Risk management from catchment to tap
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1 Risk management from catchment to tap : EurEau s views on costs, regulatory framework and parties to be involved Carsten K. Schmidt, RheinEnergie AG, Cologne, Germany 1
2 EurEau. Water Matters. ~ European Federation of National Associations of Water Services ~ We represent drinking water and waste water service providers in 28 countries in Europe ~ We reflect the diversity in the governance models across Europe - direct private management, delegated private management, direct public management and delegated public management ~ 150 experts sharing technical knowledge and enabling the EurEau Secretariat in Brussels to advocate for priorities of the water sector 2
3 Treaty on the Functioning of the European Union Article 192 (2) Union policy on the environment shall aim at a high level of protection taking into account the diversity of situations in the various regions of the Union. It shall be based on the precautionary principle and on the principles that preventive action should be taken, that environmental damage should as a priority be rectified at source and that the polluter should pay. 3
4 Preventing today, what will not be acceptable tomorrow ~ application of the precautionary principle ~ lack of complete scientific certainty ~ presence of complex systems that are not fully understood ~ follow-on consequences of hazard incidents cannot be predicted compounds in the aquatic environment are often not sufficiently evaluated (missing ADI values, even for pharmaceuticals) (partly) evaluated compounds are often transformed in the aquatic environment to non-evaluated substances mixing effects of several single substances with similar properties (e.g. pharmaceuticals) 4
5 Requirements placed on drinking water quality ~ wholesome and clean ~ colourless, clear and cool ~ free of suspended solids ~ free of disease-causing organisms and toxic chemicals ~ perfect in taste and smell ~ non-corrosive ~ appetising and inviting to drink 5
6 There is no longer any zero! Micropollutants in the aquatic environment will always be there! ~ problem for water suppliers: ~ number of micropollutants (>1000 substances under discussion) ~ perception and acceptance of the consumer ~ today s solutions might be the problems of tomorrow (e.g. ozonation, characteristics of substitutes) ~ important courses of action: ~ understandable evaluation concepts (how much is acceptable?) ~ preventive water protection ~ confidence-building measures improved consumer trust (communication, WSP) 6
7 Upstream and downstream ends of the supply chain ~ water suppliers do not have control of the catchment, nor do they control the drinking water in buildings and housings past the point of delivery ~ these ends of the supply chain form an integral part of the WSP approach, but appropriate provision must be made (other legislation) ~ regarding basin management, some provisions are already in place under the WFD (elements of the upstream risk analysis and monitoring) 7
8 Resources necessary for WSP implementation ~ depend on many factors: ~ coverage: catchment, treatment, distribution, consumer ~ size of asset base, service area ~ regulatory requirements ~ work practices already in place (e.g. code of practice / regulations) ~ current work practices can be taken as building blocks and reduce the amount of additional resources ~ ISO quality procedures ~ standardized operating manuals ~ maintenance schedules ~ monitoring programmes ~ staff training ~ stakeholder engagement programmes 8
9 Costs for WSP implementation ~ initial set up costs: ~ financial resources, staff time, materials, knowledge gathering ~ maintenance costs ~ typically lower than for the initial set up ~ costs for operational improvement programmes ~due to identified risks and improved management, verification Cost benefits of a WSP ~ decrease in costs for water quality failure ~ improvement in targeting of capital investment ~ 9
10 Costs for WSP implementation - exemplified for a water supplier ~ initial set up costs: ~30,000-40,000 per waterworks (with work practices being mostly already in place) ~ maintenance costs ~ 10,000 per cycle ~ running costs ~ costs for water management in the catchment (cooperation with farmers, SPAs management, ), e.g EURO per m 3 ~ total monitoring costs, e.g EURO per m 3 i.e. together less than 3 % of the total costs for water supply 10
11 Integral WSP implementation - cost proportions ~ catchment control? no idea! (polluter / authority) ~ 0.05 EURO per m 3 (water supplier) ~ 1000 EURO per water connection (consumer) (based on costs for legionella hazard analysis in Germany) 11
12 Roles and responsibilities drinking water supply ~ national agencies provide a framework of targets, standards and legislation to enable and require suppliers to meet defined obligations ~ agencies involved in supplying water for consumption by any means should be required to ensure and verify that the systems they administer are capable of delivering safe water and that they routinely achieve this ~ a surveillance agency is responsible for independent (external) surveillance through periodic audit of all aspects of safety and/or verification testing 12
13 WSP implementation acceptance ~ any new obligations should be kept as simple and clear as possible ~ no excessive adminstrative burden ~ WSP implementation does not need to be immediate in time and in depth - WSP evolve and develop with time 13
14 Drinking Water Standards ~ microbial aspects ~ disinfection ~ chemical aspects ~ radiological aspects ~ acceptability aspects: taste, odour and appearance ~ precautionary aspects: pesticides and biocides Article 7 (3) WFD Reduce the level of purifcation for drinking water! consumer expectations binding regulations treatment efforts missing/uncertain substance evaluation 14
15 Are priority substances relevant for drinking water? ~ not at all! ~ existing EQS values are based on ecological aspects ~ prioritisation is solely (health) risk orientated ~ other relavent quality aspects are not considered (accetability, precautionary) ~ see EQS values for pesticides alachlor 0.3 µg/l, atrazine 0.6 µg/l, simazine 1.0 µg/l, diuron 0.2 µg/l isoproturon µg/l, pentachlorophenol 0.4 µg/l vs. DWD standard 0.1 µg/l ~ no concept to handle / regulate non-evaluated compounds of emerging concern mirror consumer expectations! 15
16 Protecting a vulnerable resource Needs 1. Implementation of the control at source approach, preventing micropollutants entering the water cycle (WSP can assist as driver) 2. Protection of drinking water resources takes precedence over other interests 3. Implementation of the polluter pays principle, including liability for costs 4. Environmental impact assessment and evaluation of substances in the authorisation schemes (including relevance for drinking water (production)) no non- or only partially evaluated substances should appear at relevant concentrations in the aquatic environment 5. Substitution of micropollutants that impact the environment and public health with less hazardous substances 6. Strengthening of the precautionary principle through cooperation and dialogue with industry (multidisciplinary approach) and other actors such as farmers, retailers, consumers 16
17 Recommendations ~ better implementation and integration of (drinking) water protection measures in the relevant European policies (e.g. agriculture, energy, health, chemical legislation) ~ clear responsibilities must be assigned to the different stakeholders ~ establish strong instruments to reduce emissions ~ precautionary principle allows for regulation even in the case of uncertainty (be pragmatic) ~ strengthen WSP for water installations in buildings (being often the cause of non-compliances) ~ for products and materials in contact with drinking water a harmonized European approach is needed ~ more stringent implementation of the WFD with regard to drinking water (art. 7(2) and 7(3)), in due consideration of all DWD quality aspects 17
18 Rue du Luxembourg 47-51, B-1050 Brussels, Belgium Tel : +32 (0) Fax : +32 (0) BE secretariat@eureau.org Thank you for your attention! EurEau. Water matters.
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