feedback and refinement. All comments were collated and feedback was addressed in the final drafting of the documentation. All documents were peer reviewed by members of the National Recycled Water Regulators Forum to ensure national harmonisation between State jurisdictions. OUTCOMES AND DISCUSSION The guidance document is formatted like the NSW Guidance for Drinking Water Management Systems, For both documents, the 12 Elements of the Framework were reconfigured such that the identification and management of CCPs is at the core of the framework with elements 2 and 3 informing the CCPs and elements 5, 7, 8, 9 and 10 supporting the CCPs (Figure 1). The focus on operational control of process aligns the Framework with practices that are familiar to utilities thereby promoting understanding and acceptance of the conceptual framework. Given that the reconfigured elements of the Framework (Figure 1) places CCPs at the core and that CCPs were identified as a challange to implementation, the working party developed series of questions utilising the acronym SMART to test if a process can be classified as a CCP. The effectiveness of this tool was compared to the CCP decision tree in AGWR in one of the workshop activities and there was greater support for the SMART acronym, with participants stating it provided more clarity that the decision tree. end uses and to tailor the regulatory requirements with the risk associated with those end uses. The content of the information sheets was tailored to address the major challenges for the implementation of preventive risk management systems. Of the ten sheets, three are primarily advice whereas the majority deal with the technical aspects of risk assessment and risk management. A summary of the information sheets and associated content is presented in Table 1. Initially only five information sheets were envisaged, however some of the matters needed more background or detail to better target staff with various levels of background knowledge. Although there was a Types of Monitoring information sheet, another was dedicated to the difference between validation and verification monitoring which was noted by the working party and stakeholders as requiring further clarification. Where possible, the text was also presented in graphical format to either simplify complex concepts or to emphasise certain information. Figure 2 is an example that shows the relationship between monitoring types. Baseline and validation monitoring inform what operational monitoring should take place. CCP monitoring is a subset of operational monitoring. Verification monitoring supports operational monitoring by providing historical evidence that risks have been adequately managed. Table 2: SMART classification of CCPs S M A R T Is there a significant risk managed by the process? Can the process be measured and limits established where action needs to be taken? Are there actions that can be implemented if the process is measured to be outside acceptable limits Will these actions reduce the risk? Can the measurements and response actions be carried out in a timely manner? The guidance includes templates, tables and checklists and aims to provide a balance between the process of developing a management system and tick box compliance exercise. Compared to drinking water, the challenge with the recycled water guidance is the need to consider a range of Figure 2: Relationship between types of monitoring Where appropriate, the guidance documents drew upon recent research papers or reports to update information released since the AGWR was published in Some examples include the information sheet on chlorination which uses data from Chlor(am)ine disinfection of human pathogenic viruses in recycled waters, Keegan et al. (2012), or the use of the collective term of non-treatment barriers to describe on site and restricted access controls from the Road Map for National Validation Framework report, Muston and Halliwell (2011). The activity based workshop format used to assess the effectiveness of the guidance information worked well as active application of the information to the case studies highlighted the areas or concepts that required changes or clarification.

4 Feedback on the workshops, elicited from the evaluation surveys completed by participants, was overwhelmingly positive, with participants appreciating being both informed and involved in the development of guidance. Many participants suggested that the workshops could be reconfigured as training modules for recycled water or other guidance issued by the Office. Conclusions The Office supports and promotes the reliable and safe management of recycled water schemes. The documents were developed to address stakeholder feedback, streamline the approvals process and overcome some of the challenges for utilities in the implementation of the AGWR. The use of active stakeholder engagement and peer review ensures that documents will assist utilities in realising tangible benefits of the application of a preventive risk management framework including more confidence and reliability in the production and safe use of a recycled water product for their communities s/road-map-for-a-national-validation-framework NHMRC Australian Drinking Water Guidelines. NRMMC, EPHC & NHMRC Australian Guidelines for Water Recycling: Managing Health & Environmental Risks (Phase 1). NSW Health and NSW Department of Primary Industries Guidelines for Drinking Water Management Systems. In the development of the guidance, stakeholder feedback has identified several areas in the AGWR where the clarification of certain definitions and concepts could be incorporated into future revisions. ACKNOWLEDGMENTS The authors wish to acknowledge the support of New South Wales Health, in particular the Water Unit for their enthusiastic and constructive participation in Project Purple. We also extend our thanks to all workshop participants. REFERENCES DEC Environmental Guidelines: Use of Effluent by Irrigation. NSW Department of Environment and Conservation Kegan, A., Wati, S. and Robinson, B Chlor(am)ine disinfection of human pathogenic viruses in recycled waters Australian Water Quality Centre, South Australia, Australia Metropolitan Water Directorate, Joint review of the Water Industry Competition Act 2006 and regulatory arrangements for water recycling under the Local Government Act 1993 Stakeholder Consultation. Department of Finance and Services, NSW, Australia. Muston, M. and Halliwell, D NatVal - The Map to a National Validation Framework for Water Recycling Schemes. Water Quality Research Australia, South Australia, Australia.

5 Figure 1: Reconfigured Framework Elements from the AGWR

6 Table 1: Summary of Information Sheets Information Sheet Category Content 1 It s too late benefits of preventive risk management Overview Advice Overview preventive risk management, highlighting benefits to utilities Explanation of LRVs 2 Indicators, Reference Pathogens & Log 10 Reductions: What does it all mean? Technical Rationale behind each surrogate and reference pathogen and limits of indicators 3 Calculating Log 10 Reduction Values Technical 4 Critical Control Points Technical Calculation of LRVs for whole scheme and various exposure scenarios Defining critical control points, limits and monitoring 5 Non treatment barriers: End use and onsite controls Technical Clarify how LRVs are achieved with onsite controls. Concept of hierarchy of controls 6 Types of monitoring Technical Explanation and relationship between monitoring types - baseline, validation, operational and verification. 7 Validation & Verification What s the difference? Technical Definition and comparison between validation and verification monitoring. Designing monitoring programs 8 Getting chlorination right Technical 9 User Agreements Advice Theory of chlorine as a disinfectant Calculation of chlorine effectiveness and LRV Clarification of third parties in approval User agreements and contracts 10 Recycled Water Incident Notification & Response Advice Define which incidents require notification to NSW Health, how and within what timeframe

7