GENERAL TOPIC: QUALITY CONTROL, STANDARDS, LEGISLATION, COMPLIANCE AND POLITICS
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1 GENERAL TOPIC: QUALITY CONTROL, STANDARDS, LEGISLATION, COMPLIANCE AND POLITICS TITLE: STATE OF THE SEWAGE TREATMENT AND DISPOSAL SECTOR IN JAMAICA TOWARDS MEETING THE REQUIREMENTS OF LOCAL SEWAGE EFFLUENT REGULATIONS AND THE LBS PROTOCOL AUTHOR: Dillard Knight National Environment and Planning Agency, 10 Caledonia Avenue, Kingston, Jamaica, W.I. Telephone/fax (876)
2 List of Abbreviations BOD GPA mg/l Biochemical Oxygen Demand Global Plan of Action Milligram per liter MPN/100ml Most Probable number per 100 millilitre NEPA NRCA NWC PO4 SRC TN UNEP National Environment and Planning Agency Natural Resource Conservation Authority National Water Commission Phosphate Scientific Research Council Total Nitrogen United Nation Environmental Programme 2
3 TOWARDS MEETING THE REQUIREMENTS OF LOCAL SEWAGE EFFLUENT REGULATIONS AND THE LBS PROTOCOL 1.0 Introduction Domestic wastewater discharges are one of the most significant threats to coastal and marine ecosystems worldwide. Sewage damages ecosystems as a result of its organic and nutrient content, promoting oxygen depletion and proliferation of algae and other aquatic plants. Also, improperly treated sewage introduces pathogens to the aquatic environment, which endangers public health and the survival of aquatic organisms. The necessity to protect the marine environment and commitments by governments was articulated in the Global Programme of Action for the Protection of the Marine Environment from Land-based Activities (GPA) 1. In 1999, the Wider Caribbean responded to this initiative with the adoption of the Protocol concerning Pollution from Land-Based sources and Activities in the Wider Caribbean Region (LBS Protocol 2.) This paper assesses the state of the domestic wastewater sector in Jamaica (public/private) in respect of the readiness of the sector to meet the requirements of the upcoming Sewage Effluent Regulations and the LBS Protocol. 2.0 Regulatory Framework Jamaica is an active participant in the regional endeavour to protect the Wider Caribbean Region from land based sources of pollution and has been working on a number of initiatives in various sectors including domestic wastewater. Under the NRCA 3
4 Act of 1991, the Section 17 on Pollution Control gives the NRCA the power to request information from sewage treatment plants on the quality of their effluent, when notified so to do. The establishment of Sewage Effluent Standards in 1996 and the Permits and Licence Regulations under the NRCA Act in 1996 laid the foundation for improvement in the regulation of the domestic wastewater sector. Sewage Effluent Regulations 3 are slated for promulgation by early 2004/5 with Sludge Regulations to follow shortly after. The adoption of the LBS Protocol in 1999 was as a result of a regional endeavour at protecting the Wider Caribbean Region from land based pollution. Annex III of the Protocol stipulates limits for sewage effluent discharge to the marine environment. Jamaica expects to ratify the protocol as soon as its Sewage Effluent Regulations are promulgated. 2.1 Monitoring and Enforcement Sewage Treatment Plants are regulated by NEPA under the NRCA Act 1991, Section 17 Pollution Control Programme and the NRCA (Permits and Licence Regulations) of The Section 17 Programme 4 had not adequately evaluated the performance of sewage treatment plants, neither in terms of verification monitoring visits by NRCA/NEPA staff nor in self-monitoring reports submitted by operators of Sewage Treatment Plants. An analysis of operations and quality of sewage effluent under this Programme indicates the woeful performance of the sector. For the period 1997 to 2000, a total of 55 visits were made to 36 facilities. Assessment of effluent quality for compliance with the National Sewage Effluent Standards gave compliance levels of 56.4% for BOD, 74.5% for TSS and 38.2% for Faecal Coliform. Plants built after 4
5 January 1, 1997 and therefore regulated under the NRCA (Permit and Licence) Regulations produced effluent that meet some or all of the standards in most instances. Of course, these are newer plants but the stricter monitoring regime (compared to Section 17), suggests that this level of performance can be maintained. 3.0 Status of the Waste Water Sector There are presently more than 90 sewage treatment plants in Jamaica, with the majority (61) owned by the National Water Commission (NWC). Within the NWC system, plant capacities range from MLD 52.8 MLD (Million Litres per day) with about 90% of plants less than 2.65 MLD.There are a variety of plants within the NWC such as Contact Stabilisation, Oxidation Ditch, Aerated Lagoons and Stabilisation Ponds. In addition to the NWC, sewage treatment plants are owned by hotels, strata corporations and public housing development agencies. This sector is dominated by mechanical packaged plants, particularly the hotels. 3.1 Effluent Quality NEPA monitors the environmental performance of the sector mainly through the NRCA Act, Section 17 Programme and the Permit and Licence Regulations. In 2002, NEPA, through a special project known as the Coastal Water Quality Improvement Project, (funded by the USAID and Government of Jamaica), commissioned a special study 5 on the performance of the domestic wastewater sector. The Waste Research Management and Training Centre of the Scientific Research Council conducted the study. Also, The 5
6 Jamaica Waste Water Operators Association produced a status report on Waste Water Treatment Plants, Over the period , a combined total of 60 plants were monitored by the mentioned programmes. The frequency of visits to each plant is very low (approximate about 2 times) making it difficult to be conclusive about quality of effluent. However, there is a high level of confidence in the data as effluent data have a high level of positive correlation with operating and maintenance status of plants. A Summary of effluent data is presented below in Table 1 Details Parameters BOD FC TSS TN PO4 # of plants for which analyses were done Range of values Average #(%) in compliance with Sewage Effluent Standards 23 (40) 14 (25) 22 (39) 0 (0) 22 (39) # (%) in compliance with LBS Protocol 30 (52) 14 (25) 33 (59) Units: Parameters are in mg/l except for Faecal Coliform which is in unit of MPN/100ml BOD = Biochemical Oxygen Demand FC= Faecal Coliform TSS = Total Suspended Solids TN = Total Nitrogen PO4 = Phosphate Table 1 Summary of effluent data compared with the Sewage Effluent Standard and LBS Protocol The results present an alarming situation with low levels of compliance with both the Sewage Effluent Standards and the LBS Protocol. For example, only 23 (40%) of plants 6
7 met the Sewage Effluent Standard for BOD. Figure 1 presents a graphical representation of compliance with the BOD Standard. Comparison of BOD levels of sewage treatment plant with standard of 20mg/l BOD(mg/l) Plants Figure 1 When the data for all the plants are combined, the average values (Table 1) exceeded all the respective standards and are indicative of the woeful state of the sector. Effluent data also indicated a significant deterioration in the performance of the sector over the past three years. When compared to historical performance for under the NRCA Act Section 17 programme, there is an alarming deterioration in the level of compliance over the period (Figure 2), in particular with respect to TSS 7
8 Compliance levels (%) of effluent with Sewage Effluent Standards % compliance BOD FC TSS Parameters Figure 2 Why the low level of performance? Improper plant designs, old technology, overloading, lack of maintenance and improper operations are possible reasons for the low level of performance. A detailed examination of the situation indicates that operational and maintenance issues are the most likely reasons for the low level of performance. 3.2 Operation and Maintenance Status of Sewage Treatment Plants NEPA s monitoring programmes along with special study by the SRC indicates that poor operating practices and inadequate maintenance at sewage treatment plants are very evident. The Jamaica Wastewater Operators Association (JWOA) presents a similar situation is its status report on Wastewater Treatment Plant, The JWOA study looked at 14 plants, highlighting the conclusions of the plant operators on the facilities they operates. The significant operational and maintenance issues are; 8
9 3.2.1 Age and type Most of the plants are old extending, up to 30 years, with some exceeding their design lifespan. Coupled with this is the fact that most of the plants are mechanical, using the aerobic process for treatment. The plants are subjected to frequent breakdowns and are rarely repaired Monitoring Owners/operators of most plants do not conduct any form of monitoring in order to assess the performance of their plants. Effluent quality for most plants is only known when compliance monitoring by regulatory agencies or special studies are done. This lack of monitoring is evident from the Section 17 Programme Pollution Control Programme, with little or no monitoring reports being submitted by owners/operators of plants Overloading Plants are being overloaded. This usually occurs in urban center when the housing stocks are increased and connected to the plants without commensurate increase in capacity of existing plants Staffing Most plants are staffed by operators who lack the necessary technical knowledge. Many plants are simply being run mechanically but are not operating properly. There were 9
10 some plants that were in fairly good working condition but are producing effluent of poor quality, most likely as a result of poor operation Operation and Maintenance Procedures Most sites do not have documented Operation and Maintenance procedures. Some Operators are working based on what they are told and their own experience Equipment Important equipment for the proper functioning of a significant number of plants is either missing or not functioning properly. This is particularly so for the various pumps and motors used at the plants. Also, there seems to be no adequate maintenance programmes in place for some of these equipment. 3.3 Status Summary The average performance of the sector is poor with effluent quality not meeting the Sewage Effluent Standards and the LBS Protocol most of the times. While it is recognised that most of the plants in the system are old and their original designs might not allow them to meet the new standards, the fact is that most plants are not even meeting their design specifications. Operation and maintenance issues are the main factors responsible for the poor performance of the sector. Most plants lack a documented operational and maintenance programmes. There is little effort to replace or repair vital components responsible for the effective functioning of plants. Inadequate 10
11 monitoring and limited enforcement options by regulatory agencies continue to allow plants to operate at undesirable levels. 4.0 The Way Forward The assessment of the quality of sewage effluent indicates that there is room for considerable improvement in the performance of the sector over the next years if the obligations under the LBS Protocol and Sewage Effluent Standards are to be met. In tandem with improvements being made to the legislative framework, there needs to be commensurate improvements in designs, operation and maintenance of Sewage Treatment Plants. The UNEP/GPA Regional Working Group on Municipal Wastewater from as far back as 2001 enunciated possible arrangements that can be considered for improvement in the sector. Some of these were; 1. Resource Mobilisation e.g. using non traditional donors, promotion of private sector involvement 2. Area of Technology e.g. community financed onsite system, septage lagoon for treatment of septic sludges, wetland gardening for small systems, pre-treatment of industrial effluent. 3. Policy Orientation e.g. regulations for disposal and treatment of septic sludge 4. Institutional arrangement e.g. policy framework for wastewater management, Public Private Partnership to assist financing and operating of plants, appropriate systems for data gathering, assessment, evaluation and monitoring. 11
12 Jamaica actively participated in the formulation of these regional recommendations and already has arrangements, some of which are in line with these recommendations. 4.1 Existing arrangements for improvement of wastewater sector 1. Legislative Framework! Draft Sewage Effluent Regulations. Enactment expected 2004/5.! Sludge and Trade Regulations are currently being developed. 2. Permit and License system! Stricter approval and monitoring system! Involvement of NWC in the permitting process.! Formation of Advisory and Monitoring Committees, allowing community inputs in the operation and maintenance of plants. 3. JWOA! The fledgling JWOA is indicative of improvement in professionalism of plant operators. The Association gives operators a sense of worth and increase their awareness on issues affecting the plants that they operate. As the association strengthens, it will advocate for more training and supply of equipment which will see better plant performances. These existing arrangements are not sufficient for the proper functioning of the waste water sector and additional measure need to be recommended to enhance the performance of the sector. 12
13 4.2 Recommendations 1. Monitoring and Enforcement Improvements in the capacities of regulatory agencies to monitor and enforce the regulations are needed. In particular, adequate enforcement mechanisms need to be identified as with the present scenario, it is proving very difficult to bring actions against plants that are in breach of the standards. Also a mechanism for better collaboration between regulatory agencies such as NEPA and the Public Health Department. 2. Permitting of new developments Planers need to take a strategic view towards the permitting of developments and hence new sewage treatment plants. This will allow for one large sewage treatment plant serving a number of communities instead of small sewage treatment plants for each community. An arrangement like this should reduce costs related to monitoring, operation and maintenance. 3. Sewage Rehabilitation, Operation and Maintenance Plans The NWC, the largest owner of sewage plants, needs to develop a comprehensive Sewage Rehabilitation, Operation and Maintenance Plan for its existing plants. This is particularly so, given that the study identify operation and maintenance as significant factors affecting the quality of effluent. The plan should at least bring existing plant into compliance with original design specifications. An Environmental Monitoring and Management Programme must complement the plan. 13
14 4. Financing Mechanism Stakeholders need to collaborate on identifying appropriate financing mechanisms such as better sourcing and use of funds from Development Banks, Private Sector Financing, applying appropriate charges for sewage and water service. 14
15 References 1. UNEP UNEP/GPA Regional Working Group on Municipal Wastewater: Regional Cooperation for Innovative Action. Jamaica 2. UNEP Convention for the Protection and Development of the Marine Environment of the Wider Caribbean Region. UNEP, Caribbean Environment Programme 3. Natural Resources Conservation Authority Drafting Instructions for the National Sewage Effluent Regulations. National Environment and Planning Agency, Jamaica 4. Natural Resources Conservation Authority. Section 17 Pollution Control Programme files. 5. Waste Research Management and Training Centre Operation and Maintenance Programme and Strategy for NWC s Wastewater Facilities. Associates in Rural Development, Inc, P.O. Box 1397, Burlington, Vermont Jamaica Wastewater Operators Association Status Report on Wastewater Treatment Plants. Jamaica 15
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