water services national training group and national federation of group water schemes
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Water Services National Training Group and National Federation of Group Water Schemes. 7 th Annual Rural Water Services Conference 18 th September 2008. Rural Water Licensing Guidance and Training. Jerry Cronin and Richard Church Nicholas O’Dwyer / Entec. Presentation Contents. - PowerPoint PPT PresentationTRANSCRIPT
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Water Services National Training Group and
National Federation of Group Water Schemes
7th Annual Rural Water Services Conference
18th September 2008
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Rural Water Licensing Guidance and Training
Jerry Cronin and Richard Church
Nicholas O’Dwyer / Entec
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Presentation Contents
1. Project Objective2. Background/ Legislation3. Application Process4. Application Form / Assessment5. Overall Assessment6. Conditions7. Project Deliverables
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Over Riding Purpose of Rural Water Licensing
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
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Project Objective
To develop guidance and training for the new Rural Water Services Licensing System introduced under the Water Services Act 2007.
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Project Team
Procured by: WSNTG Consultants: Nicholas O'Dwyer and Entec Steering Group:
WSNTG DEHLG NFGWS CCMA
Other Consultees EPA Operators of five representative GWSs (site visits) Rural Water Liaison Officers from the five WSAs
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Background/ Legislation Water Services Act 2007
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.
Licensing Regulations currently being drafted and being informed by the consultation process associated with this project and in the development of the Guidance Document.
Key Focus Area: Group Water Scheme Sector
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European Communities (Drinking Water) Regulations (2007) – S.I. 278 of 2007
EPA have powers to direct a WSA to improve the management or quality of a public water supply.
WSA’s have a similar supervisory role in relation to group water schemes or private supplies.
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).
Background/ Legislation
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Threshold for Licensing
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)
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
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Phasing of Licensing 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 ParametersTable A: Microbiological (E. Coli)
Table B: Chemical: Bromate, Trihalomethane, Nitrate
Table C: Indicator: Aluminium, Turbidity
Cryptosporidium – where available
Other relevant parameters: e.g. Arsenic
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Phasing of Licensing System
Phasing details are to be set out in Regulations
Further phasing would be based on scheme size with priority given to the larger schemes
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Group Scheme Registration System
GWS serving less than 15 residences would be registered
Separate monitoring and inspection procedures.
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2007 Act 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”.
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2007 Act
Sub-section 79 (3): provides for the setting of a threshold below which a licence will not be required
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………”
Sub-section 79 (5): “A person who contravenes subsection (1) or a regulation made………commits an offence”.
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2007 Act Section 80: Determination by WSA of an activity to be a
licensable Section 81: WSA may grant/refuse a licence following
consideration of a range of matters Section 82: WSA to be the licensing authority Section 83: Conditions attached to a licence Section 84: Licence review Section 85: Licence revocation Section 86: Consider all submissions and notify all
regarding decision Section 87: Appeals process (district court) Section 88: New Regulations Section 89: Contravention of a condition Section 90: Related licences (e.g. discharge licences) Section 91: Powers to take over O & M on a temporary
basis
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Application Process
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Pre-Application
WSA to establish RAL for all GWSs within its functional area in accordance with the Licensing Regulations.
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Application Process
Stage 1
Stage 2
Stage 3
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Stage 1 - Application Submission
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Stage 2 – Preliminary Technical Assessment
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Stage 3 – Final Assessment
Licence is Issued
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Application Form / Assessment
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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.
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Section 4 – Operational Contracts/ Maintenance and Service Contracts
Details of Contract
Contractor Details
Date of Commencement
Period of Contract
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Section 5 – Scheme Source Details
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
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Section 6 – Treatment Plants
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
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Section 7 – Distribution System
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)
WSNTG/NFGWS training course Burst Details/ Problem Areas
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Section 8 – Network Water Quality
Details of supply restrictions e.g. Boil Notices, “Do Not Use” notices etc.
Cryptosporidium Risk Assessment
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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 courses available from WSNTG regional training
centres
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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
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Section 13 – Quality Assurance
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.
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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
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
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Overall Assessment
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Assessment Process
WSA to consider: 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)): 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
Drinking Water Quality Levels of Service
Other Matters
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Assessment Process
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.
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Condition Setting
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Licence Conditions
Sub-Section 83(2) requires that conditions relating to water services licensing 'shall' be included in respect of certain categories
Sub-Section 83(3) lists further categories from which conditions 'may' be included for consideration
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Standard Conditions Section 83(2)
(a) Measures to ensure against risk to human health and the environment
Example conditions for a licence: 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
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Standard Conditions Section 83(2)
(b) Water Supply Standards
Drinking water quality standardsEuropean Communities (Drinking Water) [No.
2] Regulations 2007 (S.I. No. 278 of 2007)
European Communities (Quality of Surface Water Intended for the abstraction of Drinking Water) Regulations 1989. (S.I. No. 294 of 1989)
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Standard Conditions Section 83(2)
(c) Standards of Service
Performance standards Defined in strategic resource plans e.g. 15m of head at stop-cock
Customer service Reporting Complaints procedure Annual General Meeting
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Standard Conditions Section 83(2)
(d) Monitoring and SupervisionFrequency to meet the Drinking Water
RegulationsAppropriate reporting schedule to WSA
(e) Sampling and Analysis Section Responsibility of GWS but undertaken by
WSA/HSE
(f) Other such matters as may be prescribed
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Additional Conditions – Section 83(3)
(a) Scale of Activity
(b) Specification of Households, Areas or Activities
(c) Operational and Management Procedures
(d) Procurement Procedures
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Additional Conditions – Section 83(3)
(e) Measures to ensure public safety
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Additional Measures - Section 83(3)
(f) Emergency plans
(g) Employers and Public Liability Insurance
(h) Conservation Measures
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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
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Project Deliverables
Background Scoping Document Application Forms Guidance Document Courseware Delivery of Training Courses
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Water Services National Training Group and
National Federation of Group Water Schemes
7th Annual Rural Water Services Conference
18th September 2008