Transcript Document

Water Services National Training Group
and
National Federation of Group Water Schemes
7th Annual Rural Water Services
Conference
18th September 2008
Rural Water Licensing
Guidance and Training
Jerry Cronin and Richard Church
Nicholas O’Dwyer / Entec
Presentation Contents
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2.
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6.
7.
Project Objective
Background/ Legislation
Application Process
Application Form / Assessment
Overall Assessment
Conditions
Project Deliverables
Over Riding Purpose of Rural Water Licensing
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Key driver: States response to ECJ
Drinking Water Judgement
To ensure that the required water quality
standards are achieved
To effect a planned, systematic and
sustained improvement to infrastructure
capacity along with management and
operational standards
Project Objective
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To develop guidance and training for the
new Rural Water Services Licensing System
introduced under the Water Services Act
2007.
Project Team
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Procured by: WSNTG
Consultants: Nicholas O'Dwyer and Entec
Steering Group:
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WSNTG
DEHLG
NFGWS
CCMA
Other Consultees
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EPA
Operators of five representative GWSs (site visits)
Rural Water Liaison Officers from the five WSAs
Background/ Legislation
Water Services Act 2007
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The Act provides for the introduction of a licensing
system governing the operations of water services
providers other than Water Services Authorities or
their agents.
Water Services Authority (WSA) is responsible for
the overall management and supervision of water
services provision by authorised water services
providers in its functional area.
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Licensing Regulations currently being drafted
and being informed by the consultation process
associated with this project and in the
development of the Guidance Document.
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Key Focus Area: Group Water Scheme Sector
Background/ Legislation
European Communities (Drinking Water)
Regulations (2007) – S.I. 278 of 2007
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EPA have powers to direct a WSA to improve the
management or quality of a public water supply.
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WSA’s have a similar supervisory role in relation to
group water schemes or private supplies.
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Exempted Supplies: a supply which –
a)
(i) constitutes an individual supply of less than 10
m3/day on average or serves fewer than 50 persons,
and
(ii) is not supplied as part of a commercial or public
activity (e.g. GAA club, Nursing Home), or
b)
Is used exclusively for purposes … that the quality of the
water has no interference, either directly or indirectly,
on the health of the consumers concerned (e.g. car wash
system).
Threshold for Licensing
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Following the exemption principle applied in
S.I. 278 it was decided to employ a similar
threshold level for Group Water Schemes (i.e.
schemes serving less than 15 residences
would be exempt)
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Approximately 1,400 Group Schemes will be
included in the Licensing System (approx.
400,000 persons), split approx. equally by
public and privately sourced schemes
County
Wicklow
Wexford
Westmeath
Waterford
South
Sligo
Roscommon
Offaly
North
Monaghan
Meath
Mayo
Louth
Longford
Limerick
Leitrim
Laois
Kilkenny
Kildare
Kerry
Galway
Donegal
Cork West
Cork South
Cork North
Cork City
Clare
Cavan
Carlow
No. of Schemes Subject to Licensing
Numbers of Schemes to be Licensed by County
320
300
280
260
240
220
200
180
160
140
120
100
80
60
40
20
0
Breakdown of Licensable GWS
Nationwide Breakdown of GWS by Number of Residences
600
No. of Schemes
500
400
300
200
100
50%
22%
18%
10%
>250
100-250
40-99
15-39
0
No. of Residences
percentages indicate population served
Phasing of Licensing
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It is proposed that a risk based approach will be used
for the phasing in of the licensing system; and that the
EPA Remedial Action List approach is adopted by
the WSAs to identify the priority schemes for licensing
(EPA Guidance Doc Booklet No. 3, February 2008)
Priority Remedial Action List Parameters
Table A: Microbiological (E. Coli)
Table B: Chemical: Bromate, Trihalomethane, Nitrate
Table C: Indicator: Aluminium, Turbidity
Cryptosporidium – where available
Other relevant parameters: e.g. Arsenic
Phasing of Licensing System
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Phasing details are to be set out in
Regulations
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Further phasing would be based on scheme
size with priority given to the larger schemes
Group Scheme Registration System
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GWS serving less than 15 residences would
be registered
Separate monitoring and inspection
procedures.
2007 Act
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Licensing covered under Part 6, Chapter 2, Sections
78 to 91
Sub-section 78 (2): “Each WSA, for the purpose of
the protection of human health and the environment,
is responsible for the supervision, in its functional
area, of water services provided by a person other
than a WSA”.
Sub-section 79 (1)(a): “On or after such date or
dates as may be prescribed, a person shall not –
i.
Provide water for human consumption from a
tanker, or
ii.
Otherwise provide water services except under
and in accordance with a water services licence
issued under this chapter”.
2007 Act
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Sub-section 79 (3): provides for the setting of a
threshold below which a licence will not be required
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Sub-section 79 (4): “The provision of water services
shall, in the period before a licence………is granted or
refused, be deemed not to have contravened
subsection (1), if – before the date……...an application
has been made………”
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Sub-section 79 (5): “A person who contravenes
subsection (1) or a regulation made………commits an
offence”.
2007 Act
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Section 80:
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Section 81:
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Section
Section
Section
Section
Section
82:
83:
84:
85:
86:
Section
Section
Section
Section
Section
87:
88:
89:
90:
91:
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Determination by WSA of an activity to be a
licensable
WSA may grant/refuse a licence following
consideration of a range of matters
WSA to be the licensing authority
Conditions attached to a licence
Licence review
Licence revocation
Consider all submissions and notify all regarding
decision
Appeals process (district court)
New Regulations
Contravention of a condition
Related licences (e.g. discharge licences)
Powers to take over O & M on a temporary basis
Application Process
Pre-Application
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WSA to establish RAL for all GWSs within
its functional area in accordance with the
Licensing Regulations.
Application Process
Stage 1
Stage 2
Stage 3
Stage 1 - Application Submission
Stage 2 – Preliminary Technical Assessment
Stage 3 – Final Assessment
Licence is
Issued
Application Form / Assessment
Section 1, 2 and 3 – General Information
Section 1 – About the Applicant
 Name of GWS
 Status of the GWS (Co-op, company etc.)
 Register No.
Section 2 – Nominated Contact Details
 GWS contact person's name, address and
other contact details.
Section 3 – Insurance Details
 Public Liability, Employer’s Liability and Asset
Insurance.
Section 4 – Operational Contracts/
Maintenance and Service Contracts
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Details of Contract
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Contractor Details
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Date of Commencement
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Period of Contract
Section 5 – Scheme Source Details
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Exempts schemes served from public mains
Number of Sources – details to be provided
for each
 Name and location
 Type
 Abstraction Details
 Source Capacity
 Current abstraction details
 Source protection
 Details of treatment process
Section 6 – Treatment Plants
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Number of treatment plants – details to be provided for
each
Name and location
Description of the treatment process
Build date
Design Capacity
Daily throughput
Discharge/ Sludge Disposal
Bypassing facility
Water Quality
Control/ Alarms
Metering
Section 7 – Distribution System
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Details of Distribution Mains (diameter, length, type,
age etc.)
Booster/ Pumping stations in network
Details of Network Upgrading/ Renewals
Service Reservoirs
Secondary Disinfection Points
Details of Domestic/ Non Domestic Connection
Average Day Distribution Input (ADD)
Average Day Peak Week (ADPW)
Unaccounted for Water (UFW)
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WSNTG/NFGWS training course
Burst Details/ Problem Areas
Section 8 – Network Water Quality
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Details of supply restrictions e.g. Boil Notices,
“Do Not Use” notices etc.
Cryptosporidium Risk Assessment
Section 9 and 10 – Scheme Management/
Training
Section 9 – Scheme Governance
 Details of Scheme Governing Body/ Committee
 How appointments are made
 Annual General Meetings
 Notification of members/ shareholders
Section 10 – Training
 Typical details of training undertaken by
management and operational staff
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courses available from WSNTG regional training
centres
Section 11 and 12 - Financial
Section 11 – Financial Management
 Details of Financial Accounts
 Audited/ Certified Accounts
Section 12 – Capital Investment
Programme
 Details of Capital Investment Programme
 Asset Management Plan
Section 13 – Quality Assurance
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QA system
National Rural Water Monitoring Committee
System
Water Safety Plan
O & M plan
Drinking Water Incident Response Plan/
Emergency Plan
Water Conservation Plan/ UFW Reduction
Charter of Rights/ Complaints Procedure and
Feedback.
Section 14 – Maps and Plans
Overview Map (1:10,000 or 1:5,000)
 Sources
 Treatment Plants
 Distribution Network
 Reservoirs
 Boosters
 Secondary Disinfection Points
 Treatment Plant – Layout Details
 Source Protection Maps
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Section 15 – Declaration
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Certify that information is true
Consent to make application available for
inspection
Certify that signee is duly authorised by GWS
to sign on its behalf
Overall Assessment
Assessment Process
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WSA to consider:
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Information contained in the Application Form and
Additional Information requested and Submissions
received from 3rd parties.
WSA also to have regard to (Sub-Section
81(2)):
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Relevant Strategic Water Plans
GWS resources (Financial, Operational,
Management)
Other WSAs for cross boundary scheme
Alternative supplies
Any requests to have GWS taken in charge
Water Supply Standards
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Drinking Water Quality
Levels of Service
Other Matters
Assessment Process
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Vast majority of the 1,400 GWS will receive
licences.
Where deficiencies are noted – appropriate
conditions should be attached
Sub-Section 79 (4) provides for GWS to
continue in operation after the new system
comes into force, provided an application has
been made before the commencement date.
Condition Setting
e.g. Improvements to source protection
e.g. Improvement to treatment
e.g. Improvements to Storage,
Distribution and Network Infrastructure
Licence Conditions
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Sub-Section 83(2) requires that conditions relating
to water services licensing 'shall' be included in
respect of certain categories
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Sub-Section 83(3) lists further categories from
which conditions 'may' be included for
consideration
Standard Conditions Section 83(2)
(a) Measures to ensure against risk to human
health and the environment
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Example conditions for a licence:
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comply with drinking water quality standards
provide adequate supply, treatment and distribution capacity to
meet forecasts
adequate arrangements to ensure essential and adequate
supply at all times
have all discharges authorised and regulated for disposal by
appropriate authority
ensure adequate measures to prevent contamination of local
environment
Standard Conditions Section 83(2)
(b) Water Supply Standards
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Drinking water quality standards
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European Communities (Drinking Water) [No.
2] Regulations 2007 (S.I. No. 278 of 2007)
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European Communities (Quality of Surface
Water Intended for the abstraction of Drinking
Water) Regulations 1989. (S.I. No. 294 of
1989)
Standard Conditions Section 83(2)
(c) Standards of Service
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Performance standards
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Defined in strategic resource plans
e.g. 15m of head at stop-cock
Customer service
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Reporting
Complaints procedure
Annual General Meeting
Standard Conditions Section 83(2)
(d) Monitoring and Supervision
Frequency to meet the Drinking Water
Regulations
 Appropriate reporting schedule to WSA
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(e) Sampling and Analysis Section
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Responsibility of GWS but undertaken by
WSA/HSE
(f) Other such matters as may be prescribed
Additional Conditions – Section 83(3)
(a) Scale of Activity
(b) Specification of Households,
Areas or Activities
(c) Operational and
Management Procedures
(d) Procurement Procedures
Additional Conditions – Section 83(3)
(e) Measures to
ensure public
safety
Additional Measures - Section 83(3)
(f) Emergency plans
(g) Employers and Public Liability Insurance
(h) Conservation Measures
Additional Measures - Section 83(3)
(i) Measures to prevent source contamination
(In the immediate vicinity of source)
Additional Measures - Section 83(3)
(j) Metering
Additional Measures - Section 83(3)
(k) Proper treatment,
reuse or disposal of byproducts
Additional Measures Section 83(3)
(l) time limits
(m) provisions to facilitate the application of
obligations
(n) accounts and annual reports
(o) any other matters as may be prescribed
Project Deliverables
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Background Scoping Document
Application Forms
Guidance Document
Courseware
Delivery of Training Courses
Water Services National Training Group
and
National Federation of Group Water Schemes
7th Annual Rural Water Services
Conference
18th September 2008