WSNTG Annual Conference September 2007 Water Services National Training Group 11 th Annual Conference 6 th September 2007

WSNTG Annual Conference September 2007 Drinking Water – Monitoring and Reporting Darragh Page Inspector Environmental Protection Agency

Outline of Presentation  Monitoring  Monitoring Requirements  Monitoring Shortfall  Actions Necessary  Reporting  Monitoring Programmes  Annual Returns  Non-Compliances  Risk to Human Health  EPA Actions

Monitoring of Drinking Water Minimum Requirements set out in Table B of Part 1 of the Schedule Expanded version of monitoring frequencies in Appendices 1 and 2 of EPA Handbook

Monitoring Frequencies

Monitoring in 2005  16,500 samples analysed  200,000 individual tests carried out However, Serious Monitoring Deficiency

Monitoring Deficiency 65.0% 35.6% 88 supplies 291 supplies 498 supplies

What Needs to Happen?  Monitoring programmes must be documented  Supplies not monitored must be included in monitoring programme  All supplies identified must be monitored at least at the minimum frequency  LAs should review progress with monitoring programme on quarterly basis

2007 Regulations  EPA the supervisory authority  LA must submit monitoring programme to the EPA when directed to do so  Programme must specify where samples are to be taken  EPA can amend a monitoring programme

2007 Regulations  EPA can insist on additonal monitoring (e.g. Crypto)  EPA reviewing Handbook (section on monitoring programmes unlikely to change much)

Reporting  Reporting Monitoring Programmes  Reporting Annual Monitoring Results  Reporting Non-Compliances  Reporting Risks to Human Health

Annual Reporting  Compliance Monitoring of all supplies to be submitted on EPA Template by 28 th February each year  It will be an offence not to submit returns by this date from next year  EPA reports will now focus on enforcement as well as monitoring

Annual Reporting Common Errors:  Not using the template  Wrong units used (esp. for boron, aluminium, fluoride and copper)  Incorrect supply codes used (all must be xxxxPUBxxxx or xxxxPRIxxxx)  Samples misclassified (e.g. follow up samples classified as Check samples)

Reporting Non-Compliances Regulation 10 of DW Regs 2007:  EPA must be notified by LA of failure to meet standard  EPA Guidance Booklet to be published this month outlines when notification required  EPA must be notified on notification template and ed to

Reporting Non-Compliances Notification Must Include:  General supply details  Details of the failure  An indication of the cause  Details of HSE advice  Monitoring History  Actions to be taken

Action Programmes  EPA to assess and decide whether action prorgamme needed within 14 days  LA must submit and agree action programme with EPA within 60 days  EPA can amend programme before approval  LA must complete actions within specified timeframe  Consumers must be informed of actions taken/to be taken  EPA may also use Reg 10(4)(a) or inspections as an enforcement tool

Reporting Risks to Human Health Regulation 9  Where risk to human health must consult with HSE and notify the EPA  EPA to decide to issue direction in consultation with HSE  Consumers must be advised

Reporting Risks to Human Health Risk to Human Health could include:  Failure to meet a parametric value  Presence of micro-organisms that have no parametric value  Presence of substances that have no parametric value

Enforcement to Date No. of Notifications Received: 60 No. of Directions Issued:14 No. of Boil Water/Restrictions: 21

Key Issues  Chlorine alarms not installed  Chlorine booster stations needed  Actions must deal with root cause of problem and not “patch job”  Plants run above design capacity  Tighter control over chemicals used

EPA Actions  Guidance Booklet on Notifications and Action Programmes to be published  Handbook to be reviewed  Cryptosporidium Risk Assessment being revised

EPA Handbook Will include:  Guidance on monitoring programmes  Guidance on notifications and action programmes  Guidance on exempted supplies (binding)  Guidance on auditing supplies (binding)