Application of HACCP for Distribution System Protection

Application of HACCP for Distribution System Protection

Subject Area:High-Quality Water


©2006 AwwaRF. All Rights Reserved.

About the Awwa Research Foundation

The Awwa Research Foundation (AwwaRF) is a member-supported, international, nonprofit organization that sponsors research to enable water utilities, public health agencies, and other professionals to provide safe and affordable drinking water to consumers.

The Foundation’s mission is to advance the science of water to improve the quality of life. To achieve this mission, the Foundation sponsors studies on all aspects of drinking water, including supply and resources, treatment, monitoring and analysis, distribution, management, and health effects. Funding for research is provided primarily by subscription payments from approximately 1,000 utilities, consulting firms, and manufacturers in North America and abroad. Additional funding comes from collaborative partnerships with other national and international organizations, allowing for resources to be leveraged, expertise to be shared, and broad-based knowledge to be developed and disseminated. Government funding serves as a third source of research dollars.

From its headquarters in Denver, Colorado, the Foundation’s staff directs and supports the efforts of more than 800 volunteers who serve on the board of trustees and various committees. These volunteers represent many facets of the water industry, and contribute their expertise to select and monitor research studies that benefit the entire drinking water community.

The results of research are disseminated through a number of channels, including reports, the Web site, conferences, and periodicals.

For subscribers, the Foundation serves as a cooperative program in which water suppliers unite to pool their resources. By applying Foundation research findings, these water suppliers can save substantial costs and stay on the leading edge of drinking water science and technology. Since its inception, AwwaRF has supplied the water community with more than $300 million in applied research.

More information about the Foundation and how to become a subscriber is available on the Web at www.awwarf.org.



Prepared by:Kathy Martel, Gregory Kirmeyer, and Amie HansonHDR/EES, Inc., Bellevue, WA

Melita StevensMelbourne Water Corporation, Melbourne, VIC 3001, Australia

Joanne MullengerSouth East Water Ltd., Altona Meadows, VIC, Australiaand

Daniel DeereWater Futures, LLC, Dundas Valley, NSW, Australia

Jointly sponsored by:Awwa Research Foundation6666 West Quincy Avenue, Denver, CO 80235-3098and

U.S. Environmental Protection AgencyWashington D.C.

Published by:


DISCLAIMER

This study was jointly funded by the Awwa Research Foundation (AwwaRF) and the U.S. Environmental Protection Agency (USEPA) under Cooperative Agreement No. R829409-01. AwwaRF and USEPA assume no responsibility for the content of the research study reported in this publication or for the opinions or statements of fact expressed

in the report. The mention of trade names for commercial products does not represent or imply the approval or endorsement of AwwaRF or USEPA. This report is presented solely for informational purposes.

Copyright © 2006by Awwa Research Foundation

All Rights Reserved

Printed in the U.S.A.


v

CONTENTS

LIST OF TABLES................................................................................................................... ix LIST OF FIGURES ................................................................................................................. xi

FOREWORD ........................................................................................................................... xiii ACKNOWLEDGMENTS ....................................................................................................... xv EXECUTIVE SUMMARY ..................................................................................................... xvii CHAPTER 1: BACKGROUND INFORMATION................................................................ 1 Introduction.................................................................................................................. 1 Purpose of Project ........................................................................................................ 3 Research Strategy......................................................................................................... 4 Use of Report ............................................................................................................... 5 Water Quality Framework ........................................................................................... 5 CHAPTER 2: INTRODUCTION TO HACCP ...................................................................... 7 Background.................................................................................................................. 7 The HACCP System .................................................................................................... 8 HACCP in Drinking Water Regulations and Guidelines............................................. 8 HACCP Applications in the Water Industry................................................................ 13 Watershed Protection ....................................................................................... 14 Treatment Facilities ......................................................................................... 16 Water Distribution Systems ............................................................................. 17 Other Applications in the Water Industry........................................................ 18 Summary ...................................................................................................................... 18

CHAPTER 3: TAILORED HACCP GUIDE FOR WATER DISTRIBUTION SYSTEMS . 21 Introduction.................................................................................................................. 21 Identify Goals and Expected Benefits.............................................................. 21 Estimate Resources Requirements................................................................... 22 Solicit Employee Support and Commitment ................................................... 23 Conduct a HACCP Training Workshop .......................................................... 23 Identify and Update Supporting Programs and Practices ................................ 24 Applying the HACCP Steps to Water Distribution Systems ....................................... 29 Step 1: Assemble HACCP Team ..................................................................... 29 Step 2: Describe Drinking Water..................................................................... 32 Step 3: Identify Intended Use .......................................................................... 35 Step 4: Construct Flow Diagram...................................................................... 37 Step 5: Confirm Flow Diagram........................................................................ 39 Step 6: Conduct a Hazard Analysis ................................................................. 40 Step 7: Determine the CCPs ............................................................................ 50


vi

Step 8: Establish Critical Limit(s).................................................................... 53 Step 9: Establish a System to Monitor Control of the CCP............................. 55 Step 10: Establish Corrective Actions ............................................................. 58 Step 11: Validate/Verify HACCP Plan............................................................ 59 Step 12: Establish Documentation and Record Keeping ................................. 62 CHAPTER 4: PILOT TESTING OF HACCP PLANS .......................................................... 65 Introduction.................................................................................................................. 65 Approach...................................................................................................................... 66 Training Workshops......................................................................................... 66 Formation of HACCP Team ............................................................................ 67 Development of HACCP Plan ......................................................................... 67 Development of Surveys and Evaluation Criteria ........................................... 67 Implementation of HACCP Plan ................................................................................. 73 Pilot Study Results....................................................................................................... 73 South Berwick Water District.......................................................................... 73 City of Austin, Texas ....................................................................................... 78 Sydney Water Corporation .............................................................................. 84 Power and Water Corporation ......................................................................... 92 Conclusions .............................................................................................................. 108 CHAPTER 5: CASE STUDIES.............................................................................................. 109 Introduction.................................................................................................................. 109 HACCP Implementation.............................................................................................. 112

Implementation of Other Management Systems Prior to HACCP .................. 112 International Organization for Standardization (ISO) Management Systems . 112 Costs of Implementing a HACCP System....................................................... 116

Maintenance of HACCP Systems................................................................................ 117 Benefits of HACCP Systems ....................................................................................... 118 Reductions in Customer Complaints ............................................................... 130 Improvements in Water Quality....................................................................... 130 Improvements in Process Performance............................................................ 130 Improvements in Work Processes.................................................................... 132 Improved Understanding of Risks and Risk Management .............................. 132 Improvements in Documentation and Record Keeping................................... 133 Demonstration of Due Diligence ..................................................................... 133 Summary ...................................................................................................................... 134 CHAPTER 6: RECOMMENDED NEXT STEPS AND FUTURE RESEARCH NEEDS.... 137 Consider Developing and Implementing the ISO Management Systems.................... 138 Evaluate HACCP Applications to Other Water Supply System Components ............ 138 Consider HACCP Framework in US Regulation or Regulatory Guidelines ............... 138 Evaluate HACCP Applications in Small Water Systems ............................................ 138 REFERENCES ......................................................................................................................... 141


vii

ABBREVIATIONS ................................................................................................................. 147 APPENDICES A–D (ON CD-ROM PACKAGED WITH THE PRINTED REPORT) APPENDIX A: HACCP WORKSHOP TRAINING MATERIALS...................................... A-1 APPENDIX B: UTILITY HACCP PLANS ............................................................................ B-1 APPENDIX C: PILOT STUDY REPORTS............................................................................ C-1 APPENDIX D: SYDNEY WATER MANAGEMENT PLANS............................................. D-1


viii


ix

TABLES

2.1 HACCP programs for controlling public health risks in drinking water ..................... 10 2.2 New Zealand approach for preparing Public Health Risk Management Plans............ 12 2.3 Generalized HACCP analysis of source of supply ...................................................... 15 2.4 Generalized HACCP analysis of treatment process..................................................... 17 2.5 Generalized HACCP analysis of water distribution systems....................................... 18 3.1 Examples of supporting programs ............................................................................... 25 3.2 Example roles of HACCP team members ................................................................... 30 3.3 Example descriptions of drinking water ...................................................................... 33 3.4 Example specifications for potable water .................................................................... 34 3.5 Example specifications for non potable water ............................................................. 35 3.6 Example of a long-form “intended use” statement ...................................................... 36 3.7 Example of a short-form “intended use” statement ..................................................... 37 3.8 Examples of hazards to the water distribution system................................................. 41 3.9 Example of a simple risk scoring matrix ..................................................................... 43 3.10 Example of a risk assessment for service reservoirs.................................................... 44 3.11 Example of a risk assessment for distribution systems................................................ 45 3.12 Example hazard analysis and control measures........................................................... 49 3.13 Examples of CCPs in utility HACCP plans................................................................. 53 3.14 Examples of critical limits in utility HACCP plans..................................................... 54 3.15 Examples of critical limit monitoring in utility HACCP plans.................................... 56 3.16 Examples of corrective action procedures in utility HACCP plans............................. 58 3.17 Example validation schedule ...................................................................................... 60


x

3.18 Example verification schedule..................................................................................... 61 3.19 Example of critical control point records for one process ........................................... 63 4.1 Typical Workshop Agenda .......................................................................................... 66 4.2 Evaluation criteria for pilot studies.............................................................................. 69 4.3 Outside experts invited to South Berwick workshop................................................... 74 4.4 Austin’s HACCP team................................................................................................. 79 4.5 Sydney Water’s HACCP team..................................................................................... 85 4.6 Critical monitoring parameters for Sydney Water HACCP Plan ................................ 88 4.7 Sydney Water Corporation monitoring program ......................................................... 89 4.8 Sydney Water perspective on HACCP pilot study ...................................................... 90 4.9 Power and Water Corporation’s HACCP team ........................................................... 94 4.10 Power and Water Corporation monitoring program .................................................... 99 4.11 Power and Water Corporation perspective on HACCP pilot study............................. 104 5.1 Case study utilities – system descriptions.................................................................... 111 5.2 HACCP implementation and maintenance .................................................................. 113 5.3 Gold Coast Water perspective on HACCP Application to Distribution System......... 120 5.4 South East Water Perspective on HACCP Application to Distribution System.......... 124 5.5 Yarra Valley Water Perspective on HACCP Application to Distribution System ...... 127


xi

FIGURES

1.1 Illustration of HACCP Plan as integral part of Water Quality Framework................. 6 3.1 Example of more complex system flow diagram ........................................................ 38 3.2 Example of simpler system flow diagram ................................................................... 39 3.3 Example of a complex risk ranking approach.............................................................. 48 3.4 Decision tree for identifying process steps that are CCPs ........................................... 52 4.1 Map illustrating the relative positions of the Australian pilot study sites.................... 65 4.2 Example of workshop survey form for South Berwick Water District ....................... 68 4.3 Survey results for South Berwick Water District ........................................................ 75 4.4 South Berwick Water District process flow diagram .................................................. 76 4.5 City of Austin workshop survey results....................................................................... 80 4.6 City of Austin process flow diagram ........................................................................... 82 4.7 Sydney Water Woronora system flow diagram........................................................... 87 4.8 Power and Water Corporation’s Katherine supply process flow diagram................... 96 4.9 Risk scoring matrix used for the pilot by Power and Water ........................................ 102 4.10 New risk scoring matrix to be used by Power and Water following their experience with

the pilot ........................................................................................................................ 103 5.1 Map illustrating the location of the five case study utilities ........................................ 110 5.2 Gold Coast Water average weekly turbidity of finished water from Molendinar Water

Treatment Plant............................................................................................................ 131 5.3 Yarra Valley Water number of chlorinator CCP exceedances per year ...................... 131


xii


xiii

FOREWORD

The Awwa Research Foundation is a nonprofit corporation that is dedicated to the

implementation of a research effort to help utilities respond to regulatory requirements and traditional high-priority concerns of the industry. The research agenda is developed through a process of consultation with subscribers and drinking water professionals. Under the umbrella of a Strategic Research Plan, the Research Advisory Council prioritizes the suggested projects based upon current and future needs, applicability, and past work; the recommendations are forwarded to the Board of Trustees for final selection. The foundation also sponsors research projects through the unsolicited proposal process; the Collaborative Research, Research Applications, and Tailored Collaboration programs; and various joint research efforts with organizations such as the U.S. Environmental Protection Agency, the U.S. Bureau of Reclamation, and the Association of California Water Agencies.

This publication is a result of one of these sponsored studies, and it is hoped that its findings will be applied in communities throughout the world. The following report serves not only as a means of communicating the results of the water industry's centralized research program but also as a tool to enlist the further support of the nonmember utilities and individuals.

Projects are managed closely from their inception to the final report by the foundation's staff and large cadre of volunteers who willingly contribute their time and expertise. The foundation serves a planning and management function and awards contracts to other institutions such as water utilities, universities, and engineering films. The funding for this research effort comes primarily from the Subscription Program, through which water utilities subscribe to the research program and make an annual payment proportionate to the volume of water they deliver and consultants and manufacturers subscribe based on their annual billings. The program offers a cost-effective and fair method for funding research in the public interest.

A broad spectrum of water supply issues is addressed by the foundation's research agenda: resources, treatment and operations, distribution and storage, water quality and analysis, toxicology, economics, and management. The ultimate purpose of the coordinated effort is to assist water suppliers to provide the highest possible quality of water economically and reliably. The true benefits are realized when the results are implemented at the utility level. The foundation's trustees are pleased to offer this publication as a contribution toward that end.

Walter J. Bishop Robert C. Renner, P.E. Chair, Board of Trustees Executive Director Awwa Research Foundation Awwa Research Foundation


xiv


xv

ACKNOWLEDGMENTS

The authors would like to acknowledge the gracious financial support of the Awwa Research Foundation and the U.S. Environmental Protection Agency. Without their support, this project would not have been possible.

This research has been guided from the outset by an experienced Project Advisory Committee (PAC) who provided valuable guidance, expertise and suggestions. The authors wish to thank these individuals for their time and efforts:

Homer Emery, San Antonio Water Systems, Texas Bruce Macler, EPA Region 9, California Susan Shaw, U.S. Environmental Protection Agency, Washington D.C. David Lipsky, NYC DEP/Bureau of Water Supply, New York

Four participating water utilities conducted pilot studies for this research project. Each

utility formed a team of experts to develop and implement their HACCP Plan. These utility professionals contributed their time and expertise to this research while performing their other responsibilities. The authors gratefully acknowledge these efforts:

Dan Pedersen, City of Austin Water and Wastewater Utility, Texas Edward Ojeda, City of Austin Water and Wastewater Utility, Texas Teresa Lutes, City of Austin Water and Wastewater Utility, Texas Robert Kuhn, City of Austin Water and Wastewater Utility, Texas Jane Burazer, City of Austin Water and Wastewater Utility, Texas Onnie Bohr, City of Austin Water and Wastewater Utility, Texas Rosie Barrios, City of Austin Water and Wastewater Utility, Texas Tony Bennett, Texas Commission on Environmental Quality Mike Nadeau, South Berwick Water District, Maine John Leach, South Berwick Water District, Maine Jerry Leavitt, South Berwick Water District, Maine Rick deRochemont, South Berwick Water District, Maine Corinna Doolan, Sydney Water Corporation, Australia Lindsay Mullard, Sydney Water Corporation, Australia Colin Storey, General Water Australia Keith Ross, General Water Australia M. Govintharajah, Sydney Water Corporation, Australia David Cooper, Sydney Water Corporation, Australia Shariff Shockair, Sydney Water Corporation, Australia Tony Venturino, Sydney Water Corporation, Australia Carl Deininger, Sydney Water Corporation, Australia Peter Cresta, Sydney Water Corporation, Australia Philip Broad, Sydney Water Corporation, Australia Dammika Vitanage, Sydney Water Corporation, Australia


xvi

Simon Copley, Power and Water Corporation, Australia Norm Cramp, Power and Water Corporation, Australia Mark Ewin, Power and Water Corporation, Australia Gabrielle Halcrow, Power and Water Corporation, Australia Paul Heaton, Power and Water Corporation, Australia Peter Hopkins, Power and Water Corporation, Australia Noel McCarthy, Power and Water Corporation, Australia Leon Miles, Power and Water Corporation, Australia Kevin O’Brien, Power and Water Corporation, Australia Declan Page, Power and Water Corporation, Australia

Five HACCP-certified utilities in Australia provided case study information on their experiences in implementing HACCP. The authors gratefully acknowledge these efforts:

Bob Gray, Brisbane Water George Ruta, City West Water David Smith, Gold Coast Water Dr. Greg Ryan, South East Water Asoka Jayaratne, Yarra Valley Water The authors would like to acknowledge Annette Davison of Water Futures in Australia

for her assistance in conducting HACCP training workshops for Sydney Water Corporation and Power and Water Corporation, and for review of Project work products.

The authors thank Julie Self of HDR/EES, Inc. for her efforts in bringing this work together into its final form.


xvii

EXECUTIVE SUMMARY

WHAT DOES THE TERM “HACCP” REPRESENT?

HACCP (pronounced as “hass-up”) is an acronym for Hazard Analysis and Critical Control Point.

WHAT IS HACCP AND WHAT ARE THE MAIN STEPS?

HACCP is an internationally recognized process control system that involves identifying and prioritizing hazards and risks to the quality of food or drinking water, and controlling processes to reliably maintain the desired level of quality. The application of HACCP in a systematic manner helps the water utility control water quality risks as close to their sources as possible.

The 12 steps of HACCP are defined by the Codex Alimentarius Commission (Codex 1997), an intergovernmental body established to implement the Joint Food and Agricultural Organization (FAO)/World Health Organization (WHO) Food Standards Program. The information prepared in completing these 12 steps constitutes the utility’s HACCP Plan. These steps are summarized below:

Step 1 Assemble HACCP Team Step 2 Describe Drinking Water Step 3 Identify Intended Use Step 4 Construct Flow Diagram Step 5 Confirm Flow Diagram Step 6 Conduct a Hazard Analysis Step 7 Determine the Critical Control Points Step 8 Establish Critical Limit(s) Step 9 Establish a System to Monitor Control of the Critical Control Points Step 10 Establish Corrective Actions Step 11 Validate/Verify HACCP Plan Step 12 Establish Documentation and Recordkeeping.

The contemporary application of the 12 HACCP steps requires their implementation with a broader HACCP System that includes Supporting Programs. Ideally, the Supporting Programs should be in place prior to embarking on the 12 HACCP steps. Supporting Programs included within HACCP systems in the water industry include:

• Staff training and certification programs • Distribution system maintenance programs • Standard operating procedures • Emergency response program • Quality assurance programs • Data management systems • Customer relations program • Calibration of monitoring systems.


xviii

WHERE DID HACCP ORIGINATE AND HOW HAS IT BEEN APPLIED?

The HACCP concept and acronym was first conceived in the US in 1959 by the Pillsbury Company to improve food safety for manned space missions by the National Aeronautics and Space Administration (NASA). Since the 1980’s, the HACCP system has evolved, been improved and widely adopted by the food and beverage industries world-wide where it forms an important part of their “food safety plans.” In the US, certain food processors, such as seafood, red meat, and poultry industries, are required by federal regulations to develop and implement a HACCP plan. The International Bottled Water Association requires its members to develop a HACCP program for each of their facilities. Since the mid-1990’s, HACCP has been applied by a number of individual drinking water systems in Australia, Iceland, France, Canada, and Switzerland. The HACCP system has been incorporated into many drinking water regulatory requirements and guidelines around the globe. For example, the third edition of the WHO drinking water guidelines (WHO 2004) outline a framework for drinking water safety based on the multiple barrier approach and several risk management and quality management approaches including HACCP.

WHAT WAS THE MAIN OBJECTIVE OF THIS PROJECT?

The purpose of this project was to evaluate the application of HACCP in the drinking water industry to protect and maintain distribution system water quality.

WHAT EVALUATION CRITERIA WERE USED TO ASSESS THE APPLICATION OF HACCP TO DISTRIBUTION SYSTEMS?

Six categories of evaluation criteria were used to assess HACCP implementation during the Project pilot studies and the case studies of full-scale, longer, term HACCP implementation. These categories include:

• Customer satisfaction: Has HACCP implementation resulted in reduced customer inquiries or complaints about water quality received by the utility?

• Regulatory compliance: Has HACCP implementation resulted in improved water quality compliance for the utility?

• Risk management: Has HACCP implementation resulted in strengthened mechanisms for water quality risk management at the utility?

• System management: Has HACCP implementation resulted in improved system management and control at the utility?

• Human factors: Has HACCP implementation improved the human relationships and understanding within the utility?

• Costs and benefits: Has HACCP implementation resulted in benefits that outweigh the costs to the utility?

WHAT WERE THE MAIN FINDINGS FROM THE PROJECT’S PILOT STUDIES?

All four pilot study utilities took part in training workshops and subsequently took their HACCP plan documents to various levels of completion. Two of the four participating utilities were successful in implementing the full scope of their HACCP Plan over a 12-month study


xix

period: the City of Austin, Texas and the Katherine system in the Northern Territories of Australia. The implementation of HACCP to water distribution systems was feasible and practical, but the time and resource requirements were greater than originally anticipated by the utilities when they agreed to participate.

For the South Berwick Water District, being a very small utility with only three full-time employees working during the latter part of the pilot, developing and implementing a full HACCP system was not achievable given the many day-to-day duties and activities of the staff. This revealed a fundamental difficulty in the implementation of HACCP, or for that matter, any systematic management system, within very small water utilities. Changes that could be made to enable implementation to be successful in very small utilities were considered to include:

• Increase the number of employees on staff within small utilities to provide a critical mass of personnel.

• Provide temporary, contracted support for long enough to implement the system, funded by a third party, if required.

• Provide generic HACCP plans and guidance combined with very explicit guidance, support and tools to help utilities implement the systems in practice.

• Provide more support from the state or regional regulatory and support organizations.

For the larger utilities, there were sufficient resources to implement HACCP although there was a requirement to have some specific resources reasonably dedicated and assigned to make implementation happen. Importantly, it wasn’t the preparation of the HACCP plan per se that was resource-intensive. Rather, it was the implementation of the HACCP plan to create a functional HACCP system in practice that required resources. Therefore, it can be concluded that implementing HACCP, and for that matter, any management system of similar rigor, is likely to be a significant undertaking for a water utility.

All the participating utilities concluded that their participation in the HACCP process was a valuable one. The development of the HACCP plan was useful in honing in on the most important risks and process controls for water quality management. Therefore, the decision about whether or not to implement HACCP comes down to an assessment of whether or not the benefits are worthwhile given the costs.

WHAT WERE THE MAIN FINDINGS FROM THE PROJECT’S CASE STUDIES?

All five case study utilities completed evaluation criteria and many provided additional comments and information on their experiences in implementing HACCP systems. The most important findings from the case studies are summarized below:

• Most utilities that have gained HACCP certification have done so after some core management systems [e.g. International Organization for Standards (ISO) 9001, ISO 14001] had been developed and implemented. These management systems helped the utility to gain management control of people and processes which made implementing HACCP relatively straightforward.

• In practice, the case study utilities did not operate multiple, separate systems for quality management, occupational safety, water quality and safety, and environmental considerations. Although separately identifiable and auditable, in operation, all of these systems were captured within an integrated management system (IMS). The


xx

principal benefit of an IMS, as identified by water utilities, was the avoidance of duplication, leading to reduced staff time and costs, and improved process integration.

• Water quality improvements did become evident following the implementation of HACCP, but in most cases, those changes did not appear conclusive until a consistent pattern of improvement had emerged after three or more years. Water quality improvements included reduced numbers of customer complaints and water quality incidents, and fewer microbial indicators.

• When a utility implements HACCP for water, it is likely to be doing so as one of a number of water quality improvement projects, making it very difficult, if not impossible, to precisely determine the extent to which HACCP contributed to any effect(s).

• All utilities that had implemented HACCP and attained certification continued to be audited and re-registered each year since all believed that, overall, the benefits of the HACCP system, including the certification discipline, outweighed the costs.

• Auditing, though sometimes uncomfortable for operating staff, is a necessary and useful element of HACCP. It forces periodic reviews and keeps utility staff and management up-to-date on important issues.

HOW CAN THIS REPORT BE USED?

This report may be useful to water utilities that are considering whether or not to apply the HACCP system to their distribution system. These readers are referred to the following chapters:

• Chapter 2 describes background information on HACCP and current applications. • Chapter 3 provides a tailored HACCP guidance manual providing guidance on how to

implement HACCP including resource requirements and the need for supporting utility programs and standard operating procedures.

• Chapter 4 presents findings from short term pilot studies (12 months duration) that evaluate HACCP based on six different categories: customer satisfaction, regulatory compliance, risk management, system management, human factors, and costs and benefits.

• In Chapter 5, case study information from HACCP-certified utilities in Australia is used to evaluate HACCP based on the same criteria as the pilot studies in Chapter 4. These case studies also provide insight into the challenges of implementing HACCP.

Example workshop training materials are provided in Appendix A. Example HACCP Plans for the four participating utilities are provided in Appendix B.

For industry researchers that are interested in furthering the knowledge and applications potential for HACCP in drinking water systems, research needs are outlined in Chapter 6.

WHAT ARE THE MAIN BENEFITS OF IMPLEMENTING HACCP?

The HACCP system complements the current US approach to managing distribution system water quality that is centered on water quality monitoring and compliance with regulatory requirements. It will help utilities focus resources on key risks and to improve emphasis on operations processes and controls.


xxi

The five case study utilities all reported some benefits in aspects of water quality management that were at least partly related to HACCP. Improvements considered by utilities to be associated with the implementation of HACCP included the following:

Water quality − Reduced customer complaints − Reduced water quality incidents − Reduced microbial indicator failures

Operations − Improved treatment system performance − Improved work processes

Business performance − Improved capability to demonstrate due diligence − Reduced costs − Improved documentation and record keeping − Improved training and culture of operational good practices.

The most notable improvement reported by utilities following implementation of HACCP

was an apparent drop in the frequency of customer complaints. For example, water quality complaints dropped steadily following HACCP implementation for Gold Coast Water and South East Water by a total of 66 percent and 60 percent, respectively, over a few years.

Three of the five case study utilities - South East Water, Yarra Valley Water, and Gold Coast Water - found that HACCP implementation has helped to improve system credibility and demonstration of due diligence or the “prevention of foreseeable harm.” South East Water attributed these improvements to improved record-keeping practices. At Yarra Valley Water, employees have an improved awareness of water quality risks and management processes. Gold Coast Water noted that the structure of the HACCP system has helped with system credibility and demonstration of due diligence.

WHAT ARE THE COSTS OF IMPLEMENTING HACCP?

The case studies for HACCP-certified utilities in Australia, discussed in Chapter 5, show that HACCP implementation costs were relatively modest, and in some cases were met entirely with existing resources. It is important to note that these utilities had all implemented other quality management systems prior to implementing HACCP and therefore, their costs may not be comparable to a utility implementing only HACCP. The reported cash costs of implementing HACCP varied between utilities:

• One time cash costs for HACCP training, coaching, technical advice and documentation varied from $0 (Brisbane Water) to $70,000 (Australian Dollars) ($55,000 US Dollars) (Yarra Valley Water). The variability is primarily explained by the difference in the extent to which utilities used external service providers to undertake some of the tasks.

• Recurrent cash costs associated with increased water quality monitoring and instrumentation varied from $0 (Brisbane Water) through to $105,000 (Australian Dollars) ($84,000 US Dollars) (Gold Coast Water) annually. The variability is


xxii

related to the extent to which additional monitoring or operational costs arose from the increased risk management activities deemed appropriate by the HACCP team.

• Some utilities, such as Yarra Valley Water, adopted the recommended practice of annual HACCP awareness training, requiring an additional recurrent cash cost of $1,500 (Australian Dollars) ($1,200 US Dollars) annually. New staff, or staff that are losing familiarity with HACCP, attend the training course each year.

Non-cash costs of HACCP implementation varied between utilities. Implementation almost always required a full time, dedicated officer, for at least one month and up to twelve months. For example, City West Water required 0.75 a full-time equivalent (FTE) for one month, while Gold Coast Water utilized 1 FTE for twelve months. The variability is related to the extent to which tasks were split between a core coordinator and other staff, as well as the amount of work required to implement the HACCP plan. For example, City West Water had completed the vast majority of tasks required by HACCP before the organization formally began to undertake its HACCP process and was able to complete the HACCP plan within one month.

ARE THERE ANY SPECIAL CONSIDERATIONS FOR SMALL SYSTEMS?

Small systems often lack expertise in one or more topic areas covered by the HACCP Plan. Outside experts may be utilized as necessary to help facilitate the HACCP training workshop and to support the utility HACCP team.

The small utility may lack adequate historical water quality and system data to identify and rank risks/hazards in the HACCP hazard analysis (Step 6). This dilemma, experienced by the South Berwick Water District as part of their Project-pilot study, was addressed by initially focusing the HACCP Plan to collect additional information to evaluate, document, and improve control over these hazards.

In practice, the small utility may lack adequate manpower or other necessary resources to develop and implement a HACCP Plan independently. This constraint can be addressed but in some cases, the solutions are not directly deliverable by the small utility acting alone (see above notes on findings from pilot studies).

ARE THERE ANY SPECIAL CONSIDERATIONS FOR LARGE SYSTEMS?

Large water utilities face different types of constraints than small systems in implementing HACCP. Communication across departments and between management and operational staff can be challenging. Organization-wide coordination on water quality management issues can also be difficult. These challenges can be addressed through the HACCP training workshop and through careful selection of HACCP team members and, most importantly, through strong, proactive support from the highest levels in the organization.

WHAT STRATEGIES ARE USED TO SUCCESSFULLY IMPLEMENT A HACCP PLAN?

Prior to initiating a HACCP Plan, a utility should complete the following tasks:

• Identify goals and expected benefits. • Estimate and commit resources required.


xxiii

• Solicit employee support and commitment. • Conduct HACCP training workshop. • Identify and update supporting programs and practices.

The identification of goals and expected benefits helps the utility to focus resources most efficiently and to help sell the program to utility management, staff, and customers. The utility should estimate the resource requirements for implementing HACCP in their system and make a firm commitment to providing these resources prior to initiating the process.

To assure the effectiveness of the HACCP system, it is important to gain the support of and commitment from all employees, from the front line operators to the top managers. The utility HACCP team should include experienced personnel across a wide range of topic areas to assure that all hazards can be identified and properly managed. Before HACCP implementation, utility staff should be formally trained in HACCP terminology and methodology.

Prior to initiating a HACCP plan, it is important to identify other existing utility programs and SOPs that may contribute valuable information related to the condition of the distribution system and distribution system water quality. The recommended approach is to improve water quality programs and practices to meet the AWWA Standard G200-Distribution System Operation and Management (AWWA 2004).

HOW OFTEN DOES THE HACCP PLAN NEED TO BE UPDATED?

The HACCP Plan is considered to be a “live” document that is continually updated as system changes occur, such as physical improvements or operational modifications that affect the process flow diagram. Change is inevitable as the utility implements the HACCP Plan to address the initial priority hazards by instituting appropriate control measures, monitoring, and documentation. Examples of physical improvements that should be documented in the HACCP Plan include addition of new disinfection facilities or pump stations in the distribution system, and covering an open reservoir. Examples of operational modifications that should be documented in the HACCP Plan include changes in disinfectant dosage rate, changes to pressure zone boundaries or flow direction, and use of new standard operating procedures once the initial priority hazards are controlled, the utility should review the hazard analysis fully (HACCP Step 6) and modify the HACCP Plan to focus on the next set of priority hazards.

As new drinking water regulations are promulgated or existing regulations are modified, new requirements should be documented in the HACCP Plan (HACCP Step 2).

If the utility is maintaining HACCP registration or certification, the HACCP Plan should be reviewed and updated in preparation for the independent audit which may occur semiannually or annually depending on the specific registration requirements.

WHAT ARE THE RECOMMENDED NEXT STEPS FOR APPLYING HACCP TO WATER UTILTIES?

The US drinking water industry is somewhat lagging behind its counterparts overseas in applying HACCP to watershed management, water treatment facilities and distribution systems. Many European and Australian utilities have implemented HACCP systems to full certification or have risk management or quality assurance programs that are more or less equivalent, albeit differently labeled. Although several HACCP applications in Australia and Ontario, Canada were motivated by waterborne disease outbreaks or suspected contamination incidents, a superior


xxiv

approach would be to develop and implement quality assurance programs, such as HACCP prior to experiencing such an outbreak or contamination event.

A recommended first step is to improve utility programs and practices to meet the AWWA Standard G200-Distribution Systems Operation and Maintenance. The specifications for this standard include many water utility programs and practices that are needed to successfully implement HACCP. In particular, the AWWA Standard-G200 emphasizes the need for documentation and record-keeping for all programs, key elements of the HACCP approach. Once this step is accomplished, the utility may consider developing and implementing the ISO management systems (ISO 9001 and ISO 14001) or an integrated management system that includes HACCP as well as the ISO systems.

Other recommended steps include:

• Consider whether the HACCP water quality risk management framework could be applied beneficially within the US regulatory system.

• Develop further support and case studies for HACCP application to small water utilities.


1

CHAPTER 1 BACKGROUND INFORMATION

INTRODUCTION

Current distribution system management practices may leave some systems vulnerable to contamination, as evidenced by failures linked to waterborne disease outbreaks. US waterborne disease records from 1920 to the present show that up to 40 percent of waterborne disease outbreaks have been caused by distribution system problems (Lippy and Waltrip 1984; Kramer et al. 1996; Levy et al. 1998). For example, a Salmonella typhimurium outbreak in Gideon, Missouri, was likely caused by poor distribution system flushing practices that triggered the complete draining of two finished water storage facilities into the system. The stored water was contaminated by bird droppings that carried the Salmonella typhimurium pathogen (Clark et el. 1997; Geldreich 1996). An outbreak of hemorrhagic Escherichia coli (E. coli) serotype O157:H7 occurred in Cabool, Missouri during December 1989 and January 1990 and resulted in 243 cases of diarrhea and 4 deaths (Swerdlow et al. 1992). Shortly before the peak of the outbreak, 45 water meters were replaced and two water mains ruptured. Swerdlow et al. (1992) concluded that system-wide chlorination as well as hyperchlorination during repairs might have prevented this outbreak.

Inadequacies in design, operation and maintenance of water distribution systems have also been documented through recent research funded by the American Water Works Association Research Foundation (AwwaRF). Kirmeyer et al. (2001) identified various potential pathways through which contaminants may enter the distribution system, including poorly designed, constructed, or maintained storage facilities, unprotected cross-connections; and water main break and repair sites. Kirmeyer et al. (2001) also documented evidence of fecal pollution and enteric viruses in the vicinity of water main repair sites, confirming the potential for pathogen intrusion given an available pathway and favorable pressure conditions. Further research by Friedman et al. (2004) on pathogen intrusion into distribution systems during pressure transients confirmed that transient negative pressures do occur in distribution systems and that significant volumes of water have been shown to enter a pilot-scale distribution system through small leaks during transient pressure events. Based on surveys of tank inspection firms, State primacy agencies, and utilities, Kirmeyer et al. (1999) concluded that many storage facilities in the US are not ever inspected and many facilities are inspected less frequently than the three- to five-year frequency recommended by the American Water Works Association (AWWA). A comprehensive survey on cross-connection control programs (Lee et al. 2003) showed that 91 percent of survey respondents have developed cross-connection control programs, but only 49 percent have a requirement for reporting backflow incidents (to state primacy agencies). There is no Federal reporting requirement for cross-connections. In Lee’s survey, most respondents were community water systems (99 percent of those surveyed).

In addition to inadequacies in water system processes and procedures, the human element may affect a water system’s susceptibility to contamination. Kuslikis and White (2004) provide two examples of how water system employees can impact risks and risk management:

• Competent and loyal employees sometimes take shortcuts to save time or money and unknowingly take major risks.


2

• Employees may not see the big picture and may have a much higher tolerance of risk than the corporation.

Smith (2004a) also acknowledges that some utility personnel may occasionally be careless, poorly trained, or may lack adequate resources to do their job. Most often, when things go wrong, nothing happens. But to be assured that the system is well-protected from risks, Smith (2004a) advises that a utility should be well organized and have a plan to address all risks to the quality and safety of the water supply.

Recently, the water industry has begun to move towards a more proactive approach to managing the safety of water supplies by incorporating quality assurance principles. The US drinking water industry employs several quality assurance principles, especially for the control of pathogens. For example, the Surface Water Treatment Rule (SWTR), as amended, sets goals for pathogen occurrence in the finished drinking water, and has regulatory provisions for meeting those goals (US Environmental Protection Agency (EPA) 1998). Provisions include watershed control, source water quality, and treatment performance requirements. Pathogen monitoring is not required under this rule. Additionally, the Total Coliform Rule requires periodic on-site sanitary surveys. The goal of monitoring for the SWTR and other microbial regulations is to assess the effectiveness of pathogen control measures, using monitoring tools such as total coliforms, fecal coliforms, E. coli, water turbidity, and disinfectant levels.

The AWWA has several voluntary programs that incorporate quality assurance principles for controlling pathogens in drinking water: QualServe, the Partnership for Safe Water and a new distribution system standard. QualServe is a continuous quality improvement program that helps utilities improve overall service using a self-assessment tool, a peer review process, and a benchmarking clearinghouse. The Partnership for Safe Water, a joint initiative among AWWA, EPA, and other drinking water organizations, also uses a self-assessment tool and a peer review process to optimize treatment plant performance for systems using surface water supplies. AWWA Standard G200-Distribution Systems Operation and Maintenance, effective May 1, 2004, describes critical elements for the operation and management of water distribution systems. This standard is currently being piloted at two utilities along with G100-Standard for Water Treatment Operations and Management and a draft standard, G-300, which covers source water protection (AWWA 2005). The pilot study will evaluate the practicality of these standards as part of a long-range process of standards development that could serve as the basis for a future water utility accreditation program.

This proactive, risk-based management approach is occurring on an international level as emphasized by the World Health Organization (WHO) guidelines (3rd edition) and the complementary 2004 Bonn Charter for Safe Drinking Water that are discussed in Chapter 2. In Australia, the McClellan Inquiry into the 1998 Sydney Water Cryptosporidium contamination incident recommended introducing quality assurance procedures as a framework for guiding water quality protection (Davison, Davis, and Deere 1999). A major revision to Australian food legislation in 1999 included tap water in the definition of food and required a quality assurance system incorporating Hazard Analysis Critical Control Point (HACCP) principles for all food suppliers to assure food safety (Davison, Davis, and Deere 1999). More recently, the Walkerton Inquiry in Canada also concluded, “Perhaps the most significant recommendations in this report address the need for quality management through mandatory accreditation and operational planning” (O’Connor 2002). The recommended quality management system should include real


3

time process control and preventive strategies to identify and manage risks to public health (O’Connor 2002).

Quality assurance principles and procedures, such as the HACCP system, are important in controlling risk. The EPA defines quality assurance as “an integrated system of activities involving planning, quality control, quality assessment, reporting and quality improvement to ensure that a product or service meets defined standards of quality with a stated level of confidence” (EPA 1991). The EPA defines quality control as “the overall system of technical activities whose purpose is to measure and control the quality of a product or service so that it meets the needs of users. The aim is to provide quality that is satisfactory, adequate, dependable, and economical” (EPA 1991). Application of quality assurance principles may have some value for water supply since it is very hard to manage the quality control of drinking water between release from storage and the point of consumption.

Quality assurance systems are incorporated into production and service delivery processes across the developed world. There are a number of standards and guidelines available, with International Organization for Standardization (ISO) being the internationally recognized standards that are commonly applied in Europe, Australia, and Asia. Two ISO Standards commonly employed by water utilities include ISO Standards 9001 and 14001. ISO Standard 9001 defines a Quality Management System that demonstrates the ability of an organization to consistently provide products and services that meet customer needs, regulatory requirements and internal goals (Nyman 2004). ISO Standard 14001 defines an Environmental Management System (EMS) that addresses potential impacts on the environment (Nyman 2004).

“HACCP is a tool to assess hazards and establish control systems that focus on prevention rather than relying mainly on end-product testing” (WHO 1997). The application of HACCP in a systematic manner helps the water utility to identify hazards closer to the source of the hazard, thus minimizing the occurrence and effects of incidents that may impact the safety and quality of the water.

A quality assurance system such as HACCP could have helped to prevent the waterborne disease outbreak in Walkerton, Ontario, Canada where a breakthrough of E. coli O157:H7 and Campylobacter caused seven deaths and more than 2,300 cases of waterborne disease out of a town population of 5,000 (Hrudey and Walker 2005). The tragic event “…severely undermined the trust many Canadians had in their municipal water supplies…and also cost Ontario taxpayers hundreds of millions of dollars…The official inquiry into the events leading to the tragedy showed that if the system had been monitored properly and the operators had responded effectively to the signs of trouble, the severe outbreak would have been prevented or substantially reduced” (Hrudey and Walker 2005).

A HACCP system could also help prevent a loss of confidence in water supply safety from a suspected contamination incident. The Sydney Cryptosporidium contamination incident did not cause illness or death, but it affected 3.6 million consumers and had an estimated cost of about $15 million (US Dollars) (Chapman, Jayaratne, and Pamminger 2003), plus resulted in job loss for key utility personnel.

PURPOSE OF PROJECT

Since the mid-1990s, the HACCP system has been applied to a number of drinking water systems in Australia, New Zealand, and several European countries. The experiences of these water systems show that HACCP offers many benefits to a water system. The purpose of this


4

project was to further evaluate the application of HACCP in the drinking water industry to protect and maintain distribution system water quality. A second objective was to prepare guidance for water utilities to encourage broader application of HACCP. These guidelines include information on how to integrate the HACCP approach into existing utility practices.

RESEARCH STRATEGY

The approach used to meet the Project objectives consisted of five tasks:

• Task 1—Develop HACCP Model for Water Distribution Systems • Task 2—Conduct Peer Review of HACCP Model • Task 3—Pilot Test HACCP System • Task 4—Integrate HACCP System With Existing Practices • Task 5—Prepare Project Deliverables.

In Task 1, a tailored HACCP system was developed specifically for water distribution systems. This tailored plan was primarily based on water industry experiences in Australia applying HACCP to individual water systems. Other key sources of information included the WHO drinking water guidelines, HACCP applications in water-related food industry sectors (aquaculture, bottled water, and packaged ice), and New Zealand water industry and regulatory sector experiences.

In Task 2, the draft HACCP plan for distribution systems was subjected to peer review. Reviewers included water utilities and regulatory agencies with experience of applying HACCP to water supplies. Specifically, the review was undertaken in consultation with:

• The five HACCP-certified participating utilities of the Australian Cooperative Research Center for Water Quality and Treatment (CRCWQT);

• Regulators with experience regulating through HACCP approaches (New Zealand Ministry of Health, South Australian Department of Human Services and Victorian Department of Human Services); and

• Researchers with experience developing HACCP-based systems (Monash Medical School, Melbourne).

In Task 3, the tailored HACCP system was to be pilot tested by four participating utilities including Sydney Water Corporation in Australia, Power and Water Corporation in Australia, the City of Austin, Texas, and the South Berwick Water District in Maine. A training workshop was held at each utility location so that the Project Team could train utility staff on the HACCP approach, and to initiate development of the utility’s HACCP plan. Each participating utility formed a HACCP team to further develop the HACCP plan and to guide its implementation. The goal was for each utility to implement their HACCP plan over a 12-month period during which certain operational and water quality parameters would be monitored.

In Task 4, the Project Team used findings from the first three tasks to formulate guidelines on developing and implementing HACCP Plans, and integrating the HACCP approach with current practices. Current practices for distribution system protection include sanitary surveys, water quality monitoring programs, an Emergency Operations Plan, standard operating procedures, ISO 9000 series quality system certification, QualServe activities, and daily operational procedures. Additional guidelines and feedback on HACCP implementation


5

was prepared in the form of utility case studies which captured the experiences of utilities that have operated with certified HACCP systems in place for several years (Chapter 5).

In Task 5, the Project Team prepared periodic reports to document progress and solicit input from both AwwaRF and the Project Advisory Committee (PAC) throughout the course of the project. These periodic reports included interim work products, status reports, responses to PAC comments, and reports on the project team’s outreach activities.

USE OF REPORT

This report may be useful to water utilities that are considering whether or not to apply the HACCP system to their distribution system. These readers are referred to the following chapters:

• In Chapter 2, background information on HACCP and current applications are described.

• In Chapter 3, the reader will find guidance on how to implement HACCP including resource requirements, the need for supporting utility programs, and standard operating procedures.

• In Chapter 4, short-term pilot-studies (12 months duration) evaluate HACCP based on six different categories: costs and benefits, regulatory compliance, customer satisfaction, risk management, system management, and human factors.

• In Chapter 5, several case studies from HACCP-certified utilities in Australia evaluate HACCP based on the same criteria as the pilot studies in Chapter 4. These case studies also provide insight into the challenges of implementing HACCP.

For water utilities that are ready to start applying HACCP to their water distribution system, this report presents a tailored HACCP system that can be used as a starting point for any distribution system. The reader is referred to Chapter 3 where detailed step-by-step instructions explain how to develop a HACCP plan. Example workshop training materials are provided in Appendix A. Example HACCP Plans for the four participating utilities are provided in Appendix B. Pilot study reports can be found in Appendix C. Appendix D contains Management Plans Sydney Water developed as part of the utility HACCP process.

For industry researchers that are interested in furthering the knowledge and applications potential for HACCP in drinking water systems, research needs are outlined in Chapter 6.

WATER QUALITY FRAMEWORK

It is important to recognize that water utilities operate within a very broad regulatory and operational framework that collectively contributes to, and controls, the safety and quality of drinking water produced. The term “Water Quality Framework” is used here to refer to this overall framework within which water safety/quality is both regulated by the government and managed by utilities and their contractors. Within this Framework is a Water Quality Management Plan that is specifically concerned with the operational management by the water utility and its contractors. The Water Quality Management Plan serves as a road map, linking the HACCP Plan with existing supporting programs and demonstrating that there has been a cross-checking and augmentation of existing organizational risk and quality management


6

systems. The interrelationships of these elements within the overall Framework are illustrated in Figure 1.1.

CCPs = critical control points

Figure 1.1 Illustration of HACCP Plan as integral part of Water Quality Framework


7

CHAPTER 2 INTRODUCTION TO HACCP

BACKGROUND

In 1959, the National Aeronautics and Space Administration (NASA) was planning for manned space missions and was concerned about possible contamination of the astronauts’ food from “…potentially catastrophic disease-producing bacteria and toxin” (NASA 1991). To solve this problem, NASA enlisted the help of the Pillsbury Company to develop the HACCP concept “…to establish control over the entire process, the raw materials, the processing environment and the people involved” (NASA 1991). The Pillsbury Company developed the basic HACCP concepts with cooperation and participation from NASA, the Natick Laboratories of the US Army, and the US Air Force Space Laboratory Project Group (Mucklow 1997).

Since the 1980’s, the HACCP system has been widely adopted by the food and beverage industries world-wide where it forms an important part of their “food safety plans.” Quality assurance systems incorporating HACCP principles have become the benchmark means to assure food and beverage safety since its codification in 1993 by the United Nations Food and Agricultural Organization (FAO) and WHO (Deere and Davison 1999). In 1996, the US Food and Drug Administration (FDA) and the US Department of Agriculture Food Safety and Inspection Service (FSIS) promulgated regulations requiring the use of HACCP in the seafood, red meat, and poultry industries. The WHO guidelines for HACCP, known as Codex Alimentarius, have been adopted internationally as the primary recognized food safety methodology for risk management. The current HACCP guideline was developed in 1997 by the Codex Alimentarius Commission (http://www.who.int/foodsafety/codex/en), an inter-governmental body established to implement the Joint FAO/WHO Food Standards Program.

By helping to improve food production processes to prevent contamination, the HACCP system can reduce or prevent the occurrence of food borne illnesses. In October 2003, the FDA/FSIS reported four consecutive annual drops in human Listeria infection and a 70 percent decline in positive food samples compared with years prior to HACCP implementation (Fok and Emde 2004).

The bottled water industry employs additional measures beyond regulatory requirements to help ensure the safety and quality of bottled water beginning with the source through packaging. Bottler members of the International Bottled Water Association (IBWA) must adhere to the IBWA Model Code (available at www.bottledwater.org), which requires members to develop a HACCP program for each of their facilities. The HACCP program requirement further ensures food safety and security within the production facility. The IBWA Model Code is, in several cases, more stringent than state and federal regulations and has been adopted by more than a dozen states as their standard for regulation of bottled water. At the federal level, bottled water is regulated as a packaged food product, governed by the FDA through the Food, Drug, and Cosmetic Act. At the state level, bottled water is regulated in myriad ways, typically through state environmental, food, or agricultural agencies.


8

THE HACCP SYSTEM

The Codex Alimentarius Commission defines 12 sequential steps for planning and implementing a HACCP system. The information prepared in completing these 12 steps constitutes the utility’s HACCP Plan. These steps are summarized below:

Step 1 – Assemble HACCP Team - Pull together a multidisciplinary team to prepare, develop, verify, and implement the plan. Step 2 – Describe Drinking Water - Describe the utility’s drinking water, including its source, treatment, storage, distribution and any existing standards for quality and safety. Step 3 – Identify Intended Use - Describe how the drinking water is used and the major users. Step 4 – Construct Flow Diagram - For a comprehensive HACCP plan, this would be a schematic showing sources of water, details of treatment, storage, pumping, and distribution to end users. For a HACCP plan directed towards a distribution system, the schematic would be restricted to showing the water flow path from the treatment plant to end users. Step 5 –Confirm Flow Diagram – Since the flow diagram is a critical element used as a basis for the HACCP plan, its accuracy should be confirmed by the HACCP team. Step 6 - Conduct a Hazard Analysis - Using the process flow diagram, identify hazards, their likelihood of occurrence, potential consequences, and control measures. Step 7 – Determine the Critical Control Points (CCPs) - For each significant hazard, identify points in the process where the consequences of failure are irreversible. Step 8 – Establish Critical Limit(s) - Determine critical limits for the CCPs that will trigger a corrective action. A critical limit is a criterion which separates acceptability from unacceptability. Step 9 – Establish a System to Monitor Control of the CCPs - Establish monitoring points, frequency, and responsibility. Step 10 – Establish Corrective Actions - Develop plans for follow-up activity when critical limits are exceeded. Step 11 – Validate/Verify HACCP Plan - Have the HACCP team and other affected parties check the HACCP plan for accuracy, ability to implement, and potential effectiveness. Step 12 – Establish Documentation and Recordkeeping - Develop a record keeping system to track system performance at CCPs.

These steps of HACCP are discussed in more detail in Chapter 3 as applied to a tailored HACCP plan for water distribution systems.

HACCP IN DRINKING WATER REGULATIONS AND GUIDELINES

In 2004, the WHO issued the 3rd edition of its drinking water guidelines that outline a framework for drinking water safety based on the multiple barrier approach and several risk management and quality management approaches including the HACCP principles (Davison and Bartram 2004). The WHO framework has three main components: health-based water quality targets based on public health protection and disease prevention; a Water Safety Plan as described below; and independent surveillance activities including audits of the Water Safety


9

Plan and final checks on the finished drinking water. WHO recommends that water suppliers develop a Water Safety Plan that documents the following major elements:

1. A source-to-tap system assessment that determines whether a water system can deliver water meeting certain water quality targets;

2. Control measures for identified hazards and operational monitoring of control measures; and

3. A management plan that documents the system assessment, control measures, the monitoring plan, corrective action procedures to address water quality incidents, communication plan, and supporting programs such as standard operating procedures (SOPs), employee training, and risk communication.

The 2004 Bonn Charter for Safe Drinking Water complements the WHO guidelines in providing international guidance on drinking water quality management (Breach 2004). This Charter is the end-product of two expert workshops held in Bonn, Germany in October 2001 and February 2004, and is applicable to all water systems worldwide. The Charter’s key principles include the following (Breach 2004):

1. Good, safe drinking water can only be provided reliably and consistently through an integrated, source-to-tap approach.

2. The integrated approach requires close cooperation and partnerships among governments, water suppliers, health agencies, environmental agencies, land users, contractors, plumbers, consumers, and manufacturers of materials, products, and devices used in the water supply system (Breach 2004).

3. Traditional verification of drinking water quality based on measurement of various parameters against predetermined standards or guidelines will continue to play a critical role in ensuring drinking water quality. In the future, there should be much greater emphasis on use of preventative, risk-based management control systems.

4. The quality assurance process and derivation of specific standards need to be transparent to assure consumer confidence.

5. The standards used to measure water quality and safety can legitimately vary between different countries and regions depending on local circumstances. However, these standards should ensure the provision of water that has the trust of consumers, is affordable, and meets the following minimum criteria (Breach 2004): a) Does not pose a health threat to consumers; b) Is acceptable to consumers in terms of taste, odor and appearance; and c) Is reliable in terms of both quality and quantity.

6. Effective approaches to managing drinking water quality rely on an interlinked set of processes which must involve the following three elements (Breach 2004): a) Establishment of clear responsibilities and institutional arrangements for the different

stakeholders. b) Implementation of effective control systems directed to identifying and managing

risks, thereby mitigating their impacts (Drinking Water Quality Management Plans). c) Assessment of compliance against the necessary minimum standards for drinking

water quality (verification).


10

7. A Drinking Water Quality Management Plan that includes the following three elements (Breach 2004): a) A system-wide, risk-based assessment of safety from source-to-tap; b) Identification of the most effective control points to reduce the risk; and c) Effective systems and operational plans to deal with both routine and abnormal

operating conditions. Countries which use WHO guidelines as the minimum criteria for water system

regulation will need to recommend or require that water utilities develop Water Safety Plans. In several countries, HACCP principles are being incorporated into national guidelines and standards as summarized in Table 2.1.

Table 2.1 HACCP programs for controlling public health risks in drinking water

Country/ Organization

Regulation or Regulatory Guideline

Website for current information

Reference

WHO Guidelines for Drinking Water Quality (3rd Edition)

www.who.int/water_sanitation_health/dwq/guidelines2/en/

Davison and Bartram (2004)

Australia Framework for Management of Drinking Water Quality (Guideline)

www.nhmrc.gov.au/publications/synopses/eh19syn.htm

Cunliffe (2004)

New Zealand Public Health Risk Management Plans (Proposed regulation)

www.moh.govt.nz/water Select “publications” then “Public Health Risk Management Plans”

Nokes (2001)

W1002 Regulatory guideline: Recommendations for a Simple Quality Assurance System for Water Supplies (Guideline)

www.svgw.ch (German, French and Italian only)

Swiss Gas and Water Industry Association (2003)

Switzerland

Hygiene Ordinance (SR 817.051, HyV), Article 11 (Regulation)

www.svgw.ch (German, French and Italian only)

Bosshart (2003)

France French National Transcription: Decree 2001-1220 (Dec. 20, 2001) Water Safety for Human Health, Risk Assessment and Management; Article 18-2 (Regulation)

None found Metge (2003); DeBier and Joret (2004)

Ontario, Canada Province-wide initiative; Water quality management system based on HACCP, ISO 9001, and ISO14001 (Guideline)

None found Kuslikis and White (2004)


11

The 2004 revision of the Australian Drinking Water Guidelines includes the “Framework for Management of Drinking Water Quality” which is intended to provide guidance on establishing preventive, source-to-tap risk management systems for drinking water quality (National Health and Medical Research Council and Natural Resource Management Ministerial Council 2004). These guidelines are not mandatory or legally enforceable standards. In Australia, drinking water is regulated by State health agencies. In 2003, the State of Victoria (Australia) introduced legislation, the Safe Drinking Water Act of 2003, requiring that all water utilities implement a risk management plan based on the Framework (Cunliffe 2004). The requirements of this Act are primarily addressed by implementing a HACCP Plan.

The Australian Framework has been designed to reduce the reliance on compliance monitoring as the primary means for managing water quality, and instead promotes monitoring as a verification tool for assuring that preventive measures are working effectively. “The Framework was derived by supplementing the information on preventive system management already provided in the Australian Drinking Water Guidelines with principles described in existing quality management systems such as ISO 9001 (Quality Systems), ISO 14001 (Environmental Management Systems), Australian and New Zealand Standard (AS/NZS) 4360 (Risk Management) and the HACCP system” (Cunliffe 2001) The Framework includes twelve main elements (Cunliffe 2004):

1. Commitment to Drinking Water Quality Management; 2. Assessment of the Drinking Water Supply System; 3. Planning-Preventive Strategies for Drinking Water Quality Management; 4. Implementation-Operational Procedures and Process Control; 5. Verification of Drinking Water Quality; 6. Incident and Emergency Response; 7. Employee Awareness and Training; 8. Community Involvement and Awareness; 9. Research and Development; 10. Documentation and Reporting; 11. Evaluation and Audit; and 12. Review and Continual Improvement.

In New Zealand, new legislation amended the Health Act of 1956 to require water

suppliers to develop a so-called “Public Health Risk Management Plan” (Nokes 2001). To assist water suppliers in developing and implementing this Plan, the Ministry of Health has prepared a series of guides that are based on the risk management framework contained in AS/NZS 4360:1999 (Standards Australia/Standards New Zealand 2004) and HACCP methodology (Codex Alimentarius Commission 1993). These guides contain the following information:

• Potential problems during different processes and operations that might allow contaminant intrusion;

• Corrective actions when contamination occurs; and • Preventive measures to reduce the likelihood of the problems recurring.

A separate booklet discusses the overall approach to developing and implementing a Plan as outlined in Table 2.2 (Ministry of Health 2001).


12

Table 2.2 New Zealand approach for preparing Public Health Risk Management Plans

Step No. Description

Contribution to the Public Health Risk Management Plan

1 Identify the elements in the supply and the PHRMP* Guidelines needed.

Flow diagram of the supply

2 Identify which barriers to contamination are present.

Check-list of barriers present in the supply

3 Identify events that may introduce hazards into the water.

4 Use the Guides to identify: • Causes • Preventive Measures • Corrective Actions

Risk information table for the supply overall

5 Decide where improvements should be made

6 Decide on the order in which improvements need to be made

7 Draw up a timetable for making the improvements

Improvement Schedule • Improvements needed • Levels of importance • Timetable • Responsibilities

8 Identify links to other quality assurance systems

Note of other quality assurance systems

9 Prepare contingency plans

Contingency plans for each supply element

10 Prepare instructions for Performance Assessment of the Plan

Set of instructions for review of the performance of the PHRMP*

11 Decide on communication policy and needs

Set of instructions for reporting

Source: Ministry of Health (2001) *PHRMP – Public Health Risk Management Plan

In Switzerland, Article 11 of the hygiene regulation (SR 817.051, HyV), requires

application of the HACCP principles. A regulatory guideline (W1002) entitled “Recommendations for a Simple Quality Assurance System for Water Supplies” has been prepared to assist water utilities in complying with this requirement. The regulatory guideline recommends the following nine-step approach (Swiss Gas and Water Industry Association 2003):

1. Organization, Responsibilities, and Expertise; 2. Survey of the Water Supply (develop process flow diagram); 3. Assessment of the Water Supply (evaluate hazards, list critical points); 4. Elimination of Hazards (Critical Points);


13

5. Reduction of Hazards by Maintenance; 6. Control of Hazards (Critical Points); 7. Practical Implementation of the Instructions; 8. Annual Evaluation of the Water Supply; and 9. Confirmation of Self-Assessment by Third Party.

In France, Article 18-2, Optimization of Monitoring, of the French National Transcription: Decree 2001-1220 (Dec. 20, 2001) entitled Water Safety for Human Health, Risk Assessment and Management requires risk assessment, identification of CCPs and control measures.

In Ontario, Canada, the Ontario Ministry of the Environment is currently developing a Water Quality Management Standard as a result of the Walkerton tragedy and the follow-up investigation. A province-wide initiative has resulted in the development of an integrated risk management system based on HACCP, ISO 9001, and ISO 14001 (Kuslikis and White 2004). The system is being employed in a number of cities and municipalities at water treatment facilities, wastewater treatment facilities, solid waste facilities, and engineering facilities. Several reasons given for employing such an initiative include (Kuslikis and White 2004):

• To promote water quality excellence to the public; • To secure knowledge potentially lost with retiring employees; • To satisfy a need for consistent application of best practices and continual

improvement; and • To supplement end product failure testing with a quality assurance system/quality

control system.

HACCP APPLICATIONS IN THE WATER INDUSTRY

Bryan (1993) and Havelaar (1994) first introduced the idea of applying HACCP to drinking water systems. Bryan (1993) presented the HACCP approach as a way to improve water treatment processes to reduce the occurrence of waterborne disease. He also noted the need to address distribution system inadequacies (e.g. ingress from contaminated surface water or sewage if the distribution system is poorly maintained) that could affect the quality of finished water. However, Bryan (1993) cautioned that the use of HACCP for the water industry was limited for a number of reasons:

1. The structure, equipment and cleaning standards may be inappropriate. 2. Effective communication may be lacking, preventing swift action when a problem

occurs. 3. The appropriate corrective actions may not be clearly documented. 4. The causative agent of waterborne disease outbreaks cannot always be isolated from

either the water supply or the human case due to the lack of analytical methods for many pathogenic viruses and other microorganisms associated with drinking water samples. Most existing analytical methods do not utilize on-line technologies, preventing an instantaneous reaction to failure. This can be addressed by monitoring physical parameters to control critical points (e.g. monitor particle counts to assess the presence of Cryptosporidium oocysts).


14

5. If HACCP is applied only to treatment facilities and not the distribution system, it may not prevent a waterborne disease outbreak caused by distribution system inadequacies.

Havelaar (1994) examined the applicability of HACCP to drinking water supply with a focus on microbiological contaminants. He introduced a generalized HACCP analysis for drinking water production, including source, treatment and distribution process steps, listing typical hazards, preventive measures, CCPs, monitoring procedures, and corrective actions. Havelaar (1994) noted that a key issue is properly identifying the CCPs (i.e. those points within the system or its operation whose disruption or failure would result in a greater public health risk compared to other points) because the major efforts in process control will be directed towards these steps. In many food operations, the heating step or another single step is the major barrier to pathogens. In water systems, multiple steps should be considered as CCPs because a multiple barrier approach is used to control microorganisms (e.g. source protection, filtration, and disinfection).

Since the mid-1990’s, HACCP has been applied by a number of individual drinking water systems. Several water utilities in Australia have independently audited, certified HACCP systems: South East Water, Yarra Valley Water, Melbourne Water, Brisbane City Council, and Gold Coast Water. In Iceland, Reykjavik Energy has been utilizing an accredited HACCP system since 1997 for its water works (Gissurarson 2004). In France, Veolia Water has implemented a new comprehensive management system based on HACCP at 40 different water production/water distribution systems (DeBier and Joret 2004). In Ontario, Canada, several municipalities and cities are developing and implementing an integrated risk management system based on ISO 9001, ISO 14001, and HACCP (Kuslikis and White 2004). Smaller systems have applied HACCP principles too, such as the councils in the Australian State of New South Wales and small supplies in New Zealand.

Watershed Protection

The HACCP system may be used to improve how a utility’s watershed management program is structured. For example, a successful HAACP Plan was implemented by San Francisco to address the concern that livestock may be a primary source of Cryptosporidium parvum (Barry et al. 2004). The utility was looking for a solution focused on preventive measures and one that provided a systematic approach that could be duplicated throughout the watershed. The HACCP Plan identified five management areas to control waterborne pathogens in the watershed – feral pig management, livestock/grazing, wildlife management, human/ recreation management, and treatment plant management. For each management area (except the treatment plant), the Plan identified CCPs, management measures, monitoring, critical limits, corrective actions, and record-keeping needs. San Francisco’s HACCP Plan was also expanded to control physical hazards in the watershed, such as sediment.

Hazards in the watershed may stem from recreational activities, urban storm water systems, animal feed lots, and/or licensed discharges, such as discharges from sewage treatment plants (Deere 2004). Hazards may be considered in two separate categories – those that will be significantly reduced by treatment downstream (e.g. bacterial pathogens if disinfection is practiced) and those that will not be significantly reduced by treatment (e.g. pesticides if ozone/carbon treatment is not utilized) (Deere 2004).


15

The HACCP system may improve existing watershed management programs through its emphasis on feedback loops in monitoring, corrective actions, and documentation. Monitoring activities in watershed management programs include inspections as well as water quality testing. For example, a control measure for the livestock “hazard” may be to install fencing to keep animals away from the water supply reservoir. To determine if this control measure is effective, the utility may opt to inspect the fencing on a weekly basis to make sure it is intact. When an inspection is not completed according to the frequency specified in the HACCP Plan, or when the inspection identifies problems, corrective actions must be taken (as specified in the Plan). The HACCP Plan includes provisions for documenting these corrective actions and follow-up monitoring or inspection activities to assure that the problems are followed through to a resolution.

Havelaar (1994) presents a generalized application of HACCP to water system processes associated with the source of supply, as summarized in Table 2.3. For each process step (e.g. groundwater abstraction), typical hazards, preventive measures, monitoring procedures, and corrective actions are summarized.

Table 2.3 Generalized HACCP analysis of source of supply

Hazards Preventive measures

Critical control point

(CCP)? CCP

parameters Monitoring procedures

Corrective actions

Process step – groundwater abstraction Transport of pathogens to wellhead

Define protection zone around well and restrict land use

Yes Traveling time Tracer injection studies, specific pathogens, fecal index bacteria

Remove sources of pollution

Ingress of pathogens through well casing

Proper construction and maintenance

Yes Adhere to good engineering practices

Inspection, fecal index bacteria

Instruction/re-construction

Process step – bank infiltration Transport of pathogens to wellhead

Define minimum traveling time and/or distance

Yes Site-specific Tracer injection studies, specific pathogens, fecal index bacteria

Replace abstraction wells, increase treatment

Ingress of pathogens through well casing

Proper construction and maintenance

Yes Adhere to good engineering practices

Inspection, fecal index bacteria

Instruction/re-construction

(Continued on next page)


16

Table 2.3 Generalized HACCP analysis of source of supply



(CCP)? CCP

parameters Monitoring procedures

Corrective actions

Process step – surface water abstraction Contamination by fecal discharges

Reduce point and diffuse pollution sources

No Fecal index bacteria, specific pathogens, turbidity

Increase treatment

Multiplication of pathogens

Control eutrophication, thermal discharges, residence time of water

No Not applicable

Process step – storage of surface water in reservoirs Short circuiting Build reservoirs

in series No Tracer studies,

conservative parameters, fecal index bacteria

Increase treatment

Recontamination by feces of wildlife

Discourage presence of wildlife

No Specific pathogens

Source: Adapted from Havelaar (1994). Reprinted from Food Control, Vol. 5 No. 3, Havelaar, Application of HACCP to Drinking Water Supply, pp.145-152, 1994, with permission from Elsevier.

Treatment Facilities

Smith (2004) found that implementing HACCP for treatment systems at Gold Coast Water in Australia was a “…relatively simple matter.” Fok and Emde (2004) state that water treatment plants are ideally suited for implementing HACCP because these facilities typically employ a single process train with a single end-product. Typical hazards, preventive measures, monitoring procedures, and corrective actions are summarized in Table 2.4 (Havelaar 1994).

(Continued)


17

Table 2.4 Generalized HACCP analysis of treatment process



(CCP)? CCP parameters Monitoring procedures

Corrective actions

Process steps – pretreatment, coagulation/flocculation/sedimentation/filtration Poor floc formation, poor floc removal, filter defects

Increase coagulant dose, add coagulant aid, regular backwashing and cleaning, first filtrate after backwash to waste

Yes Turbidity, particle counts, pressure loss

On-line monitoring

Increase disinfection

Process step – disinfection Survival of pathogens

Optimize dose and contact time of disinfectant

Yes Residual concentration of disinfectant (may vary during the year), pH, temperature, bacteriological indicator organisms

On-line monitoring

Automatic feedback system

Formation of disinfection by-products

Optimize dose and contact time of disinfectant

Yes Residual concentration of disinfectant (may vary during the year), pH, temperature

Modify target dose/residual


Water Distribution Systems

The HACCP model may be applied to water distribution systems to prioritize CCPs and focus the system operator’s resources on these locations and processes (Sobsey et al. 1993; Bryan 1993; Deere and Davison 1999). Typical hazards, preventive measures, monitoring procedures, and corrective actions are summarized in Table 2.5 (Havelaar 1994).


18

Table 2.5 Generalized HACCP analysis of water distribution systems



(CCP)? CCP parameters Monitoring procedures

Corrective actions

Recontamination from cross-connections and storage facilities

Adequate construction; positive pressure at all times

Yes Total coliform bacteria; system pressure; disinfectant residual

Frequent samples; testing of backflow prevention devices

Isolate part of system; rechlorination

Contamination at repair and construction sites

Sanitary practices during construction

Yes Adhere to sanitary practices

Inspection, sample

Flushing, disinfection, worker training, program assessment

Regrowth of opportunistic pathogens

Reduce residence time; reduce assimilable organic carbon and/or biofilm potential

Possibly, system

dependent

Disinfectant residual, total coliform bacteria, assimilable organic carbon, water temperature

Frequent monitoring

Flushing, disinfection, treatment optimization, reduce water age


Other Applications in the Water Industry

The Capitol Health region in Edmonton, Alberta, Canada used HACCP principles to develop a new boil water advisory protocol in 1998 (Fok and Emde 2004). “The use of the HACCP process resulted in a better understanding of monitoring parameters and fostered communication and understanding between…[the health department and the water utility]” (Fok and Emde 2004).

SUMMARY

The HACCP concept was first developed in 1959 by the Pillsbury Company to improve food safety for NASA’s manned space missions. Since the 1980’s, the HACCP system has been widely adopted by the food and beverage industries world-wide where it forms an important part of their “food safety plans.” In the US, certain food production establishments such as seafood, red meat, and poultry industries are required by federal regulations to develop and implement a HACCP plan. The IBWA requires its members to develop a HACCP program for each of their facilities.


19

The current HACCP guideline, developed in 1997, by the Codex Alimentarius Commission includes 12 sequential steps for planning and implementing a HACCP system. The information prepared in completing these 12 steps constitutes the utility’s HACCP Plan.

HACCP has been incorporated in many drinking water regulatory requirements and guidelines around the globe. In 2004, the WHO issued the 3rd edition of its drinking water guidelines that outline a framework for drinking water safety based on the multiple barrier approach and several risk management and quality management approaches including the HACCP principles (Davison and Bartram 2004). Countries that use WHO guidelines as the minimum criteria for water system regulation will need to recommend or require that water utilities develop Water Safety Plans. In Switzerland, Article 11 of the hygiene regulation (SR 817.051, HyV), requires application of the HACCP principles. In New Zealand, new legislation amended the Health Act of 1956 to require water suppliers to develop a so-called “Public Health Risk Management Plan” (Nokes 2001).

Bryan (1993) and Havelaar (1994) first introduced the idea of applying HACCP to drinking water systems. Havelaar (1994) introduced a generalized HACCP analysis for drinking water production, including source, treatment and distribution process steps. This generalized analysis, focused on microbiological contaminants, listed typical hazards, preventive measures, CCPs, monitoring procedures and corrective actions, as summarized in Tables 2.3 through 2.5. Since the mid-1990’s, HACCP has been applied by a number of individual drinking water systems in Australia, France, Canada, and New Zealand, amongst others.


20


21

CHAPTER 3 TAILORED HACCP GUIDE FOR WATER DISTRIBUTION SYSTEMS

INTRODUCTION

In Chapter 2, HACCP terminology and the 12 sequential steps for planning and implementing a HACCP system were introduced. The information prepared in completing these 12 steps constitutes the utility’s HACCP Plan.

The purpose of Chapter 3 is to provide a tailored HACCP manual to guide the production of a distribution system HACCP plan by a water utility. Although a utility could independently produce and implement a HACCP plan based on this report, training and coaching from people experienced in the application of HACCP to water is likely to greatly simplify this task.

Prior to initiating a HACCP Plan, a utility should complete the following tasks:

• Identify goals and expected benefits; • Estimate resource requirements; • Solicit employee support and commitment; • Conduct a HACCP training workshop; and • Identify and update supporting programs and practices.

These activities are discussed in the following introductory sections.

Identify Goals and Expected Benefits

Prior to initiating a HACCP Plan, it is important for the utility to decide on its overall goals for the program. This helps to focus resources most efficiently and to help sell the program to utility management, staff, and customers. The HACCP system may provide both tangible and intangible benefits to water utilities, including (Fok and Emde 2004; Davison and Deere 2004; Smith 2004; and Kuslikis and White 2004):

• Reduction in customer complaints; • Improved water quality; • Improved work processes, such as SOPs, monitoring strategies, documentation

procedures, and communication methods; • Improved understanding of risks and risk management; • Improved employee skills; and • Demonstration of due diligence.

Specific case study examples of these benefits are described in Chapters 4 and 5. For example, the City of Austin, Texas found that their HACCP pilot study helped improve employee skills and knowledge including:

• The need to respond quickly to main breaks in small pressure zones; • The location of pressure zone boundaries; • The possible occurrence of boundary zone violations;


22

• The possibility of pressure transients causing low or negative pressure in the distribution system;

• The need to maintain positive pressure at all times; and • The types of existing data sources.

Estimate Resource Requirements

The utility should estimate the resource requirements for implementing HACCP in their system, and make a firm commitment to providing these resources prior to initiating the process. This section summarizes resource needs identified by utilities that have implemented HACCP plans.

Gold Coast Water in Australia identified the need for a HACCP “champion” who is solely dedicated to administering the HACCP system. “The HACCP champion should have a background in chemistry and microbiology, plus experience in water industry processes” (Smith 2004). Gold Coast Water has not added any other staff to implement HACCP but has purchased additional instrumentation and increased water quality testing. Smith (2004) estimates a 4- to 6-week timeline for developing and implementing a HACCP system for a catchment, treatment, or distribution system with provided there are no existing fundamental flaws. However, the cultural change takes place gradually, over a longer period. The cultural change could take as long as 6 months (Smith 2004a). Other HACCP-certified water utilities in Australia also found that HACCP implementation required a full-time, dedicated coordinator or champion, for at least one month and up to twelve months, as summarized in Table 5.2.

Based on their experiences implementing HACCP in 45 water systems in France, DeBier and Joret (2004) estimate an average of 30 to 60 person-days to implement HACCP in one system (from the catchment to the customers’ taps).

Although staff will not be working full time on the HACCP plan for the whole implementation period, (with the possible exception of the HACCP Coordinator), key staff will need to be available to attend workshops, to discuss related policies/procedures/risk management issues, and possibly to develop improved risk management practices.

Some nominal allocation of resources is needed to cover issues that arise during HACCP implementation. For example, some risk assessment conclusions may be uncertain, requiring special investigations, professional services, laboratory testing, and/or procurement of new monitoring equipment; or standard operating procedures may need to be improved to reduce risks to acceptable levels. For example:

• ActewAGL in Canberra, Australia, identified that some of the spot-dosing chemicals being placed into service reservoirs did not have written statements saying they were intended for potable water use. An improvement action was raised whereby materials safety data sheets were obtained from the supplier to confirm that the chemicals were safe and intended for use in potable water systems. (Note: Actew AGL is owned by ACTEW, a government-owned corporation, and AGL, a private company. ACTEW is the asset owner and Actew AGL is the water supply system operator.)

• South East Water in Victoria, Australia, identified that it did not disinfect water mains after repairs, whereas some water authorities did. A special investigation was initiated to find out whether or not post-repair disinfection was required.


23

Importantly, the resource commitment needs to be made beyond the completion and implementation of the HACCP plan. Once in place, there is a need to occasionally update the plan as well as to maintain the organization’s focus on communicating the contents of the plan and complying with it in practice.

As discussed in Chapter 5, the resource needs for five HACCP-certified water utilities in Australia varied from $0 to $55,000 (US Dollars) for HACCP training, coaching, and technical advice, and from $0 to $84,000 (US Dollars) for annual costs, such as water quality monitoring and instrumentation.

Solicit Employee Support and Commitment

To foster employee empowerment and acceptance of HACCP, it is equally important to involve as many employees as possible, including staff with all levels of seniority. The regional municipality of Durham in Ontario, Canada recommends the following strategies to solicit employee support and commitment to HACCP (Kuslukis and White 2004): management support at all levels; top management commitment and participation; and involvement of all staff throughout the process.

Gold Coast Water has observed a progressive change in the organizational culture since implementing HACCP (Smith 2004). Operational staff members were consulted during development of the HACCP plan to identify realistic critical limits and monitoring procedures. Improved monitoring and reporting procedures implemented as part of the HACCP Plan have motivated operational staff to work harder to avoid failures (Smith 2004). Distribution system staff members now consider water quality impacts as part of the many activities they carry out. There is a high level of awareness that accountability is unavoidable and this drives ownership and involvement.

Senior management is intimately involved with the HACCP system at Gold Coast Water because all HACCP “excursions” (water quality or other incidents where critical limits are exceeded) are reported to managers for their information. Management can quickly review these excursion notices and decide if they represent minor incidents or if further inquiry is warranted. In the past, HACCP excursion reports have highlighted problems with staffing, training, asset condition, and system design.

Conduct a HACCP Training Workshop

Where HACCP is most widely used, in the food industry, it is normal practice to begin HACCP implementation by having a significant cross-section of utility staff formally trained in HACCP terminology and methodology. For the case studies referred to in this report, one- or two-day HACCP training courses were undertaken by utility staff. Example training workshop materials are provided in Appendix A. In addition, coaching was provided by people experienced in the practical application of HACCP to water distribution systems during the planning and implementation process. Yarra Valley Water, in Victoria, Australia, undertakes refresher HACCP awareness training each year and includes both contractor and utility staff in these sessions.


24

Identify and Update Supporting Programs and Practices

Water utilities have many different on-going programs and practices for assessing and correcting deficiencies and risks associated with drinking water supply. Such programs and practices may include:

• Vulnerability assessments; • Sanitary surveys; • Emergency response program; and • Compliance with AWWA distribution system standard.

Common features of these programs include (Cotruvo 2004): risk avoidance and recovery, comprehensive assessment, critical limits/targets, monitoring, plans, recordkeeping, verification/audit, and update/improvement. Some programs emphasize different elements (Cotruvo 2004). For example, the sanitary survey focuses on regulatory and sanitary deficiencies. Vulnerability assessments are primarily concerned with physical security threats.

Prior to initiating a HACCP Plan, it is important to identify these other programs that may contribute valuable information related to the condition of the distribution system and distribution system water quality. The distribution system HACCP plan may be integrated with these programs to avoid duplicative work. The programs may already exist in some form but may need improvement or augmentation. The AWWA Standard G200-Distribution Systems Operation and Maintenance provide specifications for distribution system programs and practices to maintain water quality. Compliance with this standard is recommended prior to implementing HACCP.

Many HACCP registrars (external auditors that provide third or second party certification to attest to the veracity of a HACCP plan) refer to these programs as “Prerequisite Programs” to indicate that their presence is in fact essential. In this report, we have used the term “Supporting Programs” rather than “Prerequisite Programs,” but the two are considered synonymous. In Table 3.1, examples are given based on WHO (1997) as well as programs identified on registrar checklists from organizations such as SAI Global, NATA Certification Services International, National Sanitation Foundation (NSF) International, and Lloyds Register.

Organizations that provide HACCP certification services will use the Codex approach as part of their certification criteria. However, different certification authorities and jurisdictions may require slightly different additional Supporting Programs to be in place. Therefore, a utility seeking certification for its HACCP system should check with their prospective registrar(s) at an early stage to find out what the requirements are in their jurisdiction.


25

Table 3.1 Examples of supporting programs

Program Description Example Management Programs

Organizational commitment

Staff from all levels of the organization commit to creating and implementing the HACCP plan and to the goals of reliably producing safe, quality water. Senior managerial staff, line supervisors, operations staff, and important contract workers need to collectively buy into this commitment.

Power and Water Corporation, Northern Territory, Australia, has a clear statement of commitment in its HACCP plan, signed by the General Manager for Water. Within the body of the HACCP plan the roles of key individuals in supporting and maintaining the HACCP plan are identified.

Compliance with regulations and guidelines

To help the organization consistently provide reliable, safe, quality water there needs to be a firmly reinforced organizational culture of complying with good operational practices and an intolerance of taking short cuts that lead to work not being performed in a sound and sanitary manner.

Utilities conduct water quality monitoring in the distribution system to comply with Federal Safe Drinking Water Act and State drinking water requirements. Regulations specify where monitoring must be performed, how often, and what laboratory analytical methods must be used.

Sanitary survey The sanitary survey is an external audit periodically conducted by an independent, qualified third party (e.g. a state primacy agency) to review a water system’s effectiveness in producing and distributing safe drinking water.

A sanitary survey of the drinking water distribution system of the District of Columbia was completed in 1995 to identify problems associated with bacteriological activity and to develop recommend-ations (International Studies and Training Institute, Inc. 1995). The survey found that the distribution system reservoirs had not been drained and inspected in approximately 20 years or more. Survey findings contained 185 recommendations addressing treatment practices, cross connections, distribution system O&M practices, consecutive systems, and operating proce-dures. Follow-up sanitary surveys were conducted in 1996, 1998 and 2002 to document progress on the original recommendations from the 1995 survey, and to identify any additional needs.

AWWA Distribution System Standards

AWWA Standard G200-Distribution Systems Operation and Maintenance (2004) describes critical elements for the operation and manage-ment of water distribution systems. Standard G200 emphasizes the need for specific water quality goals, action plans to respond to problems, and written SOPs.

Water quality requirements of the G200 Standard include: compliance with regulatory requirements; monitoring and control; disinfection residual maintenance; internal corrosion monitoring and control; aesthetic water quality parameters; customer relations; and system flushing.

Integrated management system (ISO 9000, ISO 14001 and HACCP)

Integrated management systems are becoming a new trend in the water industry where one quality assurance system covers all business management aspects, including general quality management (ISO 9000), protection of the environment (ISO 14001), drinking water safety to the user (HACCP), and worker health and safety. The benefit of implementing one integrated system is that only one audit would be required and utility staff will implement only one

In Ontario, Canada, a province-wide initiative has resulted in the development of an integrated risk management system based on HACCP, ISO 9001, and ISO 14001 (Kuslikis and White 2004).



26


Program Description Example set of policies and procedures (Deere 2005).

Data management and control systems

Key documents and records need to be controlled to help support continuous improvement and communication. It is important that the correct versions of operating procedures, checklists and data records are in use. This is simplified today since records and the management of records tends to be based on the use of electronic systems. However, for remote or field workers such systems may have little value and it is important to consider all areas.

South East Water, Victoria, Australia, uses an intranet-based system to support current versions of documents and records. An accountable officer is responsible for maintaining the accuracy of these records and updating them to reflect changed circumstances or to capture improvements. Staff unable to access the intranet system due to working at remote locations, are provided with controlled and registered hard copies of information that can be replaced if required and/or are trained to avoid the need for day-to-day reference to records.

Quality assurance and quality control program for professional services and purchased goods

Quality assurance of vendors and quality control of received goods are an important aspect of reducing the risk of water quality problems. These programs help to minimize contamination of materials and chemicals that come into contact with the drinking water.

Barwon Water, Victoria, Australia, screens suppliers of chemicals and materials and only uses approved suppliers. The suppliers need to describe the quality systems employed to protect product quality and must provide a written agreement that the product is suitable for potable water use. In addition, batches of chemicals are tested from time to time for chemical contaminants.

Legal requirements and best practice

Any legal requirements related to water quality should be complied and risks to breaching compliance are an important consideration in the HACCP plan. Furthermore, best practice and emerging understanding need to be taken into consideration and applied where practicable.

The City of Austin, Texas, maintains a record of the legal requirements related to water quality. The HACCP team identified water quality compliance requirements in its HACCP plan and included the possibility of breaches of these requirements as a risk factor in undertaking its risk assessment.

Operations Programs Distribution system operations

The organization needs to commit to developing and using operational procedures in a consistent and reliable manner. The purpose is to use the discipline of documentation to clarify what is expected and to enable peer review.

Sydney Water, New South Wales, Australia, has a quality management system (ISO 9001) in which key operational procedures are documented as SOPs. These SOPs are then cited in the HACCP plan to provide a point of reference for the agreed approach to undertaking important activities. When operational or other staff identifies opportunities to improve operational practices, the SOPs can be updated.

Emergency response program*

If there is a suspicion that the water might have become contaminated, even if that suspicion cannot be readily verified, the utility needs to be able to protect consumers from possibly being harmed by unsafe water. Therefore, a water quality incident response plan needs to be developed to identify how to protect consumers, dispose of suspect water and provide alternatives should an incident occur.

Sydney Water, New South Wales, Australia, has developed a water quality incident response plan in liaison with the health authority. The plan defines who will be responsible for notifying the public, which notification channels will be used, and how the utility will manage the incident to direct any suspect water away from customers and to provide alternative water supplies. Agreements are in place with water haulers and bottled water suppliers in case of such incidents.


(Continued)


27


Program Description Example Security/ vulnerability assessments

US federal legislation (H.R. 3448, the Public Health, Security, and Bio-terrorism Preparedness and Response Act. 2002), developed in response to recent terrorism events, mandated that water systems serving more than 3,300 people complete security vulnerability assessments and emergency operation plans. In these assess-ments, utilities evaluated the required level of physical security and how it will be integrated with existing operational activities.

One utility’s vulnerability assessment determined one significant threat was the intentional breach of physical security measures at the storage reservoirs. Key existing security measures included chain link perimeter fencing topped with barbed wire, locked security gates, traditional raised ladder access to the reservoirs and standard vents. Recommended security enhancements included improved surveillance, im-proved ladder access protection, and replacement of the existing vents with a more secure design.

Maintenance Programs Valve and hydrant inspection programs

In the event of a water quality incident in the distribution system, the water utility needs accurate information on the location and conditions of all system valves and hydrants. This enables operations staff to quickly isolate the area of the system experiencing a water quality problem and to efficiently remove poor quality water by flushing, if required.

ActewAGL, Canberra, Australia, has a valve-checking program where major divide valves are checked every three years to ensure that the distribution system zoning assumptions are accurate. In addition, records are kept to show when tanks are bypassed and any zoning changes are made.

Finished water storage facility cleaning program

Finished water storage facilities should be cleaned on a regular schedule to minimize water quality deterioration.

The Southern California Water Company established a district-wide reservoir cleaning program in 1995 to control algae and sediment build-up in several reservoirs (Kirmeyer et al. 1999).

Water main flushing program

A water main flushing program helps to keep the system clean and free of sediment, to remove stagnant water, and to remove any untreated or contaminated water that enters the system (Kirmeyer et al. 2000).

The Los Angeles Department of Water and Power implemented a focused flushing program to improve water quality with respect to secondary drinking water standards and to reduce customer complaints (Kirmeyer et al. 2000).

Sanitary procedures (SSOPs†)

Water supply systems need to be kept clean and this involves both scheduled cleaning of mains and water tanks as well as ensuring that when work is done on the system, the activity does not present an additional risk to water quality. The nature of any cleaning agent used needs to be considered as do risks from workers and equipment that may have become contaminated by working on sewer spills.

South East Water, Victoria, Australia, employs contractors to undertake tank and mains cleaning activities. Divers that clean tanks wear contained suits that are sanitized prior to use. When water mains are repaired, the work is done in a pumped-out trench to keep dirt out of the opening and high velocity flushing is used to clear any debris once the repair is made. Water and sewer trucks and pumps are kept separate to reduce cross-contamination risks.

Vermin control Rats, mice, lizards, frogs, roaches, and birds can all carry bacteria and there have been some examples of waterborne disease outbreaks aris-ing where one or more of these animals was thought to have caused contamination via water tanks. Therefore, minimizing their presence around water assets is important.

Power and Water Corporation, Northern Territory, Australia, keeps reservoirs roofed to keep out birds and other vermin. Gaps in hatches and vents are protected using features such as spikes and mesh to prevent or discourage bird and animal habitation. Branches are kept clear from overhanging tanks to reduce access to those tanks and reduce droppings.


(Continued)


28


Program Description Example Training and Certification Programs Employee training programs

Utility staff and any contractors employed to work on the system need to be experienced and adequately trained for their specified activities. The training needs to include water quality and public safety, security, employee ethics, sanitary procedures, hydraulics, water sampling proced-ures, and orientation for new staff.

Water utility employees need to understand the hydraulic flow paths in a distribution system in order to properly protect water quality, and to help protect consumers if water quality problems are suspected.

Operator certification program

The 1996 Amendments to the Safe Drinking Water Act requires that all operators of public water systems be certified.

ActewAGL, Canberra, Australia, has a competency system whereby qualified assessors certify the competency of staff for specific tasks following demonstration of that competency through a practical demonstration. Until certified as competent for a particular task, a staff member is not permitted to work unsupervised on that task.

Community programs Community awareness

The community needs to be made aware of how to properly use and handle water. The import-ance of backflow prevention and of proper management of water extracted from hydrants by water carriers are examples of the types of issues that require community education.

Sydney Water, New South Wales, Australia, manages a backflow prevention program in which the importance of preventing backflow of hazardous substances into the distribution system is communicated through training and awareness campaigns. User-friendly, illustrated education material is produced and distrib-uted via the internet and directly.

Customer relations

If customers notify the utility of poor water quality then, by definition, there could be a problem with the water quality for which the utility is accountable. It’s possible the problem arises in the customer’s own plumbing system but as a precaution, the underlying cause of water quality complaints needs to be investigated and future recurrences prevented through systematic changes.

South East Water, Victoria, Australia, has a database of all customer complaints and sends out field staff to investigate any complaint not readily resolved by a simple flush of an outside tap or that cannot be resolved over the telephone. The duty officer is notified of clusters of water quality complaints in any one location to enable a full investigation to take place to see what could have caused the problem and to look at making changes to prevent future, similar problems.

* HACCP registrars tend to refer to “Product Recall” procedures but for water utilities shutting off supply completely is often not appropriate due to the vital importance of sanitation and industrial uses. Therefore, water utilities tend instead to adopt a more complex response. † HACCP registrars often refer to these as ‘Sanitation Standard Operating Procedures” (SSOPs) to refer to the SOPs that are in place to document the way that the organization ensures its operations do not introduce hazards.

HACCP registrars unfamiliar with the water industry but familiar with certain sectors of

the food, beverage, pharmaceutical, and medical products industries often refer to “Good Manufacturing Practice” (GMP) and “Good Hygiene Practice” (GHP) as part of the Supporting Programs of a HACCP program (WHO 1997). This can cause confusion since GMPs have a specific meaning in an increasing number of industries and relate to certain manufacturing requirements for some types of foods, beverages, drugs, and medical products as required by the FDA in the U.S. Registrars may need educating in the regulatory requirements for the water industry since the term “GMP” is not used in the water sector outside of the packaged (bottled) water products industry and the EPA, not the FDA, is the principal regulatory agency in the U.S. Referring to how the utility meets both the EPA and state requirements for safe production of

(Continued)


29

water acceptable to consumers is the best way to explain how the water industry undertakes something analogous to GMP.

In general, Supporting Programs are formalized and are subject to review and audit as part of the HACCP plan. Very often, SOPs are developed to formally capture Supporting Programs as well as other aspects of the HACCP plan. Each SOP should detail its owner (the position responsible for its maintenance and communication), its objective, the procedures, corrective actions required if the procedures are not followed, and any reporting activities. Examples of specific SOPs for the water distribution system may include:

• Water quality sampling procedures; • Monitoring procedures during flushing; • Sanitary procedures to apply during operations such as disinfection before returning

facilities to service after maintenance (see also Sanitation Standard Operating Procedures (SSOPs) in Table 3.1);

• Calibration procedures for on-line monitoring devices in the distribution system; • Specifications for chemicals and raw materials; • Security procedures for restricting entry of unauthorized personnel; • Maintenance procedures for operational equipment; and • Designation of equipment as restricted to use on the water system.

Gold Coast Water, Queensland, Australia has developed a number of SOPs to support their HACCP Plan. SOPs for the distribution system include:

• Distribution water quality analysis and interpretation; • Investigation of dirty water complaints; • Reservoir inspections; and • Rechlorination of reservoirs.

APPLYING HACCP TO WATER DISTRIBUTION SYSTEMS

Each of the twelve steps in developing a HACCP system is explained in detail in the following sections. Specific examples from Project pilot studies and case studies from the water industry are cited where appropriate. The reader is also referred to the utility HACCP Plans in Appendix B and the utility case studies in Chapter 5 for additional examples.

Step 1: Assemble HACCP Team

The HACCP team is responsible for the planning, development, verification, and implementation of the HACCP system. A team that can collectively provide a broad range of expertise, experience, and skill in all relevant areas of the water distribution process needs to be assembled to develop the HACCP plan. Members of the team should therefore come from across the business, including the strategic planning, operational, and design/development sections of the organization. External support from other organizations may be beneficial to provide expertise and experience in the most efficient way to develop HACCP and in specific technical areas. Practicality is as important as technical validity so both operational staff and engineering and scientific staff need to be involved. Individuals with appropriate knowledge of


30

the chemical, physical, and microbiological hazards in water supplies, and the control measures used to manage them, are essential members of the HACCP team.

If the appropriate level of expertise and experience is present on the team there are two benefits. First, it is less likely that important risks will be over-looked. Second, it is less likely that unnecessarily stringent or impractical risk management controls will be implemented. For both reasons, the resource implications of assembling a good team are likely to represent a sound investment.

For consecutive systems, representatives from the bulk supplier should be consulted in the development of the HACCP system. This is imperative, as the condition of the water upon receipt will have bearing upon its management in the distribution system.

If the maintenance and repair of the water distribution system is outsourced, the contracting organization(s) should make commitments to the HACCP process that are equivalent to those made by the client organization. In addition, key persons from the contracted company(ies) should be part of the HACCP team when developing and implementing the HACCP system. This also applies if the sampling and testing of the water for compliance is undertaken by another organization since sound analytical practices are integral to validation and verification of the HACCP plan.

Team members’ names, their positions within their organization, their role within the HACCP team and their contact details should be listed in a simple table or spreadsheet (see example in Table 3.2). Formal training in HACCP is often the first step of the HACCP planning process as training imparts a sound common base of understanding among team members.

Table 3.2 Example roles of HACCP team members

Name* Position in Organization Role in HACCP Contact Information (e.g. Email

Address, Telephone no.) Water Supply & Operations

Manager

Project Director†

Water Quality Engineer

Project Manager†

Field Services Quality Controller

Expert on distribution system work practices

Water Distribution Engineer

Expert on distribution systems

Maintenance Manager Expert on maintenance and calibration

Trade Waste Manager Expert on backflow prevention

Field Services Supervisor Expert on service reservoirs

Department of Health Advisor on public health issues

Consultant HACCP plan training and coaching

Consultant Water quality technical advice

Source: ActewAGL, Canberra, Australia, April 2005 *Government and utility staff details withheld for security reasons. †Registrars often refer to those with the principal lead or coordination roles as “HACCP Champions.”


31

In larger utilities, to assure the effectiveness of the HACCP system, a core team of more experienced personnel is formed to direct the overall process. This team would include a HACCP Coordinator (Project Manager). Once the core team has been assembled and appropriately trained, working parties would be formed to develop components for their specific section of the water distribution system. Each group would be formed based on its specialist areas and should include representatives for all staffing levels from front line operators through experienced experts.

South East Water, in Victoria, Australia created five working parties in addition to the core team for its HACCP plan which included:

• Treatment systems (booster chlorination and spot dosing); • Service reservoirs; • Distribution system; • Backflow prevention; and • New extensions.

An executive-level HACCP Champion (Project Director) might be identified to provide high-level support and promotion for the HACCP plan. This can be important in multi-divisional organizations since staff from more than one division will need to work together and will need cross-organizational support. In general, the Chief Executive or General Manager of the whole water utility or water division should be in full support of HACCP implementation before the process begins. One benefit of HACCP for senior management is that HACCP certification can provide a tangible and publicly recognizable endpoint to the process. Organizational leaders can rightly take credit in demonstrating that they are running an operation to a certifiable level of rigor.

Scope of the HACCP Plan

The scope of the HACCP plan should be identified. Some utilities focus on one part of the system such as the treatment facilities or the distribution system, whereas other utilities may wish to prepare a HACCP Plan for the whole system, from source to connection. For example:

• Many utilities, such as Yarra Valley Water and South East Water, Victoria, Australia, identified the endpoint of their HACCP Plan as the endpoint of their legal responsibilities which is often at the customer water meter.

• Other utilities, such as the City of Austin, Texas, and Sydney Water, New South Wales, Australia, developed a HACCP plan that only covered one of their delivery systems, for the purposes of completing a pilot study for this project.

• Power and Water Corporation, Northern Territory, Australia, developed a HACCP plan for one of its systems, source to tap, for a pilot study conducted for this project.

Hints:

• Be open about the resource implications to prevent subsequent resentment if staff find they have committed to more than they anticipated.

• Include, rather than exclude, staff members that are initially skeptical so that they can understand the process and buy into it once they become part of the team.


32

• Include operational staff and contractors to make sure the plan is practical and sensible.

• Remember that the costs of getting the right team with the right experience are likely to be much less than the costs of struggling with the HACCP plan due to having a weak team.

Step 2: Describe Drinking Water

The drinking water being supplied by a water utility may be referred to as “tap water,” “town water,” “potable water” or other similar terms. However, for the development of a HACCP plan, more detail needs to be provided as a basis for the risk assessment in Step 6. Specifically, information is needed on the regulatory requirements and utility goals that affect the quality of the finished drinking water supplied to customers, and the so-called “inputs”, such as treatment chemicals.

One of the first required statements refers to the specific quality of water being supplied. This is important because some specialized industrial or medical uses of water may require further treatment beyond that provided by the water utility. The starting point is the regulatory and contractual requirements that specify the minimum standards that the water must meet. These should be explicitly referenced and may include:

• EPA federal regulatory requirements; • State regulatory requirements; • Operating licenses; • Customer charters or contracts; • Water supply agreements; and • Health guidelines.

A general description of the source of the water, the type of treatment used, the storage conditions, and the method of distribution needs to be specified. The raw materials used in treatment and operations, such as disinfectants, need to be specified since they effectively become part of, or could contaminate, the water as supplied. Material Safety Data Sheets can often provide evidence that the concentrations as supplied are safe for potable use.

Water utilities often distribute more than one type of water such as recycled water, potable water and raw water. All of these types of drinking water can be covered under a HACCP Plan, as illustrated in the examples in Tables 3.3 to 3.5.


33

Table 3.3 Example descriptions of drinking water

Product Group: Drinking water (also known as “potable,” “tap,” “town” water) Specifications: ActewAGL produces drinking water with the specific water quality specifications being set out in Contracts with ACTEW and cited documents and codes such as the Drinking Water Quality Code of Practice 2000 (ACT Health) and the Drinking Water Utility Licence 2005 (ACT Health). Process: Water is harvested from the Cotter River and Googong River surface water catchments. Water is abstracted directly from one location on each of the Bendora and Lower Cotter open reservoirs on the Cotter River and from the Googong open Reservoir on the Googong River. Water is treated via filtration and disinfection and distributed to customer water meters via a closed piped reticulation which includes enclosed balancing storages and pump stations. Scope: ActewAGL becomes directly responsible for the water once it is present in Bendora, Lower Cotter or Googong Reservoirs. ActewAGL is no longer directly responsible for the water once it has passed through customer water meters. Inputs*: Treatment chemicals are added at the treatment plants and at booster disinfection points in the distribution system (description omitted for brevity). The raw material is surface water harvested as described under Process, above. For booster chlorination, 12% sodium hypochlorite liquid is automatically dosed into three distal reservoirs. Product Group: Raw water (also known as “bulk,” “river,” “untreated” water) Specifications: ActewAGL produces raw water with no nominated specifications. Process: Raw Water is harvested from the Cotter River, abstracted from the open Bendora reservoir and distributed untreated to customers via a connection to the closed piped bulk transfer system. Scope: ActewAGL becomes directly responsible for the water once it is present in the Bendora and Lower Cotter Reservoirs. ActewAGL is no longer directly responsible for the water once it has passed through customer water meters. Inputs*: 65% calcium hypochlorite granules are manually dosed into reservoirs. No other chemicals are added to the raw water. The raw material is surface water harvested as described under Process, above. Source: ActewAGL, Canberra, Australia, April 2005. Reprinted with permission. *Often referred to as “ingredients” or “preservatives” by HACCP registrars not familiar with HACCP application to water.


34

Table 3.4 Example specifications for potable water

Analyte Specification E.coli* <1 organisms/100mL in 98% of samples over a 12-month period. (All distribution zones)

Free chlorine residual 95% UCL† for samples over a 12-month period ≤ 5 mg/L

Total chlorine residual 95% UCL† for samples over a 12-month period ≤ 5 mg/L

Ammonia 95% UCL‡ for samples over a 12-month period ≤ 0.5 mg/L

Aluminium (soluble) 95% UCL‡ for samples over a 12-month period ≤ 0.2 mg/L

Color (true) 95% UCL‡ for samples over a 12-month period ≤ 15 HU§

Copper 95% UCL‡ for samples over a 12-month period ≤ 1 mg/L

Fluoride 95% UCL† for samples over a 12-month period ≤ 1.5 mg/L

Hardness 200 mg/L 95% UCL‡ for samples over a 12-month period ≤ 200mg/L

Iron (mg/L) 95% UCL‡ for samples over a 12-month period ≤ 0.3 mg/L

Manganese 95% UCL‡ for samples over a 12-month period ≤ 0.1 mg/L

pH 6.5 – 9.2 within 95% confidence interval for samples over a 12-month period and no individual

sample greater than 11

Trihalomethanes (THMs)

95% UCL† for samples over a 12-month period ≤ 0.25 mg/L

Turbidity 95% UCL‡ for samples over a 12-month period ≤ 5 NTU

Electrical conductivity 95% UCL‡ for samples over a 12-month period ≤ 1000 μS cm-1

Flow rate Diameter of property service pipe (mm)

20 25 32 40 50

Minimum flow rate (L/min)

20 35 60 90 160

Interruption to supply Not to exceed 5 hours in 95% of instances over a 12-month period

Source: Yarra Valley Water 2005. Reprinted with permission. *Organism = a colony forming unit (cfu) †UCL = Upper confidence limit of the 95th percentile of annual samples ‡UCL = Upper confidence limit of the mean of annual samples §HU = Hazen units


35

Table 3.5 Example specifications for non potable water

Parameter Specification Intended use Non-potable water not intended for human consumption†, ‡ Reference: NHMRC/NRMMC

2004. Source: Yarra Valley Water 2005. Reprinted with permission. *UCL = Upper confidence limit of the mean of annual samples † Untreated water in bulk supply lines controlled by Melbourne Water. Customers in these areas have been informed of the non-potable quality of their supply and instructed of its intended use. ‡ The Department of Human Services (DHS) issued a Drinking Water Regulation Guidance Note 1 in April 2005 under Section 6 of the Safe Drinking Water Act. This note states that “Supply-by-agreement” arrangements cannot be declared as regulated water if there is a clear intent that the water is to be solely or partly used as drinking water. We will develop a policy for this customer group to meet the requirements in this Guidance Note in consultation with the customers and the DHS. Our current controls ensure that the water could not be mistaken as drinking water. Hints:

• Include all water quality parameters, i.e. chemical, physical, microbiological, and radiological.

• Focus on drinking water supplied to the majority of consumers. • Consider specific customer groups that exist such as customers supplied via private

extensions who may receive non-potable water. • If the final drinking water specification is set by a regulating body, consider

referencing this in the HACCP plan rather than including it directly, this ensures the HACCP plan does not become outdated if the regulatory requirements change.

• Identify any chemicals that are added to the water.

Step 3: Identify Intended Use

The statement given here needs to clarify who are the intended users of the water and how they will use it. In general, the most sensitive water use recognized by water utilities is that of potable water (hence the logic of applying HACCP to water). In such a case, the intended use statement needs to clearly state that the water is intended for domestic uses without further treatment by the user, including washing, drinking and food and beverage preparation, by the majority of the population. In some cases, other types of drinking water are supplied that may have different intended uses.

Some specialized industrial or medical uses of water are unlikely to be satisfactorily serviced by conventional municipal water supplies and this needs to be clearly stated in the HACCP plan. It is important to highlight any exceptions to the general case. For example, dialysis patients or severely immunocompromised persons may need to undertake additional treatment before using the water. There may be community groups that are singled out for special considerations. There may be some private extensions to the water supply which may tap off prior to completion of treatment or after excessive in-pipe residence times.

By stating that the water is intended to be consumed by the majority of the population, it excludes the necessity to cater to minority groups with special needs or industries with specific requirements. These users are likely to be advised by medical professionals (medically identified groups) or process engineers (industrial customers) if their water received at their tap may require further treatment such as boiling or filtration.


36

In some cases the water utility may think it prudent to make some explicit statements as part of its community education Supporting Program about the intended use and users of its drinking water. For example, aquarium owners often do not realize that potable water is not always safe for fish due to the presence of chlorine. Using internet sites, rates notices and pamphlets, it is possible to notify customers of the quality of the water supplied to them. For example, Sydney Water, New South Wales, Australia, sends out quarterly leaflets detailing water quality compliance results and providing a general statement regarding the water quality supplied.

Because potable water is such a familiar and common place item, extensive statements are not required. Nonetheless, the amount of detail provided in utility HACCP plans varies. Examples of intended use statements are provided in Table 3.6 and Table 3.7.

Table 3.6 Example of a long-form “intended use” statement

Drinking water. Intended Uses: Drinking water is intended for general consumption as a beverage, for washing of bodies and clothes and the preparation of beverages and foodstuffs. Intended Users: For use by the general population of Canberra, the Australian Capital Territory, and Queanbeyan. Unintended uses and users: There are some industrial, agricultural and commercial uses for which ordinary drinking water is unsuitable and such customers are not necessarily the intended users. There are people that are advised to provide additional point-of-use treatment before drinking water based on specific medical advice and such patients are not necessarily the intended users. Drinking water is not intended for use by those other than customers holding water services accounts and known to be connected to the distribution systems or holding permits to draw potable water from hydrants. Raw water. Intended Uses: No specific purpose. Intended Users: Customers are at Pierces Creek, Uriarra Forestry Settlements and at four rural properties upstream of Stromlo WTP. Unintended uses and users: Raw water is not intended for consumption without first applying treatment. Raw water is not intended for customers other than those formally recognized by supply agreements.

Source: ActewAGL 2005. Reprinted with permission.


37

Table 3.7 Example of a short-form “intended use” statement

Intended Use Potable water intended for general human consumption.

Source: Yarra Valley Water 2005. Reprinted with permission.

Hints:

• Be specific when stating intended uses of the water for each customer group. • Cater to the majority of consumers. • Consider specific customer groups such as customers supplied via private extensions. • Provide instructions to accommodate unique customers. • Consider alternative methods to notify sensitive users such as an internet site, a

written notice (bill stuffer) and as part of a Community Relations Program.

Step 4: Construct Flow Diagram

The HACCP team develops a flow diagram that depicts processes and operations that take place throughout the water distribution system. The diagram should illustrate what happens to the water from the time it is received (either at the catchment or from the bulk supplier) until it reaches the customers’ taps. It should include any points where the water is changed or controlled.

Key features of the distribution system that should be included in the flow diagram are pump stations, chemical feed points, storage tanks, and control valves. The flow diagram is an important basis for the hazard analysis in Step 6. The flow diagram should contain adequate detail to identify potential entry points for hazards and to trace any detected contamination through to subsequent process steps.

The level of detail required for the flow diagram is often a matter of opinion. Examples of a more complex and simpler flow diagram are given in Figure 3.1 and Figure 3.2, respectively. A key point is that processes and points that are common across many parts of the distribution system can be identified as just one symbol on one diagram if the risks and controls associated with those processes or points are common. Another key point is that hydraulic system diagrams and network maps and diagrams are likely to already exist. The purpose of the flow diagram is not to duplicate these, but to provide a higher-level process flow diagram at the conceptual level.

Once the critical control point and monitoring steps (Steps 7 and 9) are complete, the flow diagram will be used to indicate CCPs and monitoring points (as in Figure 3.2).

The symbols used in the flow diagram should be straightforward and illustrate key processes:

• Storage (“open” or “closed” such as tanks, reservoirs, basins); • Transport (water is moved from one place to another either by gravity or pumping); • Inspection points (monitoring occurs often resulting in a decision); and • Operation (an intentional change occurs such as disinfection).


38

Bulk treatedwater rawmaterial

Primaryservice

reservoirs(24)

Tank-headed

reticulationzones (44)

Water pumpstation

Secondaryservice

reservoirs(12)

Bulk treatedwater

transfer

Bulk treatedwater

transfer

Customerplumbing

and use ofwater

Customerconnections

and watermeter

Boosterchlorination

(one reservoironly)

Operationalstep symbol

Transportstep symbol

Storagestep

symbolBlack =

Utility hasdirect

control

Grey =Utility does

not havedirect

control

Key

Continuousprocess

Intermittentprocess

Water pumpstation

Bulk treatedwater

transfer

Bulk treatedwater

transfer

Tertiaryservice

reservoirs(8)

Boosterchlorination

(two reservoirsonly)

Pump-pressurisedreticulationzones (2)

Customerconnections

and watermeter

Customerplumbing

and use ofwater


Figure 3.1 Example of more complex system flow diagram


39

Source: Yarra Valley Water 2005. Reprinted with permission.

Figure 3.2 Example of simpler system flow diagram

Hints:

• Think in terms of “water quality processes” rather than “water quantity processes.” • Produce more specific flow diagrams as subordinate flow diagrams for each

individual section to provide greater detail if necessary. • Update flow diagrams when facilities are added or reconfigured. • Keep the flow diagram as simple as possible to avoid confusion.

Step 5: Confirm Flow Diagram

In Step 5, the accuracy of the flow diagram is checked by reviewing that all operations in the water distribution system are being considered and evaluated. This step helps to reduce re-work at a later point if gaps are subsequently found. One of the most time-efficient means of validating the flow diagram is to step through the diagram with experienced system operators and water quality engineers or scientists.

If there is uncertainty about aspects of the flow diagram, physical inspection can be undertaken. In terms of the fine details, it is not necessary to verify every valve and service pipe location but it is worth referring to the maps and plans wherein such information is kept. A program of valve checking is recommended as part of a HACCP program to ensure that assumptions about zoning are valid and that water is not, in fact, transported in different directions from what is documented on the detailed system diagrams.

Once the preliminary steps (Steps 1-5) have been completed, the core HACCP steps can be applied (Steps 6-12).

CCP

CCP

CCP


40

Hints:

• Sign and date the flow diagram to demonstrate its veracity. • Update the flow diagram(s) when new facilities are added or existing facilities are

reconfigured.

Step 6: Conduct a Hazard Analysis

Step 6 (Conduct Hazard Analysis) includes three elements: hazard identification, hazard assessment, and identification of control measures.

Hazard Identification

Once a HACCP team is formed and the preliminary steps completed (e.g. constructing and validating the process flow diagram), “…the HACCP team should list all of the hazards that may be reasonably expected to occur at each step from …distribution until the point of consumption” (Codex Alimentarius Commission 1993). To perform this step, the HACCP Team relies on their experience, system knowledge, historical data, and current technical knowledge. The flow diagram provides the frame of reference for this task with each symbol on the flow diagram representing a process step. The following procedure is undertaken for each process step:

• The process step is listed; • The causal events (hazardous events) by which hazards can arise are identified; and • The types of hazards that can arise are listed.

In identifying potential distribution system water quality hazards, the HACCP Team should consider whether the elimination or reduction of the hazard to an acceptable level is essential for water to be considered potable.

Four types of general hazard categories are used: physical, chemical, microbiological, and radiological. Examples of each category are specified in Table 3.8. In practice, the radiological category is not always considered.


41

Table 3.8 Examples of hazards to the water distribution system

Hazard Examples

Physical Dislodged pipe tubercles, dirt, tree roots, fragments of pigs and swabs

Chemical Gasoline, oil, industrial discharges, cleaning fluids, threat agents*

Microbial Bacteria including coliforms and E. coli, threat agents†

Radiological Uranium, radium, threat agents

* Chemical threat agents for drinking water systems include chemical warfare agents (e.g. hydrogen cyanide, sarin, and sulfur mustard) and industrial chemical poisons (e.g. cyanides, arsenic, fluoride, cadmium and mercury) (Mays 2004). † Biological threat agents for drinking water systems are potentially resistant to disinfection, can be produced and disseminated in large quantities, and are stable for relatively long periods in water (Mays 2004). These biological threat agents include certain waterborne pathogens (e.g. Clostridium perfringens, plague) and biotoxins (e.g. botulinum, aflatoxin, ricin).

Examples of potential hazards to a water distribution system are summarized as follows:

• Contamination due to treatment failure; • Fecal contamination of storage tanks and standpipes; • Backflow event causing contamination; • Contamination caused by negative or low pressure transient resulting in intrusion of

untreated water through submerged air valve, faulty seal or point of leakage; • Contamination caused by fecal material or by foreign inanimate objects (e.g. dirt,

mud, timber, plastic) during repair, alterations, or connection to existing mains; • Contamination by hazardous substances as a result of use of products, materials or

coatings that are not approved for contact with potable water; and • Contaminants introduced by permeation, pipe degradation or corrosion.

The system supplying water to Zurich, Switzerland considers four categories of potential risks (Bosshart 2003):

• Personnel that are not properly trained or experienced; • Materials in contact with drinking water; • Machines in contact with drinking water; and • Faulty methods or procedures related to distribution system management.

The Swiss regulatory guideline (W1002) entitled “Recommendations for a Simple Quality Assurance System for Water Supplies includes checklists of possible hazards (Swiss Gas and Water Industry Association 2003). Checklist items that pertain to distribution system reservoirs include the following hazards:

• Natural risks (e.g. trees, landslides, animals, vermin); • Unsecured access (e.g. doors, windows, ventilation); • Poorly separated water chambers;


42

• Poor building condition (e.g. concrete, coating, piping); • Poor water circulation (e.g. fire water reserve); • Poor ventilation (e.g. water chamber, dehumidification plant); • Pollution (e.g. wastewater, soiled clothing); • Unsuitable process control (e.g. no displacement of inlet); and • Materials (e.g. chemicals, cleaning agents).

Checklist items that pertain to piping networks include the following hazards (Swiss Gas and Water Industry Association 2003):

• Natural risks (e.g. line breaks); • Unsecured access (e.g. hydrants, gate valves); • Unfavorable pressure conditions (e.g. suction of external water); • Impaired functionality (e.g. motors, controllers); • Blocked access (e.g. shut-off valves); • Missing or incorrect flushing (e.g. mains, hydrants, fountains); • Improper repair work and connections; • Unsecured customer installations (e.g. immersions, pressure pumps); and • Consumer behavior (e.g. seasonal operation).

Hazard Assessment

Most U.S. water utilities are familiar with hazard assessments from their experiences with completing federally mandated vulnerability assessments and developing cross-connection control programs. For example, in developing a cross-connection control program, the utility identifies and rates possible cross-connections as low, medium or high hazards, and then installs (or requires the customer to install) backflow prevention devices for high hazard locations.

In assessing the risk of a hazard, the following criteria should be evaluated:

• Frequency of occurrence; and • Severity of consequences (possible in terms of size of the population affected, the

type of impact and the duration of the hazardous effect).

In undertaking the hazard analysis, it is possible to adopt one of three alternative approaches:

• A simple qualitative approach; • A simple semi-quantitative scoring approach; or • A complex semi-quantitative scoring approach.

The utility’s HACCP team should agree upon one risk ranking procedure. As suggested by NHMRC/NRMMC (2004), agreeing on the approach before hand and initially testing it with a small group may help assure that an appropriate risk assessment approach is selected.

In the simple qualitative approach, the HACCP team assigns one of the following risk ratings to each hazard based on the judgment of the group: “significant,” “insignificant,” or “uncertain” if further analysis was required. This simple qualitative approach was adopted by Gold Coast Water, Queensland, Australia.


43

The simple semi-quantitative scoring approach, illustrated in Table 3.9, involves assigning a score to each hazard for two factors, the hazard’s likelihood of occurring, and the severity of consequences that could result from an occurrence (Gray and Morain 2000; Deere et al. 2001). The scoring is based on a 1 to 5 scale. For the likelihood of occurrence factor, a score of 1 is given for a rare occurrence, while a score of 5 indicates a hazard that is almost certain to occur. Each hazard is also scored on the possible severity of consequences that could result, with a score of 1 for insignificant consequences and a score of 5 for catastrophic consequences. These two scores are multiplied to calculate the risk factor rating. This approach was adopted by the participating utilities in this Project, as well as by Brisbane Water, in Queensland, Australia and South East Water and Yarra Valley Water, in Victoria Australia. As an example, the risk of a pathogen (the hazard) contaminating the water and reaching hazardous levels as a result of a water main that was repaired and returned to service (the causal hazardous event) at the distribution process step (not being properly flushed) might be considered to be unlikely (likelihood factor of 2) but have a severity of consequence of 5 (public health risk). The product of these scores gives a risk factor rating of 10. Two additional examples are shown in Tables 3.10 and 3.11.

Table 3.9 Example of a simple risk-scoring matrix

Severity of Consequences

Risk Factor Matrix:

Insignificant No impact /

not detectable Rating: 1

Minor Compliance

Impact Rating: 2

Moderate Aesthetic Impact

Rating: 3

Major Regulatory

Impact Rating: 4

Catastrophic Public Health

Impact Rating: 5

Almost Certain Once a day

5 10 15 20 25

Likely Once a week

Rating: 4 4 8 12 16 20

Moderate Once a month

Rating: 3 3 6 9 12 15

Unlikely Once a year Rating: 2

2 4 6 8 10

Like

lihoo

d

Rare Once every 5 years

Rating: 1 1 2 3 4 5

Source: Adapted from AS/NZS 4360:1999 (superceded); AS/NZS 4360:2004; and HB 436-2004 (“the Works”) with permission from SAI Global Ltd. These standards can be purchased at http://www.sai-global.com

Using this method of evaluating risks, a risk is often deemed to be significant if the rating

is 6 or greater. The cut-off of 6 may be selected to avoid focusing on risks that will be inconsequential due to rarity or low severity. Depending on available resources, the HACCP team decides how many hazards can be addressed by the HACCP Plan (e.g. all hazards with a risk score >10 might be addressed) and how they will be prioritized.


Table 3.10 Example of a risk assessment for service reservoirs

Process step: Closed service reservoirs Risk

(hazard and cause) Likelihood Consequence Risk level

(max) Preventive Measures

(that reduce risk to acceptable level) Comments

(basis for assessment and supporting programs) Birds or rodents intrude through vermin-proofing then defecate in water and release pathogens or microbial indicators exceeding guidelines

3 8 Very High • Vermin proofing of storages • Residual disinfection maintained in

storages

• Covered under “pest control” supporting program

• The same applies to any open storage system and risks are higher closer to sources of human pathogens, such as refuse tips

Unsanitary maintenance and repair leading to introduction of hazards exceeding guidelines

1 3 Low • Adherence to sanitary maintenance and repair procedures

• Repairs and maintenance are only annual or less on service reservoirs

Deliberate contamination by tipping of hazardous substance through hatch to levels exceeding guidelines

2 8 Very High • Security inspections • Locked ladder shroud • Locked hatch • Fencing

• The logistical difficulties, dilution factors, and short duration make such an act both difficult and of limited maximum consequence but there have been examples of this taking place which resulted in major public confidence impacts

Loss of pressure below minimum service level leading to ingress of contaminants through back siphonage to levels exceeding guidelines

2 3 Moderate • Pumps re-fill tank at low level set point through automated feedback loop

• Dilution factors, short duration and subsurface location of assets makes such an event of limited maximum consequence

Unsafe or inappropriate materials used in making repairs or adding fittings leading to introduction of hazards exceeding guidelines.

1 3 Low • Use of approved materials • Adoption of water industry codes for

materials and construction as per prerequisites

• Covered under “inputs quality assurance” and “best practice” supporting programs

• Dilution factors make such an event of limited maximum consequence

• Materials for service reservoirs are likely to have been produced specifically for that purpose

Water becomes stagnant leading to taste and odour compounds and microbial indicator levels exceeding guidelines

3 3 High • Pumps refill tank at low-level set point through automated feedback loop to encourage turnover

• Drainage and isolation of redundant tanks during winter

• Not a health issue but a compliance issue


44 ©

2006 Aw

waR

F. A

ll Rig

hts R

eserved.

Table 3.11 Example of a risk assessment for distribution systems

Process step: Closed treated water distribution

Risk (hazard and cause) Likelihood Consequence

Risk level (max)

Preventive Measures (that reduce risk to acceptable level)

Comments (basis for assessment and supporting

programs) Sloughing of slimes or resuspension of sediment during high flow periods, following shut down and recharge, flow reversals or pipeline disinfection and cleaning leading to iron, manganese and turbidity exceeding guidelines

4 2 High • Controlled valve operation • Management of flow velocity and

direction • Systematic zoning and network operation • Scheduled mains cleaning to remove

sediment

• Variable and often low velocity in pipelines and small size of pipelines makes this event likely

• This is not a health risk if it does occur

Deliberate contamination by injection of hazardous substance into pipeline to levels exceeding guidelines

1 6 Moderate • Positive pressure maintained in pipeline • Buried pipes and fittings

• The logistical difficulties make such an act difficult and the short duration and small population affected reduces the maximum risk

Accidental contamination through pressurised cross-connection or service connection or backflow during pressure drop leading to hazardous substance flowing into pipeline to levels exceeding guidelines

2 6 Very High • Positive pressure maintained in pipeline • Backflow prevention for high hazard

connections • Separate sewer and water trenches • Coloured water, sewer and recycled

water pipes • Plumbing code requirements and

regulations

• Covered under “best practice” and “hygiene and sanitation” supporting programs

• The positive pressure makes event unlikely

• Short duration and small population affected

• Advise plumbing and home handyman sectors

Unsanitary pipeline maintenance and repair leading to introduction of hazards exceeding guidelines

4 6 Very High • Adherence to sanitary maintenance and repair procedures including thorough flushing of small lines after repair and flushing and disinfection of large lines

• Covered in “hygiene and sanitation” supporting

• Repairs are common on smaller. • Short duration and small population

affected reduces maximum risk but it can be a health risk

Unsafe or inappropriate materials used in making repairs or adding fittings leading to introduction of hazards exceeding guidelines

1 3 Low • Use of approved materials • Adoption of water industry codes for

materials and construction


• Materials used in water supplies are especially produced for that purpose


45©

2006 Aw

waR

F. A

ll Rig

hts R

eserved.

Table 3.11 Example of a risk assessment for distribution systems

Process step: Closed treated water distribution

Risk (hazard and cause) Likelihood Consequence

Risk level (max)

Preventive Measures (that reduce risk to acceptable level)

Comments (basis for assessment and supporting

programs)

Water becomes stagnant leading to taste and odour compounds and microbial indicator levels exceeding guidelines

4 2 High • Design of system to reduce dead ends and large diameter pipes where not required

• Flow management through zoning and operation

• Scheduled flushing to remove stagnant water

• Not a health issue but a compliance issue

• Small population affected reduces maximum risk

Corrosion in court bowls and service lines leading to iron or copper exceeding guidelines

4 2 High • Scheduled flushing to remove stagnant water

• Stabilization and pH control of water • Maintenance of residual disinfectant • Scheduled replacement of lines


• Of only very minor health significance, more an aesthetic issue

pH above guidelines in cement-lined pipes

3 1 Low • Use of lined fittings for new systems • Not a health issue

Loss of residual leading to microbial growth

3 1 Low • Maintenance of residual disinfectant • Can affect total coliform compliance


46

(Continued

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

47

The City of Austin, Texas identified a number of potential hazards for their pilot study area:

• Backflow through an unprotected cross connection (risk score 25); • Contamination at new construction sites (risk score 20); • Backflow from failing septic systems into distribution main (risk score 9); • Contamination due to water main break or repair (risk score 12); • Pathogen intrusion to distribution main due to leaky sewage main (risk score 10); • Intentional contamination of distribution system by vandals (risk score 9); • Contamination due to main break outside pressure zone (risk score 8); • Contamination due to pressure transient (risk score 4); • Presence of bacteria due to low disinfectant residual (risk score 4); and • Presence of bacteria due to zero disinfectant residual (risk score 4).

The HACCP team decided to base the pilot study on two particular hazard events that scored high marks in the hazard analysis – backflow from unprotected cross-connections and hazards at new construction sites that can potentially degrade the finished water quality. The concern for possible contamination at new construction sites focused on contractors’ unauthorized operation of system valves and the effectiveness of disinfection of new mains prior to being placed into service.

A more complex semi-quantitative matrix used by Sydney Water and described in Deere et al. (2001) is illustrated in Figure 3.3.


48

Source: Deere et al. 2001. Reprinted with permission from WHO, www.who.int WF = weighting factor, default value = 0.33

Figure 3.3 Example of a complex risk ranking approach

There are less structured means of prioritizing risks that do not include the use of a risk

matrix. If individuals serving on the HACCP team have the skills needed to judge the severity and likelihood of hazards and hazardous events, then risks can be prioritized in a less structured format.

Identification of Control Measures

Once hazards have been identified and ranked according to their likelihood of occurrence and severity of consequences, the HACCP Team focuses on how to eliminate or reduce the seriousness of the highest ranked hazards. This is accomplished with HACCP steps 6 through 10.

In HACCP step 6, the HACCP team identifies existing control measures that are being used within the distribution system, and any additional control measures that systems may consider for future operations. Control measures or preventive measures are defined as all

Identify Hazards

Estimate Frequency of

HazardEstimate Duration

of HazardEstimate Magnitude

of Hazard

Estimate No. ofCustomers Affected

by Hazard

Convert to Scores*Duration

Score Information 2 1-14 days

4 14-30 days 8 30-60 days 16 2-4 months 32 4-8 months

64 8-12 months 125 1-2.5 years 250 2.5-5 years 500 5-10 years

1000 10 years or more

Convert to Scores

Biological8 = pathogens present

250 = some health effects

Chemical8 = present above guidelines32 = low level health effects

250 = high level health effects

Aesthetics8 = aesthetic problems

32 = aesthetic problems and above guidelines

Customers Score x WFMagnitude Score x WFDuration Score x WF**

Frequency inevents/year

+ +

Consequence Factorx Risk Score=

Convert To Scores CustomersScore Affected2481632641252505001000

8,00015,00030,00065,000125,000250,000500,000

1,000,0002,000,0004,000,000


49

actions taken to prevent or reduce contamination in a drinking water supply. Typical control measures for distribution system hazards include maintenance of positive pressure at all times; use of sanitary procedures during construction; and adequate construction of all storage and distribution facilities. Table 3.12 lists control measures for several hazards identified by South Berwick Water District.

Table 3.12 Example hazard analysis and control measures

Hazard Event

Severity of Consequences (score using 1 to 5 scale with 5 being most

severe)

Likelihood of Occurrence

(score using 1 to 5 scale with 5

being most likely)

Risk Factor

= Likelihood x Severity

Existing Control

Measures

Additional

Control Measures Recommended by

HACCP Team Backflow through an unprotected cross-connection

4 5 20 • Utility installs double check valves on residential services

• Commercial customers install backflow prevention device as required

• Utility maintains good records of backflow prevention devices

• System static pressure >40 psi (276 kPa) system-wide

• Utility needs to enforce testing of commercial backflow prevention devices

• Public education • The feasibility of

testing backflow prevention devices at multi-family units should be further evaluated

Contamination via Storage Facility Vents

5 2 10 • Storage tank site fenced and well-maintained

• Gravel road to site is gated

• Site inspection three times weekly

• Insect screening on vents kept in good repair

• On-site security camera

• SCADA intrusion alarm

Main Break 5 2 10 • Disinfection and flushing of all main breaks before placing back into service

• Review inspection procedures

• Review water quality testing procedures


50

It is likely that during the risk assessment process, the preventive measures identified will be considered inadequate for some of the risks. In such situations, additional control measures will be identified as being desirable and the HACCP team should record these for further evaluation.

Hints:

• Remember that the risk being assessed is the risk of a hazardous event occurring at that process step and leading to a specific hazard reaching hazardous levels.

• One form of hazardous event is the failure of a control measure. Therefore, assess risks for both the normal situation of control measure operation and the hazardous situation of control measure failure.

• Undertake a reality check at the end of the process to be sure that an appropriate risk rating is assigned.

• Document the reasons for the risk ratings and validate them where there is some uncertainty.

• Remember that one hazardous event such as a burst water main can introduce a multitude of hazards.

• Remember that more than one control measure may be required to control a potential hazard.

• Remember that more than one potential hazard may be controlled by a single control measure.

• Ensure that personnel who will control/prevent the hazard know and understand their requirements.

• Ensure adequate downstream control measures exist if a potential risk is not associated with immediate water quality and safety.

Step 7: Determine the CCPs

Distinct from control measures, a CCP is a step in the water system where control measures are essential to maintain the safety of the drinking water. The CCP can be:

• A process step as identified on the flow diagram; • A specific operation or point in the system; or • A procedure.

Therefore, in distribution systems, these critical barriers are defined as CCPs by stating that the CCP is the “Process Step” on the flow diagram, not necessarily a single “Point” in time and space. For example, the “service connection” process step can be a CCP since, at that process step, backflow prevention can be critical. This approach was not preferred by WHO and New Zealand Ministry of Health who have removed the use of the term CCP. However, the Australians have retained it and have recognized the validity of the term and the ease with which experienced HACCP practitioners can apply it through conceptualizing the process via the flow diagram.

All significant hazards in the process should be controlled at a CCP or through a reliable Supporting Program to ensure they do not pose a significant water quality and/or safety risk.


51

Some water quality impacts that are not health-based but can cause aesthetic impacts, such as taste and odor or manganese slimes, can be controlled at points that could be termed quality control points (QCPs). QCP is not a Codex definition but has been adopted by some HACCP-certified water utilities to ensure appropriate focus on aesthetic water quality as well as safety (e.g. South East Water and Yarra Valley Water, Victoria, Australia). Another term, non-critical control point (NCCP), is not a Codex definition, but has been adopted by Power and Water Corporation in the Northern Territory, Australia to ensure appropriate focus on non-safety water quality issues in general as well as safety.

In practice, making such distinctions between CCPs for quality, safety, and compliance is not essential to HACCP and to do so would be a decision made by the HACCP team. For the purposes of this guidance, CCPs will be referred to with respect to control points for quality, compliance, or safety.

One possible tool for determining whether a particular step in the process is a CCP is the decision tree depicted in Figure 3.4. If a particular step is critical for maintaining safe and potable water then it should be regarded as a CCP. The reasons why this step has been determined to be a CCP should be documented in the HACCP plan.

In practice, utilities differ with respect to whether particular process steps represent CCPs. This partly reflects personal preferences, differences in risk profiles and differences in the way that the HACCP plans are structured. Utility examples are provided in Table 3.13.


52

1. Do controlmeasure(s) exist for

the identifiedhazard(s)?

2. Is the process stepspecifically designedto eliminate or reducethe likely occurrenceof the hazard(s) to anacceptable level(s)?

3. Couldcontamination withidentified hazard(s)occur in excess of

acceptable level(s) orcould these increase

to unacceptablelevel(s)?

4. Will a subsequentstep eliminate the

identified hazard(s) orreduce the likelyoccurrence to an

acceptable level(s)?

1a. Is control at thisstep necessary for

achieving objectives?

Not a CCP

Yes

Yes

YesNo

No

Yes

No

Yes

No

Not a CCP

CCP

No Not a CCP

Modify step,process or

productStart

Source: WHO 1997. Reprinted with permission.

Figure 3.4 Decision tree for identifying process steps that are CCPs


53

Table 3.13 Examples of CCPs in utility HACCP plans

Process, operation or procedure Example of a utility that has identified this CCP Interface with bulk supplier

South East Water, Victoria, Australia

Closed reservoir storage ActewAGL, Canberra, Australia

Chlorination on outlet of open reservoir

Barwon Water, Victoria, Australia

Chlorination on inlet of closed reservoir

Sydney Water, New South Wales, Australia

Maintenance of positive pressure in system

Power and Water Corporation, Northern Territory, Australia

Customer interface

Yarra Valley Water, Victoria Australia

Backflow prevention system


New construction processes

City of Austin, Texas

Hints:

• Identify CCPs only for those risks that are significant. • Record the basis for designating steps as CCPs in the HACCP plan. • If not using the Codex Decision Tree (Figure 3.4), document the reasons why the step

in the process is a CCP. • Think about process steps on the flow diagram in identifying CCPs, not just physical

points in time and space.

Step 8: Establish Critical Limit(s)

For each CCP identified in the process, a measurable parameter and limits for each parameter must be established. Current knowledge and expertise including industry standards, as well as historical data, should be used as a guide when determining the limit.

To provide appropriate control of the water distribution system, a two-tiered structure may be implemented. The first level of critical limits distinguishes when the measurable control parameters are approaching an unacceptable level. The second level identifies the absolute cut-off value that ensures the quality and safety of the water will not be compromised. That is when the water becomes unacceptable and is considered off-specification or unfit and unsafe to drink.

A simpler way of thinking is the first set of critical limits, called target limits or target criteria, is the optimum values. The second set of critical limits is the operational limits that trigger actions to rectify the deviation and bring the water back within specification.

Table 3.14 provides a summary of examples of critical limits in utility HACCP plans and covers the range of different types of limits that can be set.


54

Table 3.14 Examples of critical limits in utility HACCP plans

Process, operation or procedure

identified as a CCP

Examples of preventive measure associated with the

CCP Examples of critical limit Utility source Closed reservoir storage

Maintain integrity of storage including security devices and bird-proofing

• No breach in bird-proofing, roof, hatches, or security


Chlorination on outlet of open reservoir

Maintain free residual to control bacteria from birds

• Free residual above 0.5 mg/L at entry point


Chlorination on inlet of closed reservoir

Maintain free residual to control ammonia oxidizing bacteria development

• Free residual above 0.2 mg/L at reservoir outlet

• Free residual below 0.6 mg/L at first customer

Sydney Water, New South Wales, Australia

Maintain water in tanks to keep system pressurized

• To maintain pressure in system, reservoir levels never to drop below design service levels at any time

• Specific levels are set for each tank to give ≥ 49 ft (15 m) head at all times


Maintenance of positive pressure in system

Maintain distribution system pressure

• Pressure should be above 35 psi (241 kPa) under normal conditions

• Pressure should be above 20 psi (140 kPa) during emergency conditions

City of Austin, Texas.

Backflow prevention system

Presence of working backflow prevention device

• Compliance with plumbing code

• Backflow assemblies pass operational test


The simplest example is chlorination levels. The water leaving an open service basin

might be considered unacceptable if it has a residual chlorine level of less than 0.2 mg/L at the monitoring point leaving the contact tank. The disinfection process might be designed to produce a residual chlorine level of 0.5 mg/L at that point. If monitoring (see Step 9) detects that the water has a chlorine level of 0.25 mg/L, the dosage of sodium hypochlorite might be programmed to increase to raise the residual chlorine level in the system to 0.5 mg/L, the target level. If the level still drops and goes below 0.2 mg/L, which is the critical limit, a corrective


55

action (see Step 10) might be taken, such as spot-dosing in the downstream service reservoir or shutting off the feed and running off the high level tank until the problem is fixed.

Critical limits can involve less quantitative criteria than those generally used for chlorine residuals. For example, observational measures, such as integrity of fencing or the presence/ absence of devices such as backflow prevention devices, have been identified as critical limits in some HACCP plans.

Hints:

• Document the basis for setting critical limits (see step 11, Validate/Verify HACCP Plan).

• Establish target values that detect when the water is trending in an unacceptable direction, as well as critical limits when it reaches an unacceptable value.

• Consider setting critical limit values for aesthetic reasons such as taste and odor, as well as health issues.

Step 9: Establish a System to Monitor Control of the CCP

Monitoring procedures under step 9 serve three main purposes:

• Ensure the process system is under control and determine when target criteria and critical limits are reached, i.e. when a deviation occurs at a critical control point;

• Provide records that can be later examined during the verification step; and • Track the effectiveness of the operation over time.

It is vital that monitoring procedures are established and conducted properly. Points to be taken into account when establishing monitoring procedures include:

• What specific information is required to be collected? • How is the data to be collected and recorded? • Where should the monitoring be undertaken? • Who is to undertake the monitoring? • When should the monitoring occur, i.e. at what frequency? • Whether further analysis is required of the raw data collected to enable a meaningful

comparison to the critical limit?

The designated parameter(s) determined for each CCP is/are to be measured prior to the point where unsafe or poor quality water may reach consumers. This means that many parameters will need to be monitored online so that “real time” results are obtained as few “storage points” exist within a water distribution system. The monitoring procedures need to be documented in the HACCP plan (see examples in Table 3.15). Factors to be considered when determining appropriate monitoring are:

• Available monitoring methods; • Costs for sample collection and analysis; • Time required for sample collection and analysis; and


56

• Training requirements.

For example, E. coli is analyzed as a measure of the safety of the water. Results for E. coli however, take at least 24 hours from sampling before a confirmed result is returned. Unless the water remains in the pipes or tanks and is not consumed by customers, this parameter is not an effective monitoring control. Instead, such a parameter would be used for verification monitoring (under step 11) rather than operational monitoring. A more appropriate parameter for drinking water distribution systems may be chlorine residuals, pressure, tank levels, or turbidity.

Table 3.15 Examples of critical limit monitoring in utility HACCP plans

Critical limit Example of monitoring Utility No breach in bird-proofing, roof, hatches or security on closed service reservoir

What: Integrity How: By observation Where: Reservoir Who: Field services staff When: Fortnightly (biweekly)


Free residual above 0.5 mg/L at entry point to distribution system for water leaving open service reservoir

What: Chlorine residual How: Chlorine analyser Where: Entry point Who: Duty manager When: Online


Pressure should be above 35 psi (241 kPa) under normal conditions Pressure should be above 20 psi (140 kPa) during emergency conditions

What: Pressure How: Pressure transducer Where: Distribution system Who: Alarm monitor When: Online

City of Austin, Texas.

Location and type of backflow assemblies comply with Plumbing Code Backflow assemblies pass operational test

What: Device compliance How: Testing regulation Where: Service connection Who: Contract plumber When: Annually


At Gold Coast Water in Australia, improved monitoring and reporting procedures

implemented as part of the HACCP Plan have provided more information to management and have motivated operational staff to work harder to avoid failures (Smith 2004). Operational staff members were consulted during development of the HACCP plan to identify realistic critical limits and monitoring procedures. When a critical limit is exceeded at Gold Coast Water, the operators submit an excursion report to management (Smith 2004). For example, a plant operator may file an excursion report because of failure to maintain treated water pH for 4 hours due to aging lime dosing equipment. Management can quickly review these excursion notices and decide if they represent minor incidents or if further inquiry is warranted. Operators do not like reporting excursions so they try harder to avoid having failures in the first place. It is hard to cover up failures because the utility has numerous on-line devices to measure water quality


57

conditions (e.g. turbidity, pH, chlorine) and close internal auditing methods which that reveal cover ups (Smith 2004a).

At Gold Coast Water’s Mudgeeraba plant, Smith (2003b) reports that there was initially under-reporting of turbidity problems due to problems with the sensitivity and calibration problems with the plant’s only on-line turbidity meter (for 16 filters). This was compounded by a culture that was uncomfortable with and unused to communicating water quality data on a continuous basis. A change to better instrumentation and closer auditing eventually revealed that turbidity was not being controlled to the level of consistency expected. Two problems were revealed. First, the operator’s skills in carrying out jar tests had deteriorated due to lack of practice and, second, problems with the filters and backwash system made turbidity failures more likely and of more serious consequence. The cultural problem was addressed through tighter auditing which eventually led to better understanding of the importance of the staff’s role in managing water quality. The asset problem led to a redesign of the backwash system and an upgrade of the plant filters.

Monitoring strategies associated with a HACCP Plan do not rely solely on water quality testing, but may also include inspections and checks on various databases or other utility records. For example, as summarized in Appendix B, the City of Austin, Texas focused on two hazards for their HACCP Plan – cross-connections and new construction sites. Monitoring strategies for evaluating control measures for the cross connection hazard include:

• Plumbing inspections and water protection surveys to identify any unprotected cross-connections and to check for working backflow prevention devices.

• Plumbing inspections and water protection surveys to check on repairs of failed backflow prevention devices.

• Pressure monitoring throughout the distribution system to evaluate whether system pressure is being maintained.

• Reviews of the utility’s database to check if annual inspections of backflow prevention devices were conducted.

• Visual inspection of on-site septic systems to check for system failures.

Monitoring strategies for Austin’s new construction site hazard include:

• Phone and radio contact with site personnel to check on unauthorized use of system valves.

• Visual inspection of contractor disinfection practices on new water lines. • Water quality samples to check coliform bacteria counts and free chlorine levels of

water in new mains prior to being placed into service. • Monitoring tank water level and pressure point alarm levels that would indicate if any

valves were opened between two pressure zones. • Site inspections to check if contractors utilized the One-Call system (a

communication system that provides a toll-free number for contractors/designers to call facility owners prior to excavating to prevent damage to underground facilities and utility lines) to mark water utility lines.

• Reviews of sign-in sheets for training workshops to check whether site inspectors attended required training sessions.


58

Hints:

• Select a monitoring frequency that enables a protective response to be taken before poor quality water reaches consumers.

• Include the person responsible for the monitoring in the development of monitoring procedures to ensure that they are practical and understandable.

• Ensure procedures and work instructions exist for monitoring at each CCP.

Step 10: Establish Corrective Actions

For every monitoring procedure, corrective actions need to be developed for situations when target criteria and critical limits have been deviated from to ensure that the critical control point is brought under control or that unsafe water has been disposed of in a correct and appropriate manner. The corrective action procedures need to be tested, either by a desk-top study or field trial, to ensure that water that may be unfit or unsafe is prevented from reaching consumers.

Any and all corrective actions undertaken need to be recorded in the HACCP system as proof of compliance and to prove that all reasonable precautions have been taken in accordance with due diligence.

Examples of corrective actions for the distribution system include flushing or air-scouring, booster dosing of disinfectant, operating valves, removing a pipe from operation, redirecting flow, or taking a piece of equipment (tank or disinfection unit) offline and bypassing the asset until control is restored. Additional examples are provided in Table 3.16.

Table 3.16 Examples of corrective action procedures in utility HACCP plans

Critical limit Example of corrective action Utility No breach in bird-proofing, roof, hatches or security on closed service reservoir

• Isolate/bypass storage • Spot-dose • Scour out suspect water • Clean and restore reservoir


Free chlorine residual drops by 0.2 mg/L or more from the chlorination set-point for water leaving an open storage reservoir.

• Ensure telemetry system is operating correctly.

• Review/adjust the set-point or increase the dosing level.

• Initiate the contingency plan for chlorine plants.


Pressure should be above 35 psi (241 kPa)under normal conditions; and Pressure should be above 20 psi (140 kPa) during emergency conditions

• Turn on additional pumps to raise pressure

• Open divide valves to charge system from different zone

• Search for main breaks and shut off leaking area

• Issue boil water advisory if necessary


Location and type of backflow assemblies comply with Plumbing Code Backflow assemblies pass operational test

• Remind customer • Enforce compliance using penalties if

required



59

Corrective actions may not necessarily be carried out where the hazard event occurs but may be performed upstream or further downstream. Corrective actions in the water distribution system may be carried out because of a hazardous event that has occurred at the water treatment facility or in the watershed.

Hints:

• Note that some corrective actions may be the same as control measures, such as flushing.

• Document corrective actions and monitoring procedures next to the relevant CCP in the HACCP plan so that it can be easily followed when required.

• Identify the people responsible for undertaking corrective actions and ensure they have the required authority and training.

• Remember to include disposal or isolation and treatment of potentially unsafe water. • Corrective actions are not always undertaken where the hazardous event occurs. • Identify other parties that may be responsible for undertaking certain corrective

actions. • Review records of corrective actions to identify trends and the need for systematic

improvement actions. • Utilize emergency response plan and training materials to develop and implement

corrective actions.

Step 11: Validate/Verify HACCP Plan

Step 11 involves two types of activities, validating the technical basis for the HACCP Plan, and verifying the HACCP Plan which confirms that the HACCP system has been accurately implemented and is working as designed.

Validate the HACCP Plan

Validation is a means of substantiating that the HACCP Plan is technically sound. For example, there is a need to ensure that the stated critical limits are correct and effective for producing and maintaining safe and potable water. For example, what is the proof that the value specified is correct and controls the hazard? (See example in Table 3.17.) Proof of the technical validity of the HACCP Plan needs to be documented in the plan and may make reference to sources such as:

• Technical literature and research reports; • In-house validation exercises (i.e. specific sampling regimes to demonstrate what is

occurring); • Design specifications from reputable professional engineering firms; • Regulatory requirements; • Memoranda of understanding; or • Guidelines and regulations produced by reputable professional bodies of experts.


60

Table 3.17 Example validation schedule

Critical limit Validation Reservoir levels never to drop below design service levels at any time Levels are set for each tank to give ≥ 49 ft (15 m) head at all times

Distribution network modeling and pressure recording has verified that the minimum network pressure can be maintained when the storage levels are managed within operational limits. The minimum network head of 49 ft (15 m) is consistent with best practice for preventing or mitigating pathogen intrusion problems e.g. Recommended Standards for Water Works (Ten State Standards) 1997 nominate the minimum supply pressure as 20 psi (140 kPa).

Free chlorine residual in the reticulation system should be between 0.2 and 0.5 mg/L

To preserve the microbial quality of water during distribution the Australian Drinking Water Guidelines (2004) recommend a chlorine residual of ≥ 0.2 mg/L in the reticulation system* but below 0.6 mg/L to control taste and odor complaints.

*Note that although this is not essential in much of the USA and Europe, in the Northern Territory of Australia, water can become very warm (>30ºC (86ºF)) and pathogens such as Nagleria fowleri and Burkholderia pseudomallei can become problematic. Source: Adapted from Power and Water Corporation’s HACCP Plan (Appendix B)

Verify the HACCP Plan

This step determines that all hazards have been identified and that CCPs, critical limits, monitoring and corrective action procedures are appropriate and effective. The verification process entails obtaining objective evidence that the water is, in fact, safe and fit to drink and that good operational practices, monitoring and corrective actions are being complied with at all levels. This step is achieved by means such as:

• Conducting regular internal audits to ensure that utility staff are following SOPs; • Revisit entire HACCP Plan • Cooperate with audit conducted by independent third party and correct any noted

deficiencies. •

Verification activities should be completed according to a predetermined schedule as developed by the HACCP team, as illustrated by the example in Table 3.18. At South East Water in Victoria, Australia, internal verification procedures include the following (Mullenger 2002):

• Random water quality sampling to substantiate that the water is safe; • Daily check of exceedance records such as indicator organisms and customer

complaints; and • Checks on appropriate corrective actions (booster chlorine dosing or flushing).


61

Table 3.18 Example verification schedule

Activity Description Frequency Responsibility Records Water quality monitoring

Customer tap sites throughout the supply system are sampled on a regular basis by an accredited independent Laboratory. This sampling program verifies the effectiveness of the HACCP System. Exceedances are monitored daily and field responses and re-sampling undertaken accordingly. Automated procedure in place for processing the daily exceedance notifications from the testing laboratory and generation of field response requests to the maintenance contractor.

Monthly Reference: annual water quality monitoring program

Manager Water Quality Planning

• Water quality database

• Automated exceedance management SOP

• Exceedance database

• Department of Health Report

• Monthly water quality report

Audit HACCP Plan

Internal and external audits are conducted on a regular basis to identify areas of poor performance and opportunities for improvement of HACCP plan. Audits also verify that activities comply with documented requirements.

Annual Reference: Management System Core Process

Business Improvement Coordinator

• Audit Schedule • Audit Reports • Management

system core process SOP

Review staff training

• All staff in critical areas of process operation and control is regularly trained.

• Relevant staff are trained annually by an accredited HACCP Consultant

• Relevant staff are annually trained by Water Industry Training Centre

Annual Reference: Management System - Core Process – Manage Human Resources

Manager Water Quality Planning

• Computer based personnel system “Human Resource Information System”

• Performance plans

• Training manual

Source: adapted from Yarra Valley Water 2005. Reprinted with permission.

The HACCP system should be revisited in its entirety by the HACCP team at least annually, when a hazardous event has occurred, or a significant system change has taken place. For example, the Plan is may be reviewed in the following circumstances (Mullenger 2002):

• Changes to water quality zone boundaries or the disinfection process; • Equipment or facility modifications such as covering an open reservoir; • Regulatory amendments; • Changes in piping materials or repair techniques; and • Occurrence of a significant hazardous event such as a security breach.


62

Water quality monitoring is often conducted as part of the external audit to verify that the HACCP plan is effective at producing water without unsafe or aesthetically unacceptable levels of hazardous contaminants. This type of verification monitoring may also be conducted by the utility.

The frequency at which verification auditing and monitoring is carried out depends on how long the HACCP team feels the system can remain unchecked before deviations might go undetected. Some items may require checking on a daily basis, while others may only need to be confirmed annually. For example, checks of coliform bacteria and customer complaints may occur daily, while audits on the emergency and maintenance work occurring within the water distribution supply system may occur on a weekly basis. Review of corrective actions may be scheduled on a monthly basis and supporting programs may be reviewed annually. Hints:

• Document verification schedules (i.e. items and their frequencies) within the HACCP plan.

• Review monitoring and corrective action procedures. • Regularly review data trends to identify areas for improvement. • Check on calibration schedules and records to assure that calibration is being

accomplished. • Include the person(s) responsible for each verification activity in the HACCP plan.

Step 12: Establish Documentation and Record Keeping

“Efficient and accurate record keeping is essential to the application of a HACCP system” (Codex Alimentarius Commission 1993). It provides retrospective proof of compliance to the HACCP plan and enables product traceability and facilitates continuous improvement from trend analysis. Record keeping can even support a legal defense. All HACCP documents and records should be dated and signed (Mullenger 2002).

Documentation and record keeping should be appropriate to the nature and the size of the organization operating the water distribution system. Examples of record-keeping and documentation for the distribution system include:

• All information used to develop the HACCP Plan; • Regulatory requirements; • Utility water quality and operational goals for distribution system; • Water quality monitoring program; • Monitoring results including deviations; • Associated corrective actions undertaken when a deviation occurs; • Verification activities (e.g. audit reports); • Validation records (e.g. EPA regulations and guideline); • Modifications and reviews of the HACCP system; and • Employee training and competency records.

A detailed example of CCP records for one distribution system process step is provided in Table 3.19.


63

Table 3.19 Example of critical control point records for one process

Process (owner) Causal events controlled Hazards controlled Pressurization of the distribution system (Water Distribution Engineer)

Re-contamination through ingress from loss of pressure leading to suction (recorded in risk register).

Microbial, chemical and physical hazards (recorded in risk register)

Critical limits Monitoring Corrective Actions Tank level for reservoir-pressurized systems never below low-low alarm level at any time (actual level different for each tank, recorded in the SCADA telemetry alarm system).

What: Tank level Who: Telemetry with alarms to Hydraulics Duty Officer oversight by Water Distribution Engineer. Where: In each service reservoir with some in the distribution system. When: On line continuous. Records: CITEC

Pressure from pump-pressurized systems never below low pressure alarm setpoint of ≥ 49 ft (15 m) head at lowest point (actual level different for each system, recorded in the SCADA telemetry alarm system).

What: Pressure Who: Telemetry with alarms to Hydraulics Duty Officer oversight by Water Distribution Engineer. Where: At the pressure monitoring SCADA point of each pumped system. When: On line continuous. Records: CITEC

What: Turning on additional pumps to maintain pressure. Open valves to re route water. Flush lines if negative pressure occurred. Incident management plan if not rapidly controlled. Who: Hydraulics Duty Officer and Field Services Hydraulics Workers. Where: On site. When: Action initiated within 15 minutes of deviation alarm. Records: Corrective Actions Register.

Validation Verification Supporting Programs Hydraulic design specifications are based on ensuring pump pressures and tank levels will pressurize the entire system for adequate flow to meet service standards to give ≥ 15 m head at all times (record: Water Supply and Sewerage Standards Code). Pressure tests were performed at peak day demand at lowest pressure points in system to validate this (recorded in LIMS).

Annual review by Water Distribution Engineer to inspect records of monitoring, corrective actions and calibration (recorded in Verification Schedule). Results from pressure and flow meters at key points are checked to see that pressure remains positive at all times (recorded in CITEC). Customer complaints related to pressure checked to ensure they are not caused by systematic pressure drops (recorded in customer complaints database). Compliance static pressure monitoring by independent lab at distal sites monthly (recorded in LIMS).

Calibration and maintenance of flow, pressure, and level gauges as directed by Maintenance Manager, Water twice per year (recorded in maintenance tracking system). Compliance with flow and pressure design practices (recorded in Water Supply and Sewerage Standards Code). Staggered watering during hot days (recorded in water restriction SOP).

Source: Adapted from the ActewAGL 2005 with permission.

Hints:

• Maintain only the current version of documents to prevent duplication or confusion. • Sign and date key documents to demonstrate that they are approved for use. • Document the hazard analysis and CCP determination including critical limits. • Consider using checklists and flow diagrams to simplify record-keeping. • Record monitoring results, deviations, corrective actions and reviews. • Review records for trends to identify the need for preventative action. • Develop the documentation and record keeping system with the personnel that will be

ultimately using them. • Maximize the use of electronic and simple record keeping in order minimizing

paperwork.


64


65

CHAPTER 4 PILOT TESTING OF HACCP PLANS

INTRODUCTION

This chapter describes pilot-testing activities conducted by four participating utilities, including Sydney Water Corporation in Australia, Power and Water Corporation in Australia, the City of Austin, Texas, and the South Berwick Water District in Maine. The locations of the Australian pilot study utilities are shown in Figure 4.1. The objective of the pilot testing is to develop HACCP Plans based on the tailored HACCP system developed as part of this Project and described in Chapter 3, and then implement the Plan for a 12-month testing period. The results of the implementation experiences are used along with utility input to assess the value of the HACCP system for protecting and maintaining distribution system water quality.

Katherine

Sydney

Queensland state

Australia

NorthernTerritory

New SouthWales state

Figure 4.1 Map illustrating the relative positions of the Australian pilot study sites


66

APPROACH

For each participating utility, proposed pilot-study activities included a training workshop, formation of a HACCP team, development of a HACCP Plan, implementation of the Plan, and preparation of a final report. The Project Team conducted the training workshops and assisted the utility’s HACCP team with aspects of the HACCP Plan development and implementation activities. The Project Team also developed surveys and criteria by which the utilities could assess their experiences with HACCP. The approach used for these pilot-study activities is discussed in the following sections.

Training Workshops

A training workshop was held at each utility location so that the Project Team could train utility staff on the HACCP principles and initiate development of the utility’s HACCP plan. Invitations to attend the workshop were extended to utility staff with a broad range of expertise and skill in all areas related to distribution system water quality (e.g. management, laboratory, operations, engineering, and construction). The workshop’s success depended on the caliber of workshop attendees; therefore, it was essential to include individuals with appropriate knowledge of the potential hazards and the control measures used to manage them.

An example workshop agenda is presented in Table 4.1 and training materials are included in Appendix A to this report.

Following informal introductions, background information was provided on the AwwaRF project, the purpose of the workshop and HACCP principles. Workshop attendees then began working through the basic steps of HACCP. At the conclusion of the U.S. workshops, attendees completed a written survey to capture their opinions on the HACCP system. The survey and survey findings are discussed later in this chapter. Such a survey was not completed for the Australian workshops, although a similar two-day HACCP workshop conducted as an open workshop for the Australian Water Association received high scores.

Table 4.1 Typical Workshop Agenda

Time Session 8:00 – 8:15 Purpose of Workshop 8:15 – 8:30 AwwaRF Project Overview 8:30 – 9:30 What is HACCP? 9:30 – 9:45 Break 9:45 – 10:45 Small Groups, Steps 1-5

10:45 – 11:45 Small Groups, HACCP Step 6 11:45 – 12:00 Wrap-Up, Small Group Findings 12:00 – 1:00 Lunch 1:00 – 2:00 Small Groups, HACCP Step 7 2:00 – 3:00 Small Groups, HACCP Steps 8, 9, and 10 3:00 – 4:00 Small Groups, HACCP Steps 11 and 12 4:00 – 4:30 Workshop Wrap-Up


67

Formation of HACCP Team

Each participating utility formed a HACCP team to complete the HACCP plan and to guide its implementation. Ideally, team members were a subset of the utility staff that attended the workshop. As with the workshop, it was important to include utility management on the HACCP team as well as utility staff with varying expertise and responsibilities related to distribution system water quality.

Development of HACCP Plan

Depending on the amount of work accomplished at the training workshop, the HACCP team then completed the HACCP Plan in one or more work meetings. The Team also consulted with various utility staff to confirm the accuracy of the process flow diagram and the classification of hazards, and to collect documentation on utility standard operating procedures, monitoring and inspection programs, and data management systems. HACCP Plans for Austin, South Berwick, and Power and Water Corporation are provided in Appendix B and are discussed in the section below entitled “Pilot Study Results.” The Sydney Water HACCP plan is not included in Appendix B because it is in a preliminary draft form. Management plans developed as part of the HACCP process are in Appendix D.

Development of Surveys and Evaluation Criteria

The survey shown in Figure 4.2 was developed to capture utility feedback on the HACCP system following the U.S. training workshops. Survey findings are discussed later in this chapter for each utility.


68

Dear Workshop Participant, Thanks for taking the time from your regular work to participate in the HACCP Workshop on June 25th. As part of our research, we would like your specific feedback on the workshop to determine if this HACCP process is useful to other utilities. Please take a few minutes and respond to the following questions. Thank you! 1. At the workshop, did you gain new information about South Berwick’s distribution system management practices or potential hazards? Circle One: Yes No Maybe If yes, please summarize. 2. Do you think other workshop participants better understand your area of responsibility and/or water quality concerns as a result of the workshop? Circle One: Yes No Maybe 3. After the workshop, did you think of any additional hazards or critical control points that were not mentioned that day? If so, please list here. 4. Would you suggest the HACCP process to other utilities for improving distribution system protection? Circle One: Yes No Maybe 5. Would you like to see the South Berwick Water District apply the HACCP approach to to the whole system, source to tap? Circle One: Yes No Maybe 6. Please comment on the workshop structure: a. Length of time: (Circle One) – too long too short ok b. Size of group (Circle One) – too large too small ok c. Workshop notebook content (Circle One):

too detailed not enough detail ok as is d. Presentation content (Circle One): too detailed not enough detail ok as is Additional Comments: Thanks for your input!

Figure 4.2 Example workshop survey form for South Berwick Water District

A set of evaluation criteria was used to assess the success of pilot testing. This evaluation was completed as a written survey by the utility HACCP team. The evaluation criteria are summarized in Table 4.2.


69

Table 4.2 Evaluation criteria for pilot studies

Question

Quantitative or

qualitative How assessed? When? By whom? Answer* Basis/

examples Group 1. Has HACCP implementation improved customer satisfaction?

• Reduced taste/odor complaints Quantity Utility records At end of monitoring period, compared with

the start.

HACCP team

• Reduced discolored water complaints

Quantity Utility records At end of monitoring period, compared with

the start.

HACCP team

• Reduced low pressure complaints Quantity Utility records At end of monitoring period, compared with

the start.

HACCP team

Group 2. Has HACCP improved regulatory compliance?

• E. coli or thermotolerant coliforms? Quantity Utility records At end of monitoring period, compared

with the start.

HACCP team

• Total coliforms? Quantity Utility records At end of monitoring period, compared

with the start.

HACCP team

• HPCs? Quantity Utility records At end of monitoring period, compared

with the start.

HACCP team

• Turbidity? Quantity Utility records At end of monitoring period, compared

with the start.

HACCP team

• Low pressures? Quantity Utility records At end of monitoring period, compared

with the start.

HACCP team

Group 3. Has HACCP provided stronger mechanisms for managing risks to public health than previously?

• Reduced water quality incidents†? Quantity Utility records At end of monitoring period, compared

with the start.

HACCP team

• Reduced chlorinator failures? Quantity Utility records At end of monitoring period, compared

with the start.

HACCP team


69

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

70


Question

Quantitative or


examples • Systematic identification and

prioritization of risks and control? Quality Judgment by water

quality staff At end of monitoring

period, compared with the start.

HACCP team

• Improved understanding of the distribution system?

Quality Judgment by water quality staff

At end of monitoring period, compared

with the start.

HACCP team

• Improved understanding and maintenance of positive system pressure?



with the start.

HACCP team

• Enhanced backflow and cross-connection prevention?



with the start.

HACCP team

• Has monitoring become more focused?



with the start.

HACCP team

Group 4. Has HACCP improved system management and control?

• Improved databases? Quality Judgment by management


with the start.

HACCP team

• Improved calibration schedules? Quality Judgment by management


with the start.

HACCP team

• Better targeted reporting? Quality Judgment by management


with the start.

HACCP team

• Improved record keeping? Quality Judgment by management


with the start.

HACCP team

• Made it easier for O&M staff to operate system?

Quality Judgment by management


with the start.

HACCP team


70

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

71


Question

Quantitative or


examples Group 5. Has HACCP improved human factors?

• Enhanced operator empowerment (ownership, understanding and involvement)?

Quality Judgment by Human Resources

and/or manage-ment


with the start.

HACCP team

• Did additional training in water safety get introduced?


and/or manage-ment


with the start.

HACCP team

• Did existing training become less ad-hoc and more structured?


and/or manage-ment


with the start.

HACCP team

• Improved senior management involvement?


and/or manage-ment


with the start.

HACCP team

• Improved relationships between management and operators?


and/or manage-ment


with the start.

HACCP team

• Improved clarity of accountability? Quality Judgment by Human Resources

and/or manage-ment


with the start.

HACCP team

• Has communication been improved within the utility and between the utility and external stakeholders?


and/or manage-ment


with the start.

HACCP team

71

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

72


Question

Quantitative or


examples

Group 6. Costs and benefits of HACCP. • What are the estimated costs of

implementation of the HACCP system?

Quantity Best estimate At start and end of monitoring period

HACCP team

e.g. How many meetings in-house,

paid support, people time in–

house on the project.

• What new processes and concepts did HACCP bring in?

Quality Judgment by utility HACCP Team

At start and end of monitoring period

HACCP team

e.g. internal and external auditing

• Was good use made of existing systems to minimize duplication and maximize integration?


At start and end of monitoring period

HACCP team

• What is the estimated value of the benefits of these changes?

Quantity Best estimate At end of monitoring period, compared

with the start.

HACCP team

e.g. reduced disinfection and

monitoring costs? • Has HACCP enhanced any

environmental outcomes? Quality Judgment by utility

HACCP Team At end of monitoring

period, compared with the start.

HACCP team

e.g. discharge of chlorinated water.

• How was the auditing (inspection, evaluation) process perceived?



with the start.

HACCP team

• Has continuous improvement been introduced?



with the start.

HACCP team

• Has credibility and due diligence improved?



with the start.

HACCP team

* To be completed by the project team in liaison with the utilities. † Major water quality problems leading to some kind of emergency response such as extensive dirty water events, taste and odor events, or suspected contamination events.

72

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

73

IMPLEMENTATION OF HACCP PLAN

Each utility planned to implement their HACCP plan over a 12-month period during which certain operational and water quality parameters would be monitored. Monitoring data can consist of the following information:

• Data to show that critical limits at critical control points were within acceptable limits (e.g. chlorination records, set points);

• Documentation of record-keeping (e.g. staff training, chemical ordering, laboratory records);

• Water quality monitoring data for verification (usually end-point testing); • Inspection reports; and • Records of any emergency response, incident reporting and corrective actions.

The participating utilities used standard industry practices for sample collection and shipping, and calibration and use of field instruments. Where available, certified laboratories were used for laboratory analyses. These laboratories employed quality assurance procedures and audits as required to maintain certification status. The Project Team reviewed sampling program details with utility personnel prior to the start of monitoring.

PILOT STUDY RESULTS

South Berwick Water District

The South Berwick Water District in Maine, U.S., serves approximately 4,000 people with groundwater supplies including well points, a gravel well and drilled bedrock wells in three separate aquifers. The water is treated with chlorine and UV disinfection. The District maintains and services a distribution system that includes over 31 miles (50 km) of water main and a 1 MG (4 ML) concrete reservoir. The District is noted for its proactive management of the water system. The District has an active wellhead protection program for its many groundwater supplies, and regularly completes system maintenance such as biannual main flushing. The District has participated in several AwwaRF-funded research projects.

Training Workshop

A one-day HACCP training workshop was held at the South Berwick Water District office on June 25, 2003. Workshop attendees included the four staff members of the water district plus several outside experts needed to provide expertise on relevant topics. The outside experts are listed in Table 4.3. The workshop agenda was similar to the example provided in Table 4.1. Meeting discussions were held as one large group rather than small breakout groups. Workshop attendees were able to complete HACCP Steps 1 through 7.


74

Table 4.3 Outside experts invited to South Berwick workshop

Name Organization Title Expertise

Terry Trott State of Maine Drinking Water Program

Operator Licensing Officer

State regulations, cross connection control programs

J. Kevin Reilly US EPA Region 1 Microbiologist Microbiological hazards

Kathy Martel EES, Inc. Project Manager HACCP, distribution system best management practices

Mark Arenberg South Berwick Water District

Trustee Engineering

Jeff Musich Wright-Pierce Vice President Engineering

The results of the written survey conducted at the end of the training workshop are

summarized in Figure 4.3. Seven of nine workshop participants completed the survey. The majority of survey respondents indicated that they gained new information about the distribution system during the workshop. All survey respondents thought that others gained a better understanding of their responsibilities and water quality concerns.


75

June 25, 2003 1. At the workshop, did you gain new information about South Berwick’s distribution system management practices or potential hazards? Circle One: Yes - 4 /7 No – 2/7 Maybe – 1/7 If yes, please summarize. New information included status of current backflow prevention program and other O&M issues. 2. Do you think other workshop participants better understand your area of responsibility and/or water quality concerns as a result of the workshop? Circle One: Yes – 7/7 No Maybe 3. After the workshop, did you think of any additional hazards or critical control points that were not mentioned that day? If so, please list here (None – 7/7) 4. Would you suggest the HACCP process to other utilities for improving distribution system protection? Circle One: Yes – 6/7 No – 0/7 Maybe – 1/7 5. Would you like to see the South Berwick Water District apply the HACCP approach to to the whole system, source to tap? Circle One: Yes – 6/7 No – 0/7 Maybe – 1/7 6. Please comment on the workshop structure: e. Length of time: (Circle One) – too long too short ok

0/7 0/7 7/7 f. Size of group (Circle One) – too large too small ok 0/7 0/7 7/7 g. Workshop notebook content (Circle One):

too detailed not enough detail ok as is 0/7 2/7 5/7

h. Presentation content (Circle One): too detailed not enough detail ok as is 0/7 0/7 7/7 Additional Comments: 1. Brought a better understanding of how HACCP can be applied to a small system like ours. 2. I am looking forward to see how this will work in Town. This will at least form a template for other small systems to utilize. 3. Well done – good process for rethinking.

Figure 4.3 Survey results for South Berwick Water District


76


The HACCP team included the four members of the Water District staff including the superintendent, foreman, service person, and office manager.

HACCP Plan Development

A meeting was held September 8, 2003 to finish the draft HACCP Plan. The Plan was then submitted to the PAC and Australian team members for review. After incorporating review comments, the HACCP Plan was completed in November 2003. It is included in Appendix B.

The process flow diagram developed for the HACCP Plan is shown in Figure 4.4. Although the AwwaRF project focuses on HACCP as applied to water distribution systems, a decision was made at the South Berwick workshop to include the whole system source-to-tap in the HACCP Plan.

Figure 4.4 South Berwick Water District process flow diagram In the hazard analysis (HACCP Step 6), 14 hazards were identified for South Berwick. A

simple, semi-quantitative scoring approach, illustrated in Table 3.9, was used to rate each hazard. In this approach, a score is assigned to each hazard for two factors, the hazard’s likelihood of occurring and the severity of consequences that could result from an occurrence (Gray and


77

Morain 2000; Deere et al. 2001). The scoring is based on a 1 to 5 scale. For the likelihood of occurrence factor, a score of 1 is given for a rare occurrence, while a score of 5 indicates a hazard that is almost certain to occur. Each hazard is also scored on the possible severity of consequences that could result, with a score of 1 for insignificant consequences and a score of 5 for catastrophic consequences. These two scores are multiplied to calculate the risk factor rating.

Eight of the fourteen identified hazards were classified as a low risk for South Berwick Water District. At the workshop, it was decided that a low risk would be defined as a risk score of 5 or less. These hazards include:

• Excessive water age in storage facility; • Excessive water age in distribution system piping; • Unintentional contamination of Willow Drive well from closed landfill or golf

course; • Installation of residential services; • New construction; • Contamination via pressure transients in area of former Superfund site/low pressure

area; • Vandalism/chemical contamination of Agamenticus well field; and • Installation of service lines for fire protection.

Four hazards were determined to be a medium to high risk with risk scores ranging from 10 to 20. These hazards include:

• Backflow through an unprotected cross-connection (risk score 20); • Intentional contamination via storage facility vents (risk score 10); • Contamination due to service line break (risk score 10); and • Contamination due to main break (risk score 10).

Two hazards were not classified due to a lack of water quality data. These hazards include:

• Unintentional contamination of shallow well points at Agamenticus well field; and • Long dead-end mains with zero or poor disinfectant residual.

Due to limited resources, the District decided to focus on three hazards for its pilot study:

• Backflow through an unprotected cross-connection (risk score 20); • Unintentional contamination of shallow well points (unrated); and • Long dead-end mains with zero or poor disinfectant residual (unrated).

The focus of the District’s HACCP Plan was to collect additional information to evaluate, document and improve control over these hazards. For example, although the District has a backflow prevention program, they lack complete records on the maintenance of backflow prevention devices owned by commercial customers.

At the time of the HACCP workshop (June 2003), the groundwater supplies at the Agamenticus wellfield were not disinfected. The District initiated disinfection in August 2003 at this wellfield. The initial idea for controlling the hazard of unintentional contamination at the


78

Agamenticus shallow well points was to conduct intensive monitoring for microbiological, chemical, and physical parameters in order to better characterize the microbiological risk. Per comments from the Project Team and with the advent of disinfection, the control of this hazard was changed to focus on the effectiveness of disinfection practices.

Implementation of HACCP Plan

Due to unforeseen circumstances, the South Berwick Water District withdrew from the Project in July 2004 without implementing their HACCP Plan. Nadeau (2004) explained that the Water District staff members were unable to implement the Plan due to other priorities, such as operating and maintaining the water system, building a new treatment facility, developing a new rate structure, dealing with local and state political issues, and struggling with unanticipated personnel and medical issues. South Berwick’s experience illustrates the need for sufficient manpower to successfully implement a HACCP Plan.


The City of Austin’s source of supply is the Colorado River. Untreated water for the pilot-study area is currently diverted at Lake Austin and treated at the Ullrich Water Treatment Plant using lime softening, recarbonation/pH adjustment, chloramination, filtration, and addition of ferric sulfate, fluoride, and sodium hexametaphosphate. Treated water is stored at the Ullrich Plant in two 10 MG (38 ML) clearwells and in the distribution system in tanks. The City owns and operates a contiguous distribution system that serves a population of approximately 770,000 through roughly 183,000 service connections. The distribution system contains 2,995 miles (4,819 km) of water mains of a wide variety of materials, including cast iron, ductile iron, PVC, asbestos cement, and reinforced concrete cylinder. The distribution system also contains 30 tanks ranging in size from 300,000 gallons (1 ML) to 34 MG (129 ML). Because of the varied topography in the City’s service area, the distribution system is divided into eight major pressure zones.

Training Workshop

On May 21, 2003, the City held a one-day HACCP workshop. Attendees included staff with a broad array of skill sets from various divisions within the Utility with varying perspectives on distribution system operations. In particular, attendees included individuals from the Water Laboratory, Systems Planning, Cross-Connection Control, Process Engineering, Distribution System Operation, Water Quality, Regulatory Compliance, and the state’s regulatory agency. The workshop agenda is shown in Table 4.1. Workshop discussions were held as one large group rather than small breakout groups. Workshop attendees were able to complete HACCP Steps 1 through 7 with the exception of Step 5 (Confirm Flow Diagram).

The results of the written survey conducted at the end of the training workshop are summarized in Figure 4.5. Nine workshop participants completed the written survey. All survey respondents indicated that they gained new information about the distribution system during the workshop. Most survey respondents thought that others gained a better understanding of their responsibilities and water quality concerns.


79


Following the workshop, the Utility pulled together a multidisciplinary team to develop, verify and implement a HACCP plan. Team members are shown in Table 4.4.

Table 4.4 Austin’s HACCP team

Name Position Role and responsibility Barrios, Rosie Water Laboratory Supervisor Laboratory and analysis expert

Bennett, Tony TCEQ Regulatory Manager State regulator

Bohr, Onnie Infrastructure Superintendent Field operations and maintenance expert

Burazer, Jane Asst. Director of Treatment Treatment expert

Kuhn, Robert Cross Connection Control Supervisor Cross connection expert

Lutes, Teresa Engineer/Planner Systems planning expert

Ojeda, Edward Construction Inspector Construction inspection expert

Pedersen, Dan Water Quality Manager Team leader


80

May 2003 1. At the workshop, did you gain new information about Austin’s distribution system management practices or potential hazards? Circle One: Yes – 9/9 No – 0/9 Maybe – 0/9 If yes, please summarize. a. The most useful part of the workshop was learning more about system operations, and dialogue with other groups about how they do their jobs. b. I learned how complicated the distribution system is and how difficult it is to manage. c. The City of Austin seems to be very aware of potential hazards, and seems to have adequate management already in place. d. The ways in which the other divisions do their job and the importance of all parties know how to properly identify hazards. 2. Do you think other workshop participants better understand your area of responsibility and/or water quality concerns as a result of the workshop? Circle One: Yes – 7/9 No – 1/9 Maybe – 1/9 3. After the workshop, did you think of any additional hazards or critical control points that were not mentioned that day? If so, please list here (NONE – 9/9) 4. Would you suggest the HACCP process to other utilities for improving distribution system protection? Circle One: Yes – 6/9 No – 0/9 Maybe – 3/9 5. Would you like to see the City of Austin apply the HACCP approach to the whole distribution system? Circle One: Yes – 4/9 No Maybe – 5/9 One survey respondent said yes but indicated a concern on HACCP’s impact on work processes. 6. Would you like to see the City of Austin apply the HACCP approach to the whole system, source to tap? Circle One Yes No Maybe

3/9 0/9 6/9 7. Please comment on the workshop structure: i. Length of time: (Circle One) – too long, too short, ok

1/9 1/9 7/9 j. Size of group (Circle One) – too large, too small, ok

0/9 0/9 9/9 k. Workshop notebook content (Circle One):

too detailed not enough detail ok as is 0/9 0/9 9/9

Presentation content (Circle One): l. too detailed not enough detail ok as is 0/9 2/9 7/9 Additional Comments: 1. The process of getting information out of participants and up onto the flip chart for recording for everyone to see was slow. Perhaps some better procedure for getting brainstorming ideas out and visible for other participants to see might be found. 2. HACCP seems to be a good system; however, I don’t know if it will contribute that much to a city like Austin that seems to have covered all the bases already. A city that is not as well organized may benefit more from HACCP implementation.

Figure 4.5 City of Austin workshop survey results


81


The HACCP Team met several times during the summer of 2003 to finalize the remaining steps of the plan. The draft HACCP Plan was reviewed by the Project Team and the PAC during the Fall 2003. The HACCP Plan is included in Appendix B.

The process flow diagram developed for the HACCP Plan is shown in Figure 4.6. The utility selected one pressure zone in the distribution system to conduct its study. The Southwest C Pressure Zone is located on the periphery of the Utility’s distribution system and was selected because of a number of boil water advisories issued within that zone in recent years. Additionally, the Southwest C Pressure Zone has other features that make it appropriate for a HACCP plan. It contains four routine monitoring sites for the Total Coliform Rule that provide a history of water quality in the area. One of the monitoring sites also serves as a monitoring point for compliance with the Disinfection By-Products Rule, which further enhances understanding of water quality in the area. The Southwest C Pressure Zone is located on the extreme southwestern edge of the distribution system, containing maximum water age for that portion of the distribution system. Water traveling to this area passes through two tanks and three pump stations, which have the potential to affect water quality by increasing water age. It is a growing area with new construction occurring. It is a semi-rural area with older homes on septic systems that, should they fail, might pose a hazard to leaking water mains subject to low or negative pressure transients.


82

Figure 4.6 City of Austin process flow diagram

The hazard analysis (HACCP Step 6) completed at the workshop identified a number of

potential hazards for the pilot study area:

• Backflow through an unprotected cross connection (risk score 25); • Contamination at new construction sites (risk score 20); • Backflow from failing septic systems into distribution main (risk score 9); • Contamination due to water main break or repair (risk score 12); • Pathogen intrusion to distribution main due to leaky sewage main (risk score 10); • Intentional contamination of distribution system by vandals (risk score 9); • Contamination due to main break outside pressure zone (risk score 8); • Contamination due to pressure transient (risk score 4); • Presence of bacteria due to low disinfectant residual (risk score 4); and • Presence of bacteria due to zero disinfectant residual (risk score 4).


83

The HACCP team decided to base the pilot study on two particular hazard events that scored high marks in the hazard analysis – backflow from unprotected cross-connections and hazards at new construction sites that can potentially degrade the finished water quality. The concern for possible contamination at new construction sites focused on contractors’ unauthorized operation of system valves and the effectiveness of disinfection of new mains prior to being placed into service.


Implementation of the HACCP plan began on October 1, 2003 and ended on September 30, 2004, coinciding with the utility’s 2003-04 fiscal year.

Monitoring strategies associated with a HACCP Plan do not rely solely on water quality testing but may also include inspections and checks on various databases or other utility records. For example, one hazard selected by Austin – backflow from unprotected cross-connections includes the following monitoring strategies to evaluate the effectiveness of control measures:

• Plumbing inspections and water protection surveys to identify any unprotected cross connections and to check for working backflow prevention devices;

• Plumbing inspections and water protection surveys to check on repairs of failed backflow prevention devices;

• Pressure monitoring throughout the distribution system to evaluate whether system pressure is being maintained;

• Reviews of the utility’s database to check if annual inspections of backflow prevention devices were conducted; and

• Visual inspection of on-site septic systems to check for system failures.

Monitoring strategies for Austin’s new construction site hazard include:

• Phone and radio contact with site personnel to check on unauthorized use of system valves;

• Visual inspection of contractor disinfection practices on new water lines; • Water quality samples to check coliform bacteria counts and free chlorine levels of

water in new mains prior to being placed into service; • Monitoring tank water level and pressure point alarm levels that would indicate if any

valves were opened between two pressure zones; • Site inspections to check if contractors utilized the One-Call system (a

communication system that provides a toll-free number for contractors/designers to call facility owners prior to excavating to prevent damage to underground facilities and utility lines) to mark water utility lines; and

• Reviews of sign-in sheets for training workshops to check whether site inspectors attended required training sessions.

Results of Pilot Study

The City of Austin’s pilot study report is provided in Appendix C. Austin found that HACCP is more complex than initially envisioned. Originally, the

Utility thought that HACCP would involve identifying critical flow paths within the distribution


84

system and monitoring these flow paths more intensively to assure water quality to downstream sites. Instead, by nature of the selected hazards, the measures used to control these hazards focused on operations and maintenance activities rather than water quality monitoring. This approach added layers of complexity to the existing monitoring program.

Austin determined that existing databases would need to be modified to facilitate the implementation of HACCP system-wide. Databases that track plumbing inspections, cross-connection inspections, waterline disinfection, and etc., were not set up with HACCP in mind. Most existing utility databases can recall data by street and City grid, but not by pressure zone. Therefore, data retrieval was undertaken manually and was cumbersome.

Austin found that implementing the HACCP plan was a lengthy time commitment including HACCP team meetings, coordination meetings with other staff, and time spent on database management. It is difficult to estimate the cost of implementing HACCP for Austin because they only tracked HACCP team meeting time and not other staff time spent implementing HACCP procedures. Because Austin’s HACCP Plan only represented one small portion of their distribution system, the resource requirements for implementing HACCP system-wide were not developed.

The HACCP pilot study helped Austin to raise employee awareness on several issues:

• The need to respond quickly to main breaks in small pressure zones. • The location of pressure zone boundaries. • The possibility of pressure transients causing low or negative pressure in the

distribution system. • The need to maintain positive pressure at all times. • Improved understanding of existing data sources and data management system

capabilities. • Improved understanding of distribution system issues.

No significant water quality incidents occurred in the Southwest C pressure zone during the pilot study period or the preceding 12 months so the City was unable to assess whether the HACCP Plan helped to reduce the number of water quality incidents. Although reduced numbers of customer complaints were recorded during the pilot-study period as compared to the previous 12 months, these reductions are not necessarily a result of the HACCP Plan. The HACCP training workshop did help the City complete a systematic identification of risks and control.

Sydney Water Corporation

Sydney Water Corporation supplies 20 percent of Australia's population, about four million people. It used the Woronora Water Supply System for the purpose of this study. This system has the capacity to serve a large, urban community of 200,000 people. However, during the major part of the year, it supplies only 100,000 people due to its requirements to maximize river flow within its catchment, limiting its capacity to supply the total system. This creates operational issues in relation to variable draw down from the water filtration plant and less demand within the distribution system. The system receives surface water from a fully protected, forested watershed and is treated using direct filtration and chloramination. The system was recently successfully converted to chloramination.


85

Training Workshop

During August 2003, Sydney Water held a two-day HACCP workshop. Attendees included planning and operational staff dealing with both treatment and distribution system operations. In addition, contract staff members were in attendance. The workshop agenda is shown in Table 4.1. In this case, workshop discussions were held as one large group rather than small breakout groups. Workshop attendees were able to complete most of HACCP steps 1 through 12 but only in an outline form. The purpose of the workshop was training rather than plan completion.


At the workshop, Sydney Water decided to structure their HACCP plan along similar lines to South East Water, Victoria, Australia, by developing a series of subplans. Team members are shown in Table 4.5.

Table 4.5 Sydney Water’s HACCP team

Name Position Role and responsibility Corinna Doolan Project Manager

HACCP Champion & Project Manager

Lindsay Mullard Area Team Leader Water Distribution System Operational Team Leader

Colin Storey General Water Australia Principal Chemist

Treatment issues

Keith Ross General Water Australia Operations Manager

Treatment issues

M. Govintharajah

Relationship Leader Treatment issues

David Cooper Water Network Officer Reservoir subplan

Shariff Shockair

Network Management Officer Pressure and backflow subplan

Tony Venturino Water Quality Discoloured water subplan Disinfection subplan

Carl Deininger

Water Operations Water age and hydraulics subplan Maintenance subplan

Peter Cresta

Environment & Innovation Water quality monitoring quality assurance On-line monitoring calibration

Philip Broad

Water Quality Leader Project leadership

Dammika Vitanage Area Water Quality Specialist Project leadership


86


The HACCP Team worked together over several months with the HACCP Champion maintaining minutes and coordinating the activities of each person. A risk assessment was developed using an Excel spreadsheet.

The utility selected the whole of its Woronora system for the case study. The system has approximately 700 miles (1,126 km) of pipelines, 20 covered service reservoirs and about 78,000 service connections. The supply is continuous.

Subplans were developed for particular risk areas by operational and planning staff as designated in Table 4.5. The subplans were assembled into a single document and reviewed by the Project Team and the PAC during the Fall 2003. The process flow diagram developed for the HACCP Plan is shown in Figure 4.7.

The initial list of risks was reviewed and grouped into a shortlist of risks to develop management plans. Sydney Water proposed to focus its HACCP plan on the following issues relating to:

• Maintaining chloramine residuals; • Optimizing system hydraulics; • Securing finished water storage facilities; • Managing discoloration; • Reviewing main repairs to minimize risks for recontamination; and • Maintaining system pressure & backflow prevention.

The team identified a number of items to be monitored at frequencies varying from continous through to weekly or annually (Table 4.6 and Table 4.7). These were part of the normal compliance and operational monitoring runs that were in place already within the system.

The Sydney Water HACCP plan is not included in Appendix B because the HACCP process was undertaken within the context of the organization’s existing ISO 9001 quality management system. Instead, examples of Management Plans arising from the HACCP process are included as Appendix D.


87

Ampol

PenshurstAllawah

WP123

Woronora Dam

Woronora

Heights

ANSTO

CaringbahR020 - online total Cl2

WP030 KurnellSutherlandR175N - online

total Cl 2 , pH &

turbidity

IllawongR270 - onlinetotal Cl2

Menai

LucasHeights

Royal NationalPark

Heathcote NationalPark

Garrawarra(private)

Helensburgh

Waterfall

Georges River

Heathcote

Engadine

Loftus

MaianbarR227 - onlinetotal Cl2

25,000 customers10 ML/day




60 ML/day

WP319

WP071

WP116

WP173

WP045

X

X

X

X

X

X

X

XX

XX

1

2A

2B

3

4

5

6

7

8

9 10

11 12

WFP

Normal Supply from Warragamba Dam

C:|My documents|Woronora|schematic withonline & compliance monitoring sites.ppt

WORONORA

DISTRIBUTION

SYSTEM 13.1

(18 compliance sitesmonthly)

HELENSBURGH DIST. SYSTEM 13.2

(8 compliance sites monthly)

SUTHERLANDDIST. SYSTEM8.6 (14 compliancesites monthly)

online total& free Cl 2,pH,redox &turbidity

R348 online total Cl 2

HargraveHeights

Stanwell Pk

X - Section Valves - Reservoirs

WP318

WP320

Oatley

-Water Pumping Stations

Figure 4.7 Sydney Water Woronora system flow diagram


88

Table 4.6 Critical monitoring parameters for Sydney Water HACCP Plan

Monitoring parameter Criticality Pressure Critical

Tank level Critical

Backflow prevention Critical

Tank security Critical

Chlorine:ammonia • Free chlorine • Total chlorine • Monochloramine • Dichloramine • Ammonia

Critical

Disinfection residual • Chloramine

Critical

E. coli Critical

Nitrite Non-critical

Nitrate Non-critical

Total coliforms Non-critical

Heterotrophic plate count Non-critical


89

Table 4.7 Sydney Water Corporation monitoring program

Sampling location Monitoring parameter

Monitoring frequency, type

Documentation

HWO1 - Raw Water Chlorine E. coli

Ammonia Nitrate Nitrite

Total coliforms HPC20

Continuous, on-line Weekly

As above As above As above As above As above

SCADA LIMS database

As above As above As above As above As above

HWO2 – Downstream of CWT Compliance / hand over point

As above As above As above

Section Valve 3


Reservoirs • Engadine Helensburgh • Heathcote Menai • Maianbar Illawong • Reservoirs R362 Inlet

& • R258 Outlet

Tank level Tank security

Chlorine and speciation E. coli

Ammonia Nitrate Nitrite

Total coliform HPC20


As above As above As above As above As above As above As above

SCADA Inspection records

LIMS database As above As above As above As above As above As above

Bombora Ave Bundeena Pressure Chlorine and speciation

E. coli Ammonia

Nitrate Nitrite

Total coliform HPC20


As above As above As above As above As above As above

SCADA LIMS database

As above As above As above As above As above As above

Clough Ave Illawong


Critical backflow high hazard customers

Backflow prevention unit and audit

Annually Inspection records

Ave - Avenue LIMS – Laboratory information management system SCADA – Supervisory Control and Data Acquisition system


In implementing the HACCP plan, security patrols were increased and improved chlorine residual monitoring was undertaken. In addition, more information about system operations began to be recorded on paper and management of hydraulics and water age became more


90

systematized. The existing ISO 9001 quality system was considered to have been enhanced by the use of the HACCP system since the HACCP system helped to focus attention on the most important quality system procedures.

After the first six months of implementation, the following issues were identified as being of particular importance:

• Maintaining chloramine residuals; • Optimizing the system hydraulics; and • Securing finished water storage facilities.

Some issues were identified from the HACCP program monitoring. For example, a drop in chlorine residuals was identified that was related to system hydraulics. The issue was recognized as a result of the HACCP system implementation.

The spreadsheet register of risks generated as part of the HACCP plan was reviewed after six months. Upon reflection, many of the risks identified as high or medium were re-classified as low following more experience.

The monitoring results were not used to provide information on trends for several reasons. First, after many years where routine flushing was possible, the worst drought on record prevented this practice leading to an expectation of reduced water quality. Second, changes in water quality were expected to only conclusively arise following periods of several years. Therefore, in the short-term, HACCP was considered to be more of a system for monitoring to identify the need for corrective actions rather than a tool for trend analysis. The objective and subjective evaluation of the HACCP plan by Sydney Water is detailed in Table 4.8.

Sydney Water believed that the HACCP model utilized for the project was a useful tool for helping to structure water quality risk assessment and management. Sydney Water has proposed to adopt a standard operational procedure within its quality system that recommends the use of HACCP in updating its quality system.

Table 4.8 Sydney Water perspective on HACCP pilot study

Question Answer Basis/examples Reduced taste/odor complaints? Reduced discolored water complaints?

No attributable change

There was a slight decrease in complaint numbers but there was also a change in the complaints recording system in October 2004. It was not possible to assess the impact of HACCP.

Reduced low pressure complaints No change System experiences minimal low pressure problems, usually from short-term shutdowns only.

Reduced E. coli or thermotolerant coliforms? Reduced total coliforms? Reduced HPCs? Reduced turbidity? Reduced low pressures?

No attributable change

During the pilot study period, many system changes were instituted as well as a change in testing methods (to Colilert). Therefore, it was not possible to determine the impact of HACCP.

Reduced water quality incidents*?

No change No water quality incidents were experienced.



91


Question Answer Basis/examples Reduced chlorinator failures? Yes A HACCP plan for disinfection in the Woronora

system was in place before the project commenced and may have helped to reduce chlorination failures.

Systematic identification and prioritization of risks and control?

Yes Completed as part of the HACCP workshop. Following the workshop, major risks were grouped and developed into management plans.

Improved understanding of the distribution system?

Yes The HACCP project gave the system operators a more focused direction on system operations including a more structured performance review process.

Improved understanding and maintenance of positive system pressure?

Yes Operating reservoirs at lower levels to improve throughput without compromising system pressure.

Enhanced backflow and cross-connection prevention?

No change Audits were already required to establish adherence to maintenance procedures.

Has monitoring become more focused? Yes Awareness was raised on the possible locations of risks and the required monitoring locations. Critical performance levels were determined.

Improved databases? Yes One data management system required changes to meet the needs of the system operators to allow storage of monthly trends.

Improved calibration schedules? No change Calibration schedules were already well-managed.

Better targeted reporting? Yes Reporting became more focused on priority areas as determined by HACCP identification of risks and critical control points.

Improved record keeping? Yes The system operators became more focused on reviewing the system on a regular basis and summarizing events and exceptions.

Made it easier for O&M staff to operate system? Yes The performance review became more structured, concentrating on critical assets.

Enhanced operator empowerment (ownership, understanding and involvement)?

Yes Operators have been more involved in developing standard operating procedures and understanding their purpose and relevance. Operators and management have improved utilization of existing information systems.

Did additional training in water safety get introduced?

No change No additional training was carried out.

Did existing training become less ad-hoc and more structured?

No change Training was not part of this HACCP plan.


(Continued)


92


Question Answer Basis/examples Improved senior management involvement?

Yes A standard operating procedure on HACCP was developed for Sydney Water as a whole.

Improved relationships between management and operators?

Partially It is premature to assess improved relationships for the total process. However, in relation to the disinfection process, relationships have improved.

Improved clarity of accountability? Yes System operators have become more focused. Water quality is not seen as the exclusive domain of the water quality group.

Has communication been improved within the utility and between the utility and external stakeholders?

Yes Communication has improved within the utility on disinfection issues for the case study area.

What are the estimated costs of implementation of the HACCP system?

$60,000 Includes internal staffing costs for meetings, site visits and system review.

Did HACCP introduce new processes and concepts?

Yes Giving ownership to the system operators; promoting the drinking water framework.

Was good use made of existing systems to minimize duplication and maximize integration?

Yes The existing quality assurance system was used. As a result of HACCP, it was determined that this quality assurance system needs to be streamlined.

What is the estimated value of the benefits of these changes?

Not quantified Not applicable.

Has HACCP enhanced any environmental outcomes?

Possibly When disinfection management improves, there is less discharge of chlorinated water to the environment.

How was the auditing (inspection, evaluation) process perceived?

Not applicable No auditing was carried out.

Has continuous improvement been introduced? Yes Improvements were made to data management system and use of system performance data for decision-making. System operators have improved their focus on the daily system operations.

Has credibility and due diligence improved? Yes The HACCP process actively identifies system faults through ongoing review activities.

N/A – not applicable * Water quality incident is defined as a major water quality problem leading to some kind of emergency response such as extensive dirty water events, taste and odor events or suspected contamination events.

Power and Water Corporation

Power and Water Corporation is responsible for providing energy, water, sewerage, and communications services throughout the Northern Territory of Australia. The total population of the Territory is approximately 200,000 persons. Power and Water’s geographical coverage

(Continued)


93

extends from the city of Darwin, in the tropical north, to the outback town of Alice Springs located in the arid climate of central Australia. Power and Water operates across a diverse range of urban centers, rural centers and remote Aboriginal communities. Darwin is the largest population center with a population of 100,000 and is supplied water primarily from a surface water reservoir in a protected catchment. The surface supply is supplemented with groundwater from a protected aquifer. The reservoir is recharged during the monsoon, wet season (November to April) and is drawn down through the dry season (May to October). The only treatment is chlorination (primary and secondary) and fluoridation. In comparison, townships in the arid region rely on a groundwater bore supply where water resources are limited. In many cases, chlorination is the only form of treatment.

The Katherine water supply system was selected for the Project pilot study. Katherine is located 186 miles (300 km) south of Darwin and has a population of approximately 10,000 persons. The utility selected the whole of its Katherine system, including the water treatment plant, for the pilot study. At the treatment plant, untreated surface water undergoes coagulation/flocculation, clarification and filtration. The filtered water is then combined with groundwater that has been aerated and the combined flow is then chlorinated and fluoridated. For part of the year during which the raw surface water turbidity is low, the plant’s operation is altered and the raw surface water is only filtered. The system contains three closed storage tanks in the distribution system, approximately 61 miles (98 km) of mains and about 2,000 customer service connections.

Training Workshop

During August 2003, Power and Water Corporation held a two-day HACCP workshop. Attendees included senior management, water quality, and operational staff including those from the head office in Darwin and those operating the Katherine system. The workshop agenda was similar to the example shown in Table 4.1. Workshop discussions were held as one large group rather than small breakout groups. Workshop attendees were able to complete most of HACCP Steps 1 through 12 but only in an outline form. The purpose of the workshop was training rather than plan completion. A second workshop was also held in December 2004 to review the draft HACCP plan once written.


At the workshop, Power and Water representatives agreed there would be one HACCP team with most of the work being coordinated from the Darwin head office. A smaller coordination group was also established to drive the pilot project; however, difficulties were faced with maintaining the momentum of this group. A senior manager’s group was also established to provide oversight to the pilot project and implementation of HACCP across other systems.

Late in 2004 an engineer was employed and located in Katherine to facilitate implementation of the pilot project. Table 4.9 lists the team members who were involved in the pilot project at the completion of the pilot project. During the course of the pilot project, a number of the initial HACCP team members left the organization to undertake emergency aid work overseas following the tsunami in late December 2004.


94

Table 4.9 Power and Water Corporation’s HACCP team

Name Position HACCP role Responsibility in HACCP Simon Copley

Asset Maintenance Coordinator • Implementation of plan

Norm Cramp

Manager Water Operations Team member Management commitment

• Review plan to recommend approval

• Facilitate implementation of plan upon approval;

• Verification of plan

Mark Ewin Assistant/Water Treatment Plant Operator

Team member • Implementation of plan

Gabrielle Halcrow

Environmental Heath Officer

Team member Technical expert

• Input to plan on area of expertise

Paul Heaton

Manager Water Facilities Team member Management commitment

• Review plan to recommend approval

• Facilitate implementation of plan upon approval

Peter Hopkins Water Treatment Plant

Operator

Team member • Implementation of plan upon approval


Noel McCarthy

Project Manager Quality Systems

Coordination Team member Technical expert

• Input to plan on area of expertise • Development of plan • Verification of plan

Leon Miles Water Quality Engineer Team member

• Implementation of plan • Verification of plan

Kevin O’Brien Katherine Systems Coordinator

Team member • Implementation of plan upon approval


Declan Page

Senior Resource Planner Team member Technical expert

• Input to plan on area of expertise • Validation of plan


The Project Manager of Quality Systems undertook the majority of HACCP plan development over several months. The HACCP plan is included in Appendix B. The primary process flow diagram developed for the HACCP plan is shown in Figure 4.8.

Power and Water Corporation developed both critical control points (CCPs) and non-critical control points (NCCPs). Within the distribution system the CCPs included:

• Maintenance of chlorine residuals; • Closed storage facilities;


95

• Backflow prevention program; and • Pressure maintenance practices.

The HACCP team identified a number of critical monitoring parameters to be monitored at frequencies varying from continuous to weekly as summarized in Table 4.10.


96

CCP 1/1 & 1/2

CCP 2/1 –2/5 NCCP A-C

Catchment surface runoff to Katherine River

Catchment inflow/infiltration to aquifer

Donkey Camp pool (open storage reservoir)

Tindal aquifer

Donkey Camp transfer pumping station. COLTS monitoring DO and turbidity

Extraction by submersible pumps at production bores RN 6983 and RN 7807

Turbidity < 250 NTU and/or DO ≥ 7mg/L ? If “NO” DSS may require switch to groundwater supply

DSS sub-process

Transfer via rising main


WTP sub-process

Transfer of treated water to closed storages

Symbol Description Symbol Description Symbol Description Symbol Description Operation Decision Storage Sub-process

Inspection Delay Transfer Product user

Figure 4.8 Power Water Corporation’s Katherine supply process flow diagram


WSWT


97

(Continued)

CCP 3/1

CCP 3/1

CCP 3/1

4.5 ML closed storage tank (supplies Katherine south). COLTS monitoring closed storage tank levels

9 ML closed storage tank (supplies Katherine south). COLTS monitoring closed storage tank levels

12 ML closed storage tank (supplies Katherine East & Tindal RAAF base). COLTS monitoring closed storage tank levels

Sub-process for controlling closed storage tank levels by operation of delivery pumps

Transfer via distribution/reticulation mains

Customers in Katherine East and South supply zones

Tindal booster pump station


Interface with Tindal RAAF base






98

(Continued)

Disinfection by chlorination (by others)

Transfer of treated water to closed storages

2 x 2.5 ML closed storage tanks (Tindal RAAF base). COLTS monitoring closed storage tank levels (by Power and Water)

Sub-process for controlling closed storage tank levels by operation of Tindal booster pumping station

Transfer of treated water via pipes





99

Table 4.10 Power and Water Corporation monitoring program

Sampling location Monitoring parameter

Monitoring frequency, type Documentation

Closed storage tanks: 1.2 MG (4.5 ML), 2.4 MG (9 ML) and 3.2 MG (12 ML)

Tank level Continuous, on-line SCADA reports

Tindal booster station: test point within compound

Chlorine residual Taken week days, field measurement. Daily water test sheets

Crawford Street: Hose tap within sewage pump station compound


Lucy Street: test point on water service


Tindal booster station: test point within compound Crawford Street: Hose tap within sewage pump station compound Lucy Street: test point on water service Katherine East Pump Station

Fecal coliforms or E.coli HPC

Weekly Water quality database

Fire hydrant on each new main constructed by private developer

Fecal coliforms or E.coli HPC

Single grab sample taken and laboratory analysis performed. Connection to existing network does not proceed until pass result

Laboratory test report

SCADA – supervisory control and data acquisition


100


Implementation of the HACCP plan began on April 1, 2004 and is continuing. It is Power and Water’s intention to implement HACCP for the Katherine system plus seventeen other systems across the Northern Territory.

Power and Water found that the simple diagram that describes the 12 steps of HACCP belies the challenge of actually implementing HACCP properly to achieve the maximum benefits. For example, it is possible that completing steps 9 through 12 will require new processes to be established and, in most cases, documented to ensure their permanence. Power and Water endorsed the need to accept at least some shortcomings in existing operational monitoring, practices, records management and etc., and define a program of improvements (captured in the HACCP plan) to address these shortcomings, rather than try to achieve perfection with the initial HACCP plan. Of course, this approach only works if the identified shortcomings do not seriously compromise the system in the short-term.

Another issue identified by Power and Water in applying HACCP is the flexibility in translating broad HACCP principles into specifics (i.e. what exactly has to be done and how can it be undertaken). Power and Water found that using the management system standard ISO 9001 was useful to provide guidance on how to develop an effective management system to help effect the process control elements of HACCP. Power and Water also benefited from reviewing HACCP plans for other water utilities.

Power and Water identified that HACCP implementation to more than one water supply system across a large area, such as the Northern Territory, is significantly more resource-intensive than the effort required to implement HACCP for a single system. The effort required in conducting workshops, developing multiple plans, managing greater amounts of data and information, coordinating participants, undertaking audits, and monitoring progress can consume large amounts of time. Senior management commitment to such a program is essential and this must translate into clear priorities and adequate resources.

An existing, sufficiently developed ISO 9001 quality management system addressing water quality management can greatly facilitate HACCP implementation because the organization will have already defined, developed and, where appropriate, documented its management and production processes. Many of the HACCP prerequisite supporting programs would be addressed through the ISO 9001 system. For example:

• Management review – existing structures and processes would already be developed to

enable review of data and information including customer complaints, exceedances/ exceptions, etc.

• Internal auditing – an established auditing system (i.e. schedules, procedures, auditing tools, trained auditors etc.) would readily accommodate HACCP-specific requirements while ISO 9001 process audits would address the compliance of core management and product realization processes.

• Measuring and monitoring – appropriate monitoring of processes and drinking water would be defined and implemented (e.g. operational and compliance monitoring programs) including effective calibration of portable, laboratory, and permanent in situ water quality measuring and monitoring equipment including provision of appropriate records.


101

• Purchasing – control over procurement activities such as the supply of drinking water treatment chemicals should be in place which can impact on production processes and drinking water quality.

• Corrective and preventive actions – well established processes should be in place for responding to exceedances/exceptions including documentation of actions taken, and evaluating effectiveness of measures and processes for managing more permanent changes.

In many cases the implementation of an ISO 9001 management system will drive the

organization to address the adequacy of many of its supporting information technology systems which manage data and information (e.g. SCADA, water quality database, backflow device database, land development activity database etc.). These sources of data and information can often be the source of records to review the effectiveness of HACCP control measures.

During HACCP implementation, extra on-line instrumentation was installed at the water treatment plant and additional chlorine analyzers were installed downstream of the 1.2 MG (4.5 ML) and 2.4 MG (9.0 ML) storage facilities. Local personnel were also responsible for the provision of water supply services to six other small towns in the region, the furthest of which was located 9 hours by road from Katherine. Additional on-line instrumentation was installed in a number of these locations. During the pilot project a new chlorination facility was constructed at the water treatment plant via a construction contract and local personnel undertook training and assisted with commissioning. In combination these were significant commitments to undertake during the course of the pilot project.

In order to effectively apply HACCP requirements, new equipment must be calibrated, maintained and integrated with existing SCADA. Additionally, data capture processes must be established. There were challenges with ensuring this level of rigor due to Katherine being a remote supply. Small, remote towns are not likely to be a base for technicians that undertake specialized equipment calibration and maintenance services. This is an important finding from the project since HACCP often drives increased on-line monitoring of critical control point parameters. Because there is a need to support equipment maintenance and calibration as part of the HACCP supporting programs, the choice of monitoring equipment needs to be made while considering the available technical support.

In preparing the HACCP system for certification, significant additional process mapping and documentation was required at an operational level but this was incomplete by the time of the AwwaRF project completion. Certification had not been applied for or awarded at the time of writing. Power and Water was intending to implement ISO 9001 by July 2006 and this was assisting with the development of any required documentation and record-keeping for HACCP. There was a view that HACCP certification would be valuable to provide a driver for maintaining effort and focus on water quality management. The view was that if the emphasis on the HACCP system was taken away, people and processes may lose their focus and/or revert to previous practices.

In terms of performing the hazard (i.e. risk) analysis, a revised, novel, qualitative/semi-quantitative scoring matrix will be introduced in 2005/2006 for Power and Water. The novel matrix was considered by Power and Water to overcome a number of limitations inherent in the scoring matrix used by Power and Water for the pilot project. Figures 4.9 and 4.10 compare the two scoring matrices and indicate their important features.


102

An objective and subjective evaluation of the HACCP system by Power and Water Corporation is detailed in Table 4.11.

Likelihood

Risk Factor Matrix:

Rare Rating

1

Unlikely Rating 2

Moderate Rating 3

Likely Rating 4

Almost Certain Rating 5

Catastrophic Rating 5

High 5

Extreme 10

Extreme 15

Extreme 20

Extreme 25

Major Rating 4

High 4

High 8

Extreme 12

Extreme 16

Extreme 20

Moderate Rating 3

Low 3

Medium 6

High 9

High 12

Extreme 15

Minor Rating 2

Low 2

Low 4

Medium 6

High 8

High 10

Insignificant Rating 1

Low 1

Low 2

Low 3

Medium 4

High 5

Seve

rity

of C

onse

quen

ces

Risk Factor Matrix Source: Adapted from AS/NZS 4360:1999 (superceded); AS/NZS 4360:2004; and HB 436-2004 (“the Works”) with permission from SAI Global Ltd. These standards can be purchased at http://www.sai-global.com

Figure 4.9 Risk scoring matrix used for the pilot by Power and Water

Discontinuity as risk passes from high to low without passing through medium

Poor differentiation between risks with catastrophic consequences and almost certain likelihood


103

Likelihood Risk Factor

Matrix: Rare Unlikely Moderate Likely Almost

Certain Catastrophic

Rating 5

High 15

Extreme 19

Extreme 22

Extreme 24

Extreme 25

Major Rating 4

High 10

High 14

Extreme 18

Extreme 21

Extreme 23

Moderate Rating 3

Medium 6

Medium 9

High 13

High 17

Extreme 20

Minor Rating 2

Low 3

Low 5

Medium 8

High 12

High 16

Insignificant Rating 1

Low 1

Low 2

Low 4

Medium 7

High 11

Seve

rity

of C

onse

quen

ces

Risk Factor Matrix Source: Adapted from AS/NZS 4360:1999 (superceded); AS/NZS 4360:2004; and HB 436-2004 (“the Works”) with permission from SAI Global Ltd. These standards can be purchased at http://www.sai-global.com

Figure 4.10 New risk scoring matrix to be used by Power and Water following their experience with the pilot

All cells have unique risk score Improved

differentiation between risks with catastrophic consequences and almost certain likelihood

Discontinuity removed as risk now passes from high to low by passing through medium


Table 4.11 Power and Water Corporation perspective on HACCP pilot study

Question Answer Basis/examples Reduced taste/odor complaints? N/A Pilot study period was too short to evaluate the impact of HACCP on reduction in complaints.

Reduced discolored water complaints?

N/A Pilot study period was too short to evaluate the impact of HACCP on reduction in complaints.

Reduced low pressure complaints?

N/A Pilot study period was too short to evaluate the impact of HACCP on reduction in complaints.

E. coli or thermotolerant coliforms?

No change Already observe a high level of compliance.

Total coliforms?


HPCs?


Turbidity?


Low pressures?

No change The network has adequate pressure.

Reduced water quality incidents?*

No change No significant water quality event occurred during the pilot study period.

Reduced chlorinator failures?

N/A Chlorinators are not used in the distribution system.


Yes A risk assessment was undertaken at the workshop.


Yes Additional pressure monitoring was undertaken to assist with network modeling.


Yes All team members are more aware of the implications of system pressure loss.


Yes HACCP can drive the setting of monitoring requirements & performance measures that demonstrate program effectiveness, similar to “critical limits”.


104

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Question Answer Basis/examples Has monitoring become more focused?

Yes On-line chlorine analyzers have now been installed downstream of two distribution service storage facilities. In addition, other on-line monitoring has been installed at the water treatment plant to improve process control.

Improved databases? No change This item was outside the scope of the pilot project. However, the project has highlighted that information technology solutions are required in a number of areas to successfully implement HACCP (particularly if it is applied to multiple systems) e.g. 1) risk management software to register risks, controls, track improvements, changes in risk etc. 2) water quality database capable of accepting operational monitoring data (e.g. on-line data, field testing), water quality monitoring data, as well as recording exceedances and tracking corrective action.

Improved calibration schedules? No change Some difficulties were identified in calibrating on line systems in remote areas. These difficulties have broader implications for HACCP implementation in regional areas.

Better targeted reporting? N/A Not assessed.

Improved record keeping? Yes A variety of new forms have been developed to improve record keeping; however, it is recognized that upgraded information technology systems are needed to more efficiently assist record management.

Made it easier for O&M staff to operate system?

No change Implementation is still ongoing.


Yes Operator understanding of risks was enhanced.


No change Training was not a major emphasis of the pilot project.


N/A Training was not a major emphasis of the pilot project.

Improved senior management involvement?

Yes Two senior managers are members of the HACCP team. Five senior managers make up a higher level management group that oversees implementation of HACCP.


105

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Question Answer Basis/examples Improved relationships between management and operators?

Potentially This was not a major emphasis of the pilot project; however, through ongoing engagement, this outcome is anticipated.

Improved clarity of accountability? Potentially Documentation of a HACCP plan setting roles & responsibilities of individuals has the potential to improve accountability; however, successful implementation requires that all team members have full understanding.


Yes Communication improvement within the utility has been greater than between the utility and external stakeholders. The HACCP team included an environmental health officer so there has been some limited communication of our work to their department. Also our annual report provides some information on HACCP implementation.


Not quantified

Unable to quantify in dollar terms because implementation hours were not tracked. To successfully implement HACCP, a dedicated coordinator is required as well as a commitment/initiative from all team members to undertake their part. We initially had two workshops (one training & one workshop to agree on a final HACCP plan) which involved the team and others. This required organizing a dozen or so people to meet in Katherine which is a three hour drive from Darwin. Where there is more than one water supply system and systems that are widely dispersed geographically, then implementation of HACCP is far more complex. In addition, substantial time has been invested coordinating and attempting implementation. Also, various team members have been working on specific improvements (e.g. installing new monitoring equipment, strengthening catchment management). We initially started with a monthly coordination meeting (not on-site), a senior managers meeting every 6-7 weeks, plus about 5 site visits. It proved difficult to convene the team during implementation. All this was difficult to maintain but is required to initiate implementation. On-site we have found implementation difficult without a full time presence and have employed another engineer to drive implementation. Information technology solutions are necessary.

Did HACCP introduce new processes and concepts?

Yes Internal auditing (focus on documentation and record keeping); Semi-quantitative risk assessment; Increased awareness of pressure transients leading to intrusion.


No HACCP highlighted deficiencies in many existing areas. Applying HACCP is not as straightforward as working through the 12 steps. For successful implementation, many processes and systems need to be established (e.g. equipment calibration, complaint handling, water quality exception reporting, data management).


106

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Question Answer Basis/examples What is the estimated value of the benefits of these changes?

Not quantified

Our expectation is that operational costs will rise as a consequence of new monitoring equipment installed. (i.e. increased calibration requirements), change in treatment process requiring increased chemical use.


Potentially

HACCP is expected to result in improved environmental outcomes once new arrangements are finalized, agreed upon and implemented. A spin off from HACCP has been that it required various processes & activities be examined. This included review of existing new mains construction & commissioning processes which re-examined disposal of chlorinated water.


Too early to say

No identified problems, although only one audit completed.

Has continuous improvement been introduced?

Too early to say

Continuous improvement would require far more time to establish and would only begin to emerge with more frequent auditing, plan reviews etc.

* Major water quality problems leading to some kind of emergency response such as extensive dirty water events, taste and odor events, or suspected contamination events. N/A – not applicable O&M – operations and maintenance HPCs – heterotrophic plate count bacteria

107

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

108

CONCLUSIONS The pilot utilities found that the implementation of HACCP to water supply distribution

was feasible and practical, but that the time and resource requirements were greater than originally anticipated.

The resource constraints were most acutely noted by the experience of the South Berwick Water District. For this very small utility, with only three full time staff members working during the latter part of the pilot, developing and implementing a full HACCP system was not achievable given the many day-to-day duties and activities of the utility staff. Given the genuine commitment of utility staff to the HACCP pilot, it is likely that this is a fundamental difficulty in the implementation of HACCP within small water utilities. It is important to note that these difficulties are likely to be common to the implementation of any systematic process control system, whether it be named HACCP or something else, so the solutions to these problems are likely to be more generally relevant. If HACCP, or any other systematic process control system, is to be promoted for small water utilities, there are several changes that could be made to enable implementation to be successful:

• Increase the number of employees on staff within small utilities to provide a critical mass

of personnel. • Provide temporary, contracted, support for a sufficient time period to implement the

system, funded by a third party, if required. • Provide generic HACCP plans and guidance combined with very explicit guidance,

support and tools to help utilities implement the systems in practice. • Provide support from the state or regional regulatory and support organizations.

For the larger utilities, there were sufficient resources to implement HACCP although

there was a requirement to have some specific resources reasonably dedicated and assigned to the HACCP implementation task. Importantly, the preparation of the HACCP plan per se was not resource-intensive. Rather, it was the implementation of the HACCP plan to create a functional HACCP system in practice that required the resources. For example, the HACCP plan may recognize the need for calibration of monitoring equipment – a relatively simple item to capture within the plan. However, implementing adequate calibration processes in practice can be a significant task. Therefore, it can be concluded that implementing HACCP, or any systematic water quality process control system of similar rigor, is likely to be a significant undertaking for a water utility. Further, it is the implementation rather than the planning that is the resource intensive component of the overall HACCP process.

Despite the greater than anticipated resource requirements for implementation, the participating utilities concluded that the HACCP process is valuable. The development of the HACCP plan was useful in honing in on the most important risks and process controls for water quality management. The implementation of the HACCP system was useful in driving improvements in water quality management. The activities required to implement a HACCP plan are all sensible ones that would contribute to increased water quality security. Therefore, the decision about whether or not to implement HACCP is based on an assessment of benefits versus costs.


109

CHAPTER 5 CASE STUDIES

INTRODUCTION

Five of the leading water utility participants of the Cooperative Research Centre for Water Quality and Treatment (CRCWQT) in Australia have independently developed and certified HACCP plans for their water distribution systems. These utilities include:

• Brisbane Water (in the state of Queensland); • City West Water (in the state of Victoria); • Gold Coast Water (Queensland); • South East Water (Victoria); and • Yarra Valley Water (Victoria).

Whereas the four “Pilot Study Utilities” participating utilities for this project developed their HACCP plans during the project, the five “Case Study Utilities” described in this chapter completed their HACCP plans up to seven years before the report was written. The purpose of this chapter is to provide additional guidance based on this accumulated experience with the application of HACCP to water distribution.

All five case study utilities provide drinking water to major Australian cities as illustrated in Figure 5.1. Brisbane Water, serving Brisbane, and Gold Coast Water, serving Gold Coast, are located in a sub-tropical climate where as South East Water, Yarra Valley Water and City West Water serve different parts of Melbourne and its surrounding communities which have a temperate climate.

Brisbane Water and Gold Coast Water are part of the local government authority and utilize water from unprotected or partially protected watersheds. The three utilities serving the Melbourne area are corporations owned by state government and purchase water from a wholesaler, Melbourne Water Corporation. Additional information on the nature of the five case study utilities is provided in Table 5.1.


110

Brisbane Water

Gold Coast Water

Yarra Valley Water, South EastWater and City West Water

Queensland state

Australia

Victoria state

Figure 5.1 Map illustrating the location of the five case study utilities


Table 5.1 Case study utilities - system descriptions

Criterion Brisbane Water City West Water Gold Coast Water South East Water Yarra Valley Water Population (connections) 1.0 million +

(0.4 million +)

0.6 million + 0.5 million 1.3 million (0.6 million)

1.6 million (0.63 million).

Ownership Local government (city council) business unit

State-owned corporation (Victoria, Australia)

Local government (city council) business unit



Origin of source water Surface water dam storages, unprotected catchments

From the wholesaler, Melbourne Water. Protected catchments (70%); unprotected catchments (30%)

From Hinze Dam system (85%) semi-protected catchment. 15% from Brisbane Water (unprotected catchment)

From the wholesaler, Melbourne Water. Protected, forested catchments

From the wholesaler, Melbourne Water. Protected catchments (75%); unprotected catchments (25%)

Treatment 100% flocculation, filtration, pH correction, chloramination

70%: chlorination, pH correction, fluoridation; 30%: filtration plus as above

2 water treatment plants with coagulation, filtration, and disinfection Brisbane Water contribution is similarly treated

Melbourne Water, chlorination, pH correction, fluoridation

Melbourne Water: Chlorination (28 zones) Chloramination (3 zones) Ultraviolet disinfection (1 zone) Microfiltration (2 zones) pH correction and fluoridation Approximately 25% conventionally filtered

Distribution system management

In house. Planning in house. Field operations via maintenance contractor

In house

Planning in house. Field operations via maintenance contractor

Planning in house Field operations via maintenance contractor

Water quality monitoring In house. In-house management. Sampling and testing by laboratory contractor

In house lab for common chemistry and microbiology. Specialized tests outsourced

In-house management. Sampling and testing by laboratory contractor

In-house management. Sampling and testing by laboratory contractor

Internet address brisbane.qld.gov.au citywestwater.com.au goldcoastcity.com.au southeastwater.com.au yvw.com.au

111

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

112

HACCP IMPLEMENTATION

The five participating utilities provided information on the implementation process as summarized in Table 5.2. Implementation issues are discussed in the following section.

Implementation of Other Management Systems Prior to HACCP

Most utilities that have gained HACCP certification have done so after some core management systems had been developed and implemented. These management systems helped the utility to gain management control of people and processes. The need for management systems and other supporting programs was described in Chapter 3.

International Organization for Standardization (ISO) Management Systems

There has been great pressure from customers, regulators and the broader community for Australian water utilities to transparently and objectively demonstrate good practices with respect to environmental protection, worker safety and water quality.

The ISO has developed a number of generic management systems tailored to particular aspects of organizational management activity. For example:

• ISO 9001 covers “quality management,” that is, the quality of products or services produced by an organization. Water utilities have been using ISO 9001 systems to help drive improvements in all aspects of customer service and operations, including water quality.

• ISO 14001 covers “environmental management,” that is, the impact that an organization has on the environment. Water utilities have been using ISO 14001 certification to drive and demonstrate good environmental protection in general, and in particular, for their sewage management activities.

• ISO 4801 (and the various state and Australian equivalents) covers “occupational health and safety.” Because water utility staff sometime undertakes potentially dangerous work, utilities have been using ISO 4801 and equivalent systems to help drive and demonstrate sound occupational health and safety practices.


113

Table 5.2 HACCP implementation and maintenance

Criterion Brisbane Water City West Water Gold Coast Water South East Water Yarra Valley Water Year certified 2000 (treatment)

2003 (distribution)

2000 (distribution) 2001 (treatment and distribution)

1999 (distribution) 1999 (distribution)

Scope of HACCP Plan

Wholesaler interface to customers’ meters


Full system from dams to customers’ meters



Other management systems in place prior to HACCP

ISO 90021 Quality System; ISO 14001 Environmental System; AS ISO 4801 Occupational Health & Safety NATA Laboratory Accreditation

ISO 9002* Quality System; ISO 14001 Environmental System; AS ISO 4801 Occupational Health & Safety

ISO 9001 Quality System; ISO 14001 Environmental Management System

ISO 9001 Quality Management System (since 1995) 14001; Environmental Management System (since 1996)

ISO 9001 Quality Management System (since 1995). 14001 Environmental Management System (since 1996)

Management systems adopted after HACCP

Integrated Management System

None Member of Water Treatment Alliance (Australian version of Partnership for Safe Water)

Integrated Management System to streamline and integrate all systems (2002); State Occupational Health and Safety Management System (since 2000)

AS ISO 4801- Occupational Health and Safety (2003); AS7799 -Information Security Management System (2004)

In-house resources used to implement HACCP

Scientific Services Manager plus HACCP co-ordinator

Water Quality Scientist Director appointed a HACCP champion to create system in consultation with operational staff

Mostly done in house. Chief Executive Officer and General Manager support was established. Operations (Field Services) Division appointed a HACCP Champion who convened the high-level in-house HACCP team and sat on all five in-house sub-teams (distribution, disinfection, backflow, reservoirs, new extensions)

Management commitment from Managing Director and General Manager; HACCP Coordinator responsible for overall management of HACCP; Network Operations (CCP management) and Customer operations (backflow prevention) divisions undertake relevant individual tasks


113

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

114


Criterion Brisbane Water City West Water Gold Coast Water South East Water Yarra Valley Water (Continued on next page)

Duration of development and implementation of HACCP

Initially staged for treatment and then distribution. 12 months initially + 12 months

One month. 12 months to prepare plans and procedures for dams, two water plants and distribution system

Three months Three months

Internal resource requirement for plan development and implementation

HACCP coordinator 20% 24 months, manager 5% 24 months, various team members

0.75 FTE for one month HACCP champion full time; Approximately 10 team members contributed occasional verbal advice upon request.

HACCP champion: full time; team members (20 in total), 1/5 time; Total 5 FTE for 3 months

HACCP coordinator: full time - 3 months; team leader – full time -1 month; team members (10) – 3 days for workshops.

Ongoing internal resource requirement for maintenance of HACCP plan

0.5 FTE 0.2 FTE HACCP Champion full time

HACCP Champion: 1/3 time Team members (20 in total), 1/10 time Total 2.33 FTE ongoing.

HACCP Coordinator (15%) team members (10) – (5 %)

Contracted support Pre-audit and audit by independent firm

Pre-audit and audit by independent firm

Pre-audit and audit by independent firm

Coaching-style support from outside consultants. Certification pre-audit and audit from independent firm

External consultant was engaged to undertake a detailed risk assessment prior to HACCP Plan development External consultant with HACCP expertise in the food industry facilitated the plan development.

External costs during plan development and implementation

Funded through recurrent expenses

$13,000 (Australian Dollars) ($10,500 US Dollars)

$15,000 (Australian Dollars) ($12,000 US Dollars) in instruments and $90,000 (Australian Dollars) ($72,000 US Dollars) per year increase in testing budget. (61 out of 74

$35,000 (Australian Dollars ($28,000 US Dollars) (training and coaching costs)

Total cost approximately $40,000 (Australian Dollars) ($31,000 US Dollars)

114

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

115


Criterion Brisbane Water City West Water Gold Coast Water South East Water Yarra Valley Water urban tanks were never being tested prior to certification.)


External costs during plan maintenance

Audit fees $3,000 (Australian Dollars) ($2,500 US Dollars) per year (audit fee)

Approximately $6,000 (Australian Dollars) ($5,000 US Dollars) per year in external audit costs

$3,000 (Australian Dollars) ($2,500 US Dollars) per year (audit fees)

Audit fees $3,000 (Australian Dollars) ($2,500 US Dollars) per year. Annual staff training using an accredited HACCP trainer $1,500 (Australian Dollars) ($1,200 US Dollars)

Employee Training NATA HACCP Course, DPI Centre for Food Technology used to train staff

No formal training provided

Operational and management staff was given initial awareness training. HACCP champion was an experienced quality auditor

Around 25 staff and selected stakeholders (regulator, lab, contractor, bulk water supplier) were trained up front via a tailored 2-day HACCP for water course HACCP champion trained in quality auditing

About 20 staff and maintenance contractor personnel trained annually HACCP coordinator trained on development, validation, verification and auditing of HACCP using a licensed training provider

* ISO 9002 is a former ISO Quality System that has been phased out. ISO 9002 applied to “production” processes whereas ISO 9001 applies to “design and production.” CCP – Critical Control Point FTE – Full-Time Equivalent ISO – International Organization for Standardization NATA – National Association of Testing Authorities, Australia

115

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

116

At least two of the above systems had been implemented prior to the implementation of HACCP systems by case study water utilities. The existence of these management systems within water utilities greatly facilitated the implementation of HACCP:

• Cultural change: the organizational culture had moved to a point where utility staff was used to operating within a management system environment. Utility staff was familiar with concepts such as accountability, external and internal auditing, the use of standard operating procedures, exceedance reporting, training and competency standards, calibration, quality assurance, etc.

• Documentation and record-keeping: the additional requirements of HACCP with respect to documentation and record-keeping are often quite small once an organization has experience with a management system. For example, South East Water only required six additional procedures to be documented in implementing its HACCP plan.

• Cost – The cost of implementing HACCP may be lower for utilities that have previously implemented other quality management systems.

Integrated Management System

In practice, the case study utilities did not operate multiple, separate systems for quality management, occupational safety, water quality and safety, and environmental considerations. These separate systems were captured, as required, within an integrated management system (IMS). The principal benefit of an IMS, as identified by water utilities, was the avoidance of duplication, leading to reduced staff time and costs, and improved process integration. For example, if a utility has an SOP for a particular process, that same SOP is developed with consideration being given to the implications for staff safety, environmental impacts and drinking water quality and safety.

HACCP is one of the four common management systems that are captured within an IMS and, therefore, is readily integrated and audited as part of an IMS. Integrated audits generally took place whereby utilities could seek certification for ISO 9001, ISO 14001, AS/NZS 4801 (an occupational health and safety standard), and HACCP, as required. This integration avoided the need for a whole extra audit process. However, one or more additional auditors was usually added to the IMS auditing team to ensure sufficient expertise was available in HACCP, water safety and quality issues.

Some utilities, such as Melbourne Water (not one of the case study utilities), no longer describes their HACCP plans as “HACCP” plans. Instead, a “Water Quality Management Plan” was developed and certified against both HACCP and ISO 9001. Similarly, City West Water obtained its certification for “HACCP-9000” which represents an integrated HACCP and ISO 9001 quality and safety management system. Terms such as ‘Water Safety Plan” (Davison and Bartram 2004) are also used.

Costs of Implementing a HACCP System

The reported cash costs of implementation of HACCP systems varied between utilities:

• One-time cash costs for HACCP training, coaching, technical advice and documentation varied from $0 (Brisbane Water) to $70,000 (Australian Dollars)


117

($55,000 US Dollars) (Yarra Valley Water). The variability is primarily explained by the difference in the extent to which utilities used external service providers to undertake some of the tasks.

• Recurrent cash costs associated with increased water quality monitoring and instrumentation varied from $0 (Brisbane Water) through to $105,000 (Australian Dollars) ($84,000 US Dollars) (Gold Coast Water) on an annual basis. The variability is related to the extent to which additional monitoring or operational costs arose from the increased risk management activities that the HACCP team deemed appropriate.

• Some utilities, such as Yarra Valley Water, adopted the recommended practice of annual HACCP awareness training, requiring an additional recurrent cash cost of $1,500 (Australian Dollars) ($1,200 US Dollars) annually. New staff, or staff that are losing familiarity with HACCP, attend the training course each year.

Non-cash costs of HACCP implementation varied between utilities. Implementation almost always required a full time, dedicated officer, for at least one month and up to twelve months. For example, City West Water required 0.75 a full-time equivalent (FTE) for one month, while Gold Coast Water utilized 1 FTE for twelve months. The variability is related to the extent to which tasks were split between a core coordinator and other staff, as well as the amount of work required to implement the HACCP plan. For example, City West Water had completed the vast majority of tasks required by HACCP before the organization formally began to undertake its HACCP process and was able to complete the HACCP plan within one month.

It is important to note that these utilities had all implemented other quality management systems prior to implementing HACCP and therefore, their costs may not be comparable to a utility implementing only HACCP.

MAINTENANCE OF HACCP SYSTEMS

Active maintenance of the HACCP system and its good water quality management practices is primarily required to prevent complacency leading to the breakdown of the controls. In addition, HACCP systems are intended to respond to a variety of inputs by facilitating the implementation of ongoing improvements.

In terms of activity, maintenance of the HACCP system involves internal auditing and other forms of verification, issue identification, and the implementation of improvements. In addition, adaptation of the HACCP system is required in response to water supply system changes as well as in response to important new knowledge or information about water quality. Once certified, a utility can expect to receive external certification audits at either 6-month or annual intervals in order to maintain its certification.

Case study information related to maintenance is summarized in Table 5.2. Some utilities commented that although external audits require a significant time commitment, they do provide a source of discipline as well as help in identifying opportunities to improve water quality and safety. In one case, a utility commented that its certification was almost lost at a time when other priorities led to reduced activity in the maintenance of the HACCP system and the auditing process had the benefit of alerting the organization to the issue.

The cost of maintaining a HACCP system in a medium sized water utility was estimated by the case study utilities as follows:


118

• Recurrent cash auditing costs were consistently between $3,000 (Australian Dollars) and $6,000 (Australian Dollars) ($2,500 to $5,000 US Dollars) per year with audits requiring from three to five days.

• In terms of internal costs, maintenance of the plan required between 0.2 FTE on-going (City West Water) up to more or less one FTE on-going (South East Water, Yarra Valley Water and Gold Coast Water).

BENEFITS OF HACCP SYSTEMS

All five case study utilities noted that HACCP implementation was used to provide a coordinating framework for the implementation of risk and quality management systems to achieve water quality improvements. The HACCP system was a means of consolidating and gaining certification for these improvements. Importantly, all five case study utilities have retained their HACCP certification since it was awarded, seeing it as a net positive.

Two of the five utilities, Brisbane Water and City West Water, did not observe significant improvements as a result of HACCP system implementation. Both utilities believed that they had already undertaken the vast majority of activities required by HACCP before starting the HACCP process itself. Despite these limitations, the process was seen as positive by both utilities. HACCP was considered a likely contributor to improved water quality. For example, City West Water noted that HACCP implementation led to increased staff training with respect to water quality and awareness.

A number of tangible benefits from the implementation of HACCP were perceived by three of the five utilities: Gold Coast Water, South East Water, and Yarra Valley Water. However, specific “improvements” were considered difficult to attribute entirely to HACCP implementation for two key reasons:

• Water quality improvement activities may have been undertaken without HACCP being a driver for change.

• Tangible water quality data that may provide useful indicators of water quality improvements are highly variable due to climate and other sources of “noise”, making it very hard to conclusively detect effects and even harder to attribute them to any one possible contributory cause.

Despite the difficulties in establishing cause and effect and quantitative relationships, the case study utilities identified a number of benefits that were significantly related to HACCP implementation:

• Reductions in customer complaints; • Improvements in water quality; • Improvements in process performance; • Improvements in work processes; • Cost savings; • Improved understanding of risks and risk management; • Improvements in documentation and recordkeeping; and • Demonstration of due diligence.


119

These benefits are discussed in the following sections. Details are provided in Tables 5.3, 5.4, and 5.5 for Gold Coast Water, South East Water, and Yarra Valley Water, respectively.


Table 5.3 Gold Coast Water Perspective on HACCP Application to Distribution System

Question Answer Basis/examples Reduced taste/odor complaints? Yes See data listed under discolored water complaints.


Yes 1999-2000: 2,116 water quality complaints. 2003-2004: 730 (complaints in year 2004 calculated on a greater scope and with better data capture technique).

Reduced low pressure complaints? N/A Not measured as part of HACCP.

Reduced E. coli or thermotolerant coliforms?

Yes Prior to HACCP (prior to 2001), 82% of storage tanks were not tested. Therefore, past data are misleading but compliance with industry standards was nevertheless very high. 2002-2003: 2% positives. 2003-2004: 1.5% positives. Change from fecal coliform to E. coli February 2004.

Reduced total coliforms? Yes 2002-2003 and 2003-2004 results > 95% pass. No data for 1999-2000 but testing regime was very selective and non-representative at that time.

Reduced HPCs? Maybe Long-term average for Gold Coast is around 50 CFU/mL with a mean of <10 CFU/mL. This has not significantly changed.

Reduced turbidity? Yes At water plants, turbidity has decreased since HACCP from around 0.2-0.3 NTU to now being routinely < 0.1 NTU. Data consistency has improved and the magnitude of variations has been reduced. Distribution system turbidity values do not vary much. The mean turbidity was 0.4 NTU for 2001-2002 and 2003-2004.

Reduced low pressures? N/A Not assessed as part of HACCP.

Reduced water quality incidents?* Yes Prior to HACCP, incidents were not well-captured. In the 4 years since HACCP was implemented, there have been between 4 and 8 incidents per year. However, this is subjective because the criteria for declaring an incident is subjective. An incident to some may be business as usual for others.

Reduced chlorinator failures? N/A Complete failures are rare (Only 2 failures in 4 years); however, deviations from tighter HACCP limits have been slightly more common. These would not have been noticed prior to HACCP.


Yes Risk identification is now part of normal business, automatic and ongoing. (Continued on next page)

120

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Question Answer Basis/examples Improved understanding of the distribution system?

Yes The previous monitoring regime was based on population density and convenience. The HACCP system revealed weaknesses in smaller supply zones.


Yes But not in the scope of Gold Coast HACCP.


Yes But these problems were adequately controlled before HACCP.

Has monitoring become more focused?

Yes We now monitor according to where our risks are greater. The selection of sites, the frequency of tests and the selection of parameters are now based on risk, not just compliance. Customer complaints are better investigated and there is more accountability by distribution system operational staff.

Improved databases? Yes Central database has been altered to make investigation of trends easier.

Improved calibration schedules? Yes Calibration frequencies, record keeping and even techniques have been reviewed and improved. On-line instruments are checked against reference instruments during HACCP audits.

Better targeted reporting? Yes Reporting of all HACCP excursions is made to all senior management. Operational staff is given updates three times daily of current water quality complaints to help gauge impacts of their activities.

Improved record keeping? Yes Historical data with respect to water quality is superior in accessibility and scope now compared to pre-HACCP.


Yes HACCP excursion reports encourage best practice while simultaneously allowing operators to communicate design, maintenance, equipment, funding, and staffing issues to management.


Yes Culture change has been marked. Water plant operators now would not personally consider operating above 0.2 NTU as acceptable. Reticulation staff now considers water quality impacts as part of the many activities they carry out. There is a high level of awareness that accountability is unavoidable and this drives ownership and involvement. Energy is required to drive this cultural environment. HACCP excursion reports encourage best practice while simultaneously allowing operators to communicate design, maintenance, equipment, funding, and staffing issues to management.

121

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Question Answer Basis/examples (Continued on next page)


Yes HACCP procedures dictated the standard of performance required and gave instruction on methods to achieve this performance. This necessitated some “refresher” training e.g. jar testing skills, reservoir inspection techniques.


N/A Training was not a major emphasis of the HACCP Plan.


Yes In the Gold Coast model, management has no choice but to be intimately involved in the HACCP system. All HACCP excursions are sent to managers for their information. It would be rash of management to ignore these and in practice, they do not.


Yes HACCP excursion reports have in the past highlighted problems with staffing, training, asset condition, system design. Operators are happy that HACCP has brought attention to problems they wish addressed

Improved clarity of accountability? Yes Marked change in accountability through out the organization. HACCP system is designed to increase the probability that poor performance will be exposed. System has features that provide strong incentives for all levels of the organization to be accountable.


Yes HACCP has been such a success in this area that it has been extended to wastewater plants, effluent reuse, and trade waste management. Again, energy is required to keep communication flowing.


In the Gold Coast example (2 water plants and 500,000 population) one full time tertiary qualified person is required.

What new processes and concepts did HACCP bring in?

Better monitoring and reporting. More rapid response to adverse conditions. Plant failures in turbidity, and manganese control have demonstrably improved. Water quality complaints are better controlled (numbers lower).


Yes The improvements have primarily come from doing a better job with what we have.

122

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Question Answer Basis/examples



Gold Coast has a raw water supply that is low in risk and therefore, the consequences of failure are not necessarily serious. The reduction of water quality complaints by 50 percent in the last 4 years may or may not have a monetary value. The dramatic improvement in treated water turbidity since 2000 may or may not have a monetary value. HACCP has shown where capital and maintenance expenditure needs to be made and also, sometimes, where it does not need to be made e.g. replace filter backwash system in preference to repaint clarifier.


Yes Gold Coast has been using HACCP in wastewater since August 2003. Data already shows decreases in the mass discharges of nitrogen and phosphorus from all three HACCP-certified plants.


Mixed reaction

Staff are now used to HACCP audits and understand their necessity and value. However, they are a little uncomfortable for staff because the audits are detailed. Trends are examined closely and cross checked with other information. Even on-line instruments are checked against references. The auditing is carried out by people with technical expertise. Utility staff is called on to account for any failures not properly reported.


Yes Under the Gold Coast HACCP system, continuous improvement is unavoidable. In order to avoid HACCP excursions, operational staff focuses on being proactive. Management cannot be seen to be ignoring HACCP excursions in case the root cause is in their arena. The auditing system forces the communication both ways to continue. The “warning bell” nature of HACCP critical limits means improvement has a greater chance of being timely.

Has credibility and due diligence improved?

Yes For almost every aspect of water quality management, there is a HACCP procedure designed to detail the risk, monitoring, corrective action and reporting. Gold Coast HACCP system monitoring results are available on request to customers and all HACCP internal audit reports and excursion notifications are “discoverable documents.” The system is designed in the belief that at any time Gold Coast Water may have to produce proof of diligence. The regard for credibility and diligence is turned into a powerful driver by the structure of the HACCP system.

N/A – not applicable

* Water quality incident is defined as a major water quality problem leading to some kind of emergency response such as extensive dirty water events, taste and odor events or suspected contamination events. HPCs – heterotrophic plate count bacteria

123

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Table 5.4 South East Water Perspective on HACCP Application to Distribution System

Question Answer Basis/examples Reduced taste/odor complaints? Yes Difficult to quantify, but overall, the number of water quality customer complaints per 1,000 customers has dropped

by more than 60% since HACCP was introduced. However, all of this decrease cannot be attributed to HACCP. Some is due to changes in customer perceptions since water restrictions were introduced and changes in demand profiles with the introduction of water restrictions.


Yes See above.

Reduced low pressure complaints? N/A Not considered in HACCP plan.


Yes Number of samples with E. coli has reduced over time. This is partially due to HACCP and improved system understanding, and also due to increased disinfection levels.

Reduced total coliforms? Yes Numbers have decreased through better system understanding, some of which were related to HACCP.

Reduced HPCs? N/A Not considered in HACCP plan.

Reduced turbidity? Yes Turbidity-specific controls in place, although an improved understanding of the causes of turbidity is being used to minimize discolored water complaints.

Low pressures? N/A Not considered in HACCP plan.

Reduced water quality incidents?* Yes Water quality incidents have reduced from one every few months to none.

Reduced chlorinator failures? N/A No primary chlorinators in system.


Yes Done as part of HACCP plan development and ongoing review.


Yes As above.


Yes Improved understanding of need for positive pressure. Primary distribution systems off gravity pressure systems.


124

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Question Answer Basis/examples Enhanced backflow and cross-connection prevention?

Yes Improvements made to backflow prevention strategy.

Has monitoring become more focused?

Yes Operational monitoring was more focused at understanding causes for events. However, this is not directly driven by HACCP.

Improved databases? Yes This has occurred from continuous improvement and not HACCP.

Improved calibration schedules? Yes This has been driven by the HACCP review process.

Better targeted reporting? Yes More for internal business reporting than HACCP.

Improved record keeping? Yes Directly as a result of HACCP, improved logging of all system check records.


Yes Training of O&M staff has improved their actions, further improving our water quality.


Yes Ability for operators to have a say and have recommended changes implemented.


Yes Yes, through toolbox meetings with external contractor and internally through in-house training of all operations, planning and strategic staff.


Yes Through the development of dedicated programs targeted around HACCP.


Yes Through greater awareness of HACCP and internal training.


Maybe Relationships already good prior to introduction of HACCP.

Improved clarity of accountability? Yes Particularly as identified through record keeping procedures.


125

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Question Answer Basis/examples Has communication been improved within the utility and between the utility and external stakeholders?

Yes This is only partially through HACCP, more through alliance partnering.


Of the order $80,000-$120,000 (Australian Dollars) ($65,000-$95,000 US Dollars) initially, this includes costs for in-house staff time in actual compilation of the plan.


HACCP and the risk management framework, introducing proactive management to address or prevent risks.


Yes The existing quality documentation system was used as the backbone for HACCP.


Unable to be quantified. There are fewer complaints, less incidents, and no major health impacts from the water supply system with estimated internal savings on the order of $100,000-200,000 Australian Dollars ($80,000-160,000 US Dollars) per year. But how is a value put on increased public and regulator confidence? It is not possible to conclusively distinguish which savings arose from HACCP directly or the improved system understanding, training, and other factors.


No


As an education experience.


Yes This has been an integral component of the organization prior to HACCP.

Has credibility and due diligence improved?

Yes Through improvements in record keeping.

* Water quality incident is defined as a major water quality problem leading to some kind of emergency response such as extensive dirty water events, taste and odor events or suspected contamination events.

126

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Table 5.5

Yarra Valley Water Perspective on HACCP Application to Distribution System

Question Answer Basis/examples Reduced taste/odor complaints? No Complaints data.

Reduced discolored water complaints? No Complaints data. Factors such as drought recovery affected complaints numbers and are not a good

indicator to assess effectiveness of HACCP.

Reduced low pressure complaints? N/A Not part of HACCP.


Maybe Compliance improved every year since 1996. Cannot attribute totally to implementations of HACCP.

Reduced total coliforms? Maybe Compliance improved every year since 1996. Cannot attribute totally to implementations of HACCP.

Reduced HPCs? N/A Not part of HACCP.

Reduced turbidity? No Water quality data.

Reduced low pressures? N/A Not part of HACCP.

Reduced water quality incidents?* Yes Security breaches at storages minimized due to improved processes.

Reduced chlorinator failures? Yes Significant improvement due to joint Melbourne Water and Yarra Valley Water HACCP Management via regular HACCP coordinator meetings and reporting processes.


Yes Via ongoing HACCP management and improvements identified during internal and external audits.


Yes Development of a risk management plan for hydrant use.


Yes Appointment of a Backflow Prevention Officer. Implementation of significant improvements to the backflow prevention program and allocation of budget via the annual business planning process.


Yes As above.


127

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Table 5.5 Yarra Valley Water Perspective on HACCP Application to Distribution System

Question Answer Basis/examples Has monitoring become more focused? Yes External review of annual water quality monitoring program identified areas of improvements based on risk

assessment in the 2004 Australian Drinking Water Guideline Framework and changes introduced accordingly.

Improved databases? Yes Significant improvements to the database to undertake monthly checks for HACCP management via automated reports.

Improved calibration schedules?

N/A

Better targeted reporting? Yes Monthly water quality report to check compliance against HAACP criteria and undertake investigations or remedial works. Monthly water quality results for each water quality zone posted in the internet. Improvements identified via HACCP reviews and audits are captured, progress monitored and reported.

Improved record keeping? Yes As above.


Maybe Improved awareness of water quality risks. Improvements to the water quality Emergency Response Plan.


No Well-established processes were in place prior to HACCP and ongoing continuous improvement of processes.


Yes Annual training of key staff including contactors on HACCP and Water Quality.


Yes As above.

Improved senior management involvement? Yes Improvements identified via HACCP reviews and audits are captured, progress monitored and reported via an automated monitoring process in the intranet. The progress reported to Senior Management via the intranet and also regular Quality Council Committee meetings.


N/A

Improved clarity of accountability?

N/A


Yes Significant improvement of communication and critical control point management with the wholesaler.


128

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Table 5.5 Yarra Valley Water Perspective on HACCP Application to Distribution System

Question Answer Basis/examples What are the estimated costs of implementation of the HACCP system?

$10,000 (Australian Dollars) ($8,000 US Dollars) for annual HACCP reviews, internal and external audits etc.


Improved backflow prevention, disinfection failure management.


Yes Existing business management system comprising ISO 9000 and ISO 14000 and emergency management plans and documented quality procedures.


Reduction in responses for disinfection failures and potential backflow.


Yes HACCP now being used to manage recycled water quality management.


Positive A system audit process was already in place before HACCP. Many suggestions for improvements from HACCP audits were implemented.


Yes This was already in place and HACCP improvements were incorporated to the existing process. The progress of improvements are managed and monitored via an automated tracking process via the intranet.

Has credibility and due diligence improved? Yes Improved awareness on water quality risks and management processes.

* Water quality incident is defined as a major water quality problem leading to some kind of emergency response such as extensive dirty water events, taste and odor events or suspected contamination events.

129

(Continued)

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

130

Reductions in Customer Complaints

The most notable improvement reported by utilities following implementation of HACCP was an apparent drop in the frequency of customer complaints. For example, water quality complaints dropped steadily following HACCP implementation for Gold Coast Water and South East Water by a total of 66 percent and 60 percent, respectively, over a few years. In the case of Gold Coast Water, this reduction in complaints occurred at a time of increased veracity in capturing and recording complaints, such that the true magnitude of reduction may have been greater. For South East Water, interpreting the cause for this reduction was complicated because of changes in demand and customer expectations associated with water restrictions and an ongoing drought.

Improvements in Water Quality

A number of specific water quality improvements were attributed, at least partly, to HACCP implementation. Case study utilities reported improvements against a range of criteria as follows:

• Microbial indicators: utilities reported improved compliance with microbial results, although this started from a relatively high baseline, so changes were not large. Yarra Valley Water reported ongoing, year-by-year, compliance improvements attributed to many factors of which HACCP implementation was one. Gold Coast Water reported improved compliance from 2 percent to 1.5 percent for thermotolerant coliform occurrences.

• Incidents: water quality incidents were reported to have been reduced for South East Water who reported a drop from one incident every few months to less than one per year. A water quality incident is defined as a major water quality problem leading to some kind of emergency response, such as extensive dirty water events, or taste and odor events.

Improvements in Process Performance

Although outside of the scope of the distribution component of the project, it is worth noting a number of process performance improvements attributed, at least partly, to HACCP implementation:

• Filtration plant: Filtration plant performance has been improved following the implementation of HACCP. For example, since the Gold Coast Water HACCP system was put into place in 2001, the water treatment and distribution system performance parameters have seen steady improvement (Smith 2004a). The average weekly turbidity of the finished water has improved from 0.28 NTU in July 1999 to 0.18 NTU in June 2003, as shown in Figure 5.2.

• Disinfection plant: Chlorinator performance has been improved sine the implementation of HACCP. For example, Yarra Valley Water saw a steady decline in the number of chlorinator critical control point exceedances from around twenty per year to one per year during a four-year period following HACCP implementation as shown in Figure 5.3 (Chapman, Jayaratne, and Pamminger 2003).


131

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

Jul-9

9

Sep-

99

Nov

-99

Jan-

00

Mar

-00

May

-00

Jul-0

0

Sep-

00

Nov

-00

Jan-

01

Mar

-01

May

-01

Jul-0

1

Sep-

01

Nov

-01

Jan-

02

Mar

-02

May

-02

Jul-0

2

Sep-

02

Nov

-02

Jan-

03

Mar

-03

May

-03

Date

Turb

idity

(ntu

)

Source: Smith 2005. Reprinted with permission. ntu = nephalometric turbidity units

Figure 5.2 Gold Coast Water average weekly turbidity of finished water from Molendinar Water Treatment Plant

Source: Chapman, Jayaratne, and Pamminger 2003. Reprinted with permission from AWWA. CCP = critical control point

Figure 5.3 Number of chlorinator CCP exceedances per year


132

Improvements in Work Processes

Gold Coast Water indicated that certain operational practices were improved based on data collected for a HACCP excursion report (Smith 2004). The HACCP excursion report established that the water’s chlorine residual at a suburban booster station had fallen below a critical limit. An investigation by senior management revealed that the chlorine gas cylinders were empty because no one had been given the responsibility to keep them full. Also, the chlorine residual and other instruments at the booster station had not been calibrated since installation simply because the instruments had never been placed on a calibration schedule. Although the low chlorine residual may have been detected prior to HACCP, it is unlikely that the incident would have been investigated since no one had been given that responsibility. As a follow-up to this incident, operational and asset management staff improved their practices not only at this booster station, but across the system (Smith 2004a).

Yarra Valley Water identified a need to improve backflow prevention during its HACCP plan development process. As part of HACCP implementation, Yarra Valley Water appointed a dedicated Backflow Prevention Officer. With the officer coordinating and managing this important issue, the utility is now aiming to increase the number of connections that have the appropriate backflow prevention devices fitted as part of a retrofit program with a target of 100 percent compliance with the relevant backflow prevention standard within five years.

Improved Understanding of Risks and Risk Management

Smith (2004a) documents a case study at Gold Coast Water in Australia that illustrates how a HACCP excursion report helped the utility to identify a previously unidentified risk in an existing manganese control procedure and its reporting instructions. “The loophole in the HACCP manganese control procedure meant that staff did not technically have to report this particular failure to anyone and this became an attractive option” (Smith 2004a). The HACCP excursion reporting system was developed as part of the HACCP Plan, specifically addressing HACCP step 12, Documentation and Recordkeeping. The HACCP excursion report showed that the daily limit of six customer calls regarding dirty water (Smith 2003b) had been exceeded on one day. A follow-up investigation conducted in response to the high number of dirty water calls revealed a problem where plant staff failed to adequately respond to changes in raw water quality. The existing procedure was subsequently tightened.

In another example, at Gold Coast Water’s Mudgeeraba plant, Smith (2003b) reports that there was initially under-reporting of a turbidity problem due to inferior monitoring (one combined meter compared to six meters at another plant). There was also more cultural resistance to compliance at this plant and it took a change in instrumentation and some close internal auditing to reveal issues at that plant in 2002. Two problems were revealed. One was that operators were inexperienced in dosage optimization during changing conditions. Secondly, the backwash system components were in poor condition which compromised filter performance under certain conditions. The lack of cultural acceptance was dealt with by closer internal auditing in the early stages and eventually staff realized that there were benefits all around if everyone adhered to the system (Smith 2003b).


133

Improvements in Documentation and Record Keeping

Brisbane Water and Gold Coast Water noted that HACCP implementation led to improved documentation and fine-tuning of existing procedures. For example, Gold Coast Water (Smith 2004a) had no record of system failures prior to HACCP implementation (Smith 2003b). A HACCP excursion reporting system was implemented as part of the HACCP Plan. In December 2002, the Health Department advised Gold Coast Water of a small outbreak of cryptosporidiosis in one part of the city. The Health Department needed to know if this outbreak was caused by the public water supply. Within 20 minutes of receiving the call, the utility was able to collate comprehensive data records that indicated the outbreak was not likely caused by the water supply. These records included weekly counts for E. coli at the source of supply, 24-hour trend data for various water quality parameters (e.g. raw water turbidity, dosed water pH, filtered water turbidity, plant chlorine residuals), supply reservoir inspection reports, weekly water quality data for a sampling location adjacent to the area of concern, and consumer call records. The utility had a high degree of confidence in the information provided to the Health Department because the sampling and laboratory work was carried out by a certified lab and the trended data was provided by instruments with up-to-date calibration records and verified several times daily against a reference instrument (Smith 2004a).

Demonstration of Due Diligence

Davison and Deere (2004) illustrate how HACCP can help a utility to demonstrate “due diligence” or the “prevention of foreseeable harm.” This demonstration of due diligence is accomplished using five elements of the HACCP system (Davison and Deere 2004): (1) assessing risks from the sources of supply through to the customer’s tap; (2) implementing a risk management system; (3) employing a “culture of compliance;” (4) seeking out and incorporating new knowledge into system processes and procedures; and (5) planning for emergencies.

South East Water, Yarra Valley and Gold Coast Water found that HACCP implementation has helped to improve system credibility and demonstration of due diligence. South East Water attributed these improvements to improved record-keeping practices. For Yarra Valley, employees have an improved awareness of water quality risks and management processes. Gold Coast Water found that the structure of the HACCP system has helped with system credibility and demonstration of due diligence. For almost every aspect of water quality management, Gold Coast Water has a HACCP procedure designed to detail the risk, monitoring, corrective action, and reporting. Each procedure is a formal instruction from the manager to the operational staff (Smith 2004a). These procedures, typically one to three pages in length, outline the process steps, the risks, the monitoring strategies, control measures, corrective actions, and assignment of responsibilities.


134

SUMMARY

Important conclusions have emerged from analyzing the five case studies presented in this chapter:

• Most utilities that have gained HACCP certification have done so after some core management systems (e.g. ISO 9001, ISO 14001) had been developed and implemented. These management systems helped the utility to gain management control of people and processes. For example, the additional documentation and record-keeping requirements of HACCP are often quite small once an organization has experience with a management system.

• In practice, the case study utilities did not operate multiple, separate systems for quality management, occupational safety, water quality and safety, and environmental considerations. These separate systems were captured, as required, within an integrated management system (IMS). The principal benefit of an IMS, as identified by water utilities, was the avoidance of duplication, leading to reduced staff time and costs, and improved process integration.

• Auditing, although sometimes uncomfortable for operating staff, is a necessary and useful element of HACCP. It forces periodic reviews and keeps important issues before staff and management.

• When a utility implements HACCP for water, it is likely to be doing so as one of a number of water quality improvement projects, making it very difficult, if not impossible, to precisely determine the extent to which HACCP per se contributed to any effect.

• Improvements did become evident following the implementation of HACCP, but in most cases, those changes did not appear conclusive until a consistent pattern of improvement had emerged after three or more years.

These conclusions have major implications for the pilot-studies undertaken by four utilities as part of this Project, as well as implications beyond this study and would apply to any project that attempts to measure the effect of the implementation of HACCP. Given these limitations, conclusive evidence of major water quality or other improvements resulting directly from the implementation of HACCP would not be expected to be observable in the timeframe, or within the context of this study as reported in Chapter 4.

Importantly, a utility that voluntarily implements a certified HACCP plan would most likely not do so unless key staff had some reasonable confidence in the soundness of their water quality management practices and a prevailing belief that water quality management is important. Such utilities are already likely to be managing water quality at a higher level than those that would reject the implementation of HACCP providing less opportunity for improvement. The relatively limited improvements reported by City West Water and Brisbane Water were, for example, attributed by those utilities to the fact that by the time they implemented HACCP, most of the requirements for HACCP implementation were already in place, including mature certified quality management systems.

Despite these study limitations, the five case study utilities all reported some benefits in aspects of water quality management that all believed were at least partly related to HACCP. Furthermore, none of these utilities have withdrawn from their voluntary certification programs.


135

Improvements considered by utilities to be associated with the implementation of HACCP included the following:

Water quality − Reduced customer complaints − Reduced water quality incidents − Reduced microbial indicator failures

Operations − Improved treatment system performance − Improved work processes.

Business performance − Improved capability to demonstrate due diligence − Reduced costs − Improved documentation and record keeping − Improved training and operational good practice culture.

Since the HACCP implementation costs for these five utilities were relatively modest, and in some cases were met entirely with existing resources, it appears that implementation of HACCP may represent a positive overall experience for mid- to large-sized water utilities. However, it is important to note that cost information presented in this chapter represents utilities that had implemented other quality management systems prior to implementing HACCP and therefore, the cost information may not be applicable to a utility implementing only HACCP.

The results of the analysis presented in this Chapter are not necessarily transferable to very small water utilities that may lack the critical mass of funding, expertise and staff numbers to undertake a HACCP program. No very small water utilities with HACCP certification could be identified to be used as case studies for this Chapter. Referring back to Chapter 4, some small systems were considered through the pilot utilities. However, although the Power and Water Corporation Katherine pilot-study demonstrated the application of HACCP to a small system, it should be noted that the Katherine water supply system is managed by a mid-size water authority. The South Berwick Water District in Maine, a small system serving approximately 4,000 customers, was unable to implement its HACCP plan due to manpower limitations and the need to focus on higher priority projects.


136


137

CHAPTER 6 RECOMMENDED NEXT STEPS AND FUTURE RESEARCH NEEDS

The HACCP system has been widely adopted by the food and beverage industries, and has been incorporated in many drinking water regulatory requirements and guidelines around the globe. For example, the third edition of the WHO drinking water guidelines (WHO 2004) outlines a framework for drinking water safety based on the multiple barrier approach and several risk management and quality management approaches including HACCP.

Many European and Australian water utilities have implemented HACCP systems to full certification or have implemented approaches that are more or less equivalent, albeit differently labeled. The US drinking water industry has been slower than its counterparts overseas in applying HACCP or similar approaches to watershed management programs, water treatment facilities and distribution systems. The US drinking water community can use the experiences from European and Australian utilities as a practical basis for applying the HACCP principles to improve protection of the water distribution system. Although several HACCP applications in Australia and Ontario, Canada were motivated by waterborne disease outbreaks or suspected contamination incidents, a superior approach would be to develop and implement quality assurance programs such as HACCP prior to experiencing such an outbreak or contamination event.

A recommended first step is to improve utility programs and practices to meet the AWWA Standard G200-Distribution Systems Operation and Maintenance. The specifications for this standard include many water utility programs and practices that are needed to successfully implement HACCP. Examples of supporting programs include an emergency response program, a water main flushing program, and a tank inspection program. Examples of specific SOPs for the water distribution system may include water quality sampling procedures, calibration procedures for on-line monitoring devices, and security procedures for restricting entry of unauthorized personnel. The distribution system HACCP plan will simply include and reference these programs and practices to avoid duplicative work. The programs/practices may already exist in some form, but may need updating or augmentation.

Other recommended steps for water utilities include:

• Consider developing and implementing the ISO management systems (ISO 9001 and ISO 14001) or an integrated management system that includes HACCP as well as the ISO systems.

• Evaluate HACCP applications to other water supply system components.

Additional recommended action items for the drinking water community include:

• Consider the HACCP framework in US regulations or regulatory guidelines. • Evaluate HACCP applications in small water systems.

These recommended steps and actions items are discussed in the following sections.


138

Consider Developing and Implementing the ISO Management Systems

The case studies discussed in Chapter 5 showed that most utilities that have gained HACCP certification have done so after some core management systems (e.g. ISO 9001, ISO 14001) had been developed and implemented. These management systems helped the utility to gain management control of people and processes. Also, the case study utilities did not operate multiple, separate systems for quality management, occupational safety, water quality and safety, and environmental considerations but captured these systems within an integrated management system.

Evaluate HACCP Applications to Other Water Supply System Components

Some of the participating utilities have implemented comprehensive HACCP systems, from source of supply to connection. In addition, one of the project Principal Investigators, from Melbourne Water, has developed a watershed HACCP plan for watershed and reservoir management. Water utilities are encouraged to consider applying HACCP principles to watershed management programs and treatment facilities in addition to the distribution system. This investigation may be a joint effort amongst the utility, USEPA regulators, state regulators and other stakeholders.

Consider HACCP Framework in US Regulations or Regulatory Guidelines

The USEPA is currently revising the Total Coliform Rule and is considering new possible distribution system requirements as part of these revisions. As part of this process, the USEPA is currently developing a series of issue papers on topics relevant to the Rule. An issue paper on the HACCP system has been developed as part of this effort. The next step for the USEPA is to present and discuss these issue papers at an expert workshop to provide further refinement and to support any rulemaking activity. To support USEPA’s evaluation of HACCP, it would be helpful to have additional US case studies on HACCP applied to water distribution systems.

Evaluate HACCP Applications in Small Water Systems

Further research is needed to document the costs and benefits of implementing HACCP by small water systems and to answer other outstanding questions, as listed below. This research is needed to develop better guidance information for small systems, and to help regulators evaluate HACCP as a possible tool or framework as part of upcoming regulatory developments. No small water utilities with HACCP certification could be identified to be used as case studies for this Project.

More information is needed to assess the adequacy of supporting programs and practices in small systems. Small systems may rely on verbal information exchanges rather than written SOPs. While this may be acceptable for many situations, there can be significant risks if too much reliance is placed on procedures that are not systematic, formalized and documented. When key staff is on vacation or becomes sick, or if there is no opportunity for checking and auditing, it is difficult for health authorities to be confident that water quality risks are being reliably managed. Internal auditing, employee training programs, document control and data


139

management systems require additional resources that may not be available in small systems at present. This means that small water utilities are potentially under resourced or under supported by state and federal agencies.

Outstanding questions on HACCP implementation in small systems include:

• How should small systems develop a HACCP Plan (outside consultant vs. in-house HACCP team; use of guidelines or checklists; workshop setting; committee meetings)?

• How much training on HACCP is needed for system employees? • What is the man-hour requirement for developing and implementing a HACCP Plan? • What are the documented costs and benefits of implementing HACCP for small

systems? • What are the barriers to implementing HACCP in a small system, and what are the

strategies to overcome these barriers (e.g. multiple demands on resources)? • Does the small system have adequate historical water quality and system data to

complete the HACCP hazard analysis (Step 6)? • Does the small system have the appropriate utility culture in place to be successful in

implementing HACCP?


140


141

REFERENCES

ActewAGL. 2005. HACCP Plan Working Draft Version 5.0. Internal Document, Canberra, Australia: ACTEWC.

AWWA. 2005. Three possible accreditation standards piloted. E-MainStream, 2(3):1. AWWA. 2004. ANSI/AWWA G200-04 Standard - Distribution Systems Operation and

Management. Denver, Colo.: AWWA. AWWA. 2001. Emergency Response Planning for Water Utilities. Manual of Water Supply

Practices #19, Fourth Edition. Denver, Colo.: AWWA. AWWA (American Water Works Association). 2001a. Accreditation Manual of Policies and

Procedures – Draft. AWWA. Denver, CO. AwwaRF (American Water Works Association Research Foundation). 2005. Project Abstract –

Developing an Environmental Management System for Water Utilities. www.awwarf.com/research/TopicsAndProjects/abstract.aspx?pn=2930.

Barry, S.J., E.R. Atwill, K.W. Tate, T.S. Koopman, J. Cullor, and T. Huff. 1998. Developing and Implementing a HACCP-based Program to Control Cryptosporidium and Other Waterborne Pathogens in the Almeda Creek Watershed: Case Study. In Proc. of the AWWA Annual Conference. Denver, Colo.: AWWA.

Barry, S.J., T.S. Koopmann, T. Huff, E.R. Atwill, K.W. Tate, and J. Cullor. 2004. A HACCP-based Program to Protect San Francisco’s Drinking Water. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Bosshart, U. 2003. HACCP – Hazard Analysis and Critical Control Points at the Zurich Water Supply. In HACCP in Drinking Water Supplies in Switzerland. Zurich, Switzerland: Swiss Gas and Water Industry Association.

Breach, B. 2004. The Bonn Workshops – A Charter for Safe Drinking Water. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Bryan, J.J. 1993. Hazard Analysis and Critical Control Points and Their Application to the Drinking Water Treatment Process. In Proc. of the 1993 AWWA Water Quality Technology Conference. Denver, Colo.: AWWA.

Chapman, T., A. Jayaratne, and F. Pamminger. 2003. Water Quality Benefits Gained From Having a Hazard Analysis and Critical Control Point (HACCP) System in Place Since 1999. In Proc. of the AWWA Annual Conference. Denver, Colo.: AWWA.

Clark, Robert M., D.A. Reasoner, K.R. Fox, and C.J. Hurst. 1997. Drinking Water Treatment and Distribution: Its Role in Preventing Waterborne Outbreaks. Presented at Workshop on Design of Waterborne Disease Occurrence Studies. March 12-13, 1997, Atlanta, GA.

Codex. 1997. Guidelines for the Application of the HACCP System. Rome, Italy: Codex Alimentarius Commission and the FAO/WHO Food Standards Program, Food and Agriculture Organization of the United Nations and World Health Organization.

Codex Alimentarius Commission. 1993. Guidelines for the Application of the Hazard Analysis Critical Control Point (HACCP) System, CAC/GL 18-1993.

Cotruvo, J. 2004. Comprehensive Water Quality Management Systems: Potential Scope of a Complete System. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html


142

Cunliffe, D.A. 2004. Australian Framework for Management of Drinking Water Quality. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Cunliffe, D.A. 2001. Australia’s Framework for Management of Drinking Water Quality. In Proc. of the AWWA Annual Conference. Denver, Colo.: AWWA.

Davison, A., and J. Bartram. 2004. HACCP and WHO Water Safety Plans. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Davison, A., S. Davis, and D. Deere. 1999. Quality Assurance and Due Diligence for Water: Can HACCP Deliver? In Proc. of the Australian Water and Wastewater Association Conference.

Davison, A. and D. A. Deere. 2004. Liabilities, Due Diligence and Utilities: HACCP as a Legal Defense. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Davison, A. and D. A. Deere. 1999. Safety on Tap! Microbiology Australia, 20(2):28-31. DeBier, L. and J-C. Joret. 2004. HACCP as a Tool for Assuring Safe Drinking Water: The

Veolia Water Experience. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Deere, D. 2005. Question on Sydney Water. Email to K. Martel. 1.3.05. Deere, D. 2004. Implementation of a HACCP Approach to Watershed Management. In Proc. of

the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Deere, D.A. 1999. Applicability of HACCP in the Water Industry. In Proc. of the Conference Harmonized Risk Assessment for Water-Related Microbiological Hazards. Geneva, Switzerland: World Health Organization.

Deere, D. and A. Davison. 1999. Assuring Water Quality. WATER21, 1(1): 8-9. Deere, D. and A. Davison. 1998. Safe Drinking Water: Are Food Guidelines the Answer?

WATER:Nov/Dec. Deere, D., M. Stevens, A. Davison, G. Helm, and A. Dufour. 2001. Chapter 12 - Management

Strategies. In: Water Quality: Guidelines, Standards and Health. Assessment of Risk and Risk Management for Water-Related Infectious Disease. London, England: IWA Publishing.

Deighton-Smith, R. and B. Labza. 2005. Determining benefits of a regulatory framework for drinking water quality. Journal of the Australian Water Association, 32(2):94-103.

Fok, N. and K. Emde. 2004. HACCP in Water Treatment – What It Is and What It Isn’t. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Friedman, M.J., G. Kirmeyer, G. Pierson, S. Harrison, K. Martel, A. Sandvig, and A. Hanson. 2005. Development of Distribution System Water Quality Optimization Plans. Denver, Colo.: AwwaRF.

Friedman, M.J., L. Radder, S. Harrison, D. Howie, M. Britton, G. Boyd, H. Wang, R. Gullick, M. LeChevallier, J. Funk and D. Wood. 2004. Verification and Control of Low Pressure Transients in Distribution Systems. Denver, Colo.: AwwaRF and AWWA.

Geldreich, E.E. 1996. Microbial Quality of Water Supply in Distribution Systems. Boca Raton, FL: Lewis Publishers.


143

Gissurarson, L.R. 2004. HACCP and ISO Systems at Reykjavik Energy. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Gray, R. and M. Morain. 2000. HACCP Application to Brisbane Water. Water, 27: 41-43. Havelaar, A.H. 1994. Application of HACCP to Drinking Water Supply. Food Control,

5(3):145-152. Hebenstreit, C. 2004. EMS Initiatives in the State of Missouri. In Proc. of the NSF Conference

on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Hrudey, S.E. and R. Walker. 2005. Walkerton 5 Years Later – Tragedy Could Have Been Prevented. Opflow, 31(6):1, 4-7.

International Studies and Training Institute, Inc. 1995. Final Report: Sanitary Survey of the Drinking Water Distribution System of the District of Columbia. Whiteford, MD: ISTI.

Kirmeyer, G.J., M. Friedman, J. Clement, A. Sandvig, P.F. Noran, K. Martel, D. Smith, M. LeChevallier, C. Volk, E. Antoun, D. Hiltebrand, J. Dykesen, and R. Cushing. 2000. Guidance Manual to Maintain Distribution System Water Quality. Denver, Colo.: AwwaRF and AWWA.

Kirmeyer, G.J., M. Friedman, K. Martel, D. Howie, M. LeChevallier, M. Abbaszadegan, M. Karim, J. Funk and J. Harbour. 2001. Pathogen Intrusion Into the Distribution System. Denver, Colo.: AwwaRF and AWWA.

Kirmeyer, G.J., L. Kirby, B.M. Murphy, P.F. Noran, K. Martel, T.W. Lund, J.L. Anderson, and R. Medhurst. 1999. Maintaining and Operating Finished Water Storage Facilities to Prevent Water Quality Deterioration. Denver, Colo.: AwwaRF and AWWA.

Kramer, M.H., B.L. Herwaldt, G.F. Craun, R.L. Calderon, and D.D. Juranek. 1996. Waterborne Disease: 1993 and 1994. JAWWA, 88(3):66-80.

Kuslikis, B. and B. White. 2004. Implementing a Sustainable, Integrated Risk Management System for Water Safety and Quality. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/pdf/3Hebenstreit.pdf

Lee, J.J., P. Schwartz, P. Sylvester, L. Crane, J. Haw, H. Chang and H.J. Kwon. 2003. Impacts of Cross Connections in North American Water Supplies. Denver, Colo.: AwwaRF and AWWA.

Levy, D.A., M.S. Bens, G.F. Craun, R.L. Calderon, B.L. Herwaldt. 1998. Surveillance for Waterborne Disease Outbreaks--United States, 1995-1996. www.cdc.gov/epo/mmwr/preview.

Lippy, E.C. and, S.C. Waltrip. 1984. Waterborne Disease Outbreaks - 1946-1980: A Thirty-Five Year Perspective. JAWWA, 76:60-67.

Mays, L.W. 2004. Chapter 1 Water Supply Security: An Introduction. In Water Supply Systems Security. New York, NY: McGraw-Hill Books, Inc.

Melbourne Water Corporation. 2001. HACCP Plan (Version 3). Internal Document. Melbourne, Australia: Melbourne Water Corporation.

Metge, S. 2003. The French Experience with the Application of HACCP Principles in Drinking Water. In Water Safety-Risk Management Strategies for Drinking Water - Conference Materials. Berlin, Germany: Federal Environmental Agency (Umweltbundesamt).

Ministry of Health. 2001. How to Prepare and Develop Public Health Risk Management Plans for Drinking-Water Supplies. Wellington, New Zealand: Ministry of Health.


144

Mucklow, R. 1997. Where Did HACCP Come From? In Heads Up for HACCP. National Meat Association. www.nmaonline.org/files/headsup12-1.htm , November 3, 2004.

Mullenger, J. 2002. HACCP Principles 6 and 7. In The How, Where and Why of Applying HACCP to Water – AWWA WQTC Workshop Manual. Melbourne, Australia: Melbourne Water Corporation.

Nadeau, M. 2004. Letter to K. Martel (July). South Berwick, Maine: South Berwick Water District.

NASA (National Aeronautics and Space Administration). 1991. A Dividend in Food Safety. Spinoff 1991, NASA Technical Report ID 20020086314.

NHMRC/NRMMC (National Health and Medical Research Council and Natural Resource Management Ministerial Council). 2004. Australian Drinking Water Guidelines. Canberra, Australian Capital Territory, Australia: National Health and Medical Research Council and Natural Resource Management Ministerial Council.

Nokes, C. 2001. Public Health Risk Management Plans: An Introduction to New Zealand's Use of a Risk Management-Based Approach to Improving the Safety of Drinking-Water Supplies. In Proc. Of the NZIEH Conference.

Nyman, L. 2004. Benefits of ISO Programs at Elizabethtown Water Company. In Proc. of the NSF Conference on Risk Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

O’Connor, D.R. 2002. Report of the Walkerton Inquiry. Part 2. A Strategy for Safe Drinking Water. Toronto, Canada: The Walkerton Inquiry.

Shamsuddin, A.J., S.G. Mahmud, M.F. Ahmed, D. Deere, A. Davison, and G. Howard. 2005. Developing a water-safety framework in Bangladesh. Waterlines, 23(4): 1118.

Smith, D. 2005. Updated turbidity graph. Email to D. Deere. 8.19.05. Smith, D. 2004a. HACCP in Water: The War on Error. In Proc. of the NSF Conference on Risk

Management Strategies for Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html

Smith, D. 2004b. Updated turbidity and complaints graphs. Email to K. Martel. 6.8.04. Smith, D. 2003a. HACCP Procedures. Email to K. Martel. 2.17.03. Smith, D. 2003b. HACCP Case Study. Email to K. Martel.10.28.03. Sobsey, M.D., A.P. Dufour, C.P. Gerba, M.W. LeChevallier, and P. Payment. 1993. Using a

Conceptual Framework for Assessing Risks to Health From Microbes in Drinking Water. JAWWA, 85(3), 44-48.

South East Water Limited. 2002. HACCP Plan. Internal Document. South East Water Limited. 1999. Developing HACCP Systems Training for South East Water

Limited. Prepared by Australian Water Technologies and Quality Assurance Services. Standards Australia/Standards New Zealand. 2004. AS/NZS 4360:2004 Risk Management

Standard, Third Edition. Sydney, NSW, Australia: Standards Australia International Ltd. Swerdlow, D.L., B.A. Woodruff, R.C. Brady, P.M. Griffin, S. Tippen, H.D. Donnell, Jr., E.

Geldreich, B.J. Payne, A. Meyer, Jr., and J.G. Wells. 1992. A waterborne outbreak in Missouri of Escherichia coli O157:H7 associated with bloody diarrhea and death. Ann Intern Med, 117(10):812-9.

Swiss Gas and Water Industry Association. 2003. W1002 Regulation-Recommendations for a Simple Water Quality Assurance System for Water Supplies. Zurich, Switzerland: Swiss Gas and Water Industry Association.


145

U.S. Environmental Protection Agency. 1998. National Primary Drinking Water Regulations: Interim Enhanced Surface Water Treatment Rule. Federal Register, 63(241): 69478-69521.

U.S. Environmental Protection Agency. 1991. Quality Assurance Glossary and Acronyms. ORD-QA Management Staff. Washington, D.C.

World Health Organization (WHO). 2004. Guidelines for Drinking-Water Quality, 3rd Edition. Geneva, Switzerland: World Health Organization.

World Health Organization (WHO). 1997. HACCP – Introducing the Hazard Analysis and Critical Control Point System. Geneva, Switzerland: WHO.

World Health Organization (WHO). 1996. Guidelines for Drinking-Water Quality, Second Edition. Geneva, Switzerland: World Health Organization.

Yarra Valley Water, Ltd. 2005. HACCP Plan Version 8.1. Internal Document. Victoria, Australia: Yarra Valley Water Ltd.


146


147

ABBREVIATIONS aka also known as AS Standards Australia AS/NZS Australian/New Zealand Standard AUD Australian dollars AWWA American Water Works Association AwwaRF Awwa Research Foundation C Celsius CCP Critical control point cfu Colony forming units CITEC Australian Capital Territory Electricity and Water Corporation Cl2 chlorine CRCWQT Cooperative Research Center for Water Quality and Treatment EMS Environmental management system EPA Environmental Protection Agency F Fahrenheit FAO Food and Agricultural Organization FDA Food and Drug Administration FSIS Food Safety and Inspection Service ft feet FTE full-time equivalent gal gallons GHP Good hygiene practice GIS Geographic information system GMP Good manufacturing practice gpm gallons per minute HACCP Hazard Analysis and Critical Control Point HPC Heterotrophic plate count bacteria HU Hazen units IBWA International Bottled Water Association IMS Integrated management system in inches ISO International Organization for Standardization km kilometers kPa kilopascal L liters LIMS Laboratory Information Management System


148

m meters MCL Maximum Contaminant Level mg milligram MG million gallon min minute mL milliliters ML megaliters mm millimeters N/A not applicable NaOCl sodium hypochlorite NASA National Aeronautics and Space Administration NATA National Association of Testing Authorities, Australia NCCP Non-critical control point No. Number NSF National Sanitation Foundation NSW New South Wales (State of New South Wales, Australia) NTU Nephelometric Turbidity Units O & M Operations and Maintenance PAC Project Advisory Committee PHRMP Public Health Risk Management Plan PRV pressure reducing valve psi pounds per square inch QCP Quality control point SCADA Supervisory Control and Data Acquisition SOPs Standard Operating Procedures SSOPs Sanitation Standard Operating Procedures UCL upper confidence level US United States USA United States of America μS cm-1 microSiemens per centimeter USEPA United States Environmental Protection Agency UV ultraviolet VIC Victoria (State of Victoria, Australia) vs versus WF Weighting factor WHO World Health Organization


A- 1

APPENDIX A

EXAMPLE OF HACCP TRAINING WORKSHOP NOTEBOOK


A-2

AwwaRF 2856 – Application of HACCP for Distribution System Protection

Workshop Notebook List of Contents

Section 1 Workshop Agenda Section 2 HACCP: An Overview The Twelve Steps of HACCP Section 3 Steps 1 – 5: Preliminary Steps Worksheet 1: HACCP Team Identification Worksheet 2: HACCP Team Details Worksheet 3: Product and/or Process Description Worksheet 4: Intended Use and Consumer of Product Worksheet 5: Process Flow Chart Section 4 Step 6: Conduct a Hazard Analysis Worksheet 6: Hazard Identification Section 5 Step 7: Determine Critical Control Points Worksheet 7: HACCP Summary Information Section 6 Steps 8, 9, and 10 (Refine Worksheet 7) Section 7 Steps 11 and 12 Worksheet 8: HACCP System Verification Schedule Extra Worksheets References Glossary


A-3

SECTION 1

Workshop Agenda

Date

8:00 – 8:15 Purpose of Workshop (Utility Manager)

8:15 – 8:30 AwwaRF Project Overview (Workshop Facilitator)

8:30 – 9:30 What is HACCP? (Workshop Facilitator)

9:30 – 9:45 Break

9:45 – 10:45 Small Groups, Steps 1-5 (All)

10:45 – 11:45 Small Groups, HACCP Step 6 (All)

11:45 – 12:00 Wrap-Up, Small Group Findings (Workshop Facilitator)

12:00 – 1:00 Lunch

1:00 – 2:00 Small Groups, HACCP Step 7 (All)

2:00 – 3:00 Small Groups, HACCP Steps 8, 9, and 10 (All)

3:00 – 4:00 Small Groups, HACCP Steps 11 and 12 (All)

4:00 – 4:30 Workshop Wrap-Up (Workshop Facilitator)


A-4

SECTION 2

OVERVIEW OF HACCP METHOD: HAZARD ANALYSIS CRITICAL CONTROL POINTS


A-5


A-6


A-7


A-8


A-9


A-10


A-11


A-12


A-13

SECTION 2

The Twelve Steps of HACCP

Step 1 Assemble the HACCP Team

Step 2 Describe the Product

Step 3 Identify Intended Use

Step 4 Construct Flow Diagram

Step 5 Confirm Flow Diagram

Step 6 List all Potential Hazards Conduct Hazard Analysis

Determine Control Measures

Principle 1

Step 7 Determine Critical Control

Points (CCPs) Principle 2

Step 8 Establish Critical Limits for

Each CCP Principle 3

Step 9 Establish Monitoring for Each

CCP Principle 4

Step 10 Establish Corrective Actions for

deviations Principle 5

Step 11 Establish Verification

Procedures Principle 6

Step 12 Establish Record Keeping and

Documentation Principle 7


Adapted from South East Water Ltd. (1999) A-14

SECTION 3

STEPS 1 – 5: HACCP PRELIMINARY STEPS

Step 1 Assemble the HACCP Team Step 2 Describe the Product Step 3 Identify Intended Use Step 4 Construct Flow Diagram Step 5 Confirm Flow Diagram



Step 1 Assemble the HACCP Team It is the Team’s responsibility to develop each step of the HACCP plan in accordance with the preliminary steps and seven principles. The HACCP Team

Plan Develop Verify Implement the HACCP plan

Codex recommends that a team of multi-disciplinary people (maintenance, operations, sanitation, quality control, marketing, chemists, microbiologists etc.) knowledgeable of the process and product should contribute to the development of the HACCP plan. As applied to drinking water, the HACCP team should: • Have knowledge of the types of drinking water safety hazards to be anticipated in the product

and process; • Have authority to implement any necessary changes to ensure safe water is capable of being

produced; • Include people who are directly involved with the daily operations such as operational

personnel, line supervisors etc; • Have sufficient people on the team to allow for multi-disciplinary approach, but not have so

many that the team has difficulty making decisions. Team numbers will vary according to the size of the organization and complexity of product/process;

• Appoint a team leader to drive the project and ensure the team stays on track. The team

leader should have organizational and interpersonal skills to ensure the project meets the planned time line;

• Identify requirements for specialist external support, scientific or technical expertise to

resolve problems. External expertise may include microbiologists, toxicologists (with specific knowledge on chemical hazards), statistical process control experts (to determine process capability) and HACCP experts (to facilitate the HACCP development).

In large organizations it may be more effective to have a number of HACCP teams. This could be structured so that there is a core HACCP team that will coordinate activities and provide expertise to departmental HACCP teams.



This approach is advantageous as it allows for a greater number of people to be involved in the project and will foster a greater sense of ownership within the organization.



Step 2 Describe the Product A full description of the product should be documented. This description may include: • Source of water; • Water treatment process; • Storage after treatment; • Distribution of product; and • Any special considerations to maintain product safety. Step 3 Identify Intended Use The expected use of the product needs to be determined and documented by the HACCP team. The description may include: • How is the product to be used; • What consumer instructions are there for product use? How are these communicated to

consumers? (This consideration may also include how consumers are notified of potential contamination);

• Who is the product intended for? (Consider if product is intended for vulnerable groups such

as infants, the elderly and immunocompromised). This information is very important as it will be used in the hazard analysis to determine the hazard potential of the product. Step 4 Construct Flow Diagram The flow diagram of the process must clearly indicate all process steps used in the operation. Optional steps should also be included. As a minimum the flow chart must state when the company’s responsibility starts (bulk treated water, raw source water) and end where their direct responsibility for the product ends (at the meter box, at consumer tap).



It is highly recommended that the flow process consider steps that occur prior to and after the organization’s direct responsibility as there may be a significant hazard that needs to be addressed by the company. For example, Water Utility A receives its water from Melbourne Water. Although Water Utility A does not have control over the catchments, the company may want to consider the hazards that may be present in the raw product. Similarly Water Utility A may not have direct control over household services, therefore is not strictly responsible for water quality problems due to, for example, corrosion of household pipe. However, it would be reasonable to examine these potential hazards as part of the flow process. Table 1 contains the symbols that can be used to create flow diagrams.

Table 1 Flow Diagram Symbols Flow Chart Symbol Definition of Symbol

Operation – Indicates when there is an operation or group of operations that result in intentional change in the product.

Inspection – Represents an inspection or decision. Eg. Product is examined for identification or is verified.

D

Delay – Represents a delay to material when conditions do not permit the immediate performance of the next planned step. Note: does not include any planned changes to the physical or chemical characteristics of the product.

Storage – Where product is kept in an unchanged form and protected against unauthorized removal.

Transport – Occurs when a product is moved from one place to another, except when such movements are part of an operation or are caused by an operator during and operation or inspection.

Combined activity – Indicates activities performed either concurrently or by the same operator at the same workstation. Any combination of symbols may be used. Example shown indicates a combined operation and inspection.



Step 5 Confirm Flow Diagram It is essential that the flow diagram is correct as the HACCP team will use the flow diagram as the basis for the hazard analysis. If the flow diagram is not correct, the HACCP team may miss potential hazards that may be significant, and as such, miss CCPs in the process. The HACCP team must validate that the flow diagram is both complete (includes all steps) and is accurate. The most effective method of validating the flow diagram is to have people physically walk through and verify the set up of the system and processes. If this is not possible, individuals with operational knowledge of the system can validate the flow diagram. Proof of flow chart validation needs to be documented. This may be indicated by a member of the HACCP team signing and dating the validated flow chart as accurate and complete.



Workshop Activity Application of Preliminary Steps

Form multi-disciplinary HACCP teams and using the HACCP worksheets provided: 1. Fill out Worksheets 1 and 2 describing the HACCP team. 2. Describe your product and its intended uses in Worksheets 3 and 4. 3. Construct a flow diagram commencing where your utility takes responsibility for the product

and continue the flow diagram through distribution to the consumer using Worksheet 5.



SUMMARY

Steps 1 – 5: Preliminary Steps • A HACCP team must be appointed to develop, verify and implement the HACCP system; • The HACCP team must be multidisciplinary; • Sufficient detail must be provided in the preliminary steps to provide background

information for the hazard analysis; • It is essential that the flow diagram is complete and accurate as it forms the basis for the rest

of the HACCP plan. • Once these preliminary steps are completed, the team is ready to conduct the hazard analysis,

which is the first of the seven HACCP principles (Steps 6 – 12).


Adapted from South East Water Ltd. (1999)

Example Worksheet 1: Team Contact Information Name Position Telephone Fax Mobile Email A

Water Supply Operator 03 9560 8217 etc.

B

Environmental Technician

Dr Stevens

Principal Scientist

C

Environmental Health Officer

D

Consultant/University type

Date Plan Prepared: ___________________________________________ Date Plan Revised: ___________________________________________ Date Plan Approved: ___________________________________________

EXAMPLE

A-22

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Worksheet 1: Team Contact Information Name Position Telephone Fax Mobile Email

Date Plan Prepared: ___________________________________________ Date Plan Revised: ___________________________________________ Date Plan Approved: ___________________________________________

A-23

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Example Worksheet 2: HACCP Team Details Coordinator: _________________________________________________ Team Details: Name Position Role Responsibility Contact Information A

Water Supply Operator HACCP Team Leader Production and upkeep of HACCP plan

Silvan system

B

Environmental Technician HACCP team member Establishment of HACCP plan and validation

Silvan system

Dr Stevens

Principal Scientist Microbiological and water quality knowledge

Establishment of HACCP plan and validation

Head office of water corporation

C

Environmental Health Officer Stakeholder and consultative role for health department perspective

Liaises with HACCP team on periodical basis

State Health Dept.

D

Consultant/University type Technical expert Contacted as necessary for input to plan

XYZ consultancy or university etc

Etc.

Date: ____________ Prepared By: ____________________________________________________________ Page _____ of _____

EXAMPLE

A-24

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Worksheet 2: HACCP Team Details Coordinator: _________________________________________________ Team Details: Name Position Role Responsibility Contact Information


A-25

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Example Worksheet 3: Product and/or Process Description Step Description Water source Abstraction from rivers, groundwater.

Receipt of water from bulk supplier.

Water treatment Filtration, chlorination to meet the objectives of the appropriate health authority requirements, guidelines etc. Storage after treatment Reservoirs Distribution of product Pipes/pumps Any special controls required? Quality of chemicals, materials etc used in the production and delivery of the product.

Example product definition based on the above elements: XYZ water utility’s objective is to produce safe, potable water. The water will be received from a bulk water supplier and delivered to customers to meet the water quality objectives set by the Health Authority according to public health targets. The water quality objectives are captured in the Operating Licence, Customer Contract (if in place by the local water utility) and the current and relevant drinking-water Guidelines. Disinfection and fluoridation chemicals are supplied by ABC chemical manufacturer and form part of the delivered product. Quality agreements are in place in relation to treatment chemicals received from manufacturers and bulk water received. Notes: • Consider source of water; • The water treatment process required for the intended use of the water; • How the water is stored after it is treated; • The distribution of the water; and • Any consideration needed to maintain the quality and/or safety of the product. Date Description Prepared: ___________________________________________ Date Description Revised: ___________________________________________ Date Description Approved: ___________________________________________

EXAMPLE

A-26

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Worksheet 3: Product and/or Process Description Step Description

Any special controls required?

Date Description Prepared: ___________________________________________ Date Description Revised: ___________________________________________ Date Description Approved: ___________________________________________

A-27

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Example Worksheet 4: Intended Use and Consumer of Product Intended Use Intended Consumer XYZ water utility provides water to the general population. The water supplied is intended for general consumption by ingestion. Dermal exposure to waterborne hazards through washing of bodies and clothes, and inhalation from showering and boiling are also exposure routes for waterborne hazards. Foodstuffs may be prepared from the water.

The intended consumers do not include those that are significantly immunocompromised or industries with special water quality needs. These groups are advised to provide additional point-of-use treatment.

Date Intended Use Description Prepared: ___________________________________________ Date Intended Use Description Revised: ___________________________________________ Date Intended Use Description Approved: ___________________________________________ Notes: • What is the normal use of the product by intended consumers? • Who will consume the product? • Is product intended for high-risk populations? (i.e. infants, elderly, immunocompromised).

EXAMPLE

A-28

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Worksheet 4: Intended Use and Consumer of Product Intended Use Intended Consumer

Date Intended Use Description Prepared: ___________________________________________ Date Intended Use Description Revised: ___________________________________________ Date Intended Use Description Approved: ___________________________________________ Notes: • What is the normal use of the product by intended consumers? • Who will consume the product? • Is product intended for high-risk populations? (i.e. infants, elderly, immunocompromised).

A-29

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Example Worksheet 5: Process Flow Chart

S1 Raw waterS1.1 Surface andgroundwatersS1.2 Roof catchments

S2 Development ofnew supplies

P1 Source abstractionP1.1 Surface waters - rivers/streams/infiltration galleriesP1.2 Surface waters - lakes/reservoirsP1.3 Groundwaters - wells/boresP1.4 Groundwaters - springs

P2 Conduit tostorage or plant

P3 Pre-treatment storage D1 Post-treatmentstorage

D2 Reticulation networkD2.1 ConstructionmaterialsD2.2 System pressureD2.3 OperationD2.4 Backflowprevention

D3 Staff training

D4 Monitoring

P4 Pre-treatment processesP4.1 Algicide applicationP4.2 DestratificationP4.3 Pre-oxidationP4.4 Waste-liquor recycling

P5 Coagulation/flocculation processesP5.1 Conventional coagulation, flocculation,sedimentationP5.2 Dissolved air flotationP5.3 Direct Filtration

P6 FiltrationP6.1 Rapid sand filtrationP6.2 Slow sand filtrationP6.3 Cartridge filtrationP6.4 Diatomaceous earth filtrationP.6.5 Membrane filtration

P7 DisinfectionP7.1 ChlorinationP7.2 Chlorine dioxideP7.3 OzonationP7.4 Ultra-filtration

P8 Aesthetic property adjustmentP8.1pH adjustmentP8.2 Fe, Mn removalP.8.3 SofteningP8.4 Trace organics removal

P9 Fluoridation

Raw Water Treatment Distribution

Date Flow Chart Prepared and by Whom: ___________________________________________ Date Flow Chart Verified and by Whom: ___________________________________________ NB: Each number refers to a module describing that particular part of the system in detail. More information can be found on the NZ Ministry of Health Website (www.moh.govt.nz).

Example

A-30

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


STEP 6: CONDUCT HAZARD ANALYSIS

Step 6 Actions: • List all potential hazards • Conduct a hazard analysis • Determine control measures.



SECTION 4 Step 6 Conduct Hazard Analysis Once the preliminary steps have been completed, the HACCP team then conducts a hazard analysis to identify significant hazards in the process. A significant hazard is a hazard that must be prevented, eliminated or reduced to acceptable levels to produce safe drinking water. Hazards that are determined as not significant would not require further consideration. Outcomes of the Hazard Analysis • To identify significant hazards and associated control measures for raw water, and the process

that need to be controlled to prevent causing illness or injury to consumers; • The analysis can be used to modify a process or product to further assure or improve safety; • The hazard assessment provides a basis for determining which control measures become

CCPs and which form part of the Supporting Programs.



List all Potential Hazards This requires the HACCP team to identify all potential biological, physical and chemical hazards that are associated with the drinking water supply. The team should start with each step in the production of drinking water and then progress through the validated flow diagram. At each step ask “What could happen here or what could go wrong here?” Also consider influencing factors such as: • Receiving and storage practices; • Water treatment process; • Sanitation and hygiene; • Distribution; and • Intended consumer use. Types of Hazards in Water Note that in the case of water, it is likely that the main hazards are likely to be chemical and/or biological rather than physical. Biological Hazards These hazards include: • Bacteria; • Viruses; • Parasites. All three types of biological hazards should be considered in the hazard analysis. With modern treatment and delivery processes for drinking water the incidence of biological hazards, or pathogens, resulting in illness in the community is relatively rare. However, there are still numerous recent cases of water borne pathogens causing illness in relatively modern water supply systems throughout the world. To eliminate these pathogens from water supplies may seem straightforward to customers (ie. simply apply sufficient disinfectant), but in reality it is impossible to completely eliminate pathogens from drinking water supply systems (that is, make it sterile). The most common source of pathogens in water supply systems originates from fecal material (human or animal) that is initially present in the raw water or finds its way into the water supply delivery system. Common examples include birds and vermin in and around reservoirs, backflow from unprotected connections, and illegal cross connections. Bacteria are very common organisms present in natural waters, air, and soils. Although most are not pathogenic, pathogenic bacteria such as Legionella, Salmonella typhi, Shigella, and Vibrio cholerae are commonly associated with waterborne disease.



In the water industry, thermotolerant coliforms or E. coli have been used to track and understand biological contamination of water supplies. These bacteria in of themselves are not necessarily pathogenic, however, when they are found, it indicates that other pathogenic microorganisms may be present. Viruses commonly linked to waterborne disease have protein coats that provide protection from hostile environmental conditions. Key pathogens of potential concern include Hepatitis A and Norwalk virus. Protozoa are common in natural bodies of water. To survive hostile environmental conditions many species form a resting phase called a cyst or oocyst. This form of some protozoa may be resistant to common disinfectants such as chlorine. Key protozoa include Giardia and Cryptosporidium. Chemical Hazards The main sources of chemical hazards in drinking water include: Chemicals from catchment management

Chemicals from reservoir and storage

Chemicals from water treatment processes

Chemicals from distribution

• Insecticides • Fungicides • Fertilizers • Pesticides • Algal toxins

• Cleaners • Chemicals

from liners • Sanitizers • Equipment

lubricants • Pesticides • Metals and

PAHs present in urban stormwater

• Flocculants • pH adjusting

chemicals • Excess

chlorine • Disinfection

by-products (THMs)

• Manganese • Impurities in

treatment chemicals

• Copper, iron, manganese, zinc, from pipe and fitting corrosion

• Cleaners, lubricants, petroleum products used in maintenance

• pH changes from concrete linings

Physical Hazards The most common physical hazard in water is sediments. Suspended or resuspended sediments can contain toxic chemicals or can have pathogens attached and can represent the above hazards as well. Sediments and particulate materials in general can also include pipe materials, pipe liner materials, or sloughed biofilms or iron/manganese films.



Questions to assist in identifying potential hazards: (Based on NACMCF HACCP Guidance notes)

Catchment water: 1. What are the environmental factors that will introduce microbiological, chemical or physical

hazards? Intrinsic factors of treated water: 1. Physical characteristics and composition (such as pH, dissolved organic carbon, sediments,

addition of chlorine and other treatment chemicals, buffering capacity), of the water before and after treatment. Which intrinsic factors must be controlled in order to assure safety?

2. What is the normal microbial content of the water? How does this content vary and over

what periods of time? 3. Does the water permit survival or multiplication of pathogens and/or toxin formation in the

treatment process and during subsequent steps in the distribution chain? 4. What has been the safety record of other industry competitors? Procedures used to treat water and maintain treatment standard: 1. Does the water treatment include a controllable step that destroys pathogens, vegetative cells,

spores and parasites? 2. Where is the product potentially subject to recontamination between treatment and

distribution to consumers? 3. What special conditions, like negative pressure or reversal of flows might lead to

recontamination? Water treatment equipment design: 1. Is the equipment properly sized for the volume of water to be treated? 2. Can the equipment be sufficiently controlled so that the variation in performance will be

within the tolerances required to produce safe water? 3. Is the equipment reliable or prone to frequent breakdowns? 4. What product safety devices are used to enhance safety (eg. filters)?



Workshop Activity Identifying potential hazards to provision of “safe” water

Consider all of the possible sources of biological, chemical and physical contamination.



Conduct Hazard Analysis The outcome of the hazard analysis is to determine significant hazards. The determination of significant hazards requires the HACCP team to adopt a methodology to assist in the decision making process. There are many sources of uncertainty and variability when considering a risk assessment of hazards to human health. The analysis process uses experience, asks questions, examines the literature, and conducts research if necessary, referring back to the product definition and intended use/consumer group identification. It would be beneficial to have the decision of which hazards are significant based on the principles of risk analysis, however this information is not always available and at a minimum, CODEX requires the HACCP team to apply best judgment. Information used by the team in determining significant hazards includes knowledge of end product use by the consumer to determine hazard potential of final product that links to the preliminary steps that identified the product definition, intended use and consumer group. Once hazards are identified, as described above, the hazard analysis technique uses estimates of frequency and consequence (sometimes called severity) of each hazard to determine the overall risk. Frequency is measured by how often the hazard is expected to occur. Frequency estimates are made in terms of the number of times per year that an event is expected to occur. If the hazard is expected to occur, for example, once in ten years, this estimate is expressed as 0.1 events/year. Consequence is measured by three criteria:

Duration - The amount of time that water delivered to the customer is of unacceptable quality.

Number of Customers Affected -

How many customers receive the water of unacceptable quality.

Magnitude - How poor the quality of the water is (ie: how great is the concentration of contaminants).

Estimates can be made for each criterion in plain language terms. For duration, the amount of time can be expressed in days, weeks, months, or years. The numbers of customers can be expressed in terms of absolute numbers (eg. 1000 customers). For chemicals, the magnitude can be expressed in terms of the expected level of contaminants relative to the water quality guidelines, where “high” equates to 10 to 100 times the guidelines, “medium” equates to 2 to 10 times the guidelines, and “low” equates to less than 2 times the guidelines.



Once some plain language estimates are obtained for each measure of consequence they can be scored on a consistent basis using the scales in the following figure. These scales may need to be adapted further once the range of estimates across all hazards have been made and can be examined. Once frequency and consequence scores (for each measure of consequence) are obtained, the calculation of risk is defined as: Frequency x Consequence Factor = Risk This calculation process is summarized in Figure 1 below. The frequency is expressed as originally estimated in terms of events/year. The consequence factor is obtained by multiplying each measurement of consequence by a weighting factor that reflects the importance of the measurement in determining the overall consequence. Each water supplier needs to determine the weighting which best reflects the company’s concerns and objectives. The calculation (using example weights) is defined as: Duration Score x Weighting Factor of 0.25 = D Magnitude Score x Weighting Factor of 0.5 = M Customers Affected x Weighting Factor of 0.25 = C The results of each calculation are added together to arrive at an overall consequence factor, or: D + M + C = Consequence Factor. Based on the risk scores obtained from the above process, hazards can easily be ranked in terms of risk levels. Further, this system provides some means to determine which hazards should be managed first. A water utility could choose to deal with those hazards which represent the top 80 percent of the risk score, before moving on to remaining hazards which constitute less than 20 percent of the risk score.



Identify Hazard Events

Conduct Following Stepsfor Every Hazard Event

Estimate Frequency of Hazard Event

Estimate Durationof Hazard Event

Estimate Magnitudeof Hazard Event

Estimate No. ofCustomers Affected

by Hazard Event

Convert to Scores*Duration

Score Information 2 < 12 hours

4 12-24 hours8 1-7 days

16 7-14 days 32 14-30 days 64 1-2 months 125 2-6 months

250 6-12 months500 1- 2 years

1000 2 years or more

Convert To Scores*Customers

Score Affected2 <7504 1,5008 3,00016 6,00032 12,50064 25,000125 50,000250 100,000500 200,0001000 >400,000

Convert to Scores*

Low (less than double Guidelines) = 8

Medium (2 to 10 timesGuidelines) = 32

High (>10 timesGuidelines) = 250

Customers AffectedScore x 0.25**

MagnitudeScore x 0.5**

DurationScore x 0.25**

Frequency inevents/year

* Scores are on a logarithmic scale** Numbers are example weighting factors for each criterion

+ +

Consequence Factorx Risk Score=

Flow Chart of Hazard Analysis Process

Figure 1



Simpler Risk Classification System However a more simple risk classification system (using a 1 to 5 scale for severity and a 1 to 5 scale for frequency) can be used. The following Risk Factor Matrix is a more simple approach to prioritizing risks. It is derived from the AS/NZS 4360:1999 Risk Management Standard.

Severity of Consequences Risk Factor Matrix: Insignificant Minor Moderate Major Catastrophic

Almost Certain 5 10 15 20 25 Likely 4 8 12 16 20 Moderate 3 6 9 12 15 Unlikely 2 4 6 8 10 Li

kelih

ood

Rare 1 2 3 4 5

Risk Factor = Likelihood x Severity of Consequences The scores used to rate the likelihood and severity for calculation of the Risk Factor is defined in the table below. All Risk Factors with a score equal to or greater than 6 should be considered significant by the HACCP Team and investigated in more detail.

Item: Definition: Weighting: Almost certain Once a day 5 Likely Once per week 4 Moderate Once per month 3 Unlikely Once per year 2 Rare Once every 5 years 1 Catastrophic Public health risk 5 Major Impact on Operating Licence 4 Moderate Impact on Customer Charter 3 Minor Significant impact 2 Insignificant No impact or not detectable 1

Determine Control Measures The team must then consider what control measures, if any, exist which can be applied for each hazard. Control measures are physical, chemical, or other factors that can be used to control an



identified hazard. More than one control measure may be required to control a specific hazard. More than one hazard may be controlled by a specified control measure. The control measures for significant hazards need to be documented as this information forms the basis for the determination of CCPs. In water supply, any action that is taken to reduce or eliminate a hazard is a control measure. Many control measures are preventive actions such as standard operating procedures, system operating rules or personnel training. These control measures are not generally engineered barriers, such as treatment, and do not generally be considered as CCPs. These control measures form part of the Supporting Program for a water supplier. For many water supply activities, such as catchment management and distribution system management, most control measures are not considered CCPs. Examples of control measures are shown in Table 2.



Table 2- Examples of Control Measures for Hazards to Drinking Water Hazards Examples of Control Measures Biological Eg. Bacteria, viruses, protozoa

• Better control of chlorine dosing through Standard Operating Procedures, training, or new equipment.

• New disinfection technologies. • Maintenance of chlorine residual in

system through rerouting flows or increased flushing.

• Maintenance of chlorine residual through tablet dosing or rechlorination facilities.

• Inspection and repair of reservoir roofs and removal of infestations.

• Backflow prevention programs. • Negotiating for increased raw water

controls. • Increased cleaning of mains to remove

biofilms. Chemical Eg. Overdosing of treatment chemicals, disinfection by-products, chemical impurities, spills of cleaning agents or lubricants, corrosion by-products, pesticides in raw water.

• New procedures/equipment for dosing of chemicals.

• Chlorine optimization study to reduce THMs.

• Removal of precursors to reduce THMs. • Isolating system from potential spills. • QA system for chemical suppliers. • Backflow prevention for key industries. • New liners/materials for pipes and

reservoirs. Physical Eg. sediments/particulates

• Increased cleaning of mains. • Replacing unlined pipes and fittings. • Flocculation or filtration treatment steps. • New maintenance Standard Operating

Procedures to avoid unnecessary resuspension of materials.

• Practices to avoid reversal of flows.



Workshop Activity Hazard Determination and Risk Assessment

For each of the hazards identified in the previous activity, estimate the frequency, duration, magnitude, and number of customers affected by the hazard. Use Worksheet 6 to make note of your estimates.



SUMMARY Step 6 - Hazard Analysis • Document all hazards, control measures and the methodology used to determine hazards of

significance. • Acknowledge limitations of the Risk Analysis process to ensure suitable revalidation of

hazards on a regular basis. Limitations include: ∗ Knowledge of hazards incomplete or not yet determined; ∗ Estimations based on mix of experience, judgment and calculation of probability; ∗ Underestimation of hazards and unidentified hazards. • For a hazard to be significant, it must be of such a risk/severity that its prevention,

elimination, or reduction to acceptable levels is essential to produce the water within consideration of the hazard analysis scope.

• Ideal situation is to identify all significant hazards, and design or change the process to

eliminate or prevent them from occurring. • If process can be changed to eliminate a significant hazard or reduce it so that it is no longer

significant, then it should. Otherwise, hazards that are significant must be controlled through the HACCP process.

• The purpose of HACCP is to control significant hazards. If the hazard is within the scope,

properly identified, and significant, then its control is just as important as any other significant hazard and no CCP is "more critical" than another. What differs is the extent of the preventative measures, monitoring and sampling, and corrective actions.



Example Worksheet 6: Hazard Analysis Describe the durations, magnitude, number of customers affected, and frequency of each hazard event. Consequence

Criteria

No.

Process Step or Activity

Hazard Event Name & Cause

Duration

Magnitude

Customers Affected

Event Frequency

1 Storages Microbial –

pathogen contamination of

storages by vermin access

12 – 24 hours Medium 12,500 Rare

2

3

4


A-45

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Example Worksheet 6: Hazard Analysis Describe the durations, magnitude, number of customers affected, and frequency of each hazard event. Consequence

Criteria

No.

Process Step or Activity

Hazard Event Name & Cause

Duration

Magnitude

Customers Affected

Event Frequency

1

2

3

4

Date: ____________ Prepared By: _____

A-46

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


SECTION 5 Step 7 Determine Critical Control Points (CCPs) A Critical Control Point is defined as a point, step or procedure at which control can be applied and a safety hazard can be prevented, eliminated, or reduced to acceptable levels. All significant hazards identified through the risk assessment process need to be managed to ensure the risk is reduced to an acceptable level. Critical Control Points indicate where in the process, an action needs to be taken to either reduce, prevent or eliminate a significant hazard. If the scope of the HACCP plan includes product quality issues the difference between a CCP for public health safety and water quality should be clearly indicated. Many HACCP plans indicate CCPs for public health safety hazards and control points, CCPs for aesthetic quality. The key difference being that a CCP must be met to ensure safe water and a CCP is where a loss of control will not lead to unsafe product. Examples of control points may include taste, odor, color, etc. Identification of CCPs The CCP Decision Tree recommended in the 1996 Codex document may be used to determine if a process step is a critical control point. Remember, the Decision Tree is a tool only, the team’s good judgment is also important.



CODEX Decision Tree to Identify CCPs

Q1. Do control measure(s) exist (for the identified hazard) ?

Modify step, NO process or YES product Is control at this

step necessary for safety? YES NO Not a CCP Q2. Is the process step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level? YES NO Q3. Could contamination with identified hazard(s) occur in excess of acceptable level(s) or could these increase to unacceptable level(s)? YES NO Not a CCP Stop* Q4. Will a subsequent step eliminate identified hazard(s) or reduce the likely occurrence to an acceptable level? NO Critical

Control Point YES Not a CCP Stop* *Proceed to next step in the described process.



Guidance Notes on the CCP Decision Tree Question 1: Do control measures exist for the identified hazard? • Consider the measures already in place and any measures that could be implemented. • If the answer to this question is NO and control measures are not and cannot be put in place,

the HACCP team must consider if whether control at this point is necessary to produce safe water. If control is not necessary here then it is not a CCP.

• If a hazard has been identified at a process step and there are no possible control measures at

that or any following step, then either the process step, process or product needs to be modified.

Question 2: Is the step specifically designed to eliminate or reduce the

likely occurrence of a hazard to an acceptable level?

• It is the step NOT the control measures that is being questioned. This question is really asking whether the step itself controls the hazard.

• This question was originally developed to accommodate process steps that are specifically

designed to control specific hazards. Consider both the hazard analysis information and the process flow diagram when considering this question.

• Ensure that all process steps are considered not just the key processes. Question 3: Could contamination occur at or increase to unacceptable

level(s)?

• This question requires the hazard analysis as well as knowledge of the process and processing environment.

• Acceptable and unacceptable levels need to be defined within the overall objectives in

identifying the CCPs of the HACCP plan.



• Consider the following; ⇒ Is the immediate environment likely to include the hazard? ⇒ Is cross contamination possible from other product? ⇒ Could product build up in dead spaces and increase the hazard? ⇒ Are other factors or conditions present that could cause contamination to increase to

unacceptable level(s) at this step? • Consider scenarios where contamination may increase unacceptable levels through a

combination of steps. Question 4: Will a subsequent step or action eliminate or reduce the

hazard to an acceptable level?

• This question is designed to allow the presence of a hazard or hazards at a particular process stage if they will be controlled either later in the process.

• This question will minimize the number of process steps that are considered to be CCPs and

focuses on steps that are essential for product safety. • If the answer is YES then this step is not a CCP however the subsequent step/action will be. • This question may not always be appropriate as although it reduce the likely number of CCPs

it may be commercially viable to institute control sooner rather than later.



Workshop Activity

Determine CCPs In HACCP teams, use the decision tree to determine where the likely CCPs are in your process. Refer to your listing of significant hazards and associated control measures and the flow process diagram. Record your CCPs on Worksheet 7 provided. The remaining columns will be filled out later.



SUMMARY Step 7: Determine Critical Control Points • Critical Control Points are the stages in a processing operation where the water hazards are

controlled. • These are the points that ensure that the hazard is not able, in the finished product, to cause

harm to the consumer. • The CCP itself doesn’t control the hazard - it is the action taken at the CCP that controls the

hazard. • A process step can only operate as a CCP if preventative/control measures can be introduced. • CCP risk management should be a continuing process that takes into account all newly

generated data in the evaluation and review of the HACCP plan.



Example Worksheet 7: HACCP Summary Table Process

Step CCP Critical

Limit Monitoring Corrective Action Records Verification

Storages 1. Intact bird proofing mesh and action on any breach in bird-proofing

Method: Water Operations’ field technicians carry out during site visits.

Components: SOPs for corrective actions taken, policy on how to disseminate information and what to record, and records of actions taken.

Activity:

Frequency: Inspections occur fortnightly on average.

Actions: Water Operations’ Engineers are notified of breaches and repair bird-proofing and undertake the appropriate procedures: Drain and clear storage; Flush affected area; Increase disinfection dosing; Bypass storage; Alternative supply: and recording of actions taken.

Method:

Responsibility: Reports are recorded in field technicians’ personal diaries or rung in immediately for action if required.

Responsibility: Water Operations’ Engineers are responsible for taking action

Responsibility: Water Operations’ Engineers

Frequency:

Responsibility:


A-53

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Example Worksheet 7: HACCP Summary Table

Process Step

CCP Critical Limit

Monitoring Corrective Action Records Verification

Method:

Actions: Components: Activity:

Frequency:

Method:

Responsibility: Responsibility:

Responsibility: Frequency:

Responsibility:

Method:

Actions: Components: Activity:

Frequency:

Method:

Responsibility:

Responsibility:

Responsibility: Frequency:

Responsibility:


A-54

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


SECTION 6 Step 8 Establish Critical Limits A critical limit needs to be assigned for each control measure associated with a CCP. A critical limit defines the absolute cut off to ensure product safety. If a critical limit is not met (or exceeded) then the significant hazard is no longer controlled and corrective action must be taken. Some hazards at CCPs may require several critical limits to control the hazard. For example, time and temperature critical limits or chlorine contact time to ensure lethal or biostatic treatment of biological hazards. Determining Critical Limits As critical limits are the cut off point for product safety they need to be carefully determined as even if the correct significant hazard, control measures and CCP have been determined, an incorrect critical limit will mean that safe water is not produced. Critical limits are determined by referring to known theoretical information to set the limit and by determining capability to meet the limit, (process capability). Both components need to be addressed when setting critical limits. (This is the process of validating critical limits). Information used to determine critical limits may include: • Literature; • Supplier records or data; • Regulatory guidelines and tolerances; • Experimental studies. Critical limits for biological hazards may have physical and/or chemical critical limits such as chlorine concentration instead of actual measurements of microorganisms and parasites present due to unrealistic time delays and costs to determine contamination. Other considerations when determining critical limits include: • Process variations; • Monitoring method including cost and time factors; • Realistic limits as opposed to targets or tolerances. Regulatory requirements for maximum permissible total chlorine residual may serve as the tolerance however the critical limit for chlorine residual may be set below the tolerance. Describing Critical Limits: Critical limits must be clearly communicated in the HACCP plan. Numerical critical limits such as those for chlorine residual or pH must be indicated as either a maximum, (a value not to



exceed), minimum, (value that must be exceeded), or range with clearly defined upper and lower criteria. Validation of Critical Limits Validation is, “the initial review by the HACCP team to ensure that all elements of the HACCP Plan are accurate” (NACMCF, 1992). Validation confirms that the HACCP Plan, if implemented as designed, will be effective in controlling the safety hazards identified as significant. Validation includes documenting that CCPs effectively address significant hazards. Validation also confirms that the HACCP plan, if implemented as designed, will be effective in controlling the water safety hazards identified as significant. Prior to and during HACCP plan implementation, the company must validate the HACCP Plan. Validation must also occur whenever significant changes are made in the process, equipment, formulation, raw materials, etc. The nature and quantity of information required to validate a HACCP plan will vary depending on factors such as the nature of the hazard and the control measures chosen to address it. Validation of HACCP Plans often will require process studies, confirmation of equipment specifications, microbiological challenge studies, literature reviews, and a variety of other scientific and technical examinations. It is the facility’s responsibility to assure that validation activities are completed, either through the HACCP Team or through competent processing authorities. Data assembled to validate a HACCP plan are usually of two types, theoretical data and process capability data. 1. Theoretical data: Expert advice from water authorities, scientific data, or other information demonstrating that particular process control measures can adequately address specified hazards, such as studies establishing the chlorine concentration and contact time to inactivate organisms of concern. The critical limits for biological hazards are not normally a measure of the number or presence of the biological hazard. On the other hand, it is not unusual for critical limits associated with physical and chemical hazards to be a measure of the hazard. There is limited scientific information on specific criteria for physical hazards. However, there is considerable scientific information on chemical hazards. Often regulatory requirements will serve as an excellent source for validating critical limits for chemical hazards.



2. Process Capability: Observations, measurements, test results, or other information demonstrating that the control measures, as written into a HACCP plan, can be operated within a particular establishment to achieve the intended product safety objective. This means that the data used to validate a HACCP plan may be derived from various sources, including the scientific literature, product testing results, experimental research results, scientifically based regulatory requirements, computer-modelling programs, and data developed by process authorities. This part of validation involves the assurance that equipment or procedures as used in production are adequate and the operating parameters are properly established. Equipment manufacturers and processing experts are good sources of information in determining the proper equipment and its use. Example of validation Chlorination is used to control pathogenic bacteria. For example, Campylobacter is a bacterial pathogen that causes gastroenteritis. It may enter an open reservoir from bird feces and there have already been outbreaks assumed to be subject to this cause. Experimental work could be performed in which known numbers of Campylobacter bacteria could be added to water. Chlorine could be added to the water and the number of bacteria remaining after a certain amount of time could be used to determine how much chlorine reduces these bacterial numbers to very low levels. For example, if it were shown that 0.2 mg/L of free chlorine would kill more than a million Campylobacter cells per mL in 5 mins at pH < 8.0 then this could be set as the critical limit for disinfection for this pathogen.



Workshop Activities Determine and Validate Critical Limits

• In HACCP teams, determine the most suitable critical limit for CCPs identified in your

process. For the purpose of the activity these critical limits will be based on best judgment. Record critical limits on the Worksheet 7 provided.

• In HACCP teams, determine what questions you would research to validate critical limits

that your team has determined for CCPs. Remember to consider both theoretical validation and sources of information you would reference and variables to consider when determining process capability.



Step 9 Monitoring Monitoring may be defined as planned observations or measurements to provide a record. All critical limits will have an associated monitoring activity to ensure that the critical limit is met. If monitoring indicates that the critical limit has not been met, then predetermined corrective action must be taken. Monitoring serves three main purposes (NACMCF, 1992). 1. Monitoring is essential to safety measurement in that it tracks the system's operation. If

monitoring indicates there is a trend towards loss of control, ie. exceeding a target level, then action can be taken to bring the process back into control before a deviation occurs.

2. Monitoring is used to determine when there is loss of control and a deviation occurs at a

CCP, ie. exceeding the critical limit. Corrective action then must be taken. 3. Monitoring provides written documentation for use in verification of the HACCP System.

As the most active part of HACCP, monitoring requires management action and commitment. Determining Appropriate Monitoring The appropriate monitoring for critical limits will be dependent on whether the critical limit is numerical or descriptive. Numerical critical limits such as total chlorine residual will have measurement based monitoring where as descriptive critical limits such as “compliance to work instructions ” will have observation based monitoring. When designing HACCP monitoring activities for CCPs the following steps may be considered; Step 1: Ask the right questions. The questions must relate to the specific information need. Otherwise, it is very easy to collect data that is incomplete or answers the wrong questions. Step 2: Conduct appropriate analyses. What analysis must be done to get from raw data collection to a comparison with the critical limit? Step 3: Define “where”. If a critical limit is an internal temperature of a product or a particular chemical contact time, then the monitoring must be done when the maximum temperature or time has been shown to be reached. Step 4: Select the monitor. The data collector must have easy access to the CCP and understand the purpose, importance, and process of the monitoring activity.



Step 5: Understand the needs of the monitor. Including special environmental requirements, training, and experience.

Step 6: Design monitoring forms, which are simple but effective. Be sure the forms are self-explanatory, record all appropriate data, and reduce opportunity for error.

Step 7: Prepare instructions. Detail the monitoring process.

Step 8: Test the forms and instructions. Ensure forms and instructions are logical and able to be easily completed.

Step 9: Provide appropriate training for the allocated monitor.

Step 10: Audit the process and validate the results. Measurement Monitoring • May be continuous, automated alarmed systems recorded on data sheets or control charts; • Less subjective; • Requires use of calibrated equipment. Observation Monitoring • Frequently recorded on checklists; • May be subjective as it relies on interpretation by the person monitoring and therefore has

room for error; • Subjectivity may be reduced by providing trained and skilled monitors that are consistent in

interpretation of monitoring results. Other considerations for determining appropriate monitoring: • Available methods; • Time & cost of monitoring methods; • Training required by monitors; • Attribute sampling may be used in the HACCP plan to determine acceptability of a “lot”.

Because not every sample is tested, incorrect decisions may be made. Reference should be made to an Operating Characteristic Curve that identifies the probability of a wrong decision based on the sampling plan.



Determining Frequency of Monitoring: Monitoring must provide assurance that the critical limit has been met. Consider the following; • Does nominated monitoring frequency provide an early warning system to allow the process

to be adjusted before critical limits are exceeded? • Does nominated monitoring reduce product and economic issues? ie. What is the volume of

product produced between monitoring intervals? If monitoring indicates that the critical limit has not been met, all product since the last known compliance to the critical limit will be subject to corrective action.

Describing Monitoring in the HACCP Plan: Monitoring instructions in the HACCP plan should include: • Monitoring method used for each CCP critical limit including the monitoring procedure and

where the monitoring is done to reflect the critical limit; • Frequency of monitoring, continuous or scheduled; • Responsibility for monitoring.



Workshop Activity

Determine Monitoring for Critical Limits In HACCP teams, determine the most appropriate monitoring activity for the critical limits

identified for CCPs. Identify any existing monitoring procedures that are applicable. If so, is the

frequency appropriate. Record monitoring activity on Worksheet 7 provided.



Step 10 Establish Corrective Actions CODEX requires that corrective actions are planned for when monitoring indicates that a critical limit has not been met or is exceeded. The outcome of planned corrective actions is to ensure that the CCP is brought under control and non-conforming product is correctly handled. Corrective action plans may include the following: 1. Immediate action required to resolve problem. This may include stopping water production

and appropriate segregation of product to prevent further contamination. 2. Responsibility for corrective action indicating who has responsibility for decisions

regarding immediate actions. This may also include which problem needs to be reported on for future action to prevent re-occurrences.

3. Disposition of product indicating whether product can be reworked or if it needs to be

rejected. Any reworking of product needs to be supported with documented proof that reworking will eliminate the product safety risk created by failure to comply with the critical limit.

4. Root cause of problem should be prompted so that the actual cause of the problem can be

addressed and preventative action taken to prevent recurrences. The need for further tests and validation of process may be relevant. (This would also be referenced in an ISO 9000 system under preventative action)

All corrective actions taken need to be recorded as proof of compliance to the HACCP plan and to prove all reasonable precaution and due diligence.



Workshop Activity Determine Corrective Actions

In HACCP teams, determine the most suitable corrective action for when monitoring indicates that the critical limit has not been met. Identify any existing corrective action procedures that are applicable. Record corrective actions on Worksheet 7 provided.



SUMMARY Step 8 - Critical Limits: • Critical limits need to be assigned for each CCP • Critical limits need to be validated (Objective evidence of validation may include documented

facility trials and research, references to regulatory and scientific information, etc.) • Critical limits must be appropriately described, ie. maximum/minimum values. Step 9 - Monitoring: • Each CCP needs an associated monitoring activity. • Monitoring procedure should describe the “what, how, where, when, who” information. • Monitoring needs to provide a high level of assurance that the process is under control. Step 10 – Corrective Actions • Corrective action records must be completed for all deviations from the critical limit. • Corrective action records should correlate to the relevant monitoring records. • Corrective action records need to include a description product segregation, correction and

disposition and signed by the responsible person. • Corrective action records should be reviewed to assess the HACCP plan for any trends and

therefore identify the need for preventative action.



SECTION 7 Step 11 Establish Verification Procedures Verification is the use of methods, procedures, or tests in addition to those used in monitoring to determine if the HACCP system is in compliance with the HACCP Plan and/or whether the HACCP Plan needs modification and revalidation. Verification is a confirmation process. It confirms that the HACCP system follows the HACCP plan, ie. that the HACCP plan has been accurately implemented. Verification confirms that the HACCP Plan identifies hazards and sets appropriate CCPs and critical limits, ie. that the HACCP Plan is accurate. Verification also confirms that the HACCP system established as a result of the HACCP Plan is effective for producing a safe drinking water. There are four types of verification. Three are the company’s responsibility and the fourth centres around the regulatory agency’s responsibilities. Industry Verification Each company that institutes a HACCP Plan must verify it. The NACMCF suggests three types of verification for industry HACCP Plans: 1. Critical Limits - Prior to implementing the HACCP Plan, the firm must verify that the

critical limits established are satisfactory and do indeed control the hazard. (This is the process of validation).

2. HACCP Plan - The second verification process ensures that the HACCP Plan is functioning

effectively. On a daily basis, the firm should review all HACCP records generated that day. The review should confirm that records are completed properly and that critical limits have been met or proper corrective actions instituted. Additionally, firms should walk through their facility frequently, check CCPs, and verify that the HACCP Plan is being followed. During this verification process, firms should also check that appropriate decisions are being made regarding corrective actions and product disposition.

3. Revalidation- Revalidation is done independent of the second verification process where the

company is checking to see that the HACCP Plan is being followed. The HACCP Team should perform revalidations on a set frequency, usually yearly, more often if the process is changed. The revalidation includes an entire HACCP Plan review, starting with the product definition through the flow diagram and seven HACCP Principles.

4. Regulatory Verification - Ensures that the HACCP system is functioning properly.



Internal & External Verification Activities: The principles of HACCP require internal verification activities and encourage external verification as a separate check and balance. The protocol recommended by the NACMCF HACCP system document details ten different types of verification. 1. Establishment of appropriate verification inspection schedules 2. Review of the HACCP plan - Internal and External 3. Review of CCP records - Internal and External 4. Review of deviations and dispositions - Internal and External 5. Visual inspections of operations to observe if CCPs are under control - Internal & External 6. Random sample collection and analysis - Internal and External 7. Review of critical limits to verify that they are adequate to control hazards - Internal and

External 8. Review of written record of verification inspections which certifies compliance with the

HACCP plan or deviations from the plan - Internal and External 9. Validation of the HACCP plan(s), including on-site review and verification of flow diagrams

and CCPs - Internal and External 10. Review of modifications of the HACCP plan - Internal. Scheduling Verification Activities: The HACCP plan is initially reviewed before it is implemented and continuously updated as it grinds over the bumps and holes. Once the HACCP plan is implemented, its review becomes less frequent. As there are many types of verification activities, there are many frequency schedules. Each type of verification has its own frequency for adequate assurance that the HACCP plan is acceptable and effective. However, verification frequency and schedules should be pre-established in the HACCP plan.



Example of HACCP System Verification Schedule Activity Frequency Responsibility Reviewer Verification Scheduling Yearly or upon

system change HACCP coordinator

Operations Manager

Verification of HACCP support programs (ISO 9000)

Prior to HACCP plan implementation

HACCP team Operations Manager

Individual CCP verification activities

See HACCP plan See HACCP plan

HACCP Team

Critical Limit Validation When adopted or changed

Q.A. or Independent Expert

HACCP Team

HACCP system Verification

Yearly or upon system failure or significant change

HACCP Review Team or Independent

Operations Manager

Examples of triggers for HACCP verification • Change in raw materials (in this case long term changes in raw water quality for example,

due to prolonged flooding in the catchment), product formulation, raw material source or supplier.

• Change in processing system and/or conditions (eg. changes in treatment steps). • Change in system layout and environment (eg. new treatment equipment). • Modification to process equipment (eg. placing new type of mixer in chlorine contact tank). • Change in cleaning and sanitation program (eg. new programs of cleaning, scouring, or

flushing). • Change in packaging, storage and distribution (eg. new reservoirs or large new

developments). • Change in staff levels and / or responsibilities. • Anticipated change in consumer use. Receipt of information from the market place indicating a health or spoilage risk associated with the product (eg. incidences of gastrointestinal disease in the community that are clearly associated with the water supply).



Workshop Activity Determine Verification for CCPs

In HACCP teams, determine the most suitable verification activities for CCPs. Identify any existing verification procedures, such as training programs, calibration of equipment etc, that are applicable. Record verification on HACCP Worksheet 8 provided.



Step 12 Establish Documentation and Record-Keeping The HACCP system needs to be documented to provide proof of compliance to the HACCP plan, to meet legal requirements and to provide a legal defense for all reasonable precaution and all due diligence. HACCP records provide retrospective proof of compliance to the HACCP plan. They also enable product traceability to be maintained and provide information that may be used for trend analysis and continuous improvement. To provide proof of compliance, HACCP records should be dated and signed. HACCP monitoring and corrective action records may have two signatures, by the person completing the record and the person verifying the record. Records should provide product traceability and will need to include specific product identification such as batch number, production code, quantity produced, equipment used etc. Ideally HACCP monitoring records should correlate to corrective action records. Types of HACCP records: Examples of HACCP Documentation: All information used during the development of the HACCP plan including; • Preliminary steps • Hazard Analysis • CCP determination • Critical limit determination and validation • Sampling plans for monitoring Examples of HACCP Records: • CCP monitoring activities • Deviations and associated corrective actions • Modifications to the HACCP system • Verification activities Examples of other documentation that support the HACCP plan may include; A: Raw materials • Supplier certification from bulk water supplier documenting compliance with industry

standards. • Processor audit records verifying supplier compliance.



B: Records relating to the product safety • Sufficient data and records to establish the efficacy of barriers in maintaining product safety. • Documentation of the adequacy of the processing procedures from a knowledgeable process

authority. C: Processing • Records from all monitored CCPs • Records verifying the continued adequacy of the processes. D: Distribution • Records indicating compliance with specifications for distribution network. E: Deviation and corrective action records F: Validation records and modification to the HACCP plan indicating approved revisions and changes in ingredients, formulations, processing, packaging and distribution control, as needed. G: Employee training records Establishing a Record-Keeping System Record-keeping is a system within a system and it may be useful to reference ISO 9000, 4.16 that describes the key elements for a record-keeping system. This states that procedures shall be developed for the identification, collection, indexing, access, filing, storage, maintenance and disposition of records. Records Review and Retention Considerations for records retention may include; • Use of due diligence defense and the time for a prosecution case to be presented. Confirm

with Local Government and State Health Authority as times for prosecutions may differ between states;

• Advice from your public liability insurer.



Workshop Activity Determine HACCP documentation and record keeping requirements

In HACCP teams, determine what HACCP documentation and records will be retained to provide retrospective proof of compliance and to support due diligence requirements. Record this information on Worksheet 8.



SUMMARY Step 11 – HACCP Verification • Verification activities should be identified with a separate frequency (ie. daily, weekly,

monthly) and recorded on a verification inspection schedule. • Verification activities need to demonstrate that the HACCP program is effective. • Verification of HACCP supporting programs such as ISO 9000 is also required. Included in

these activities could be; equipment calibration, review of purchase specifications, environmental sampling, stock rotation checks, product challenge tests, confirmation of cleaner and sanitizer concentrations.

Step 12 – Establishing Documentation and Record-Keeping • Documents and records that provide proof of a HACCP system must be retained to provide an

auditable system. • Records need to include product identification, critical limit and signatures. • Corrective action records must correlate to monitoring records and include a description of the

problem, product segregation and disposition. • Records should be reviewed at appropriate intervals to identify any trends that may indicate

the need for preventative action.



Example Worksheet 8: Validation Schedule Planned Verification Activity Time Interval Responsibility for

Action Responsibility for Review/Approval

Records

Establish Verification Inspection Schedules

Review of HACCP plan and its implementation

Yearly Quality Manager HACCP Team

Internal Auditors Audit Schedule Audit Reports

Validation of Critical Limits

Presence and correctness of CCP Monitoring

Monitoring equipment calibrated/operating

Review monitoring and corrective action records

Sample analysis to verify CCP is under control

Presence of written verification reports


A-74

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Worksheet 8: Validation Schedule Planned Verification Activity Time Interval Responsibility for

Action Responsibility for Review/Approval

Records

Establish Verification Inspection Schedules

Review of HACCP plan and its implementation

Validation of Critical Limits

Presence and correctness of CCP Monitoring

Monitoring equipment calibrated/operating

Review monitoring and corrective action records

Sample analysis to verify CCP is under control

Presence of written verification reports


A-75

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


References Codex. 1991. General Definitions of HACCP and Procedures. Codex Committee On Food Hygiene, Codex Alimentarius Commission, 25th Session. Rome: FAO. Codex. 1996. Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for its Application. Alinorm 97/13A Appendix II. Codex Committee on Food Hygiene, Codex Alimentarius Commission, 29~ Session. Rome: FAO. Davison, A., Howard, G., Stevens, M., Callan, P., Kirby, R., Deere, D., Bartram, J. (2002) Water Safety Plans. World Health Organization. WHO/WSH/02.09. Deere, D., Stevens, M., Davison, A., Helm, G., Dufour, A. (2001) Management Strategies. In:Water Quality:Guidelines, Standards and Health. Eds Fewtrell, L., Bartram, J. World Health Organization. Published by IWA Publishing, London, UK. Foodborne Microorganisms of Public Health Significance, 1997, Australian Institute of Food Science and Technology (NSW Branch) Food Microbiology Group, 5th Edition, International Commission On Microbiological Specifications For Foods (ICMSF). 1988. HACCP in Microbiological Safety And Quality. Blackwell Scientific, Oxford, England. NACMCF. 1992. Hazard analysis and critical control point system. National Advisory Committee on Microbiological Criteria for Foods (NACMCF).Washington D.C. Pierson, M.D. and Corlett, D.A. 1992. HACCP - Principles And Applications. Based on the Institute of Food Technologists Short Course on HACCP. Chapman Hall, New York.



HACCP GLOSSARY Audit A systematic comparison of a defined procedure with an actual process. In food safety terms a check on documentation and procedures and whether the hazards have been identified and effectively controlled. An audit may be internal or external.(CODEX,1997) Auditor A person who conducts an audit. (CODEX,1997) Control (verb) To take all necessary actions to ensure and maintain compliance with criteria established in the HACCP plan. (CODEX,1997) Control (noun) The state wherein correct procedures as being followed and criteria are being meet. (CODEX,1997) Control Measure Any action and activity that can be used to prevent or eliminate a food safety hazard or reduce it an acceptable level. (CODEX,1997) Corrective Action Any action to be taken when the results of monitoring at the CCP indicate a loss of control. (CODEX,1997) Critical Control Point (CCP) A step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level. (CODEX,1997) Critical Limit A criterion which separates acceptability from unacceptability. (CODEX,1997) Deviation Failure to meet a critical limit. (CODEX,1997) Flow diagram A systematic representation of the sequence of steps or operations used in the production or manufacture of a particular food item. (CODEX,1997)



Food A substance, whether processed, partly-processed live or raw, intended for or represented as being for, human consumption and includes drink, chewing gum and any substance used in the preparation, production, manufacture or treatment of food, but does not include substances declared in the Food Standards Code not to be food and therapeutic goods within the meaning of the therapeutic Goods Act 1989. (ANZFA, October 1998) HACCP A system which identifies, evaluates and controls hazards which are significant for food safety. (CODEX,1997) HACCP Plan A document prepared in accordance with the principles of HACCP to ensure control hazards which are significant for food safety in the segment of the food chain under consideration. (CODEX,1997) Hazard A biological, chemical or physical agent in, or condition of, food with the potential to cause an adverse health effect. (CODEX,1997) Hazard Analysis The process of collecting and evaluating information on hazards and conditions leading to their presence to decide which are significant for food safety and therefore should be addressed in the HACCP plan. (CODEX,1997) Monitor The act of conducting a planned sequence of observations or measurements of control parameters to assess whether a CCP is under control. (CODEX,1997) Process In relation to food, means activity conducted to prepare food for sale including chopping, cooking, drying, fermenting, heating, pasteurizing, thawing, and washing, or a combination of these activities. (ANZFA, October 1998) Processing Aids Any substance or material, not including apparatus or utensils, and not consumed as a food ingredient by itself, intentionally used in the processing of raw materials, foods or its ingredients to fulfil a certain technological purpose during treatment or processing and which may result in the non-intentional but unavoidable presence of residues or derivatives in the final product. (CODEX,1997) Risk Analysis A process consisting of three components: risk assessment, risk management and risk communication.



Risk Assessment A scientifically based process consisting of the following steps: (i) hazard identification, (ii) hazard characterization, (iii) exposure assessment, and (iv) risk characterization. Hazard Identification The identification of biological, chemical, and physical agents capable of causing adverse health effects and which may be present in a particular food or group of foods. Hazard Characterization The qualitative and/or qualitative evaluation of the nature of the adverse health effects associated with biological, chemical and physical agents which may be present in food. For chemical agents, a dose-response assessment should be performed if the data are obtainable.

Dose Response Assessment The determination of the relationship between the magnitude of exposure (dose) to a chemical, biological, or physical agent and the severity and/or frequency of associated adverse health effects (response). Exposure Assessment The qualitative and/or quantitative evaluation of the likely intake of biological, chemical, and physical agents via food as well as exposures from other sources if relevant. Risk Characterization The qualitative and/or quantitative estimation, including attendant uncertainty, of the probability of occurrence and severity of known or potential adverse health effects in a given population based on hazard identification hazard characterization and exposure assessment. Risk Management The process of weighing policy alternatives in the light of the results of risk assessment and, if require, selecting and implementing appropriate control option, including regulatory measures. Risk Communication The interactive exchange of information and opinions concerning risk among risk assessor, risk managers, consumers and other interested parties. Safe Food Food that is not likely to cause harm to a person who consumes the food when it is prepared, stored and consumed according to its reasonable intended use. (ANZFA, October 1998) Step A point, procedure, operation or stage in the food chain including raw material, from primary production to final consumption. (CODEX,1997)



Suitable Food Food that: (a) is not damaged, decomposed, deteriorated or perished or does not contain a damaged,

decomposed, deteriorated or perished substance, having regard to its reasonable intended use; (b) does not contain any biological or chemical agent, or other matter or substance that is foreign

to the nature of the food except for any matter or substance permitted by the Food Standards Code; and

(c) is not the product of a diseased part of an animal or one that has died otherwise than by slaughter; (ANZFA, October 1998)

Validation Obtaining evidence that the elements of the HACCP plan are effective. (CODEX,1997) Verification The application of methods, procedures, tests and other evaluations, in addition to monitoring to determine compliance with the HACCP plan. (CODEX,1997)


B-1

APPENDIX B HACCP PILOT-STUDY PLANS


B-2

AUSTIN HACCP PLAN


B-3

AUSTIN WATER UTILITY

HAZARD ANALYSIS AND CRITICAL

CONTROL POINT PLAN

(March 14, 2004)

Prepared By:

Austin Water Utility Environmental and Regulatory Services Division

Staff Contact: Dan W Pedersen 512-972-0074


B-4

HAZARD ANALYSIS AND CRITICAL CONTROL POINT PLAN

TABLE OF CONTENTS

TABLE OF CONTENTS ......................................................................................................................... B-4

INTRODUCTION .................................................................................................................................... B-5

BACKGROUND....................................................................................................................................... B-6

MODEL HACCP PLAN DEVELOPMENT.......................................................................................... B-7 A. STEP 1 – ASSEMBLE A TEAM ................................................................................................ B-7 B. STEP 2 – DESCRIBE THE PRODUCT ..................................................................................... B-7 C. STEP 3 – IDENTIFY INTENDED USE ..................................................................................... B-7 D. STEP 4 – CONSTRUCT A FLOW DIAGRAM ......................................................................... B-7 E. STEP 5 – VALIDATE PROCESS FLOW DIAGRAM............................................................... B-7 F. STEP 6 – CONDUCT HAZARD ANALYSIS............................................................................ B-7 G. STEP 7 – IDENTIFY CRITICAL CONTROL POINTS............................................................. B-7 H. STEP 8 – ESTABLISH CRITICAL LIMITS.............................................................................. B-7 I. STEP 9 – IDENTIFY MONITORING PROCEDURES ................................................................. B-8 J. STEP 10 – ESTABLISH CORRECTIVE ACTION PROCEDURES............................................. B-8 K. STEP 11 – VALIDATE/VERIFY HACCP PLAN...................................................................... B-8 L. STEP 12 – ESTABLISH DOCUMENTATION AND RECORD KEEPING ............................. B-8

AUSTIN’S HACCP PLAN....................................................................................................................... B-9 A. STEP 1 – HACCP TEAM ........................................................................................................... B-9 B. STEP 2 – PRODUCT DESCRIPTION ..................................................................................... B-10 C. STEP 3 – IDENTIFY INTENDED USE ................................................................................... B-11 D. STEP 4 – CONSTRUCT A FLOW DIAGRAM ....................................................................... B-11 E. STEP 5 – VALIDATE PROCESS FLOW DIAGRAM............................................................. B-11 F. STEP 6 – CONDUCT HAZARD ANALYSIS.......................................................................... B-11 G. STEP 7 – IDENTIFY CRITICAL CONTROL POINTS........................................................... B-15 H. STEP 8 – ESTABLISH CRITICAL LIMITS............................................................................ B-15 I. STEP 9 – IDENTIFY MONITORING PROCEDURES ............................................................... B-15 J. STEP 10 – ESTABLISH CORRECTIVE ACTION PROCEDURES........................................... B-15 K. STEP 11 – VALIDATE/VERIFY HACCP PLAN.................................................................... B-20 L. STEP 12 – ESTABLISH DOCUMENTATION AND RECORD KEEPING ........................... B-20

VERIFICATION .................................................................................................................................... B-21

ATTACHMENT B – LIST OF STREETS IN THE SOUTHWEST C PRESSURE ZONE ............ B-21

ATTACHMENT B – LIST OF STREETS IN THE SOUTHWEST C PRESSURE ZONE ............ B-22

ATTACHMENT C – SOUTHWEST C PRESSURE ZONE MAP .................................................... B-23


B-5

INTRODUCTION

Hazard Analysis Critical Control Point (HACCP) is a food quality control program originally developed for the National Aeronautics and Space Administration (NASA) in the early 1960’s. It focuses on the process of preparing food for consumption by astronauts in space that is safe to eat. HACCP looks at each step in the process of preparing, packaging, storing, and delivering food. Critical points where the food might become contaminated are identified and monitored so that food safety is assured. In subsequent years, HACCP has been widely adopted in the food industry. In recent years there has been discussion of applying HACCP to the drinking water industry. The Partnership for Safe Water, in which the Utility participated, is in many respects a HACCP program. It focuses on turbidity as a critical control point in the treatment of drinking water. Australian Utilities have been in the forefront of applying HACCP to control source water quality prior to treatment. Even though the application of HACCP to distribution systems is not yet fully developed, the EPA has been studying it as they revise the Total Coliform Rule and in the development of a Distribution System Rule.


B-6

BACKGROUND

In March 2002, the American Water Works Association Research Foundation released a request for proposal entitled Application of Hazard Analysis and Critical Control Points (HACCP) for Distribution System Protection. The objective of the research is to evaluate the HACCP model for application in protecting and maintaining distribution system water quality. The first major tasks in the research project is to review previous HACCP plans to see how they were tailored to meet the unique needs of the users and tailoring a HACCP for use in the distribution system. The next step is to develop a model HACCP system and have it reviewed by Utilities with an emphasis on the ability to implement the HACCP. The review was performed predominantly by Australian Utilities who have applied HACCP principals to source water protection. The final tasks are to develop and implement a HACCP Plan based on the model and adjust the model as necessary based on implementation results. The Utility was approached by the lead researcher, Economic and Engineering Services, Inc., and asked to participate as a research team member. The Utility agreed to participate because a better understanding of the critical control points in the distribution system will assist in optimizing the operation of the distribution system. Our commitment to the project was estimated to be at least 200 man-hours, with an in-kind value of at least $15,000. Actual tasks include participating in a HACCP workshop in our office, development of a HACCP plan based on the model, implementation of the HACCP plan in at least a portion of our distribution system, assembling system records, and performing monitoring and analysis activities. The Southwest C Pressure Zone was selected as a manageable area in which to apply the HACCP plan. The complete research team consists of Economic and Engineering Services, Inc., the Cooperative Research Centre for Water Quality and Treatment, Melbourne Water, Sydney Catchment Authority, Sydney Water Corporation, Austin Water and Wastewater Utility, South Berwick Water District, Northern Territories Power and Water Authority, South East Water, Yarra Valley Water, Gold Coast Water, Monash University, Egis, and the Victoria Department of Human Services.


B-7

MODEL HACCP PLAN DEVELOPMENT

In the initial tasks of the research, the research team developed and refined a twelve-step model for preparing and implementing a HACCP plan for a typical distribution system. The following are the twelve steps and a brief description of them: A. STEP 1 – ASSEMBLE A TEAM Pull together a multidisciplinary team to plan, develop, verify, and implement the plan. B. STEP 2 – DESCRIBE THE PRODUCT Describe the product, in this case drinking water, including its source, treatment, storage, distribution and any existing standards for product safety. C. STEP 3 – IDENTIFY INTENDED USE Describe how the product is used and the major users. D. STEP 4 – CONSTRUCT A FLOW DIAGRAM For a comprehensive HACCP, this would be a schematic showing sources of water, details of treatment, storage, pumping, and distribution to end users. For a HACCP directed toward a distribution system, the schematic would be restricted to showing the water flow path from the treatment plant to end users. E. STEP 5 – VALIDATE PROCESS FLOW DIAGRAM As a critical element around which the HACCP is based, the flow diagram needs confirmation of accuracy by the HACCP team. F. STEP 6 – CONDUCT HAZARD ANALYSIS Using the process flow diagram, identify hazards, their likelihood of occurrence, potential consequences, and control measures. G. STEP 7 – IDENTIFY CRITICAL CONTROL POINTS Based on the hazard analysis select the most significant hazards for control. These are typically points in the process where the consequences of failure are irreversible. H. STEP 8 – ESTABLISH CRITICAL LIMITS Determine critical limits for the critical control points that will trigger a corrective action. A critical limit is a criterion which separates acceptability from unacceptability.


B-8

I. STEP 9 – IDENTIFY MONITORING PROCEDURES Establish monitoring points, frequency, and responsibility. J. STEP 10 – ESTABLISH CORRECTIVE ACTION PROCEDURES Develop plans for follow up activity when performance measures for critical control points are exceeded. K. STEP 11 – VALIDATE/VERIFY HACCP PLAN Have the HACCP team and other affected parties check the HACCP plan for accuracy, ability to implement, and potential effectiveness. L. STEP 12 – ESTABLISH DOCUMENTATION AND RECORD KEEPING Develop a record keeping system to track system performance at critical control points.


B-9

AUSTIN’S HACCP PLAN

On May 21, 2003, the Utility held a one-day HACCP workshop. Attendees included staff with a broad array of skill sets from various divisions within the Utility with varying perspectives on Utility and distribution system operation. In particular, attendees included individuals from the Water Lab, Systems Planning, Cross-Connection Control, Process Engineering, Distribution System Operation, Water Quality, Regulatory Compliance, and the State’s Regulatory Agency. Workshop attendees were able to completed Steps 1 through 7 and identified a core group of people to serve as the HACCP Team. The Team met several times during the summer of 2003 to finalize the remaining steps of the plan prior to implementation. The following are the results of the workshop and work of the Team and serves as the HACCP plan that will be implemented: A. STEP 1 – HACCP TEAM The following are members of the Utility’s HACCP team:

Name Position Phone Fax Email HACCP Team Role and Responsibilities

Barrios, Rosie

Water Laboratory Supervisor [email protected]

Laboratory and analysis expert

Bennett, Tony TCEQ Regulatory Manager

[email protected] State regulator

Bohr, Onnie

Infrastructure Superintendent [email protected]

Field operations and maintenance expert

Burazer, Jane

Asst. Director of Treatment [email protected]

Treatment expert

Kuhn, Robert

Cross Connection Control Supervisor

[email protected] Cross connection expert

Lutes, Teresa Engineer/ Planner [email protected]

Systems planning expert

Ojeda, Edward Construction Inspector [email protected]

Construction inspection expert

Pedersen, Dan

Water Quality Manager [email protected]

Team leader


B-10

B. STEP 2 – PRODUCT DESCRIPTION The following description of the Utility’s drinking water (product) was prepared at the May 21, 2003 HACCP Workshop:

Step Description Source Water Austin’s source of supply is the Colorado River. Raw water for the Southwest C pressure zone is

currently diverted at Lake Austin. Treatment Processes Raw water for the Southwest C pressure zone is treated at the Ullrich Water Treatment Plant using

treatment processes consisting of: lime softening, recarbonation/pH adjustment, chloramination, filtration, ferric sulfate, fluoride, and addition of sodium hexametaphosphate

Storage After Treatment Treated water is stored at the Ullrich Plant in two 10 MG clearwells, and in the distribution system in tanks.

Conveyance The Utility owns a contiguous distribution system that serves a population of approximately 770,000 through roughly 183,000 service connections. The distribution system contains 2,995 miles of water mains of a wide variety of materials including cast iron, ductile iron, plastic, asbestos cement, and reinforced concrete cylinder. The distribution system also contains 30 tanks ranging in size from 0.3 to 34 MG. Because of the varied topography in the Utility’s service area, the distribution system is divided into eight major pressure zones. The flow path to the Southwest C pressure zone, which is the subject of the HACCP plan is shown in the attached flow diagram.

Special Controls Federal or State Drinking Water Regulations • Water pressure must be maintained at 35 psi under normal conditions and 20 psi during

emergencies throughout the distribution system. • Maintain a minimum total chlorine residual of 0.5 mg/l throughout the distribution system. • Monthly flushing of dead-end water mains that have a history of customer complaints. • Inspection of new service connections. • An active cross-connection control program. • Water main separation from sanitary sewers. • Finished water storage design and construction requirements. • Annual cleaning and inspection of finished water storage tanks. • Routine distribution system total coliform monitoring.

More stringent City of Austin requirements • Maintain total chlorine residual of 1.0 mg/l throughout the distribution system. • Routine maintenance program for public and private fire hydrants • Monthly chlorine residual and total coliform monitoring at finished water storage tanks.

MG = million gallons, mg/l = milligrams per liter, psi = pounds per square inch


B-11

C. STEP 3 – IDENTIFY INTENDED USE Based on the results of the May 21, 2003 workshop the following table lists the typical uses and customer classes for the Utility’s drinking water:

Intended Uses Intended Consumer • Drinking • Manufacturing, including semi-conductor

manufacturing processes which are sensitive to total organic carbon and trihalomethane levels

• Irrigation • Culinary uses • Fire fighting • Construction uses • Sanitary uses (toilet flushing and showers) • Medical uses (hospitals, dialysis centers,

dental offices) • Product water (Coca Cola and Abbott Labs)

The City of Austin supplies drinking water to the general population including residential, commercial and industrial customers. Intended users do not include those individuals, organizations, manufacturers, or industries requiring water for special processes or purposes. These groups are advised to provide additional treatment, such as a point-of-use device.

D. STEP 4 – CONSTRUCT A FLOW DIAGRAM The process flow diagram is included as Attachment A. The utility’s area of responsibility extends from the source of supply through the distribution system to the points where customer service lines connect to the distribution system. E. STEP 5 – VALIDATE PROCESS FLOW DIAGRAM The process flow diagram was developed on May 21, 2003, reviewed for accuracy by July 28, 2003, and verified on August 15, 2003. F. STEP 6 – CONDUCT HAZARD ANALYSIS At the May 21, 2003 HACCP Workshop, Utility staff conducted a hazard analysis for the distribution system in the Southwest C Pressure Zone. The complete results of this hazard analysis are shown in the following table. While there were a large number of potential hazards identified for the Southwest C Pressure Zone, Utility staff decided to base its HACCP pilot study on two particular hazard events that scored high marks in the hazard analysis – cross-connections and new construction.


Hazard Analysis Table

Process Step

Hazard Event

Hazard

Type

Severity of

Consequences (Score Using 1

to 5 Scale)

Likelihood of Occurrence (Score Using 1 to 5 Scale)

Risk Factor = Likelihood

x Severity

Existing Control Measures

Additional Required Control

Measures

Distribution system, customer taps

Backflow through an unprotected cross connection

M, P, C 5 5 25 • Identify cross-connections and install backflow prevention devices

• Repair failed backflow devices • Require annual inspections of backflow

prevention devices • Perform field surveys especially at commercial

installations with significant potential for cross-connections

• Inspect plumbing of new customers • Check for cross-connections when responding to

customer complaints • Maintain distribution system pressure • Monitor on-site sewage facilities and report

failures

• Provide public education such as safety presentations

• Inspector sign-off on inspection of finished projects

Distribution system

Contamination at new construction sites

C, P, M 5 4 20 Note: No new construction inspectors were present at the May 21, 2003 workshop and a comprehensive discussion of “Existing” and “Additional” control measures was not possible.

• Inspection • Design standards which

include plan review, monitoring of pressure and bacteria upon installation, and good materials storage practices

• Inspector training which includes training on water quality –related issues

• Coordination between Water Quality and Supply and Public Works groups

• Ensure that storm water does not reach trenches

• Make contractor responsible for water quality-related condition of new mains

B-12

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Process Step

Hazard Event

Hazard

Type

Severity of


to 5 Scale)



x Severity



Measures

• Flushing to clean new mains • Review of finished project • Limit valve operations to

approved personnel only • Disinfect new mains • Improve education of

operators with respect to valve operation

• Ensure the correct amount of pressure is available in areas of pressure zones and with potential for transients

Distribution system

Backflow from failing septic tanks into distribution main

M 3 3 9 • Inspect and certify (County) septic systems to demonstrate that they meet county criteria

• Inspect (County) septic fields upon sale of home

• Inspect septic systems annually

• Hook customers up to city sewer system

Distribution system

Contamination due to water main

break or repair

M, P 3 4 12 • Follow SOPs for repair, shut-down, water quality and pressure testing

• Meet state requirements for depressurization • Supervise repair work • Maintain positive pressure during work where

possible • Use standard products for disinfection, etc. • Use different tools on drinking water main repairs

and wastewater repairs Distribution system

Pathogen intrusion to distribution main due to leaky sewage main

M 2 5 10

Distribution system

Intentional contamination of distribution system by vandals

C 3 3 9

B-13

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Process Step

Hazard Event

Hazard

Type

Severity of


to 5 Scale)



x Severity



Measures

Distribution system

Contamination due to main break outside pressure zone

M 4 2 8

Break external to zone

M 4 2 8

Distribution system

Contamination due to pressure transient

M 2 2 4

Distribution system

Presence of bacteria due to low disinfectant residual

M 2 2 4

Distribution system

Presence of bacteria due to zero residual

M 4 1 4

Tanks Example: unmaintained screens, ponding on top, or cleaning

M 1 4 4

Hazard Types: M = microbiological; C = chemical; P = physical SOPs – standard operating procedures

B-14

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

B-15

G. STEP 7 – IDENTIFY CRITICAL CONTROL POINTS As mentioned in the Introduction, the Utility’s role in the research project is to develop and implement a pilot of the model HACCP. To facilitate this role, the Utility selected a portion of its distribution for purpose of the pilot. Workshop participants were asked for suggestions on which portion of the distribution system was most suitable for the pilot with the Southwest C Pressure Zone given as a possibility because of a number of boil water advisories issued there in recent years. Additionally, the Southwest C Pressure Zone has other features that make it appropriate for a HACCP plan. It contains four sites (Blue 2, Blue 11, Blue 19, and Maroon 1) that are routinely monitored under the Total Coliform Rule and provides a history of water quality in the area. Additionally, one of those sites (Blue 19) is a monitoring point for compliance with the Disinfection By-Products Rule, which further enhances understanding of water quality in the area. The Southwest C Pressure Zone is located on the extreme southwestern edge of the distribution system, containing maximum water age for that portion of the distribution system. Water traveling to this area passes through two tanks and three pump stations, which have the potential to affect water quality by increasing water age. It is a growing area with new construction occurring. It is a semi-rural area with older homes on septic systems that, should they fail, might pose a hazard to leaking water mains subject to low or negative pressure transients. At the May 21, 2003 workshop, participants identified twelve hazard events and for purposes of the HACCP selected the two highest-ranking hazards as areas to focus on. The HACCP Team met subsequently and identified specific critical control points within these two hazards. The critical control points are as follows: Cross-connection Hazard Each connection to a potential hazard within the customer’s plumbing system Throughout Southwest C Distribution System New Construction Hazard At each site of new construction H. STEP 8 – ESTABLISH CRITICAL LIMITS Critical limits for the cross-connection hazard and the new construction hazard are listed in the two tables below. I. STEP 9 – IDENTIFY MONITORING PROCEDURES Monitoring of the critical limits for the cross-connection hazard and new construction hazard are listed in the two tables below. J. STEP 10 – ESTABLISH CORRECTIVE ACTION PROCEDURES Corrective actions, in the event that a critical limit is exceeded, for the cross-connection hazard and new construction hazard are listed in the two tables below.


B-16

Table for the Cross Connection Hazard

Critical Control

Point (Step 7)

Control Measure (Step 6)

Critical Limits

(Step 8)

Validation

(Step 8)

Monitoring

(Step 9)

Corrective Action

(Step 10)

Method: Plumbing inspections and water protection surveys

Existing Corrective Actions: Enforce requirements using penalties, etc.

Monitoring Frequency: Annual testing of backflow prevention on high hazard situations.

Additional Corrective Actions Required: Enforcement actions on non -compliant customers.

List Responsible Person: Plumbing Inspections – Robert Brown, chief plumbing Inspector Water Protection Surveys – Robert Kuhn, water Protection Supervisor

Immediate Action Plan: Permit and Inspect new and remodeled plumbing installations.

Monitoring Location(s): At residential, commercial, industrial, and institutional customers.

List Responsible Person: Robert Kuhn

Identify cross-connections and install backflow prevention assemblies & devices

Critical Limit #1: Presence of working backflow prevention device

Texas Commission on Environmental Quality’s regulations for public drinking water and City ordinances

Tracking: WPTS Database

Method: Plumbing inspections and water protection surveys


Monitoring Frequency: Annual testing of backflow prevention on high hazard situations.

Additional Corrective Actions Required: Enforcement actions on non -compliant customers.

List Responsible Person: Robert Kuhn, water Protection Supervisor

• Immediate Action Plan: Permit and Send Customer Notice

• Send reminder notice

• Run delinquent report



Repair failed backflow assemblies




Method: On line & manual data entry


Each connection to a potential hazard within the customer’s plumbing system

Require annual inspections of backflow assemblies

Critical Limit #1: Backflow assemblies pass operational test


Monitoring Frequency: Monthly

Additional Corrective Actions Required: enforcement actions on non -compliant customers


B-17

Critical Control

Point (Step 7)


Critical Limits

(Step 8)

Validation

(Step 8)

Monitoring

(Step 9)

Corrective Action

(Step 10)

Responsibility: Robert Kuhn

Immediate Action Plan: • Send Customer

Notice • Send reminder

notice • Run delinquent

report • Terminate

service or file criminal charges as necessary.




Method: Visual inspection by City plumbing inspectors

Existing Corrective Actions: Enforcement per the Plumbing Code and Cross-connection Ordinance

Monitoring Frequency: Each occurrence of new plumbing construction

Additional Corrective Actions Enforcement actions on non -compliant customers.

List Responsible Person: Plumbing Inspections – Robert Brown, chief plumbing Inspector Water Protection Surveys – Robert Kuhn, water Protection Supervisor

Immediate Action Plan: Schedule at least two water protection surveys in the sample area



Inspect plumbing of new customers

Critical Limit #1: Compliance with Plumbing Code

City ordinances


Method: Visual inspection

Existing Corrective Actions: Enforce requirements using timeframe for correction and penalties, etc.

Distribution system

Check for cross-connections when responding to customer complaints

Critical Limit #1: No potable water services with a cross-connection


Monitoring Frequency: Each customer complaint upon customer demand

Additional Corrective Actions Required: enforcement actions on non -compliant customers


B-18

Critical Control

Point (Step 7)


Critical Limits

(Step 8)

Validation

(Step 8)

Monitoring

(Step 9)

Corrective Action

(Step 10)

Responsibility: Robert Kuhn and his staff

Immediate Action Plan: • Send Customer

Notice • Send reminder

notice • Run delinquent

report • Terminate

service or file criminal charges as necessary.

Monitoring Location(s): Customer properties.

List Responsible Person: Robert Kuhn and his staff


Method: Pressure transducer and data logger. Pump station discharge points on the SCADA System w/ tracking through SCADA.

Existing Corrective Actions: Turn on additional pumps to raise pressure. Search for main breaks Issue boil water advisory, if necessary.

Monitoring Frequency: Continuous with data recorder.

Additional Corrective Actions Required:

Responsibility: Dan Pedersen

Immediate Action Plan:

Monitoring Location(s): SCADA monitoring locations.

List Responsible Person: Turning on pumps – pumping division Search for main breaks -- field crews Boil water advisory – Dan Pedersen.

Maintain distribution system pressure

Critical Limit #1: Pressure should be above 35 psi under normal conditions. Pressure may be as low as 20 psi during emergency conditions

Texas Commission on Environmental Quality’s regulations for public drinking water

Tracking: Utility’s SCADA system.

Method: Visual, olfactory inspection.

Existing Corrective Actions: On-site inspection and enforcement plan

Monitoring Frequency: As part of customer complaints, plumbing inspections, and surveys.

Additional Corrective Actions Required: Municipal court fines for not correcting failing septic system

Responsibility: Robert Kuhn Seyed Miri

Immediate Action Plan: Follow Utility process for correcting failing septic systems.

Monitoring Location(s): Throughout the Southwest C Distribution System as other inspections are made.

List Responsible Person: Seyed Miri and OSSF staff

Monitor on-site septic facilities for failure

Critical Limit #1: No above ground discharges from failing septic systems

City ordinances

Tracking: SRs and monthly report to the TCEQ.


B-19

Table for the New Construction Hazard

Critical Control

Point (Step 7)


Critical Limits

(Step 8)

Validation

(Step 8)

Monitoring

(Step 9)

Corrective Action

(Step 10)

Method: Via telephone or radio call.

Existing Corrective Actions: Close valves to isolate affected area. Speed memo/warning to contractor or verbal warning to inspector. Special billing/fines.

Monitoring Frequency: Each occurrence.


Responsibility: W&WW Dispatch. Infrastructure Support.

Immediate Action Plan: Close valve(s).

Monitoring Location(s): At the Dispatch Office

List Responsible Person: Inspector or valve crew.

Valve operation

Critical Limit #1: No unauthorized valve opening or closing

Standard specifications, Section 510.

Tracking: Through SRs, work orders, or log books.

Method: Visual or olfactory.

Existing Corrective Actions: Isolate main, disinfect, and flush.



Responsibility: On site inspector.

Immediate Action Plan: • Isolate main • Flush • Sample • Issue Boil Water

Advisory Monitoring Location(s): Job site.

List Responsible Person: Valve Crews, Dan Pedersen

Critical Limit #1: All water mains to be disinfected prior to being placed in service

AWWA Standards and City standard specifications

Tracking: Water lab approval letters.

Method: Grab samples

Existing Corrective Actions: Flush main and resample. If necessary redisinfect.

Monitoring Frequency: Each new main.


Responsibility: On site inspector.


Monitoring Location(s): Job site.

List Responsible Person:

Disinfection of water lines

Critical Limit #2: All water mains to have typical COA water (bacti and free chlorine negative) prior to being placed into service

State regulations, AWWA standards, and City SOPs

Tracking: Water lab approval letters.

At each site of new construction

Intact Pressure Zone Boundaries

Critical Limit #1: No valves opened between pressure zone boundaries

Standard Operating Procedures

Method: SCADA tank or pressure point alarm levels.

Existing Corrective Actions: Close valves to isolate affected area. Speed memo/warning to contractor or verbal warning to inspector. Special billing/fines.


B-20

Critical Control

Point (Step 7)


Critical Limits

(Step 8)

Validation

(Step 8)

Monitoring

(Step 9)

Corrective Action

(Step 10)



Responsibility: Water and Pumping Division

Immediate Action Plan: Close valve(s).

Monitoring Location(s): South First Street Office.

List Responsible Person: Inspector or valve crew.

Tracking: Through the SCADA system.

Method: Visual – markings on the ground.

Existing Corrective Actions: Job site shut down. Speed memo/warning to contractor. Special billing/fines.

Monitoring Frequency: Each occurrence and periodically throughout the project.


Responsibility: Project Inspector.


Monitoring Location(s): Job site.


No contractors to accidentally hit water mains while performing their work

Critical Limit #1: Contractors to contact One-Call prior to conducting work.

One-Call Law requirements in place except for emergencies. Contractor’s responsibility to locate underground utilities and renew One-Call ticket every 30 days. A general construction notes requirement

Tracking: An access database.

Method: Attendance sign in sheets.

Existing Corrective Actions: None, course attendance is voluntary.

Monitoring Frequency: Annually at each bacti sampling training session.


Responsibility: Water Quality Manager – Dan Pedersen.


Monitoring Location(s): Bacti sampling training session classroom.


Inspector Training

Critical Limit #1: Inspectors to have essential knowledge to perform their work.

Standard operating procedures

Tracking: Attendance sign in sheets.

K. STEP 11 – VALIDATE/VERIFY HACCP PLAN The HACCP plan was validated at meetings on August 15 and 28, 2003 by members of the HACCP Team. Additional validation was done with inspection staff and staff of the On-Site Sewage Facilities Division. L. STEP 12 – ESTABLISH DOCUMENTATION AND RECORD KEEPING Tracking of monitoring of the critical limits is shown in the cross-connection hazard and new construction hazard tables.


B-21

VERIFICATION The HACCP plan was validated at meetings on August 15 and 28, 2003 by members of the HACCP Team. Additional validation was done with inspection staff and staff of the On-Site Sewage Facilities Division. Signature on file Dan W Pedersen, PE Water Quality Manager

Attachment A – Process Flow Diagram


B-22

Attachment B – List of Streets in the Southwest C Pressure Zone

Street Block Street Block

Acton Drive Medicine Creek Drive Anchusa Trail Midwood Parkway

Arroyo Canyon Mowinkle Cove Black Mountain Cove Mowinkle Drive Black Mountain Drive Murmuring Creek Drive

Blue Hill Drive Nandas Trail Boling Drive Oak Valley Road

Bright Star Lane Old Bee Caves Road 8700 Candelaria Drive Phoenix Pass

Chiplea Cove Pitter Pat Lane Cima Circle Putnam Drive Circle Drive Rawhide Trail 10100-10700

Claxton Drive Rehobeth Circle Clear Night Drive Rehobeth Cove

Cobble Stone Rising Smoke Loop Conifer Cove Roaring Springs Cove Copper Path Roaring Springs Drive

Covered Bridge Cove Roaring Springs Road Covered Bridge Drive Rockwood Circle Crackling Creek Drive Rosson Drive

Crest View Road Sam Carter Drive Dawning Court Samuel Bishop Drive

Deer Haven Road San Diego Road Distant View Drive San Juan Pass

Dorella Lane Scenic Brook Drive 7900-8100 El Dorado Drive South Bend Avenue

El Rey Boulevard 8400-9300 Southview Road Espanola Trail State Hwy 71 West 8700-11000

Feather Hill Road Streamside Drive Felts Lane Summer Sky Drive

Fenton Drive 8600-8800 Sunset Ridge Foggy Mountain Drive Superview Drive

Fort Benton Drive Thomas Springs Road Granada Hills Drive 8400-9000 Thomas Wood Lane

Haskel Drive Thunderbird Cove Hudson Loop Thunderbird Road

Indian Scout Trail Towana Circle Jay Creek Cove Towana Trail

Kathleen Drive Trenton Drive Kingston Drive US Hwy 290 7700-8600 La Fauna Path Weir Hills Road 5800 La Fauna View West Creekview Drive La Tosca Drive West View Road Lauralan Drive Williamson Creek Drive

Lenape Cove Lenape Trail


B-23

Attachment C – Southwest C Pressure Zone Map


B-24

SOUTH BERWICK HACCP PLAN


B-25

HAZARD ANALYSIS AND CRITICAL

CONTROL POINT PLAN

October 2003

Prepared By:

South Berwick Water District 80 Berwick Road

South Berwick, ME 03908 Staff Contact: Mike Nadeau

207-384-2257


B-26

INTRODUCTION Hazard Analysis and Critical Control Point (HACCP) is a risk management system developed in the 1960’s to help minimize or prevent hazardous microbial incidents. The process was originally designed by the Pillsbury Company, together with the National Aeronautics and Space Administration (NASA) and the U.S. Army Laboratories, to ensure the safety of astronauts’ food. Since then, the HACCP system has become internationally recognized as a method of food safety, and has been expanded to include chemical and physical hazards in foods. In 1996, the World Health Organization (WHO) set HACCP guidelines, which have since been adopted internationally as the primary food safety methodology for risk management. The increasing worldwide trend to classify water as a food has resulted in a logical next step: applying HACCP principles to manage the quality of drinking water supplies and reduce or eliminate related risks. With HACCP, water quality issues and risk management requirements are assessed at each critical control points in the water treatment and delivery process, creating a multiple barrier system that helps control, minimize, or prevent hazards at numerous key steps throughout the system. A current American Water Works Association Research Foundation (AwwaRF) project, “Applications of Hazard Analysis at Critical Control Points for Distribution System Protection” is being conducted in partnership with the USEPA. This HACCP Plan for South Berwick Water District was developed as part of this AwwaRF-funded project.


B-27

HACCP PRINCIPLES and APPLICATION

There are 12 steps to the application of HACCP systems, or more accurately, 5 preliminary steps followed by the implementation of 7 principles. These 12 tasks, detailed below, follow a logical and structured sequence, resulting in a customized HACCP Plan. Step 1: Assemble a Team To develop the HACCP system a team should be assembled, ideally comprising a broad range of expertise and skill in all areas of process. It is essential to include individuals with appropriate knowledge of the potential hazards and the control measures used to manage them. The team is responsible for the planning, development, verification, and implementation of the HACCP system. Members of the team should therefore come from the planning, operational, and design/development areas of the organization. When appropriate, wholesalers, contractors, and other parties should be involved in developing and implementing the HACCP process. STEP 2: Describe the Product Generally, the desired end product can be described as “potable water intended for consumption by the majority of the population”. A more specific description may be preferred in some situations. Specify all materials to be used in operations. Information included in the description should include relevant safety information. STEP 3: Identify Intended Use The description of the product from step 2 assists in identifying the intended consumers. In addition to complying with federal, state, and local regulations, and depending on a utility’s water quality goals and specific situation, consideration may also be given to consumers with special needs, such as industries with specific requirements. STEP 4: Construct a Flow Diagram The HACCP team develops a flow diagram describing all processes and operations throughout the water distribution system. The flow diagram should illustrate what happens to the water from the time it enters the distribution system until it reaches the customers’ tap. The flow diagram should also contain adequate detail to identify potential entry points for hazards and any detected contamination to be traced.


B-28

STEP 5: Validate Process Flow Diagram Validation of the flow diagram is a means of confirming that all operations in the water distribution system are being considered and evaluated. This will ensure that the flow diagram is accurate and is a true representation of the system. STEP 6 (Principle 1): Identify Hazards and Preventative Measures A hazard analysis is conducted to identify all potential hazards and points of entry into the water distribution system. There are four types of hazards categories: physical, chemical, microbiological, and radiological. Once a hazard has been identified, the risk of possible contamination events needs to be determined. A qualitative and/or quantitative evaluation of the potential hazard should be conducted. This is usually achieved by determining a risk factor rating or risk score. The calculation of the risk rating or score can be as complex or as simple as is appropriate. For each hazard, the current control measures used to prevent or minimize possible contamination are identified. The HACCP team may identify additional suggested control measures that are needed. STEP 7 (Principle 2): Identify Critical Control Points A critical control point (CCP) is a step in the drinking water supply process where control measures are essential to maintain the safety of the water. All significant hazards in the process should be controlled at a CCP, depending on whether or not they pose a significant water quality and/or safety risk. Some water quality impacts that are not health based, but that can cause aesthetic impacts such as taste and odor or color, can be controlled at a quality control point (QCP). Both CCPs and QCPs are steps in the process at which the potential exists for a negative impact on the water.


B-29

STEP 8 (Principle 3): Establish Critical Limits For each CCP/QCP identified in the process, a measurable parameter and limits for each parameter must be established. Current regulations and knowledge and expertise, including industry standards and research as well as historical data, should be used as a guide when determining limits. To provide appropriate control of the water distribution system, a two-tiered structure may be implemented. The first level of critical limits distinguishes when the measurable control parameters are approaching an unacceptable level. The second level identifies when the absolute cut off value that ensures the quality and safety of the water has been reached. At that point the water becomes unacceptable and is considered off specifications (e.g., exceeds maximum contaminant levels, MCLs,) and corrective actions are needed. STEP 9 (Principle 4): Identify Monitoring Procedures Monitoring is an essential part of the HACCP system and provides an early warning of critical limits that potentially could be exceeded. A monitoring activity is associated with each critical limit identified. It is critical that monitoring procedures are established and conducted properly. The designated parameter(s) for each CCP or QCP are measured prior to water continuing through the distribution system to ensure that poor quality water does not reach consumers. This means that many parameters will need to be monitored online so that “real time” results are obtained, since few “hold points” exist within a water distribution system. The monitoring techniques are documented in the HACCP plan. Detailed information for each critical limit should include 1) where the monitoring is to be carried out, 2) the monitoring procedure, 3) the frequency of the monitoring, 4) the person responsible, and 5) whether the monitoring is done on a continuous basis or at scheduled times. STEP 10 (Principle 5): Establish Corrective Action Procedures For every monitoring procedure, a corrective action should be developed. Corrective actions are used when a deviation from target criteria and critical limits has occurred. This ensues that the critical control point is brought under control or that unacceptable water has been disposed of in a appropriate manner. Examples of corrective actions include flushing or air scouring, booster dosing, operating valves to remove a pipe from operation or redirect flow, and taking a piece of equipment (tank or disinfection unit) offline. The corrective actions are tested to ensure their effectiveness in preventing unfit or unsafe water from reaching consumers should a hazardous event occur. All corrective actions should be recorded in the HACCP system as proof of compliance and due diligence. STEP 11 (Principle 6): Validate/Verify HACCP Plan


B-30

Verification is a process that confirms that the HACCP system has been accurately implemented and is working as intended, in other words, that all hazards have been identified and that CCPs, critcal limits, monitoring, and corrective actions are appropriate and effective. Validation is the process of obtaining objective evidence that the water is in fact safe and fit to drink and that good operational practices, monitoring, and corrective actions are being completed with at all levels. STEP 12 (Principle 7): Establish Documentation and Record Keeping Efficient and accurate documentation and record keeping is imperative to the application of a HACCP system. These records provide retrospective proof of compliance to the HACCP plan, enable product traceability, and facilitate continuous improvement based on trend analysis. In addition, record keeping ensures that legal requirements are met and provides a legal defense for all reasonable precaution and due diligence.


B-31

SOUTH BERWICK WATER DISTRICT HACCP PLAN

On June 25, 2003, the Utility held a one-day HACCP workshop. Attendees included all District staff, a USEPA representative, a state regulator, a consulting engineer familiar with the SBWD system, and a utility trustee. Workshop attendees were able to complete Steps 1 through 7. A second meeting was held September 8, 2003 to finalize the remaining steps of the plan prior to implementation. The following are the results of the workshop and follow up meeting, and serves as the HACCP plan that will be implemented: STEP 1 – HACCP TEAM The members of the Utility’s HACCP team are listed in Table 1.

Table 1 HACCP Team Contact Information

Name Title Email Telephone/ Pager HACCP Team Role and Responsibilities Mike Nadeau Superintendent [email protected] Point Person; Implementation of

HACCP Plan; Providing utility data to AwwaRF team

John Leach Foreman [email protected] Implementation of HACCP Plan and Monitoring

Jerry Leavitt Service Person Implementation of HACCP Plan and Monitoring

Rick deRochemont Office Manager

Implementation of HACCP Plan and Monitoring

Additional outside experts participated in the HACCP workshop in South Berwick, Maine on June 25, 2003. Their contact information is summarized in Table 2. These people may be consulted as needed as the HACCP Plan is developed and implemented.

Table 2 Outside Experts

Name Company Title Phone

Number Email Expertise

Terry Trott State of Maine Drinking Water Program

Operator Licensing Officer

[email protected] State regulations, cross connection control programs

J. Kevin Reilly

US EPA Region 1 Microbiologist [email protected] Microbiological hazards

Kathy Martel

EES, Inc. Project Manager [email protected] HACCP, distribution system best management practices

Mark Arenberg

South Berwick Water

Trustee [email protected] Engineering

Jeff Musich Wright-Pierce Vice President [email protected] Engineering


B-32

STEP 2 – PRODUCT DESCRIPTION Table 3 summarizes the product description for the Utility’s drinking water that was prepared at the June 25, 2003 HACCP Workshop.

Table 3 Product and/or Process Description

Step Description Source of Supply Groundwater Treatment Wellhead protection program, all groundwater supplies

Free chlorine disinfection (Junction Road, Blackmore and Willow Drive Wells only) At the time of the HACCP workshop (June 2003), the groundwater supplies at the Agamenticus well field were not disinfected. The District initiated disinfection in August 2003 at this well field. Future treatment of Willow Drive Well (Filtration with oxide-coated media to remove iron, Mn, As).

Storage after treatment The treated water is stored in a 1 MG partially buried concrete tank.

Conveyance

31.5 miles of main, ranging in diameter from 1½ inch up to 12 inches. The larger diameter water mains are primarily cement-lined ductile iron and asbestos cement. Most pipe (60%) is 8-inch diameter.

Any special controls required?

Drinking Water Regulations State regulations mirror federal regulations, no additional requirements SBWD internal goals Incorporate a continuous improvement and multiple barrier approach with regards to water quality. Develop an enhanced customer awareness (partnership) program.


B-33

STEP 3 – IDENTIFY INTENDED USE Based on the results of the June 25, 2003 workshop, the Table 4 lists the typical uses and customer classes for the Utility’s drinking water:

Table 4 Intended Uses and Consumers

Intended Uses Intended Consumer Sanitary Needs Fire Protection Consumption Commercial Industrial Irrigation Construction uses

South Berwick Water District supplies drinking water to the general healthy population. Drinking water is safe to drink for people in most stages of normal life. Intended consumers do not include those individuals that are significantly immunocompromised, or infants aged six months or less. Intended users do not include those individuals, organizations, manufacturers, or industries requiring water for special processes or purposes. These groups are advised to provide additional treatment, such as a point-of-use device. Notes: One elderly care facility in town; no special notification has been given regarding use of drinking water. Future emergency care facility planned within service area.

STEP 4 – CONSTRUCT A FLOW DIAGRAM The process flow diagram included as Attachment A was developed on June 25, 2003. STEP 5 – VALIDATE PROCESS FLOW DIAGRAM The process flow diagram was reviewed for accuracy and finalized on September 8, 2003. STEP 6 – CONDUCT HAZARD ANALYSIS At the June 25, 2003 HACCP Workshop, utility staff conducted a hazard analysis for the SBWD distribution system. The complete results of this hazard analysis are shown in Table 5. While there were a large number of potential hazards identified, utility staff decided to base its HACCP pilot study on three particular hazard events of concern – cross-connections, unchlorinated wells, and dead ends.


Table 5 Hazard Analysis

Process Step Hazard Event Hazard Type

Severity of Consequences(Score Using 1 to 5 Scale)


Risk Factor = Likelihood x

Severity Existing Control MeasuresAdditional Required Control

Measures Distribution System, customer taps

Backflow through an unprotected cross-connection

M, P, C 4 5 20 • Utility installs double check valves on every residential service

• Commercial customers install backflow prevention device as required.

• Utility maintains good records of who has backflow prevention devices.

• System static pressure >40 psi system-wide under normal operating conditions.

• Utility needs to enforce the required installation of proper backflow devices on all service connections

• Utility needs to enforce testing and maintenance of commercial backflow prevention devices.

• Public education is needed regarding risk of cross connections, and the need for backflow prevention.

• The feasibility of testing backflow prevention devices at multi-family units should be further evaluated.

Source of Supply, Agamenticus wellfield

Unintentional contamination of shallow well

points

M 5 Unknown, need to conduct

source water monitoring

10 +/- depending on monitoring

results

• Well point screens cleaned every 3 to 5 years.

• Formal wellhead protection review process in place

• Review State Source Water Assessment Program information

• Source water monitoring for biological, chemical and physical hazards needed to better evaluate microbiological risk.

• Disinfect well • Public education for

residential customers within Zone 1.

Distribution System, Dead -end mains

Long dead end mains with zero

or poor disinfectant

residual

M Unknown Unknown Need more data • Flushing conducted semi-annually at a minimum, and more often in response to complaints

• Monitoring • Booster chlorination if

needed • Bleeders?

B-34

©2006 A

ww

aRF

. All R

igh

ts Reserved

.






Measures Distribution system storage facility

Intentional contamination

via storage facility vents

C 5 2 10 • Storage tank site fenced and well-maintained

• Gravel road to site is gated; vehicular access to reservoir site is prohibited

• Site inspection 3x weekly

• Insect screening on vents kept in good repair

• On-site security camera (utility applied for state grant)

• SCADA intrusion alarm

Distribution system, customer service lines

Contamination due to service

line break

C, P, M 5 2 10 • Disinfection and flushing of all service breaks before placing back into service

• Perform bacteria test; verify passed results before placing back into service

Distribution system

Contamination due to main

break

C, P, M 5 2 10 • Disinfection and flushing of all main breaks before placing back into service

• Perform bacteria test; verify passed results before placing back into service

Distribution system, customer service lines

Installation of Service Lines

for Fire Protection

P, M 5 1 5 • Parts supplied by utility 75% of time

• High velocity flush of service line before setting meter

• Measures may be needed to prevent excessive water age in existing fire service lines.

• Should parts be supplied by utility 100% of time?

Source of supply

Vandalism/ Chemical

Contamination of Agamenticus

wellfield

C 5 1 5

B-35

©2006 A

ww

aRF

. All R

igh

ts Reserved

.






Measures Contamination

via Pressure Transient in area

of former Superfund

site/low pressure area

C 5 1 5 • Superfund site cleaned up

On-going monitoring at Superfund site

Distribution system

New Construction

M, C, P 5 1 5 • Flush, pressure test, disinfect, flush and verify passed bacteria results before placing into service

• Use quality assured suppliers where feasible

• Use quality assured contractors to perform work

Distribution system

Installation of Residential

Services

M, C 5 1 5 • Parts supplied by utility 75% of time

• High velocity flush of service line before setting meter

• Use quality assured suppliers where feasible

• Use quality assured contractors to perform work

• Disinfect service line before placing into service

Source of supply

Unintentional contamination

of Willow Drive well from closed landfill or golf

course

C 4 1 4

Distribution system

Excessive water age in

distribution system piping

M, P, C 2 2 4

Distribution system

Excessive water age in storage

facility

M, P, C 2 1 2 Track tank cycles and figure turnover rates.

M = microbiological; C = chemical; P = physical

B-36

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

STEP 7 – IDENTIFY CRITICAL CONTROL POINTS The HACCP Team identified specific critical control points for the three hazards selected for further development as part of the AwwaRF project. The critical control points are listed in Tables 6-8. STEP 8 – ESTABLISH CRITICAL LIMITS Critical limits for each control measure are listed in Tables 6-8. STEP 9 – IDENTIFY MONITORING PROCEDURES Monitoring procedures for each critical limit are listed in Tables 6-8. STEP 10 – ESTABLISH CORRECTIVE ACTION PROCEDURES Corrective actions, in the event that a critical limit is exceeded, are listed in Tables 6-8. STEP 11 – VALIDATE/VERIFY HACCP PLAN The HACCP plan validation will be accomplished by outside experts that attended the HACCP workshop. In addition, a quality assurance manager for nearby Poland Springs bottling company will provide review comments to support the validation process. STEP 12 – ESTABLISH DOCUMENTATION AND RECORD KEEPING Recordkeeping and tracking procedures are shown in Tables 6-8.

B-37


Table 6 Steps 7 to 10 for Cross-Connection Hazard

Critical Control Point (From Step 7):

Control Measure

(From Step 6)

Critical Limits (From Step 8)

Validation

(From Step 8)

Monitoring

(From Step 9)

Corrective Action (From Step 10)

Method (i.e. Online, Grab): Inspection and testing

Existing Corrective Actions: Customer repairs or installs backflow prevention device as necessary.

Monitoring Frequency Annual; semi-annual dependent upon the degree of hazard; inspect new and remodeled installations


Enforcement actions on non -compliant customers

Responsible Persons: John Leach,, Foreman Jerry Leavitt, Service Person


• Send Customer Notice • Send reminder notice • Run delinquent report • Terminate service or file

criminal charges as necessary.


Maine Dept. of Human Services Cross-Connection regulations, Title 22, MRSA, c601, sub-chapter 2, Sec. 2612(5), 10-144A CMR226 South Berwick Water District Cross Connection Control Program

Monitoring Location(s): Each commercial service connection

Tracking System: Town Code Enforcement Officer and Plumbing Inspector

Method (i.e. Online, Grab): Inspection

Existing Corrective Actions: Enforcement actions on non-compliant customers

Each commercial service connection

Commercial customers install, test and repair backflow prevention device as required.

Critical Limit #2: Device meets Plumbing Code specifications and is applicable to the degree of hazard as determined by the South Berwick Water

Maine State Plumbing code Part 1, 10-144A CMR 238 South Berwick Water District Cross Connection Control Program

Monitoring Frequency Annually at minimum; as needed; inspect new and remodeled installations


Improve follow through on enforcement actions on non -compliant customers

B-38

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Control Measure

(From Step 6)


Validation

(From Step 8)

Monitoring

(From Step 9)


Responsible Persons: John Leach, Foreman, Jerry Leavitt, Service Person, Rick deRochemont ,Office Manager, Mike Nadeau, Supt.

Immediate Action Plan: • Send Customer Notice • Send reminder notice • Run delinquent report • Terminate service or file charges as

necessary.

District

Monitoring Location(s): Each commercial service connection

Tracking System: Town Code Enforcement Officer and Plumbing Inspector

Method (i.e. Online, Grab): On-site inspection

Existing Corrective Actions: Repair or install backflow prevention device if necessary.

Monitoring Frequency: Upon start of service; in response to customer complaints or service calls.

Additional Corrective Actions Required: Enforcement actions on non-compliant customers

Responsibility: John Leach, Foreman, Jerry Leavitt, Service Person

Immediate Action Plan: • Send Customer Notice • Send reminder notice • Run delinquent report • Terminate service or file

charges as necessary


Maine Dept. of Human Services Cross-Connection regulations, Title 22, MRSA, c601, sub-chapter 2, Sec. 2612(5), 10-144A CMR226 South Berwick Water District Cross Connection Control Program

Monitoring Location(s): Each residential service connection

Tracking System: Town Code Enforcement Officer, Plumbing Inspector, Water District records

Method (i.e. Online, Grab):Inspection

Existing Corrective Actions: Enforcement actions on non-compliant customers

Each residential service connection

Utility/Customer installs double check valves on every residential service.

Critical Limit #2: Device meets Plumbing Code specifications and applicable degree of Hazard as determined by the South Berwick Water District

Maine State Plumbing code Part 1, 10-144A CMR 238 South Berwick Water District Cross Connection Control Program

Monitoring Frequency: Start of new service; inspect new and remodeled installations; at meter repair or change-out; service calls


Enforcement actions on non-compliant

customers

B-39

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Control Measure

(From Step 6)


Validation

(From Step 8)

Monitoring

(From Step 9)


Responsibility: John Leach, Forman, Jerry Leavitt, Service Person

Immediate Action Plan: • Send Customer Notice • Send reminder notice • Run delinquent report • Terminate service or file

charges as necessary Monitoring Location(s): Each residential service connection

Tracking System: Inspection reports, work orders/invoices, scheduled/ non-scheduled maintenance

Method (i.e. Online, Grab): multi media communication

Existing Corrective Actions: None

Monitoring Frequency: Annually @ minimum


• Remind plumbing inspector’s office and water district staff to distribute flyer with every customer

Responsibility: John Leach, Foreman, Rick deRochemont, Office Manager

Immediate Action Plan: Distribute flyers

Critical Limit #1: Bill Stuffers or other informational flyers distributed

AWWA Manual M14 Recommended Practice for Backflow Prevention and Cross-Connection Control

Monitoring Location(s): All customers

Tracking System: Inventory:# flyers distributed/year

Method (i.e. Online, Grab): annual mailing, posting on WEB and other locations

Existing Corrective Actions: Make it a priority to produce and distribute consumer confidence report

Monitoring Frequency: Annually


None

Throughout system

Public education is needed regarding risk of cross connections, and the need for backflow prevention.

Critical Limit #2: Consumer Confidence Reports produced and distributed to customers

1996 SDWA Amendments EPA Consumer Confidence Report Rule

Responsibility: Mike Nadeau, Supt., Rick deRochemont, Office Manager

Immediate Action Plan: Produce and distribute report

B-40

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Control Measure

(From Step 6)


Validation

(From Step 8)

Monitoring

(From Step 9)


Monitoring Location(s): All customers, WEB/other locations

Tracking system: hard copies of annual reports

Method (i.e. Online, Grab): SCADA monitoring; customer complaints

Existing Corrective Actions:

Identify/repair deficiency

(i.e., main break, etc.)

Monitoring Frequency: Online, real-time


Responsibility: John Leach, Foreman, Jerry Leavitt, Service Person, Rik deRochemont, Office Manager, Mike Nadeau, Supt

Immediate Action Plan: Identify/repair deficiency

Maintain adequate system pressure.

Critical Limit #1: Pressure should be above 35 psi under normal conditions. Pressure may be as low as 20 psi during emergency conditions

AWWA. 1996. Water Transmission and Distribution. 2nd Edition. Denver, Colo.: AWWA 10 State Standards ME Rules Relating to Drinking Water 10-144 Chapter 231

Monitoring Location(s): Reservoir, pump stations, other locations(Water District office, Town Hall, Sewer District, Fire Station, other gov’t buildings

Tracking System: SCADA system, daily report, customer log book, repair log

B-41

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Table 7 Steps 7 to 10 for Unchlorinated Wells Hazard


Control Measure

(From Step 6)


Validation

(From Step 8)

Monitoring

(From Step 9)

Corrective Action

(From Step 10)

Method (i.e. Online, Grab): pH ( grab) and chlorine residual (grab)

Existing Corrective Actions: Check and fix chemical feeder

Monitoring Frequency Daily

Additional Corrective Actions Required: Use backup chemical feeder.

Replace or fix problem chemical feeder



• Check chemical feeder

Disinfection Critical Limit #1: Chlorine residual

Monitoring Location(s): Agamenticus pump station

Tracking System: Daily logs


Existing Corrective Actions: Clean screens

Monitoring Frequency 3-5 years


Construct new wellpoint if screen cannot be cleaned.



• Clean screens

Clean well screens

Critical Limit #1: Screens cleaned every 3 to 5 years

SBWD Comprehensive Plan

Monitoring Location(s): Each well

Tracking System: Contractor report

Agamenticus Pump Station

Maintain formal wellhead protection program. Specific

Critical Limit #1: Wellhead protection activities implemented

SBWD Wellhead Protection Plan

Method: Review plan and activity reports

Existing Corrective Actions: Meet with trustees, town officials as needed to implement wellhead protection activities.

B-42

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Control Measure

(From Step 6)


Validation

(From Step 8)

Monitoring

(From Step 9)

Corrective Action

(From Step 10)

Monitoring Frequency Annual


Responsible Persons: Mike Nadeau, Supt.


•

activities include review of state Source Water Assessment information, educational activities for residential customers in Zone 1.

per Plan

Monitoring Location(s): Agamenticus wellhead protection area

Tracking System: Superintendent reports to trustees

B-43

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Table 8 Steps 7 to 10 for Dead End Mains Hazard


Control Measure

(From Step 6)


Validation

(From Step 8)

Monitoring

(From Step 9)

Corrective Action

(From Step 10)


Existing Corrective Actions: Additional flushing in response to customer complaints

Monitoring Frequency Semi-annual, minimum


Install bleeders if necessary


Immediate Action Plan: • Collect water sample at

customer’s tap. • Flush water main in local area

Flushing Critical Limit #1: Flushing conducted semi-annually at a minimum, or as needed

AwwaRF Guidance Manual for Maintaining Distribution System Water Quality (2000)

Monitoring Location(s): Dead end mains

Tracking System: Daily logs

Method (i.e. Online, Grab): Grab samples

Existing Corrective Actions: Flush main

Monitoring Frequency Monthly for 12 month period


1. Install bleeders 2. Booster disinfection



• Flush main

Dead End Mains (Hooper Sands Road, Vine Street, Hill Drive)

Monitor water quality to complete hazard assessment

Critical Limit #1: Chlorine residual < 0.2 mg/L

AwwaRF Guidance Manual for Monitoring Distribution System Water Quality (2002)

Monitoring Location(s): Each dead end main

Tracking System: Laboratory reports

B-44

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Attachment A

South Berwick Water District

Process Flow Diagram

October 2003

B-45


B-46

KATHERINE SYSTEM HACCP PLAN


B-47

Power and Water Corporation

Katherine Potable Water Supply System

HACCP Plan

2004/2005 Identifier: TBA Version: FD3 Status: Final Draft Effective Date: 1/07/04

NT Government Restricted Class:

Total pages: 184


B-48

DOCUMENT IDENTIFICATION SHEET DESCRIPTION

Title

Katherine Potable Water Supply System HACCP Plan 2004/2005

Identifier: TBA Effective Date: 1/07/04

Abstract An operational plan describing how the principles of HACCP are to be applied to the Katherine water supply system to ensure control over hazards which are significant for water quality, including safety.

Keywords Water quality Water safety Risk management HACCP

Author and Approval Author: Noel McCarthy Position: Project Manager HACCP Location: Water Facilities Approval by: Darryl Day Position: General Manager Water Services Location: Water Services

Version, Status and Type Status Version Category Classification

Working Draft Policy Highly Protected Draft for Comment Manual (IMS) Protected Final Draft a FD2 Standard In-Confidence Proposed for Issue Procedure NT Government Restricted a Released Issue Work instruction Unrestricted Form Other a

Publication Controlled hard copies a Uncontrolled hard copies a Controlled electronic copy a File path: H:\Water\Facilities\Water\KatherineRegion\Katherine\PotableWater\HACCP\HACCP Plan\2004-

05\Drafts\HACCP Plan_Katherine Water Supply_Final Draft_FD2_nhm_March2004


B-49

COPYRIGHT

This document is copyright and apart from any use as permitted under the Copyright Act 1968, no part may be sold or reproduced by any process or made available to a third party for use in relation to a project which does not involve the Power and Water Corporation. Requests and inquiries concerning reproduction and rights shall be directed to the Project Manager HACCP.

Power and Water Corporation Project Manager HACCP – Water Facilities

P O Box 1921 DARWIN NT 0801

3 rd floor Energy House 18-20 Cavenagh Street

DARWIN NT 0800

Telephone: 08 8924 7177 Facsimile: 08 8924 7161

E-mail: [email protected]

Copyright © 2004 Power and Water Corporation

ACKNOWLEDGEMENT

Power and Water acknowledges the assistance provided by representatives from Melbourne Water Corporation, South East Water Ltd and the Sydney Catchment Authority in developing this HACCP Plan.

COMMENTS/REVISIONS

Suggestions and comments on this HACCP Plan can be forwarded to the Project Manager HACCP. These will be considered when the HACCP Plan is reviewed.

Power and Water Corporation Project Manager HACCP – Water Facilities

P O Box 1921 DARWIN NT 0801

3 rd floor Energy House 18-20 Cavenagh Street

DARWIN NT 0800

Telephone: 08 8924 7177 Facsimile: 08 8924 7161

E-mail: [email protected]


DOCUMENT REVISION HISTORY

Version Month/Year Coordination

by Position Summary of Changes

FD1 March 2004 Noel McCarthy Project Manager HACCP First version adopted for AwwaRF project trial implementation. FD2 May/June 2004 Noel McCarthy Project Manager HACCP Refer to Review Plan Katherine Water Supply System HACCP Plan 2003/2004 FD1

B-50

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

B-51

Foreword Power and Water Corporation is committed to the provision of a reliable water supply system that delivers good quality potable water which is safe to drink and aesthetically acceptable. In recent years an important part of this commitment has been involvement through the CRCWQT in the development and trialing of the Framework for Drinking Water Quality Management (1999) developed by the NHMRC/NRMMC for future inclusion in the next edition of the ADWG proposed for release in 2004. The Framework identifies that the establishment of systems complying with the requirements of established risk management and business quality management standards can largely be used to fulfil the Framework. Established systems include HACCP described within the Codex Alimentarius (1996, ?1999) which is commonly applied in the food production and service industries; and quality management systems conforming to the quality standard AS/NZS ISO 9001 (2000) which is applied in manufacturing and service industries. Across Australia and throughout the world leading companies have had their systems independently certified which verifies that the systems comply with the requirements of these standards. As part of a continuing commitment, Power and Water decided to actively participate in and contribute funding to a research project initiated by the CRCWQT to develop and trial HACCP in potable water supply systems. This project, AwwaRF Project 2856 – Application of HACCP for Distribution System Protection requires the development and implementation of a HACCP plan to ensure the safety of the potable water being supplied to customers. This work will focus Power and Water’s development of improved systems to protect potable water quality, placing Power and Water in a position to achieve independent certification of its potable water quality management system. I would like to recognise the research project funding contributions provided by the AwwaRF, CRCWQT and other Australian organisations. In addition, the guidance and input provided by Dr Melita Stevens, Dr Daniel Deere and Joanne Mullenger proved invaluable during the course of the project. Further, I would like to acknowledge the commitment by Power and Water personnel to the continuous review and improvement of the potable water supply system in the interests of improved public health. Darryl Day General Manager Water Services


B-52

CONTENTS Page Document Identification Sheet B-48 Copyright B-49 Acknowledgement B-49 Comments/Revisions B-49 Document Revision History B-50 Foreword B-51 Executive Summary B-54 Glossary of Terms, Abbreviations and Measurement Units B-56 Methodology and Plan Overview B-67 Scope B-75 Katherine HACCP Team B-76 Katherine HACCP Workshop Participants B-78 HACCP Project Manager B-78 HACCP Project Co-ordination Group B-79 HACCP Project Steering Group B-81 Production Process and Finished Product Description B-84 Intended Uses and Users of Finished Product B-87 Development of Process Flow Diagrams B-88 Primary Process Flow Diagram KWS – Water Supply B-91 Key Area Sub-Process Flow Diagram KWSWT – Water Treatment B-94 Key Area Sub-Process Flow Diagram KWSwtCF – Coagulation and Flocculation B-97 Key Area Sub-Process Flow Diagram KWSwtC – Clarification B-99 Key Area Sub-Process Flow Diagram KWSwtA – Aeration B-100 Key Area Sub-Process Flow Diagram KWSwtFi – Filtration B-101 Key Area Sub-Process Flow Diagram KWSwtD – Disinfection B-104 Key Area Sub-Process Flow Diagram KWSwtFl – Fluoridation B-107 Key Area Operational Hazard Process Flow Diagram GWSWTDWTC – Procurement of drinking water treatment chemicals

B-109

Key Area Sub-Process Flow Diagram KWSSC – Storages (Closed) B-111 Key Area Operational Hazard Process Flow Diagram GWSNM – New Mains Construction B-112 Key Area Operational Hazard Process Flow Diagram GWSEM – Existing Mains Alterations, Connections and Repairs

B-114

Key Area Operational Hazard Process Flow Diagram GWSBF – Backflow B-119 Key Area Operational Hazard Process Flow Diagram GWSI – Intrusion B-120 Key Area Operational Hazard Process Flow Diagram GWSMat – Materials and Products Manufacture and Utilisation

B-121

Hazard Identification B-123 Risk Analysis Methodology B-123 Risk Evaluation B-125 Critical Control Points and Non Critical Control Points B-126 Risk Assessment Schedule B-128 CCP, NCCP and SP Summary Information Schedule B-158 CCP and NCCP Detailed Information Schedule B-162 SP Detailed Information Schedule B-169


B-53

Page Validation Schedule for CCPs/NCCPs (Critical Limits) B-178 Validation Schedule for SPs (Performance Limits) B-181 Verification Schedule for HACCP Plan B-184 Potable Water Quality Improvement and Protection Action Schedule B-187 Acceptance Schedule by HACCP Team for HACCP Plan B-191 References B-192 Referenced Standard Operating Procedures B-195 List of Figures Figure 1: HACCP Plan Development and Supporting Programs B-68 Figure 2: HACCP Governance within Power and Water Organisational Structure B-83 Figure 3: CODEX Decision Tree to Identify CCPs B-126 List of Tables Table 1: Water Services Organisational Positions B-66 Table 2: Process Flow Diagrams B-70 Table 3: Contamination Pathways/Concerns and Possible Water Quality Problems B-73 Table 4: Katherine Water Supply Production Process and System B-75 Table 5: Katherine HACCP Team B-77 Table 6: HACCP Project Co-ordination Group B-80 Table 7: HACCP Project Steering Group B-82 Table 8: Process Flow Diagram Symbols and Descriptions B-89 Table 9: Process Flow Diagrams B-90 Table 10: Risk Factor Matrix B-124 Table 11: Severity and Likelihood Scales B-125 Table 12: Katherine HACCP Workshop Participants B-231 Appendices Appendix 1: Raw Water Specifications B-196 Appendix 2: Finished Product Specification B-224 Appendix 3: Table 12: Katherine HACCP Workshop Participants B-230 Appendix 4: Project Responsibilities B-232


B-54

Executive Summary Power and Water Corporation is a Northern Territory Government owned corporation that provides water, wastewater, electricity and telecommunications services to customers located across the Northern Territory. Water Services operate as both a retailer of water and wastewater services to customers, as well as harvesting raw water and providing wastewater treatment services. Operation is subject to a licence issued by the Utilities Commissioner pursuant to the Water Supply and Sewerage Services Act (2000). Water Services manages the provision of water and wastewater services to customers located in five major and twelve minor centres including the town of Katherine (population approximately 10 000) located approximately 300 km south of Darwin. This HACCP Plan encompasses the supply of potable water provided by Katherine’s water supply system which comprises: One weir creating an open raw water storage pool One raw water intake and transmission pumping station Two production bores One WTP Three closed storage tanks for treated water One booster pumping station 98 km of water mains Approximately 2000 customer service connections

HACCP is a system which was developed to ensure the safety of food. It is systematic and based upon scientific principles which identify specific hazards, evaluates their risk and requires measures for their control. The focus of a HACCP system is on prevention rather than relying upon end point testing to demonstrate food safety. The HACCP system has recently been developed and applied to potable water by a number of Australian water businesses. In all cases these businesses also operate quality management systems conforming to AS/NZS ISO 9001 (2000). Power and Water has chosen to implement a HACCP system based upon the requirements described in the Codex Alimentarius Commission Recommended International Code of Practice General Principles of Food Hygiene (?1999). HACCP has been applied throughout the entire chain of producing potable water from catchment to point of supply to the final consumer. Its application included consideration of the potential hazards affecting potable water quality caused by external parties such as suppliers, manufacturers, constructors/contractors and customers whose action, or lack of action may impact on Power and Water’s operations and ability to supply potable water. Hazardous events identified included processes, circumstances, situations and activities which lead to microbiological, physical, chemical and radiological contaminants being created within or introduced into the water supply system. Preventative measures developed included establishment of effective approaches to manage critical assets, activities and processes such as:


B-55

Catchment management Supply and use of drinking water treatment chemicals Construction of new water mains and their interconnection with existing water mains Repair of existing water mains and their recommissioning Design of reticulation mains Maintenance of the disinfection process Connection of new customers Use of approved products and materials for construction of water supply infrastructure Security of infrastructure

It is expected that implementation of the HACCP system will strengthen Power and Water’s ability to consistently supply potable water that meets the needs of customers. Implementation of HACCP commenced in April 2004 and after approximately twelve months its application will be reviewed and reported upon as a requirement of the AwwaRF project. It is anticipated that the experience gained will enable improved application when developing and implementing HACCP plans in other centres and provide a basis for identifying the areas requiring improvement to achieve independent certification.


B-56

Glossary of Terms, Abbreviations, Acronyms and Measurement Units AC: An acronym for asbestos cement. A material from which pipes can be manufactured, although it is no longer used in Australia to manufacture pipes. ADWG: An acronym for the Australian Drinking Water Guidelines. AIDS: An acronym for acquired immununodeficiency syndrome. ANSI: An acronym for American National Standards Institute. ANZFA: An acronym for Australia New Zealand Food Authority. ARMCANZ: An acronym for the Agriculture and Resource Management Council of Australia and New Zealand. Audit: A systematic comparison of a defined procedure with the actual process. In food safety terms a check on documentation and procedures whether the hazards have been identified and effectively controlled. An audit may be internal or external. Auditor: A person who conducts an audit. AWWA: An acronym for the American Water Works Association. AwwaRF: An acronym for the American Water Works Association Research Foundation. AwwaRFP: An acronym for an American Water Works Association Research Foundation project. Bactericidal lubricant: A pipe jointing lubricant formulated for use in contact with potable water. BPD: An acronym for backflow prevention device. C: An abbreviation for a chemical water quality hazard.


B-57

Closed storage: A tank/reservoir that is roofed or covered. Codex Alimentarius: Latin meaning “food code” or “food law”. Codex Alimentarius Commission: An organisation created in 1963 by FAO and WHO to develop food standards, guidelines and related texts such as codes of practice under the Joint FAO/WHO Food Standards Programme. The main purposes of this Programme are protecting health of the consumers and ensuring fair trade practices in the food trade, and promoting coordination of all food standards work undertaken by international governmental and non-governmental organizations. Australia is represented on the Commission. Shortened to Codex. COLTS: An acronym for continuous on-line testing system(s). Real time analysis that transfers data via the telemetry system. Control: Verb – To take all necessary actions to ensure and maintain compliance with criteria established in the HACCP plan, Codex (?1999). Noun – The state wherein correct procedures are being followed and criteria being met, Codex (?1999). Control measure: Any action and activity that can be used to prevent or eliminate a food safety hazard or reduce it to an acceptable level, Codex (?1999). Corrective action: Any action to be taken when results of monitoring at the CCP indicate a loss of control, Codex (?1999). CRCWQT: An acronym for Cooperative Research Centre for Water Quality and Treatment. The Cooperative Research Centre for Water Quality and Treatment was established in 1995 under the Australian Government's Cooperative Research Centres Program to provide a national strategic research capacity for the Australian water industry. The CRCWQT focuses on issues relating to water quality management and health risk reduction. Power and Water is an industry participant of the CRCWQT. Critical control point (CCP): A point, step or procedure at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level, NHMRC/ARMCANZ Co-ordinating Group (1999). Critical limit: A criterion which separates acceptability from unacceptability, Codex (?1999). Used for monitoring parameters associated with CCPs or NCCPs. Deviation: Failure to meet a critical limit, Codex (?1999).


B-58

DBP: An acronym for disinfection by-product. DICL: An acronym for ductile iron cement (mortar) lined. Ductile iron is a material from which pipes can be manufactured. Cement mortar is used to line the internal surface of the pipe. DIPE: An acronym for Department of Infrastructure, Planning and Environment. DN: An abbreviation for nominal size. An alphanumeric designation of size for components of a pipeline system, which is used for reference purposes. It comprises the letters DN followed by a dimensionless whole number, which is indirectly related to the physical size, in millimetres, of the bore or outside diameter of the end connections, WSAA (2002). DHCS: An acronym for the Department of Health and Community Services. Power and Water report to the Environmental Health Unit of this organisation. They make the decision whether or not to issue a ‘boiled water’ alert to customers. DNA: An acronym for data not available. DO: An acronym for dissolved oxygen. Dose response assessment: The determination of the relationship between the magnitude of exposure (dose) to a biological, chemical or physical agent and the severity and/or frequency of associated health effects (response). Drinking water: Potable water DSS: An acronym for decision support system. A tool or process for decision making. Due diligence: The proper conduct of the general food operation including testing, manufacturing and monitoring to ensure safe food is produced. DWTC: An acronym for drinking water treatment chemical(s).


B-59

Exposure assessment: The qualitative and/or quantitative evaluation of the likely intake of biological, chemical and physical agents via food as well as exposures from other sources if relevant. FAO: An acronym for the Food and Agriculture Organisation of the United Nations. Flow chart/diagram: A systematic representation of the sequence of steps or operations used in the production or manufacture of a particular food item, Codex (?1999). Food: A substance, whether processed, partly-processed, live or raw, intended for or represented as being for, human consumption and includes drink, chewing gum and any substance used in the preparation, production, manufacture or treatment of food, but does not include substances declared in the Food Standards Code not to be food and therapeutic goods within the meaning of the Therapeutic Goods Act 1989, ANZFA (1999). Food safety systems: Series of proactive, formally documented programs and procedures, typically preventative in nature, designed to assure high standards of safety and quality in food manufacturing. A system which identifies, evaluates and controls significant food safety hazards. GMPs: An acronym for good manufacturing practices. These are standard practices that are in place to reduce, eliminate or minimise a potential hazard or risk. This is a food industry term and the supporting program is used in the water industry. H: An abbreviation for high when used to designate a priority. HACCP: An acronym for hazard analysis and critical control point. A system which identifies, evaluates and controls hazards which are significant for food safety, Codex (?1999). HACCP plan: A document prepared in accordance with the principles of HACCP to ensure control over hazards which are significant for food safety in the segment of the food chain under consideration, Codex (?1999). Hazard: A biological, chemical or physical agent in, or condition of, food with the potential to cause and adverse health effect, Codex (?1999). In the case of potable water a hazard may also be radiological. Hazard analysis: The process of collecting and evaluating information on hazards and conditions leading to their presence to decide which are significant for food safety and therefore should be addressed in the HACCP plan, Codex (?1999).


B-60

Hazard characterisation: The qualitative and/or quantitative evaluation of the nature of the adverse health effects associated with biological, chemical and physical agents which may be present in food. For chemical agents, a dose-response assessment should be preformed if the data is obtainable. Hazard identification: The identification of biological, chemical and physical agents capable of causing adverse health effects and which may be present in particular food or group of foods. HIV: An acronym for human immunodeficiency virus. Hygiene: All measures necessary to ensure the safety and wholesomeness of the food at all stages of the food chain (including preparation, processing, packaging, storing, handling, transportation and offer for sale or supply to the consumer). IMS: An acronym for integrated management system. A management system designed to fulfil quality, environmental and OHS requirements. Incident: An incident is any event or circumstance within our operation that causes or is likely to cause any of the following impacts: a) interruptions of services to customers; b) threat to our systems; c) threat to community health and safety; d) threat to the environment; e) threat to private or public property; or, f) creation of the need for urgent action under statute or legislation. There are three classification of incidents: minor, significant, and major. km: An abbreviation for the unit of measurement for kilometre. L: An abbreviation for low when used to designate a priority. LCL: An acronym for lower control limit. M: An abbreviation for medium when used to designate a priority. M: An abbreviation for a microbiological water quality hazard. ML: An abbreviation for the unit of measurement for megalitre.


B-61

MWC: An acronym for the Melbourne Water Corporation. Monitor: The act of conducting a planned sequence of observations or measurements of control parameters to assess whether a CCP [or NCCP] is under control, Codex (?1999). N: An abbreviation for no. NA: An acronym for not applicable. NACMCF: An acronym for the National Advisory Committee on Microbiological Criteria for Foods. NHMRC: An acronym for the National Health and Medical Research Council. Non-conformity: The non-fulfilment of specified requirements, AS/NZS ISO 9000 (2000). Non-critical control point (NCCP): A point, step or procedure at which control can be applied and is essential to prevent or eliminate a food quality hazard not associated with food safety, or reduce it to an acceptable level.. NRMMC: An acronym for the Natural Resource Management Ministerial Council. NST: An acronym for no scheduled test. NT: An acronym for Northern Territory. NTU: An acronym for Nephelometric Turbidity Unit. A measure of the clarity of water. Open storage: A basin/reservoir that is not covered, i.e. has no roof. The water’s surface is exposed to the environment. P: An abbreviation for a physical water quality hazard. PE: An acronym for polyethylene. A material from which pipes can be manufactured.


B-62

Performance limit: A criterion which separates acceptability from unacceptability. Used for monitoring parameters associated with SPs. pH: A measure of the acidity or alkalinity of water. Potable water: Water that is safe to drink. Principles of hygiene: The practices that keep basic food controls in place for sanitisation and personnel cleanliness. These practices are generally identified through regulations. Also known as good manufacturing practices (GMPs). A major component of an effective food safety system. Process: In relation to food, means activity conducted to prepare food for sale including chopping, cooking, drying, fermenting, heating, pasteurising, thawing, and washing or a combination of these activities, ANZFA (1999). Processing aid: Any substance or material, not including apparatus or utensils, and not consumed as a food ingredient by itself, intentionally used in the processing of raw materials, foods or its ingredients to fulfil a certain technological purpose during treatment or processing and which may result in the non-intentional but unavoidable presence of residues or derivatives in the final product, Codex (?1999). PVC: An acronym for polyvinyl chloride. A family of materials from which pipes can be manufactured. Quality control point (QCP): A point, step or procedure at which control can be applied and is essential to prevent or eliminate a food quality hazard not associated with food safety, or reduce it to an acceptable level. In this Plan the term non critical control point (NCCP) is used in preference to quality control point. This avoids confusion because the term water quality is often used with two meanings: 1) where health/safety is an attribute of water quality and 2) where water quality only encompasses the aesthetic quality of water. R: An abbreviation for a radiological hazard. RAAF: An acronym for Royal Australian Air Force. Raw water: Water that has not been treated in any way. It is generally considered unsafe to drink. RFS: An acronym for removed from service, meaning the equipment is not operated.


B-63

Risk analysis: A systematic use of available information to determine how often specified events may occur and the magnitude of their consequences, AS/NZS 4360 (1999). Risk assessment: The overall process of risk analysis and risk evaluation, AS/NZS 4360 (1999) Risk communication: The interactive exchange of information and opinions concerning risk among risk assessor, risk managers, consumers and other interested stakeholders. Risk evaluation: The process used to determine risk management priorities by comparing the level of risk against predetermined standards, target risk levels or other criteria, AS/NZS 4360 (1999). Risk management: The culture, processes and structures that are directed towards the effective management of potential opportunities and adverse effects, AS/NZS 4360 (1999). Risk management process: The systematic application of management policies, procedures and practices to the tasks of establishing the context, identifying, analysing, evaluating, treating, monitoring and communicating risk, AS/NZS 4360 (1999). RRJ: An acronym for rubber ring joint. A type of pipe joint. Safe food: Food that is not likely to cause harm to a person who consumes the food when it is prepared, stored and consumed according to its reasonable intended use, ANZFA (1999). SE Water: An acronym for South East Water Limited. SCADA: An acronym for Supervisory Control and Data Acquisition. A telemetry system that continuously monitors and down loads real time information from monitoring points throughout Power and Water’s water supply system. SOP: An acronym for standard operating procedure which is documented procedure for performing a particular task or activity. Such a procedure may include measures to reduce the risk of various types of hazards occurring including those to water quality, personnel, infrastructure, service reliability etc. A SOP is equivalent to the food industry’s GMP.


B-64

SP(HS) or SP(A): An acronym for supporting program and identifying that the associated water quality hazard(s) was either a health/safety concern or an aesthetic concern. Supporting programs are defined as required foundation activities that ensure good water quality. Step: A point, procedure, operation or stage in the food chain including raw material, from primary production to final consumption, Codex (?1999). The included definitions of CCP and NCCP/QCP recognise the Codex (?1999) definition of step. Suitable food: Food that: a) is not damaged, decomposed, deteriorated or perished or does not contain a damaged,

decomposed, deteriorated or perished substance, having regard to its reasonable intended use; b) does not contain any biological or chemical agent, or other matter or substance that is foreign to

the nature of the food except for any matter or substance permitted by the Food Standards Code; and,

c) is not the product of a diseased part of an animal or one that has died otherwise than by slaughter, ANZFA (1999).

SCA: An acronym for the Sydney Catchment Authority. TBA: An acronym for to be advised. Treated water: Disinfected and/or filtered water served to water system customers. It must meet or surpass all potable water standards to be considered safe to drink. Universal food safety programs: Those programs or elements which address product protection and food safety issues that are not covered in the HACCP plan or under principles of food hygiene (e.g. allergen protocols, raw material specification, new product introduction). A major component of an effective food safety system. UCL: An acronym for upper control limit. Validation: Obtaining evidence that the elements of the HACCP plan are effective, Codex (?1999). Verification: The application of methods, procedures, tests and other evaluations, in addition to monitoring to determine compliance with the HACCP plan, Codex (?1999). VOC: An acronym for volatile organic compounds.


B-65

v and v: An abbreviation for volume/volume. WHO: An acronym for the World Health Organisation. WSAA: An acronym for the Water Services Association of Australia. WSSSA: An acronym for the Water Supply and Sewerage Services Act (2000). WTP: An acronym for water treatment plant WQ: An acronym for water quality Y: An abbreviation for yes.


B-66

Position Title Abbreviation/Acronym

Asset Maintenance Coordinator AMC Asset Maintenance Engineer AME (replaced by AMC) General Manager Water Services GMWS Instrumentation Coordinator IC Manager Land Development MLD Manager Infrastructure Technical Policy MITP Manager Water Engineering MWE Manager Water Facilities MWF Manager Water Operations MWO Project Manager HACCP PM HACCP Regional Manager (Alice Springs) RM (A/S) Senior Engineer Treatment SET Senior Resource Planner SRP Water Coordinator (Katherine) WC (Katherine) Water Safety Advisor WSA Water Quality Officer WQO Water Quality Specialist No1 WQS1 Water Quality Specialist No 2 WQS2 Water Quality Systems Engineer/Scientist WQSE/S Water Treatment Plant Operator WTP Operator

Table 1: Water Services Organisational Positions


B-67

Methodology and Plan Overview This section outlines the concept of the HACCP methodology and provides an overview of the HACCP Plan. More detailed information is contained in the remainder of the HACCP Plan. Development of this HACCP Plan for the Katherine water supply system focussed primarily on understanding and assessing the discrete water supply processes (e.g. treatment, storage, distribution etc.) involved in delivering potable water. Hazardous events and sources of hazards impacting on these processes were identified and the risk they pose estimated using a simple qualitative model. This approach was considered suitable for initiating the use of HACCP within Power and Water. A more comprehensive approach to developing a HACCP plan requires a detailed understanding and assessment of the water supply system. Broadly this would require investigation of: Catchments Source waters including both surface and groundwater systems Storage reservoirs and intake structures Treatment systems Distribution system including storages and reticulation system Consumers

As an example, it is possible to specifically account for the condition of infrastructure and its environment. Such an approach enables a more considered determination of risk, as it is possible to take into account the potential for specific infrastructure assets to be the source of hazards. Such an approach takes into account the: 1) Physical condition, design or both of specific infrastructure assets. For example, a particular: closed storage tank may be more at risk to bird entry than another due to its design or state of repair closed storage tank may be prone to poor mixing because of its design part of the reticulation network may be at higher risk from biofilms due to a predominance of pipe

materials that promote biofilm formation 2) Location of specific infrastructure assets. For example, a particular: low lying area may be prone to flooding and hence at higher risk of intrusion an area where on-site wastewater treatment and disposal is utilised may pose a higher risk of the

surrounding ground being contaminated than an area with reticulated sewers Documentation of such a plan might include a number of sub-plans for specific zones, areas or parts of a larger water supply system. For Katherine a single HACCP plan was developed and the process followed to develop the HACCP Plan involved the application of twelve elements (five steps and seven principles) as shown in Figure 1. This HACCP Plan does not explain or detail the various supporting programs required to support HACCP, however, a schedule has been included with performance limits associated with some supporting programs.


B-68

Figure 1: HACCP Plan Development and Supporting Programs

WATER QUALITY OBJECTIVES

Describe the product

Document intended use of product

Construct a process flow diagram

Verify process flow diagram

Identify Critical Control Points

Establish critical limits

Identify monitoring procedures

Establish documentation and record

Identify hazards and preventative

Validate/verify HACCP plan

Establish corrective action procedures

PRINCIPLES

STEPS

HACCP

Assemble a team

WATER SUPPLY SYSTEM ASSESSMENT

SUPPORTING PROGRAMS

Resource and source protection

Procurement of DWTC

Operation and maintenance

Approved products and materials

Cross-connection control/backflow prevention

Asset management

Supplier management

Planning and design

Verification of water quality

Incidents and emergencies

Community involvement and awareness

Research and development

Employee awareness and training


B-69

The scope of this HACCP Plan covers Katherine’s potable water supply system from the catchment and basin from which raw waters are sourced, through to the interface point with each customers’ building plumbing system. This interface point is usually the downstream side of the water meter installed on each service connection. To prepare this HACCP Plan a multi-disciplinary team of Power and Water personnel was assembled and trained in the fundamentals of the HACCP methodology. The HACCP team developed specifications for the following: Raw water extracted from sources Drinking water treatment chemicals procured from suppliers Finished product (i.e. potable or drinking water) supplied to customers

These specifications were prepared using: National guidelines for potable water quality (i.e. ADWG (2003)) reflecting health and aesthetic

considerations Water quality monitoring results reported for compliance purposes Operational monitoring results Specific customer expectations Drinking water treatment chemical standards

Power and Water’s water supply process was documented as a series of process flow diagrams. The production process flow diagrams were then used to identify potentially hazardous events impacting upon water quality. Additionally, a number of significant hazardous threats that can introduce hazards capable of compromising water quality were also documented as process flow diagrams. These are listed in Table 2. The HACCP team identified the following major areas for water quality degradation which include a number of general pathways for contamination of the water supply system: Surface water and groundwater resource and source WTP failure/contaminant breakthrough Intrusion: – intrusion due to transient pressure events Water aging: – free chlorine residual decline, sediment accumulation, biofilm formation Cross connections: – backflow contamination entry via unprotected cross-connections Existing mains: – alterations, connections and repairs Uncovered reservoirs/storage New mains: – construction Covered reservoirs/storages Materials and products: – contact/leaching/permeation, corrosion byproducts Deliberate contamination

Table 3 broadly describes the possible water quality problems associated with these major areas.


Diagram

Code Production

Process/Step Production

Sub-process Step Significant Operational WQ Hazardous Threat

KWS Water supply KWSH Harvesting KWSSO Storage (open) KWSSE Source extraction GWSMat Materials, products, coatings and equipment contact/permeation/leaching

KWST Transmission GWSNM New mains construction GWSEM Existing mains alterations, connections and repairs GWSBF Cross-connection and backflow GWSI Intrusion GWSMat Materials, products, coatings and equipment contact/permeation/leaching

KWSWT Water treatment KWSwtCF Coagulation and flocculation KWSwtC Clarification KWSwtA Aeration KWSwtFi Filtration KWSwtDf Disinfection KWSwtFl Fluoridation GWSWTDWTC Procurement and addition of DWTC GWSMat Materials, products, coatings and equipment contact/permeation/leaching

KWSSC Storage (closed) GWSMat Materials, products, coatings and equipment contact/permeation/leaching

KWSDt Distribution (i.e. delivery) GWSNM New mains construction GWSEM Existing mains alterations, connections and repairs GWSBf Cross-connection and backflow GWSI Intrusion GWSMat Materials, products, coatings and equipment contact/permeation/leaching

Notes: 1. Shading of diagram code cell indicates diagram included in HACCP Plan. G – General K – Katherine WS – Water supply

Dt – Distribution SC – Storage (closed)

SO – Storage (open)

H – Harvesting SE – Source Extraction

T – Transmission WT – Water treatment

wt - water treatment sub-process

A – Aeration Bf – Backflow C – Clarification CF – Coagulation & Flocculation

Df – Disinfection DWTC – Drinking Water Treatment Chemicals

EM – Existing Mains

Fi – Filtration Fl – Fluoridation I – Intrusion Mat – Materials NM – New Mains

Table 2: Process Flow Diagrams

B-70

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Summary of Possible Water Quality Problems Primary Contamination Pathways/Concerns

Related Diagram

Code

Production Sub-

process Step

Microbiological Issues

Chemical Issues

Physical Issues

Radiological Issues

Harvesting KWSH Pathogen contamination*

Chemical contaminants*

Turbidity Radioactivity*

Pathogen contamination* Turbidity Nitrification* Storage (open) KWSSO


Tastes and odour from M

Source extraction KWSSE Pathogen contamination*


Turbidity Radioactivity*

Water treatment failure/contaminant breakthrough KWSWT Pathogen contamination* Turbidity

KWSwtCF Coagulation and flocculation

DWTC over dosing*/under dosing

Low/high pH

KWSwtC Clarification KWSwtA Aeration KWSwtFi Filtration

KWSwtDf Disinfection DWTC over dosing*/under dosing

Taste and odour from Cl2

KWSwtFl Fluoridation DWTC over dosing*/under dosing

Procurement and addition of DWTC GWSWTDWTC Pathogen contamination* HPC increase Disinfectant decay

KWS Ammonia oxidizing bacteria (AOB) increase

Nitrite/nitrate formation*

Nitrification KWSSC Nitrite oxidizing bacteria (NOB) increase

DO depletion

KWD Reduction in pH and alkalinity

DBP formation due to mitigation techniques*

Microbial regrowth* Disinfectant decay Corrosion Nitrification* Chemical

contaminants* Temperature/stratification

Pathogen contamination* DBP formation* Sediment deposition* Storage (closed) KWSSC

Taste and odour from M & C

Pathogen contamination* Chemical contaminants*

Turbidity

Exposure to excess chlorine*

Colour

Loss of disinfectant residual

pH stability

New mains construction GWSNM

Taste and odour from C

B-71

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Related Diagram

Code

Production Sub-

process Step


Chemical Issues

Physical Issues

Radiological Issues


Turbidity

Exposure to excess chlorine*

Colour

Loss of disinfectant residual

pH stability

Existing mains alterations, connections and repairs GWSEM

Taste and odour from C DBP biodegradation DBP formation* Increased temperature KWSSC

Nitrification* Disinfectant decay Sediment deposition* Microbial regrowth/recovery/shielding*

Corrosion control effectiveness

Colour Water aging KWSDt



Corrosion

Non microbial (e.g. blood, body fluids)*

Disinfectant decay Turbidity

Microbial regrowth/recovery/shielding*

Increased metals levels*

Colour

Cross-connection and backflow

GWSBf



Sediment deposition*

Colour Intrusion GWSI

Taste and odour from C KWSSO KWSSE KWSWT KWSSC GWSBf GWSMat


Colour

Deliberate contamination

KWSDt

Pathogen contamination*

Taste and odour from C

Pathogen contamination* Increased VOC content*

Colour

Microbial growth support* Vinyl chloride formation from PVC pipes*

Increased pH levels from cement pipes or linings*

Increased lead and copper levels from pipes, fittings, ancillaries etc.*


Materials, products, coatings and equipment contact/permeation/leaching GWSMat

Increased asbestos levels from AC pipes*

B-72

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Related Diagram

Code

Production Sub-

process Step


Chemical Issues

Physical Issues

Radiological Issues

Increased organic contaminants from PE pipes*

Increased metals levels from cement pipes or linings*

Increased organic contaminants from organic linings*

Notes: 1. Shading of diagram code cell indicates diagram included in HACCP Plan. 2. * Potential health impact G – General K – Katherine WS – Water supply

Dt – Distribution

SC – Storage (closed)





A – Aeration Bf – Backflow C – Clarification CF – Coagulation & Flocculation


EM – Existing Mains Fi – Filtration Fl – Fluoridation

I – Intrusion Mat – Materials NM – New Mains

Table 3: Contamination Pathways/Concerns and Possible Water Quality Problems

B-73

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

B-74

Each of these areas was then examined and the circumstances under which hazardous events could occur that could lead to contamination were documented. Existing and potential control measures which would prevent the hazardous events from occurring were also listed. A simple risk analysis model based upon a five by five matrix of likelihood of occurrence and severity of consequences was then used to determine a risk factor (i.e. score) for the hazard(s) arising from each hazardous event. Filtering was applied to distinguish significant hazards from those considered to be of less significance, and to separate hazards related to aesthetic concerns which did not result in potable water becoming unsafe to consume. Significant hazards arising from each hazardous event were then examined to identify whether a point, step or procedure existed which constituted a CCP or NCCP, and if so monitoring parameters selected which were then assigned target and action critical limits. Each CCP or NCCP was then examined in detail to identify the following requirements: Monitoring requirements necessary to track adherence to target or exceedence of action critical limits Corrective actions/responses taken in the event of action critical limits being exceeded Provision and storage of records forming evidence of adherence to procedures, collection of

data/information, adherence to target or exceedence of action critical limits etc. In some cases, a process point, step or procedure whilst technically considered a CCP (also applies to NCCP) was not practical to monitor to enable prompt corrective action to be taken and thus it was not designated as a CCP (NCCP). In such cases the point, step or procedure was controlled under a supporting program (designated as SP) and assigned target and action performance limits. Many of these requirements will need to be developed and documented; and have been carried over to an action plan designed to capture required improvements. CCPs and NCCPs were validated using scientific knowledge, expertise and reference to available published information (e.g. accepted best practice codes, guidelines, standards etc.). A verification schedule was developed and documented to ensure the scheduled review of critical activities and also to facilitate continuous improvement.


B-75

Scope This HACCP Plan has been developed and implemented across Katherine’s potable water supply system as outlined in Table 4 and includes both headworks and distribution works.

Production Process

Steps Production

Inputs System General System Components/Assets

Katherine System Components/Assets

Details Harvesting Rain water, environmental

contaminants Catchment and basin

Katherine River catchment and aquifer within Tindal Limestone formation

Source extraction

Raw water sources: Surface water Groundwater

Materials, products, coatings and equipment

Dams, weirs, wells, bores

Donkey Camp weir creating pool (i.e. open storage reservoir)

Production bores RN 6983 and RN 7807

Transmission Materials, products coatings and equipment

Raw water transfer system: Intake structures Pumping stations Transmission trunk mains

Donkey Camp pool raw water intake, pumping station and rising main

Equipped production bores and rising mains

Treatment/ preservation

Procurement and addition of DWTC: Coagulants and aids pH correction Disinfectants Other

Materials, products, coatings and equipment

Headworks

WTP

Katherine WTP Coagulation and flocculation Aeration Blending/clarification Filtration Disinfection Fluoridation

Storage

Materials, products, coatings and equipment Disinfectants associated with cleansing of materials/equipment and spot dosing

Reservoirs, storages and tanks: Service tanks Balance tanks Terminal storages

4.5 ML, 9 ML and 12 ML closed storage service tanks

Materials, products coatings and equipment Disinfectants associated with cleansing of materials/equipment and spot dosing

Distribution trunk mains Pumping stations

Tindal booster pump station and distribution mains generally without customer service connections Distribution (i.e.

delivery) Materials, products coatings and

equipment Disinfectants associated with cleansing of materials/equipment and spot dosing

Distribution works

Reticulation mains Mains with customer service connections

Table 4: Katherine Water Supply Production Process and System


B-76

Katherine HACCP Team To develop a HACCP plan for the Katherine potable water supply system an in-house team was assembled and convened on a number of occasions ahead of a workshop conducted in Katherine on 6-7 August 2003. A second follow up workshop was conducted on 3-4 December 2003 to review a draft HACCP Plan developed during the third and fourth quarters of 2003. As the scope of the HACCP plan required for the AwwaRFP 2856 – Application of HACCP for Distribution System Protection did not encompass the water supply catchment/basin, the team did not initially include a member with expertise in the area of catchment/basin management. Early on it was decided that because a HACCP plan for the entire potable water supply system was ultimately required for operational purposes, an additional member should be included on the team and the HACCP Plan’s scope widened to encompass the catchment/basin. In addition, the scope of the HACCP Plan was widened to include other headworks elements (i.e. raw water sources and WTP), thus requiring additional team members. The composition of the HACCP team and their details are shown in Table 5. Broadly the team possessed expertise in the areas of: Catchment and resource management Potable water risk management Disinfection, filtration and other forms of water treatment Microbiological, physical and chemical water quality, water quality monitoring Strategic products, materials and drinking water treatment chemicals Cross-connection control and backflow prevention Water main construction, repairs and alterations Water supply system operation e.g. security, storage operation, mains flushing Water supply system design Constructor/contractor management Technical writing e.g. policy, specifications, standard operating procedures Quality management systems


Work Telephone Work Facsimile Name

Organisation Organisation

Position Role Responsibility Work E-mail

Postal Address Physical Location

Kathryn Clarkson 08 8924 7059 Power and Water Corporation 08 8924 7161

WQS Team member/technical expert

Input to Plan on area of expertise Validation of Plan

Verification of Plan

[email protected]

P O Box 1921 DARWIN NT 0801 Energy House 3 rd floor

Simon Copley 08 8924 5047 Power and Water Corporation 08 8924 5033

AMC Team member Implementation of Plan upon approval

[email protected]

P O Box 37471 WINNELLIE NT 0821 Ben Hammond Complex

Norm Cramp 08 8924 5910 Power and Water Corporation 08 8924 5033

MWO Team member/manage-ment commitment

Review Plan to recommend approval

Facilitate implementation of Plan upon approval Verification of Plan [email protected]


TBA 08 8924 7096 Power and Water Corporation 08 8924 7161

WQS2 or WQO Team member/technical expert

Input to Plan on area of expertise Development of Plan

TBA


Paul Heaton 08 8924 7359 Power and Water Corporation 08 8924 7161

MWF Team member/manage-ment commitment

Input to Plan on area of expertise

Review Plan to recommend approval

[email protected]


Peter Hopkins 08 8973 8969 Power and Water Corporation 08 8973 8955

WTP Operator Team member Validation of Plan Implementation of Plan upon approval Verification of Plan [email protected]

P O Box 1045 KATHERINE NT 0851 Morris Road

Noel McCarthy 08 8924 7177 Power and Water Corporation 08 8924 7161

PM HACCP Team member/technical expert

Input to Plan on area of expertise Development of Plan Validation of Plan

[email protected]


Tony Morley 08 8973 8411 Department of Health and 08 8973 8592 Community Services


Team member/technical expert

Input to Plan on area of expertise

[email protected]

PMB 73 KATHERINE NT 0851 Government Centre

Kevin O’Brien 08 8973 8730 Power and Water Corporation 08 8973 8733

WC (Katherine) Team member Validation of Plan Implementation of Plan upon approval Verification of Plan [email protected]


Declan Page 08 8924 7942 Power and Water Corporation 08 8924 7161

SRP Team member/technical expert

Input to Plan on area of expertise Validation of Plan

[email protected]


Table 5: Katherine HACCP Team

B-77

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

B-78

Katherine HACCP Workshop Participants The purpose of conducting the workshops was to bring together the complete HACCP Team. This enabled the Team’s operational personnel, whose knowledge of the water supply system was critical to ensuring all potential hazards, operational processes and preventative measures were identified and fully understood were input into the development of the HACCP Plan. The first workshop was facilitated by representatives from MWC, SE Water and the SCA who are part of the CRCWQT project team involved in the AwwaRF RFP 2856 – Application of HACCP for Distribution System Protection. In addition to the workshop, a walk over of parts of the Katherine water supply system was undertaken including: Donkey Camp Pool raw water open storage reservoir and weir Donkey Camp raw water transfer pumping station Katherine WTP

A second workshop was held on 3-4 December 2003 to review and discuss the developed HACCP Plan and discuss implementation. A complete list of the participants who attended the workshops can be found in Table 12 located in Appendix 3. HACCP Project Manager Within Power and Water the Project Manager HACCP undertakes the project management of the HACCP project and is the custodian of all HACCP plans. The project manager’s role encompasses the management of the following broad project phases associated with the adoption of a HACCP system, it’s implementation and upkeep: Initiation Planning Execution Controlling Closure Review Maintenance

Specific responsibilities of the Project Manager HACCP are described in Appendix 4.


B-79

HACCP Project Co-ordination Group The HACCP Project Co-ordination Group is a group of stakeholders brought together to discuss and deal with operational issues for the project. Members may be part of the HACCP team, but, also, clients/users/other parties from areas across Power and Water that will be impacted upon by the HACCP project. Specific responsibilities of the HACCP Project Co-ordination Group members are described in Appendix 4 The composition of the HACCP Project Co-ordination Group and their details are shown in Table 6. For additional information on any aspect of HACCP, inquiries may be directed in the first instance to the Project Manager HACCP who acts as the representative of HACCP Project Co-ordination Group.







WQS1 Member Input water quality issues

[email protected]


TBA 08 8924 7096 Power and Water Corporation 08 8924 7161

WQS2 or WQO Member Input water quality issues

TBA



PM HACCP Chair Organise meetings Chair meetings Document meeting minutes

[email protected]


Andrew Mills 08 8924 7096 Power and Water Corporation 08 8924 7161

SET Member Input water quality issues Assign tasks/activities to WQT team members

[email protected]



SRP Member Input resource and source management issues

[email protected]


Table 6: HACCP Project Co-ordination Group

B-80

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

B-81

HACCP Project Steering Group The HACCP Project Co-ordination Group in turn reports to a strategic HACCP Project Steering Group. Specific responsibilities of the HACCP Project Steering Group are described in Appendix 4. The composition of the HACCP Project Steering Group and their details are shown in Table 7. The relationship between the HACCP Team, HACCP Coordination Group, HACCP Steering Group and other Power and Water executive is shown in Figure 2.







MWO Water Operations client

Review project process Recommend approval of Plan

Implement dinking water improvement schedule outcomes Monitor and drive supporting programs

[email protected]


Darryl Day 08 8924 7002 Power and Water Corporation 08 8924 7161

GMWS Project sponsor Review project progress Approve HACCP Plan Approve resources for project

Chief project champion

[email protected]



MWF Water Facilities client

Review project progress Recommend approval of Plan


[email protected]



PM HACCP HACCP specialist and chair

Report to Steering Group Document Steering Group outcomes

Raise HACCP awareness

[email protected]


John Pudney 08 8924 7323 Power and Water Corporation 08 8924 7212

MWE Water Engineering client

Review project progress Recommend approval of Plan


[email protected]


Alan Whyte 08 8951 7249 Power and Water Corporation 08 8951 7347

RM (A/S) Water Services client Review program process

Recommend approval of Plan

Monitor and drive supporting programs

[email protected]

P O Box 1521 ALICE SPRINGS NT 0871 Sadadeen Valley

Table 7: HACCP Project Steering Group

B-82

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Membership /influence

WC (KATH)

Figure 2: HACCP Management within Power and Water Organisational Structure

HACCP PLANS KATHERINE REGION

IMS Network Group

HACCP Steering Group

Katherine Team

Pine Creek Team

Daly Water Team

Borroloola

Team

HACCP Sponsor

Larrimah Team

HACCP Co-

ordination Group

NEW MAINS

EXISTING MAINS

BACKFLOW

OTHERS

WATER SERVICES

RM (AS)

MWF

MWO

MWE

GMWS

WATER

WATER FACILITIES

WATER OPERATIONS

PMQ

Mataranka

Team

Timber Creek Team

SPECIALIST TEAMS

INTERNAL SYSTEM AUDITOR(s)

EXTERNAL SYSTEM AUDITOR(S)

IMS Planning

Group

BUSINESS

GMBS

MQSR

EMC

B-83

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

B-84

Production Process and Finished Product Description

General Finished product name: Potable water

Type Description Significant Human Activity

Surface water Katherine River (NT Portion 4700) catchment rising within Sandstone Escarpment above the Katherine Gorge and extending into Arnhem Land Harvesting:

Groundwater Aquifer within Tindal Limestone formation of the Daly River Group found within the Daly River geological basin

Katherine Gorge tourism/recreation (boating, swimming, fishing, walking tracks, camping)

Agriculture (livestock, fruit trees) Township (regional hub, major

inter/intrastate highways)

Type Extraction Location Description Production Qty/Annum

(average last 3yr)

Surface water Donkey Camp Pool off Gorge Road

Weir across Katherine River creating open storage reservoir

≅ 2900 ML/annum (≅ 80% total)

Source:

Groundwater Morris Road WTP site (NT Portion 1339)

Production bores RN 6983 & RN 7807

≅ 920 ML/annum (≅ 20% total)

Type Location Description

Surface water Katherine River (NT Portion 4700) off Gorge Road

Donkey Camp raw water intake and pumping station. Raw water is pumped through a 6 km DN 450 DICL rising main Trans-

mission:

Groundwater Morris Road WTP site (NT Portion 1339)

Electro-submersible pumps installed in bores pump through a short section of AC and DN 300 DICL rising main

Location Process Comments

Coagulation/ flocculation

Required for surface water approximately 7 months of year

Aeration All groundwater only

Clarification Required for surface water approximately 7 months of year

Filtration All surface water Disinfection All surface and groundwater chlorinated

Treatment: Morris Road WTP (NT Portion 1339)

Fluoridation All surface and groundwater

Location Capacity (ML) Comments

Morris Road WTP site (NT Portion 1339) 4.5 Closed reinforced concrete storage tank

Morris Road WTP site (NT Portion 1339) 9.0 Closed reinforced concrete storage tank Storage:

Katherine East (NT Portion 2969)

12.0 Closed welded steel storage tank

Preservation: Free chlorine residual. Limit set to control bacterial regrowth and minimise disinfection by-products, taste and odour problems

Delivery/distribution: Network of predominantly below ground pressure pipes of various materials. Water is transferred via a booster pump station and rising main to the Tindal RAAF base at the


B-85

water supply system’s extremity General (cont)

Resource and source protection program Procurement program for drinking water treatment chemicals Scheduled operation and maintenance program Approved strategic products and materials program Cross-connection control and backflow prevention program Supplier (contractor, constructor, designer etc.) management program Drinking water monitoring program Asset management program Distribution system planning and design program Employee and awareness training

Controls:

Incident and emergency protocols

Raw Water Specification – General

Raw water comprises surface runoff extracted from the Katherine River at the Donkey Camp weir and groundwater from production bores RN 6983 and RN 7807. An overview of the physical, chemical and radiological characteristics applicable to raw water which are monitored for water quality compliance and operational purposes, along with the associated ADWG (2003) heath and aesthetic guideline values are presented in Appendix 1. Appendix 1 also presents Power and Water’s raw water specification. Where a specification value is known for a characteristic not monitored for water quality or operational purposes (marked NA), then this value has been listed.

Drinking Water Treatment Chemicals Product Standard Contract Number Chemical Technical

Name Form Delivery Form Comments Specification Number

ANSI/AWWA B403 TBA Aluminium sulphate Powder 25 kg bags

Delivered by road. 40 bags per pallet. Ordered in 10 tonne lots. TBA

Calcium hypochlorite

NOT CURRENTLY USED

ANSI/AWWA B301

TBA Chlorine Liquid/Gas 920 kg pressure cylinder

Delivered by road. One cylinder on-line and one spare held. Additional 70 kg pressure cylinders held for Remote Operations which can be used. TBA

ANSI/AWWA B703 TBA Hydrofluorosilic acid Liquid 2 x half full 1000 L bulky

bins Delivered by road. 500 L per bulky bin. 2 bulky bins held on-site. TBA

TBA TBA Polyelectrolyte Liquid 1 x 1000 L bulky bin

Delivered by road. 1000 L per bulky bin. 1 bulky bin held on-site. TBA

ANSI/AWWA B201 TBA Sodium carbonate (soda

ash) Powder 25 kg bags Delivered by road. 40 bags per pallet. Ordered in 10 tonne lots. TBA

ANSI/AWWA B300 TBA Sodium hypochlorite Liquid 1 x 1000 L bulky bin

Delivered by road. 1000 L per bulky bin. 1-2 bulky bins held on-site. Decantered into 25 L container. TBA


B-86

Finished Product Specification – General

Power and Water’s objective is to produce good quality potable water that is safe and aesthetically acceptable. Consistent with this objective, Power and Water’s specification for potable water is derived where relevant from the ADWG (2003), with the exception that by agreement with the RAAF the hardness of water supplied to Katherine is not to exceed an average of 100 mg/L (operational maximum 140 mg/L). The ADWG (2003) are based primarily on WHO recommendations, any deviations from these are detailed in the ADWG (2003). Adoption of the ADWG (2003) is consistent with the intent of the WSSSA Act which requires water quality standards to take into account relevant national benchmarks. In respect of the provision of the Katherine water supply DHCS grant no special exemptions, exceptions or variations via Power and Water’s operating licence or by other means for ADWG (2003) health guideline values. DHCS do set an aesthetic guideline value for the physical parameter TDS of 800 mg/L, however, the ADWG (2003) guideline value of 500 mg/L is easily complied with. An overview of the microbiological, physical, chemical and radiological characteristics applicable to potable water which are monitored for water quality compliance and operational purposes, along with the associated ADWG (2003) heath and aesthetic guideline values are presented in Appendix 2. Appendix 2 also presents Power and Water’s potable water specification. For details of actual information reported for water quality compliance purposes refer to the Power and Water annual Water Quality Report.


B-87

Intended Uses and Users of Finished Product

Intended Uses Power and Water’s specification for potable water is determined to ensure that it is suitable for immediate human consumption by ingestion by the general population without further treatment or boiling. This is provided the quality of the water is not adversely affected by virtue of its conveyance through plumbing systems located downstream of Power and Water’s point of supply, or other storage/handling processes the user is responsible for or causes. Specific attention is drawn to the need for appropriate maintenance of plumbing systems and other equipment in order to preserve water quality for specific uses. Potable water may also be used in beverages or the preparation of food intended for ingestion. Potable water may also have other uses (some of which may lead to indirect ingestion), including: Hand washing, bathing, showering and ablutions Recreation Washing of laundry Cleaning purposes Watering of grazing stock and animals Irrigation Heating and cooling purposes Public and private fire fighting

The listing of the above other uses for potable water is not meant to imply that potable water cannot be used for other purposes not listed. In some cases, other uses may require or would normally require additional treatment by the user for optimum results.

Intended Users Power and Water supplies potable water to the general population. Some users require water of a quality that is at variance to the specification supplied by Power and Water. Intended users do not include those individuals, organisations, manufacturers or industries requiring water for special processes or purposes. Potable water may not be suitable for use, or may require further treatment when used for such purposes including organic farming, commercial food production (e.g. brewing), pharmaceutical production, laboratory testing (i.e. preparation of standard samples), hemodialysis, etc. In such cases users may need to consider providing additional treatment, for example a point-of-use treatment device. Potable water is safe to drink for people in most stages of normal healthy life meaning: Infants over six months of age and children Teenagers and adults Elderly persons

Some individuals may be more vulnerable to contaminants in potable water than the general population. Those individuals that are significantly immunocompromised, such as those with cancer undergoing chemotherapy, persons that have undergone organ transplants, people with HIV/AIDS or other immune system disorders are vulnerable to infection. Elderly persons and infants whose health may be considered poor, or who may be on forms of medication that suppress the immune system can be particularly at risk of infection. Also the very young have immature immune systems which place them at increased risk. These people and their carers are advised to obtain specialist medical advice. Groups who are uncertain whether their use of water may require additional treatment may contact Power and Water for further advice.


B-88

Development of Process Flow Diagrams The HACCP team developed an overall primary process flow diagram representing the complete water supply process. This process flow diagram identifies the water supply process from catchment to customer point of supply and provides a broad overview of the process. A number of key areas were identified for which separate process flow diagrams were also prepared. Some key areas represent a sub-process of the primary water supply (production) process. These sub-process flow diagrams further expand on key steps within the primary process flow diagram. On these sub-process diagrams the team detailed both process control monitoring performed by on-line equipment and specific tests undertaken by the WTP’s operators (e.g. coagulant jar test). This activity assisted with identifying areas for process monitoring improvement. In addition, the sub-process flow diagrams detail operational monitoring performed by the WTP’s operators which is used to check that the processes and equipment that have been put in place to protect and enhance water quality are working properly. This does not include bacterialogical monitoring used for operational purposes (i.e. HPC). Other key areas for which process flow diagrams were prepared relate to significant hazardous events which arise during the routine course of operating the water supply system. Examples of significant hazardous events include backflow of polluted water into the potable water supply system and performance of repairs on existing mains. A set of process symbols as shown in Table 8 were used to construct the flow diagrams. Certain steps within a process flow diagram consist of a combination of two or more symbols indicating that more than one event or activity occurs at that step in the process. Table 9 lists the flow diagrams that were developed. Preparation of the process flow diagrams assisted with the full understanding of a process and where important product inspection points occur. All flow diagrams were verfified by the HACCP team as being a true and accurate representation of the Katherine water supply system and other important processes.


B-89

Symbol Description Symbol Description

Operation – occurs when there is an operation or activity. This may result in an intentional change or the use of a product. The product may be the finished product or another type of product specific to the process

Storage – occurs when a product is intentionally kept or held awaiting release.

Inspection – represents an inspection, test or measurement undertaken on a product

Transfer – occurs when a product is moved from one location to another.

Decision – A point at which a choice is made usually following an inspection

Sub-process – Another process which in itself consists of a number of separate steps

Delay – occurs when there is an inability to proceed to the next step because a previous step is incomplete

Product user – as previously described

Table 8: Process Flow Diagram Symbols and Descriptions


Diagram Code

Production Process/Step

Production Sub-process Step

Significant Operational WQ Hazardous Threat

KWS Water supply KWSH Harvesting KWSSO Storage (open) KWSSE Source extraction GWSMat Materials, products, coatings and equipment contact/permeation/leaching

KWST Transmission GWSNM New mains construction GWSEM Existing mains alterations, connections and repairs GWSBF Cross-connection and backflow GWSI Intrusion GWSMat Materials, products, coatings and equipment contact/permeation/leaching

KWSWT Water treatment KWSwtCF Coagulation and flocculation KWSwtC Clarification KWSwtA Aeration KWSwtFi Filtration KWSwtDf Disinfection KWSwtFl Fluoridation GWSWTDWTC Procurement and addition of DWTC GWSMat Materials, products, coatings and equipment contact/permeation/leaching

KWSSC Storage (closed) GWSMat Materials, products, coatings and equipment contact/permeation/leaching

KWSDt Distribution (i.e. delivery) GWSNM New mains construction GWSEM Existing mains alterations, connections and repairs GWSBf Cross-connection and backflow GWSI Intrusion GWSMat Materials, products, coatings and equipment contact/permeation/leaching

Notes: 1. Shading of diagram code cell indicates diagram included in HACCP Plan G – General K – Katherine WS – Water supply

Dt – Distribution SC – Storage (closed)





A – Aeration Bf - Backflow C – Clarification CF – Coagulation & Flocculation


EM – Existing Mains

Fi – Filtration Fl – Fluoridation I – Intrusion Mat – Materials NM – New Mains

Table 9: Process Flow Diagrams

B-90

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

B-91

Primary Process Flow Diagram KWS – Water Supply

CCP 1/1 & 1/2 CCP 2/1 –2/5 NCCP A-C

Catchment surface runoff to Katherine River Catchment inflow/infiltration to aquifer Donkey Camp pool (open storage reservoir) Tindal aquifer Donkey Camp transfer pumping station. COLTS monitoring DO and turbidity Extraction by submersible pumps at production bores RN 6983 and RN 7807 Turbidity < 250 NTU and/or DO ≥ 7mg/L? If “NO” DSS may require switch to groundwater supply DSS sub-process Transfer via rising main Transfer via rising main WTP sub-process Transfer of treated water to closed storages

Symbol Description Symbol Description Symbol Description Symbol Description Operation Decision Storage Sub-process Inspection Delay Transfer Product user

NO

YES

KWSWT


B-92

CCP 3/1 CCP 3/1 CCP 3/1

4.5 ML closed storage tank (supplies Katherine south). COLTS monitoring closed storage tank levels 9 ML closed storage tank (supplies Katherine south). COLTS monitoring closed storage tank levels 12 ML closed storage tank (supplies Katherine East & Tindal RAAF base). COLTS monitoring closed storage tank levels Sub-process for controlling closed storage tank levels by operation of delivery pumps Transfer via distribution/reticulation mains Customers in Katherine East and South supply zones Tindal booster pump station Transfer via rising main Interface with Tindal RAAF base



B-93

Disinfection by chlorination (by others) Transfer of treated water to closed storages 2 x 2.5 ML closed storage tanks (Tindal RAAF base). COLTS monitoring closed storage tank levels (by Power and Water) Sub-process for controlling closed storage tank levels by operation of Tindal booster pumping station Transfer of treated water via pipes



B-94

Key Area Sub-Process Flow Diagram KWSWT – Water Treatment

Note: All surface water passes through flash mixer and reactivator in both WTP operational modes

Donkey Camp transfer pumping station. COLTS monitoring turbidity and DO (note turbidity equipment suitability has resulted in use as initial warning mechanism only, rather than continuous information monitoring. DO equipment is currently not operating) Turbidity < 250 NTU and/or DO ≥ 7 mg/L? If “NO” DSS may require switch to groundwater supply DSS sub-process Extraction by submersible pumps at production bores RN 6983 and RN 7807 Turbidity ≥4 NTU? If “NO” operate in “filtration” mode. If “YES” operate in “flocculation” mode Transfer of groundwater water via rising main Transfer of raw surface water via rising main to treatment plant Aeration of groundwater


YES

YES

KWSwtA

NO

NO


B-95


Sub-process for: Operational monitoring:-

Daily water tests Coagulation process

control:- Jar tests Coagulation and flocculation of raw surface water. COLTS monitoring pH. Flash mixer removed from service during filtration mode operation Sub-process for: Clarification process

control:- Sludge volume blanket determination tests

Clarification. Reactivator removed from service during filtration mode operation Sub-process for: Filter performance

monitoring Filtration


KWSwt-CF

KWSwtC

KWSwt-CF

KWSwtC

RFS KWSwt-

CF KWSwtC

RFS KWSwt-

CF KWSwtC

KWSwtFi KWSwtFi


B-96

Disinfection and fluoridation sub-processes Blending in delivery pump well COLTS monitoring turbidity and pH and alarms to indicate failure Transfer of water to closed storage tanks Monitoring sub-process. Various samples taken and analysed for treatment verification purposes


KWSwtFl KWSwtDf


B-97

Key Area Sub-Process Flow Diagram KWSwtCF – Coagulation and Flocculation


If turbidity of surface water ≥ 4 NTU, then WTP operated in flocculation mode, otherwise WTP operated in filtration mode Transfer of surface water to flash mixer Sample surface water and flash mixer contents and perform jar test Flash mixer. Coagulants and polyelectrolyte (i.e coagulant aid) added. Soda ash added for pH adjustment for coagulation optimisation. COLTS monitoring pH Target range 6.2 ≤ pH ≤ 6.3 achieved? Check COLTS pH and turbidity measurements Adjust coagulant and polyelectrolyte dose rates? Clarification sub-process Set/adjust coagulant/soda ash and polyelectrolyte dose rates Delay allow WTP operation to stabilise Filtration sub-process


YES

YES

NO

KWSwtFi

NO KWSwtC


B-98


Transfer of groundwater from aerator Blending in delivery pump well. Disinfection and fluoridation sub-processes COLTS monitoring of turbidity via on-line meter and alarm to indicate failure Transfer of water to closed storage tanks


KWSwtDfKWSwtFl


B-99

Key Area Sub-Process Flow Diagram KWSwtC – Clarification


If turbidity of surface water ≥ 4 NTU, then WTP operated in flocculation mode, otherwise WTP operated in filtration mode Transfer of surface water to flash mixer Flash mixer. pH monitoring sub-process Reactivator. COLTS monitoring rake/ agitator operation and alarmed if operation fails Rake/agitator operating? If “NO” investigate and rectify Minimum twice daily sludge blanket volume determination test and visual inspection of sludge blanket depth Is inlet turbidity > 30 NTU? Delay Is sludge volume v & v test result 5/10? Transfer of water to filter Is sludge volume v & v test result 10/20? Optimise sludge volume in reactivator


YES NO

YES

NO

YES

NO

YES

NO


B-100

Key Area Sub-Process Flow Diagram KWSwtA – Aeration

Transfer of surface water Transfer of groundwater Filtration Aeration of groundwater to raise pH level Blending in delivery pump well. Disinfection and fluoridation sub-processes COLTS monitoring pH and alarm to indicate failure Target range 6.5 ≤ pH ≤ 8.5 achieved? Is pH < 6.5? Response sub-process. Check coagulant and coagulant aid dosing levels and review Response sub-process. Check soda ash dosing levels and review


YES

KWSwtFi

NO

KWSwtDf KWSwtFl

YES

NO


B-101

Key Area Sub-Process Flow Diagram KWSwtFi – Filtration

Transfer of surface water Transfer of groundwater from aerator Filtration of surface water in sand filter Blending in delivery pump well. Soda ash addition if required. Disinfection and fluoridation sub-processes Periodic process monitoring by operator COLTS monitoring of turbidity via on-line meter and alarm to indicate failure < 72 hours elapsed since last filter backwash Transfer of treated water to closed storage tanks < 1m headloss across filter? Turbidity ≤ 1.5 NTU (filtration mode) or ≤ 1 (flocculation mode)?


NO

YES

YES

YES

NO

NO

KWSwtDf KWSwtFl


B-102

Undertake filter backwash COLTS monitoring closed storage tank levels < 10 ML filter throughput in 24 hour period? 4.5 ML, 9 ML and 12 ML closed storage tanks Short circuiting of filter is not occurring? Daily water samples from WTP outlet and reticulation mains. Turbidity measurement Transfer via distribution and reticulation mains Turbidity ≤ 1 NTU? Turbidity ≥ 2.0 NTU? Response sub-process Shut down delivery well pumps Sample WTP outlet flow and determine turbidity using hand held meter


YES

NO

YES

NO

YES

NO

YES

NO


B-103

Is turbidity measured using hand held meter similar to concentration measured by on-line meter? WTP in flocculation mode? Sample WTP surface water inlet flow and flash mixer contents Perform jar test Calibrate on-line turbidity meter Adjust coagulation process Delay allow WTO operation to stabilise Check on-line turbidity meter readings


YES

NO

NO

YES


B-104

Key Area Sub-Process Flow Diagram KWSwtDf – Disinfection

Filtration Transfer of surface water from filter Transfer of groundwater from aerator Blending in delivery pump well. Dosing with disinfectant. Fluoridation sub-process COLTS monitoring (c/w alarm) of free chlorine residual. Sample WTP outlet flow and determine chlorine concentration using hand held analyser Correct dosing concentration of chlorine? i.e ≥ 1.0 mg/L and ≤ 1.5 mg/L Is dosing concentration of chlorine < 0.5 mg/L or > 1.5 mg/L? Shut down delivery well pumps Sample WTP outlet flow and determine chlorine concentration using hand held analyser Is concentration measured using hand held analyser similar to concentration measured by on-line analyser?


KWSwtFi

KWSwtFl

YES

NO

YES

NO

YES

NO


B-105

Calibrate on-line chlorine analyser Transfer of treated water to closed storage tanks Check chlorine dosing concentration (e.g. check dosing pump operation, settings) Rectify as necessary e.g. increase/decrease dosing pump settings Check on-line analyser readings Sub-process for controlling closed storage tank levels by operation of delivery pumps 4.5 ML, 9 ML and 12 ML closed storage tanks. COLTS monitoring closed storage tank levels Transfer via distribution and reticulation mains Daily water sample and measurement of chlorine concentration in reticulation system Is concentration of chlorine ≥ 0.2 mg/L and ≤ 0.5 mg/L?

Symbol Description Symbol Description Symbol Description Symbol Description

Operation Decision Storage Sub-process Inspection Delay Transfer Product user

NO

YES


B-106

Resample and determine chlorine concentration Is concentration of chlorine ≥ 0.2 mg/L and ≤ 0.5 mg/L Response and investigation sub-process


YES

NO


B-107

Key Area Sub-Process Flow Diagram KWSwtFl – Fluoridation

Transfer of surface water from filter Transfer of ground water from aerator Blending in delivery pump well. Dosing with fluoride (Hydrofluorosilicic acid). Disinfection sub-process COLTS monitoring fluoride concentration Correct dosing concentration of fluoride? i.e. 0.5 – 0.7 mg/L Is dosing concentration of fluoride > 1.5 mg/L? Shut down delivery well pumps Sample WTP outlet flow and determine fluoride concentration using hand held analyser Is concentration measured using hand held analyser similar to concentration measured by on-line analyser?



KWSwtDf

YES

NO

YES

NO

YES

NO


B-108

Calibrate on-line fluoride analyser Transfer of treated water to closed storage tanks Check fluoride dosing concentration (e.g. check dosing pump operation, settings. Check volumetric consumption) Rectify as necessary e.g. increase/decrease dosing pump settings Check on-line analyser readings Sub-process for controlling closed storage tank levels by operation of delivery pumps 4.5 ML, 9 ML and 12 ML closed storage tanks. COLTS monitoring closed storage tank levels Transfer via distribution and reticulation mains Daily water sample and measurement of fluoride concentration in reticulation system




B-109

Key Area Operational Hazard Process Flow Diagram GWSWTDWTC – Procurement and Addition of Drinking Water Treatment Chemicals

Approval process during tender process for DWTC for use within area of operation Assessment completed/contract issued? Manufacture DWTC Return DWTC for retesting or rework Inspect/test DWTC at point of manufacture Examine test results, okay? Transport DWTC to warehouse point Store DWTC to minimise contamination Transport DWTC to treatment site Compare delivery docket against order e.g for correct chemical type



YES

NO

PASS

FAIL


B-110

Transport DWTC back to supplier Reorder correct DWTC Ordered chemicals match delivery docket? Examine DWTC test certificate for acceptability Store products and materials to minimise contamination at treatment plant site DWTC used in water treatment processes Treated potable water transferred to closed storage tanks



NO

YES

FAIL

PASS


B-111

Key Area Sub-Process Flow Diagram KWSSC – Storages

Raw water treatment process undertaken Treated water conveyed to storage. Storage tanks may also be bypassed Water held in closed storage tanks. COLTS monitoring closed storage tank levels Tank levels at delivery pumps’ “stop” operating level? Tank levels at delivery pumps’ “start” operating level? Stop delivery pumps Start delivery pumps Water conveyed through distribution/reticulation mains to points of supply for users


YES

NO

NO

YES


B-112

Key Area Operational Hazard Process Flow Diagram GWSNM – New Mains Construction

Transport and unload products and materials at project site Store pipes, fittings, valves etc. on site to minimise contamination Inspect products and materials to identify non-approved products All products and materials approved? Quarantine non-approved products and materials Order approved products and materials Prepare trench ahead of pipe laying Inspect pipes, fittings, valves etc. internally before laying for possible sources of contamination. Check for use of bactericidal lubricant (RRJ only)


NO

YES


B-113

No contamination identified and correct lubricant used? Clean pipes, fittings, valves etc. as appropriate. Obtain and use correct lubricant. Lay and joint pipes. Use clean dedicated brushes to apply lubricant. Cap pipes at breaks, stoppages and at end of shift Flush/clean and hydrostatically test new pipeline Examine hydrostatic test results against construction specification requirements Disinfect pipeline, sample discharge, organise bacteriological test and flush pipeline Await bacteriological test results Examine test results. E.coli<1 and HPC <10? Connect new pipeline to existing main Water conveyed through distribution/reticulation mains to point of supply for users


FAIL

PASS

FAIL

PASS

NO

YES


B-114

Key Area Operational Hazard Process Flow Diagram GWSEM – Existing Mains Alterations, Connections and Repairs

Situation occurs such as a burst, leak, installation of new valve/hydrant, connection of completed new main/service connection. WIMS work order raised Procure products and materials; and inspect to identify non-approved products All products and materials approved? Quarantine non-approved products and materials Order approved products and materials Deliver and unload products and materials at project site Store pipes, fittings, valves etc. on site to minimise contamination Preliminary situation assessment: Can repair be undertaken under pressure? Isolate affected area/main/customers


YES

NO

YES

NO


B-115

Is repair above ground so no excavation is required? Prepare a plan to minimise risk of contamination Inspect pipes, fittings, valves etc. internally before laying for possible sources of contamination. Check for correct lubricant (RRJ only) Carry out excavation for repair No contamination/correct lubricant? Reassess situation: Can repair be undertaken under pressure? Remove contamination/obtain correct lubricant (RRJ only) Isolate affected area/main/customers if not already undertaken Swab or spray disinfect equipment, products, materials and area to be repaired Trench area heavily contaminated? Carry out repair. Use clean dedicated brushes to apply lubricant Disinfect trench


NO

NO

YES

YES

NO

YES

NO

YES


B-116

Drain main to be repaired Works to be left unattended? Cap pipes at breaks, stoppages and at end of shift Inspect pipes, fittings, valves etc. internally before laying for possible sources of contamination. Check for correct lubricant (RRJ only) No contamination/correct lubricant (RRJ only)? Remove contamination/obtain correct lubricant Swab or spray disinfect equipment, products, materials and area to be repaired Carry out repair. Use clean dedicated brushes to apply lubricant Recharge main, flush, sample discharge upstream of repair and determine free chlorine residual Water flows through main



YES

NO

NO

YES


B-117

Has surface water or trench water entered the main? Has mud or dirt entered the main? Slug chlorinate mains Is there a risk of faecal contamination? Achieve a C.t ≥ 150 Achieve a C. t ≥ 30 Continue flushing of main Sample discharge downstream of repair and determine free chlorine residual


YES

NO

YES

YES

NO

NO


B-118

Is downstream free chlorine residual ≥ upstream free chlorine residual and ≥ 0.2 mg/L? Is downstream free chlorine residual ≤ 0.5 mg/L? Complete required WIMS records


YES

YES

NO

NO


B-119

Key Area Operational Hazard Process Flow Diagram GWSBf – Backflow Potable water conveyed through

distribution/reticulation system to points of supply for users Event occurs that results in loss of pressure in reticulation system, pressure in plumbing system is greater than in the reticulation system Flow of water reverses due to back siphonage or back pressure Cross-connection to polluted water supply or other contaminants exists? Cross-connection is unprotected by BFD? BFD fails? Polluted water is conveyed through unprotected cross-connection into distribution/reticulation mains potentially to points of supply for users Contamination of potable water supply identified? Polluted water unable to enter potable water systems. Safe potable water conveyed through distribution/reticulation mains to points of supply for users Response to contamination


YES

NO

YES

YES

NO

NO

NO

YES


B-120

Key Area Operational Hazard Process Flow Diagram GWSI – Intrusion

Potable water conveyed through distribution/reticulation mains to points of supply for users Event occurs that results in low or negative pressure transient Flow of water from point of higher energy to lower energy Intrusion point(s) to polluted water supply or other contaminants exists? Polluted water is conveyed through intrusion point(s) into distribution/reticulation mains potentially to points of supply for users Polluted water unable to enter potable water systems. Safe potable water conveyed through distribution/reticulation mains to points of supply for users Contamination of potable water supply identified? Intrusion points detected? Response to actual or potential contamination Existing mains repair sub-process


YES

NO

YES

NO

YES

NO


B-121

Key Area Operational Hazard Process Flow Diagram Mat – Materials and Products Manufacture and Utilisation

Approval process for products and materials for use within area of operation Assessment completed/approval issued? Manufacture products and materials Return products and materials for retesting or rework Inspect/test products and materials at point of manufacture Examine test results, okay? Transport products and materials to warehouse point Store products and materials to minimise contamination Transport products and materials to construction project site Store products and materials to minimise contamination at construction site


FAIL

YES

NO

PASS


B-122

Products or materials used e.g. at WTP, at storage, in new mains construction or existing main alteration, connection or repair. Potential for leaching/permeation of contaminants Water conveyed e.g from treatment plant, to storage, through distribution/reticulation system to point of supply for users. Potential for permeation of contaminants



B-123

Hazard Identification Four general categories of hazard types exist: 1) physical (P), 2) chemical (C), 3) microbiological (M) and 4) radiological (R). Each hazardous event was examined and determined to result in one or more of these four hazard types. Risk Analysis Methodology The qualitative risk analysis model shown in Table 10 was used by the HACCP team to calculate the risk factor (i.e. score) for each identified hazard(s) arising from a hazardous event. The risk factor is defined as:

Risk Factor = Likelihood (L) x Severity of Consequences (S) A simple numerical rating (i.e. score between 1-5) was assigned to the different levels assigned to likelihood and severity of consequences. To perform the risk analysis the existing controls were determined and the risks analysed in terms of likelihood and severity of consequences in the context of those controls. The likelihood of the hazardous event occurring and the severity of the consequences were derived by consensus using the knowledge of the HACCP team, workshop participants, historical data and the ADWG. Table 11 provided guidance on determination of likelihood and severity of consequences.


B-124

Severity of Consequences

Risk Factor Matrix:

Insignificant (No impact / not

detectable) Rating: 1

Minor (Temporary minor

exceedence) Rating: 2

Moderate (Temporary minor non-compliance)

Rating: 3

Major (Licence non-compliance)

Rating: 4

Catastrophic (Potential loss of

licence) Rating: 5

Rare

(Every 100 years) Rating: 1

1 2 3 4 5

Unlikely

(Every 10 years) Rating: 2

2 4 6 8 10

Possible

(Yearly) Rating: 3

3 6 9 12 15

Likely

(Monthly) Rating: 4

4 8 12 16 20

Almost Certain

(Daily / weekly) Rating: 5

5 10 15 20 25

Like

lihoo

d

Table 10: Risk Factor Matrix


B-125

Severity Rating General Description Likelihood

Rating Probability/Frequency

1 Insignificant No impact Undetectable

1 Rare. 0.01 probability or 1 in 100 years.

2 Temporary minor exceedence Minor impact on small number of customers Customer complaints No reporting

2 Unlikely. 0.1 probability or 1 in 10 years.

3 Temporary minor non-compliance, not severe Minor impact on a larger number of customers Clear impact on a small number of customers

3 Moderate or uncommon. 1 probability or once per year.

4 Licence non-compliance/breach Major impact on large customer group Significant level of stakeholder concern

4 Likely. Several times per year (e.g. monthly)

5 Major licence non-compliance with potential loss of licence Major impact on large customer group and on community Public health jeopardised High litigation potential

5 Almost certain, regular (e.g daily or weekly)

Table 11: Severity and Likelihood Scales Risk Evaluation Risks with a risk factor equal to or greater than six were classified as significant risks to water quality and were assigned a higher priority for further investigation. Risks with a risk factor less than six were classified as risks that did not pose a significant risk to water quality. These hazards were assigned a lower priority for further investigation. The value of six is recommended in a guidance paper prepared for AwwaRF Project 2856 and has previously been used by other Australian water suppliers that have implemented HACCP systems using the above method of evaluating risks. Risks with risk factors less than six represent 40% of the risk factor matrix.


B-126

Critical Control Points and Non Critical Control Points The decision making methodology used to determine if a point, step or procedure was a CCP generally utilised the Codex decision tree shown in Figure 3.

Figure 3


B-127

Where a CCP was identified from the application of the decision tree, the step in the process was only considered a CCP if the safety of the water was compromised by the hazard. If at the step in the process the water has not reached a state where the water had become unsafe to drink (i.e. is detrimental to consumers’ health) but has become aesthetically unsatisfactory, then the step in the process was designated as a NCCP. The above was performed in the context that appropriate monitoring parameters relevant to the step could be assigned critical limits that were able to monitored and responded to quickly in order to return the water quality or process back to an acceptable state. If it was not possible to identify suitable monitoring parameters, then the step was not considered a CCP/NCCP. This may have been because appropriate monitoring may not be possible, or because appropriate monitoring exists but is not currently performed (e.g. because equipment is not currently installed). Instead the step was identified as being an item that would be monitored under a SP. Items monitored under SPs were assigned performance limits. In the event that appropriate monitoring is performed, it is possible to reconsider the step as a CCP/NCCP. SPs also lend themselves to treating hazardous events or threats (e.g. a backfow event) that can occur at more than one step in the process and the occurrence of which cannot be predicted by conventional monitoring. The decision tree was applied to all risks, even those where the risk factor was determined to be less than six. In such cases, if the decision tree outcome indicated that the step in the process was a CCP/NCCP, then this triggered the need to conduct further investigation of the risk analysis to ensure its certainty. However, at this stage the process step associated with the risk was not identified as a CCP/NCCP. This does not mean that the process step might not be a CCP/NCCP and subsequent investigation may lead to a review of the process step’s status as a CCP/NCCP.


Risk Assessment Schedule

CCP Decision Tree Diagram

Code Hazard Type

Potentially Hazardous Event


Potential Control Measures L S Risk

Score 1 2 3 4

CCP or

NCCP Action

Schedule

KWS M Pathogen

Bathers swimming/fishermen in Donkey Camp pool resulting in faecal discharges

Signage to deter swimming/fishing

Penalty (i.e. fine) regime to discourage swimming/fishing, if possible

4 2 8 Y N Y Y No Yes. Investigate penalty options within operating legislation if not already addressed

Improved signage

Review signage e.g.

location and message i.e. warn about fine if not already stated

Encourage launching of boats/swimming from dedicated boat ramp/area downstream of Donkey Camp pool (may not be feasible as insufficient areas for boating/swimming)

Discourage launching of boats from river bank by appropriate fencing and placing obstacles at current launch sites/access tracks, if possible

Yes. Review ability to prevent boating in Donkey Camp pool

KWS M Pathogen

Contamination of Donkey Camp pool associated with sewage handling spill from Katherine Gorge tourist cruise boats

No direct control measures employed over specific activity by Power and Water at this time

Implement MOU with Parks and Wildlife/tourist cruise boat operators/DIPE influencing management of facilities

3 2 6 Y N Y Y No

Yes. Obtain further information to determine/verify risk. Implement MOU with Parks and Wildlife/tourist cruise boat operators/DIPE containing emergency response protocol to enact DSS to consider switching to alternative groundwater supply. Investigate ability to influence management of current facilities through MOU/regulator e.g. operating procedures, operator training etc.

? Design of handling

facilities to minimise spillage e.g. bunding

B-128

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

? Adherence to handling

procedures including response to spillage to mitigate effects

? Trained operators KWS

M Pathogen

Contamination of Donkey Camp pool associated with sewage overflow from Katherine Gorge tourist park sewage pumping station (operated by Parks and Wildlife)


Implement MOU with Parks and Wildlife/DIPE influencing management of facilities

Y N Y Y No

Yes. Obtain further information to determine/verify risk. Implement MOU with Parks and Wildlife/DIPE containing emergency response protocol to enact DSS to consider switching to alternative groundwater supply. Investigate ability to influence management of current facilities through MOU/regulator e.g. operating procedures, operator training etc.

Mechanical failure of pumps ? Standby pumpset 3 2 6 Pump blockage ? Standby pumpset 4 2 8 Extended electricity outage ? Standby generating

set 3 2 6

Flooding leading to inundation of sewage wet well

? Design of wet well to incorporate sealed access covers or bunding to prevent flood inundation

3 2 6

? Trained operators

? Scheduled

maintenance of sewage pump station assets

KWS M Pathogen

Contamination of Donkey Camp pool by local discharges from septic tanks/drains

Catchment management via land use development controls

4 2 8 Y N Y Y No

Yes. Obtain further information to determine/verify risk. Ensure representation in appropriate forums. Consider monitoring of faecal coliforms in raw water

B-129

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

KWS M Pathogen

Contamination of Donkey Camp pool from grazing animals depositing faeces


Vegetation buffer zones/strips along river bank to deter entry. Off river watering points

5 2 10 N N No

Yes. Obtain further information to determine risk

KWS M Pathogen

Contamination of Donkey Camp pool from birds , native and feral animals depositing faeces


Feral animal control program

5 2 10 N N No

Yes. Obtain further information to determine/verify risk. Consider faecal sterol analysis of water quality to determine dominant faecal inputs

KWS M

Pathogen P

Taste/odour

Contamination of Donkey Camp pool associated with dead animal(s) within or nearby open storage

Scheduled weekly inspection of Donkey Camp pool intake area

1 3 3 YY NN YY YN No (M) <6 (P)

Yes. Obtain further information to determine/verify risk. Taste and odour effects unable to be corrected by WTP

Maintain supply from existing reserves in closed storages

Switch to alternative groundwater supply while contamination exists in surface water source

KWS M

Pathogen P, C

Contaminants

Contamination of Donkey Camp pool as a result of deliberate sabotage e.g. addition of chemical substance


Appropriate signage to deter entry

1 5 5 YY N N YY YN No (M)

<6(P, C)

Yes. Obtain further information to determine/verify risk. Ensure signage in place. Note surveillance cameras or thermal/motion detectors on this site not practical. Consider option for limited fencing

? Routine security patrols


B-130

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

KWS

M Pathogen

P Turbidity,

colour C

Contaminants

First substantial rainfall event at commencement of wet season transporting sediments and organic matter to open storage at Donkey Camp pool

COLTS monitoring turbidity & DO of raw water and data monitored via SCADA system linked to DSS (note turbidity equipment suitability has resulted in use as initial warning mechanism only, rather than continuous information monitoring. DO equipment is currently not operating)

Integration of operations with hydrographic flood warning network to predict first flush

3 2 6 Y N Y N CCP1/1

Yes. Obtain further information to determine/verify risk. Analyse monitoring data to determine when event is likely to occur and develop/document DSS for operator. Note baffles across pool (to increase residence time) on this site not practical. Upgrade turbidity equipment and repair DO equipment

Change mode of operation of WTP



KWS

M Pathogen

P Low DO,

dead aquatic species

First substantial rainfall event at commencement of wet season transporting sediments and organic matter to open storage at Donkey Camp pool causing low DO resulting in fish kill

COLTS monitoring turbidity & DO of raw water and data monitored via SCADA system linked to DSS (note turbidity equipment suitability has resulted in use as initial warning mechanism only, rather than continuous information monitoring. DO equipment is currently not operating)

Integration of operations with hydrographic flood warning network to predict first flush

3 2 6 Y N Y N CCP1/2

Yes. Obtain further information to determine/verify risk. Implement MOU with Parks and Wildlife containing emergency response protocol to enact DSS to consider switching to alternative groundwater supply. Investigate ability to influence management of current facilities through MOU/regulator e.g. operating procedures, operator training etc.


B-131

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule


Scheduled weekly

inspection of Donkey Camp pool intake area

KWS

M Algae

P Taste, colour,

odour C

Toxins

Contamination caused by algal bloom (possibly toxic)

Routine nutrient monitoring program

1 3 3 Y N Y N <6

Yes. Obtain further information to determine/verify risk


KWS M

Pathogen C

Contaminants

Contamination caused by discharge of wastewater from potential aquaculture industry


1 1 1 Y N Y Y No

Yes. Obtain further information to determine/verify risk. Ensure representation on appropriate forums

KWS C Contaminants

Chemical contamination of Katherine River/Donkey Camp pool due to mining activity in catchment (e.g. cyanide)


2 2 4 Y N Y N <6

Yes. Obtain further information to determine/verify risk. Ensure representation on appropriate forums

KWS C Contaminants

Anoxic conditions in Donkey Camp pool due to stagnation/stratification leading to presence of manganese and iron

? Monitoring: COLTS monitoring DO of raw water and data monitored via SCADA system (note DO equipment currently not operating). Yearly chemical monitoring program

Limit upstream extraction to maintain environmental flows

1 2 2 Y N Y Y No

Engage with regulator to ensure environmental flows considered. Ensure DO equipment is fully operational

B-132

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

KWS C Contaminants

Chemical contamination of Donkey Camp pool caused by spray drift of pesticides associated with agricultural activity (e.g. mango growing)

? Monitoring: Yearly pesticide monitoring program

Authorised list of pesticides. Encourage best practice usage of pesticides by land holders

1 5 5 Y N Y N <6

Yes. Obtain further information to determine/verify risk e.g. pesticides used, quantities, effects of pesticides etc. Engage with DIPE to improve regulation of pesticides e.g. approved list, monitor usage, sales etc.


KWS C Contaminants

Chemical contamination of raw water sources caused by pesticide usage associated with vegetation management activity by Power and Water

? Monitoring: Yearly pesticide monitoring program

Authorised list of pesticides. Encourage best practice usage of pesticides 1 5 5 Y N Y N <6

Yes. Establish list of pesticides and communicate

Standard operating

procedure for use of pesticides

Yes. Develop SOP

Trained Water Operations personnel and contractors Yes


KWS C Contaminants

Chemical contamination of Donkey Camp pool/Katherine River by accidental fuel spillage

Water Management Zone provides statutory catchment management protection

Stricter enforcement and increased geographical coverage. Audit program to prevent unauthorised activities

Y N Y N <6

Yes. Review geographical extent of Water Management Zone

B-133

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

1) Boating activity Appropriate signage to deter boating

Penalty (i.e. fine) regime to discourage boating, if possible

3 1 3

Yes. Review signage e.g. location and message i.e. warn about fine if not already stated. Investigate penalty options within operating legislation. Obtain further information to determine/verify risk e.g. types of activities and numbers of persons using Donkey Camp pool


Discourage launching of boats from river bank by appropriate fencing and placing obstacles at current launch sites/access tracks, if possible

Encourage launching of boats/swimming from dedicated boat ramp/area downstream of Donkey Camp pool (may not be feasible as insufficient areas for boating/swimming)

Use electric motors on boats

2) Private bore extraction using diesel driven pumps

3 1 3

B-134

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

3) Vehicle accident on crossing

1 3 3

Yes. Obtain further information to determine/verify risk e.g. actual locations of crossing, type of traffic. Implement MOU with NTFRS/Police containing emergency response protocol to enact DSS to consider switching to alternative groundwater supply. Investigate ability to influence management of current facilities through MOU/regulator e.g. operating procedures, operator training etc.


KWS Contamination of groundwater source at point of extraction not as a result of deliberate security breach:

M Pathogen

P Sediments

C Contaminants

1) Ingress of surface flood waters into bore head

Elevated site location well above flood levels

1 5 5 Y Y

N N

Y Y

Y N

No (M) <6(P, C)


M Pathogen

2) Entry of bird, reptile, vermin, amphibian etc

Sealed bore head Vermin control program 1 2 2 Y N Y Y No

Routine inspection and maintenance program

C Contaminants

3) Spillage of fuel used for backup generator

Bunded fuel storage area

2 2 4 Y N Y N <6


Contamination of groundwater source (Tindal aquifer):

Yes. Obtain information to determine/verify risk e.g. presence of rubbish dumps, waste management practices

B-135

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

M

Pathogen C

Contaminants

1) Hydraulic connection between rubbish dumps and landfills

Integrated waste management (separation of rubbish types e.g. separation of solvents)

1 5 5 Y Y

N N

Y Y YN No (M)

<6 (C)


M Pathogen

P Turbidity Colour

C Contaminants

2) Ingress of surface flood waters into abandoned/private bore heads

Routine inspection and capping of open bores

5 1 5 Y Y

N N

Y Y YN No (M)

<6 (P, C)

Yes. Investigate role regulator can play to minimise risk

KWSWT M Pathogen

Treated water quality unable to be confidently determined due to inability to control/monitor treatment process:

3 3 9 Y Y CCP2/1

P C

1) Failure of critical monitoring instrument(s)

Routine inspection, servicing and calibration of instruments

Duplication of critical instruments

2) Major SCADA equipment failure (e.g. PLC, server)

Retention of replacement spares on-site

3) Interruption to electrical power supply

SCADA system has a 60 minute UPS

KWSwtCF Contamination stemming from:

M

Pathogen P

Turbidity

1) Underdosing of aluminium sulphate ( i.e. coagulant) due to incorrect operator setting of dose rate

Twice daily jar test performed during wet season to determine coagulant chemical dose concentration

COLTS monitoring turbidity downstream of reactivator and data monitored via SCADA system

1 3 3 Y Y

Y Y <6 (M)

<6 (P)

M Pathogen

P Turbidity

2) Underdosing of aluminium sulphate (i.e. coagulant) due to equipment malfunction/failure

Coagulation Control System (CCS) equipment installed, however, not currently being used to for process monitoring purposes and to full potential. CCS would detect over dosing/under dosing

2 3 6 YY YY

CCP2/2 (M)

NCCPA (P)

C Contaminants

3) Overdosing of aluminium sulphate (i.e. coagulant) due to incorrect operator setting of dose rate

Polyelectrolyte (coagulant aid) usage reduces amount of coagulant required

1 2 2 Y N Y N <6 (C)

B-136

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

C Contaminants

4) Overdosing of aluminium sulphate (i.e. coagulant) due to equipment malfunction/failure


2 2 4 Y N Y N < 6 (C)

Daily water testing to determine aluminium concentration in water supply

Daily water testing for Al not considered necessary because of reduced coagulant usage

Corrective action: Automatic plant shutdown

Corrective Action: Switch to alternative groundwater supply

KWSwtA P Low pH

Failure of aerator:

1) Structural collapse Routine inspection and maintenance program

1 1 1 Y Y <6 Yes. Organise inspection and condition report

COLTS monitoring pH of blended surface water and groundwater including alarm

Use WIMS to schedule periodic inspection

Daily water testing at

WTP outlet to determine pH

Corrective Action: Dose

with sodium carbonate to increase pH

KWSwtA M Pathogen

Contamination occurring in aerator:

1) Bird faeces Roof over aerator to limit entry of bird faeces, alternative strategies to scare birds from landing on aerator

5 1 5 Y N Y Y No

2) Micro-organism regrowth Roof over aerator to limit UV light exposure 5 1 5 Y N Y Y No

KWSwtC M Pathogen

Mechanical failure of agitator and or rake in reactivator causing ineffective treatment


2 3 6 Y Y CCP2/3

(M) Yes. Investigate/review strategies to prevent failure of agitator and rake

P

Turbidity

Monitoring: Operation of agitator and rake automatically alarmed

Y Y NCCPB

(P)

B-137

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

Monitoring: COLTS monitoring turbidity downstream of reactivator and data monitored via SCADA system

Yes. Review turbidity instrumentation requirements

Corrective Action:

Switch to alternative groundwater supply

KWSwtFi M

Pathogen P

Turbidity

Contamination as a consequence of filter backwash water being returned to plant

Pipework valved to use backwash water for site irrigation

Update process instrumentation diagram to reflect current operation 1 3 3 Y Y <6

Consider decommissioning

pipework/pumps to prevent return of backwash water

KWSwtFi

M Pathogen

(some) P

Turbidity C ?

Sand filter break through Monitoring: COLTS monitoring turbidity and data monitored via SCADA system

Construct larger capacity/more efficient filters

3 4 12 Y Y CCP2/4

(M) NCCPC

(P)

Review operation of current filters. Investigate costs/benefits of upgraded filters

Monitoring: Filter

headloss, throughput and backwash frequency

Monitoring: Periodic

visual examination of sludge accumulation

Operate WTP in flocculation mode continuously

Review operation of WTP

on an annual basis

Routine filter backwashing

KWSwtDf Contamination as a result of:

M Pathogen

1) Underdosing of chlorine (i.e. disinfectant)

COLTS monitoring free chlorine residual on outlet of WTP including alarm and data monitored via SCADA system

COLTS monitoring free chlorine residual on outlet of closed storages including alarm and data monitored via SCADA system

2 4 8 Y Y CCP2/5 (M)

Design of new chlorination facility commenced

Daily water testing to determine free chlorine residual concentration at WTP outlet and in reticulation system

COLTS monitoring free chlorine residual within reticulation system and data monitored via SCADA system

Identify suitable location of free chlorine residual analysers on storage outlets and in reticulation system

B-138

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

C Excess Cl2

Excess DBPs

2) Overdosing of chlorine (i.e. disinfectant)

Routine inspection and maintenance program (e.g. calibration of meters)

2 2 4 Y N N No (C)

P

Taste and odour

Corrective Active: Spot dosing of closed storage tanks

2 2 4 Y N Y N <6 (P)

M

Pathogen C

Excess Cl2 DBPs

Rainfall event causing fluctuations in surface water turbidity (≈ >10 - <30 NTU) and surface water being extracted (WTP in filtration mode of operation) in order to prepare for coagulation, however, unusual undetected microbiological contamination present indicated by unusually high disinfectant demand

Daily water testing to determine free chlorine residual concentration at WTP outlet and in reticulation system

Documented DSS/procedure outlining WTP operation based upon Donkey Camp pool conditions

3 2

3 2 YY YN

N

CCP2/5 (M)

No (C)

COLTS monitoring free chlorine residual on outlet of closed storages including alarm and data monitored via SCADA system

P

Taste and odour

(Excess Cl2)

COLTS monitoring free chlorine residual within reticulation system including alarm and data monitored via SCADA system

2 2 4 Y N Y N <6

KWSwtDf M Pathogen

Contamination as a result of reuse of empty chlorine cylinder

COLTS monitoring free chlorine residual on outlet of WTP including alarm and data monitored via SCADA system

Automatic changeover of cylinders

2 2 4 Y Y <6

Design of new chlorination facility commenced

One spare 920 kg

cylinder and smaller 70 kg cylinders kept on site

Magnetic tags to identify empty cylinders

Corrective Active: Spot

dosing of closed storage tanks

B-139

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

KWSwtFl C Contaminants

Contamination as a result of overdosing of fluoride

COLTS monitoring fluoride dosing level on outlet of WTP including alarm and data monitored by SCADA system

2 2 4 Y N Y N <6

Yes. Obtain information to determine/verify risk

Dosing pump size

Yes. Review pump size to

determine if pump can overdose

Daily water test to

determine concentration of fluoride in reticulation system

Daily reading of fluoride

meter to determine volume used

KWS P Hardness

Excessive hardness of finished product (blending of surface and groundwater occurs in delivery well)

Daily water tests to determine hardness and pH of finished water

1 1 Y Y <6

Daily WTP log sheets to monitor blending ratio

KWSwtCF KWSwtC P

Accidental contamination of open storages in coagulation or clarification process (e.g. flash mixer, reactivator) from foreign inanimate objects e.g. dirt, mud, timber, glass, rubbish

Review railing design to prevent/hinder accidental contamination

3 1 3 Y N Y Y No

Review platform design e.g.

rubber sheet over gridmesh to prevent mud, dirt entry

KWSwtCF KWSwtC P

Contamination of open storages in coagulation or clarification process (e.g. flash mixer, reactivator) from foreign inanimate objects e.g. dirt, mud, timber, glass, rubbish from a deliberate security breach

Secured fenced site with locked access gate

1 2 2 Y N Y Y No

Thermal/motion sensor on stairs/platform

Review physical access to external stairs/platform

Routine inspection and

maintenance program Review railing design to prevent/hinder deliberate contamination

B-140

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

Standard operating

procedure for isolation of storages

Routine security patrols

KWSwtCF KWSwtC

M Pathogen

C Contaminants

P Taste and

odour Colour

Contamination of open storages in coagulation or clarification process (e.g. flash mixer, reactivator) as a result of deliberate sabotage e.g. addition of chemical substance, persons defecating in storage


11 15 1 5 YY YN

Y N

<6 (M) <6 (C, P)


Thermal/motion sensor on stairs/platform

Review physical access to external stairs/platform


maintenance program Review railing design to prevent/hinder deliberate contamination

Standard operating

procedure for isolation of storages


KWSSC M Pathogen

Contamination of closed storages not associated with a deliberate security breach

Rooves on all storages COLTS monitoring free chlorine residual of treated water on outlet of closed storage tanks and data monitored via SCADA system

2 5 10 Y Y SP(HS) a

Roof ventilation design to ensure drainage runoff effectively diverted to stormwater and not blown or splashed into stored water

Daily water test of free chlorine residual at storage tank outlets

Secured fenced site with

locked access gates Surveillance cameras or thermal/motion detectors on critical sites

Yes. Review condition of

perimeter fencing at all sites

Bird, reptile, vermin, amphibian etc. proofing of roof structure e.g. security cages over ventilators, secure flashing/insertion foam, sealed overflow pipes

Vermin control program

Yes. Review all points of entry including screens/flap valves on storage overflows

B-141

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule


maintenance program

Yes. Documented program

with schedule and records reporting protocol

Standard operating

procedure for cleaning of storages

KWSSC M

Microbial regrowth

Contamination as a result of microbiological regrowth

1 5 5 Y Y <6


1) Long storage residence time causing low free chlorine residual

Maintenance of disinfection residual in storage

COLTS monitoring free chlorine residual of treated water on outlet of closed storage tanks and data monitored via SCADA system

2) Short circuiting causing ineffective mixing

Design of inlet/outlet to promote mixing

3) Caused by excessive UV light entry

Roof design/ventilation to minimise UV light entry.

KWSSC C Excess DBP

Increased disinfection by-product formation e.g. due to increased hydraulic residence times, increased temperatures

Storage management

1 3 3 Y N Y N <6

KWSSC P

Contamination of closed storages from foreign inanimate objects e.g. dirt, mud, timber, glass, rubbish from a deliberate security breach

Rooves on all storages.

1 2 2 Y N Y N <6


Roof/ventilation design to ensure drainage runoff effectively diverted to stormwater and not blown or splashed into stored water

KWSSC

M Pathogen

C Contaminants

Contamination of closed storages as a result of deliberate sabotage e.g. addition of chemical substance, persons defecating in storage


Surveillance cameras or thermal/motion detectors on critical sites. Appropriate signage to deter entry 1 5 5 Y N Y N <6 (C)

B-142

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

Locked access hatches. Access hatches with alarms Locked cage over

external access ladder

Security cages over ventilators


Yes. Documented program with schedule and records reporting protocol

Maintenance of disinfection residual in storage

COLTS monitoring free chlorine residual of treated water on outlet of closed storage tanks and data monitored via SCADA system

1 5 5 Y Y <6 (M)

Standard operating procedure for isolation of storages


KWSSC M

Microbial regrowth

Contamination of closed storages from sediment transport

Routine inspection and maintenance program (tank cleaning program)

1 5 5 Y N Y N <6 (M)

P Sediments Turbidity

Standard operating procedure for cleaning of storages

1 3 3 Y Y <6 (P)

GWSBf KWSSC M

Pathogen Backflow event causing contamination:

Maintenance of disinfection residual in distribution and reticulation mains

Register of high risk customers interfaced with FIS

Y Y SP(HS)

c CCP 3/1

Control point for maintaining positive pressure is at storages

Maintain distribution pressure at or above 15 m

Jumper valves in ferrule taps (note not formally accepted as a BPD)

1) BPD not initially installed when required 2 5 10

2) BPD removed from service and not replaced

No specific control measures currently in place to prevent this from occurring

Cross-connection control and backflow prevention policy

3 5 15 Yes. Document cross-connection control and backflow prevention policy

3) Incorrect BPD installed when required 1 5 5 Customer Information

Handout 7

B-143

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

4) Failure of installed BPD No specific control measures currently in place to prevent this from occurring

3 5 15

5) Unintentional creation of unprotected cross-connection

3 5 15

6) Deliberate creation of unprotected cross-connection

1 5 5

Installation of containment BPDs, (e.g. testable/non testable device, spring loaded NRVs or approved NRVs) on new permanent service connections DN 20-50 where appropriate (refer Std Drgs W 1-1-01 to W1-1-04)

Yes. Review DN 20-50 property service connection drawings (refer Std Drgs W 1-1-01 to W101-04) to ensure clear division of responsibility for provision of containment BPD by building owner

Installation of containment BPDs (e.g. testable/non testable device, spring loaded NRVs or approved NRVs) on new permanent service connections DN 80 and above where appropriate (refer Std Drg W 1-1-17)

Traceable process for all building development work where new or altered service connections are constructed: 1) Documented hazard identification and control plan by qualified person 2) Certification by building owner/installer(s) that individual, zone and containment devices actually installed 3) Field auditing to verify installation of BPDs

Yes. Develop and implement traceable process

Installation of containment BPDs (e.g testable/non testable device, spring loaded NRVs or approved NRVs) on existing permanent service connections where appropriate

Yes. Retrospective compliance program requiring installation of containment BPDs (e.g. testable/non testable device, spring loaded NRVs or approved NRVs) on existing permanent service connections where appropriate

GWSBf P

Turbidity Sediments

Backflow event causing contamination Y Y SP(A) d

B-144

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule




3 2 6

3) Incorrect BPD installed when required 1 2 2

4) Failure of installed BPD


3 2 6


3 2 6


1 2 2

GWSBf C Contaminants

Backflow event causing contamination. Y Y SP(HS)

c




Compulsory annual certification of testable BPDs as required by AS/NZS 3500.1.2

3 5 15

Yes. Develop and implement register of testable BPDs to enable annual certification of testable BPDs as required by AS/NZS 3500.1.2

3) Incorrect BPD installed when required 1 5 5

4) Failure of installed BPD


3 5 15


3 5 15


1 5 5

B-145

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

Installation of domestic meters with integral BPDs for protection against low hazards

Yes. Develop and implement a rolling changeover program requiring installation of domestic meters with integral BPDs for protection against low hazards

Minimise likelihood of unprotected cross-connections within plumbing systems

Yes. Develop and implement education and awareness program for building owners/customers

Minimise likelihood of direct temporary cross-connections to transmission/reticulation systems

Yes. Review scope of metered filling point program to ensure appropriate coverage in major and minor centres

1) Through the use of metered filling points

Install overhead filling point to current construction standard

2) Scheduled inspection of obvious points e.g air valves on rising mains

3) Above ground fire hydrant undergrounding program

Authorised direct temporary cross-connections to reticulation systems protected by appropriate BPD e.g. new mains construction:- NRV on pipework connecting new and existing mains (refer Std Drg W1-2-07)

Yes. Identify possible authorised direct temporary cross-connections (e.g pools filled from fire hydrants, filling of new mains) and review procedures etc. Review adequacy of W1-2-07 to determine what type of BPD required.

Disinfection procedure followed when hydrant flushing performed

Yes.

B-146

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

KWSSC GWSNM GWSEM GWSMat

M Microbial growth

Contamination as a result of non approved products, materials or coatings being used without provision of acceptable form of potable water contact approval

Approval process for strategic products/materials used in contact with potable water including reliance upon WSAA Product Appraisal Process

Documented policy on managing acceptance/rejection of non-approved products when identified

2 3 6 Y Y SP(HS) e

P

Taste, odour C

Contaminants

Approval applicant required to submit test certificate demonstrating conformance to AS/NZS 4020 or product/material certification encompassing conformance to AS/NZS 4020

Documented policy on acceptance of test certificates when not to current version of AS/NZS 4020

33 23 6 9 YY N

N Y Y

N N

SP(A) f (P)

SP(HS) e (C)

Documented policy on acceptance of test certificates to alternative standards when conformance to AS/NZS 4020 not initially available (e.g. for products/materials manufactured overseas)

Project specifications for major works involving repainting/resealing of reservoirs with appropriate hold point to enable verification of potable water contact certification of coatings/sealants etc. by Superintendent

Yes. Develop and implement specification for repainting etc.

Work supervisors coordinating maintenance and repairs works responsible for verifying coating materials have potable water contact certification

Maintenance and repair coating specifications referencing APAS approved coating products with potable water contact certification

Yes. Develop and implement maintenance and repair coating specifications

B-147

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

Water and Sewage Infrastructure Products Manual (published every 2 years) listing approved products/materials

Yes. Update Products Manual on a more regular basis and consider alternative delivery approaches (e.g. web based)

APAS List of Approved Products (published every year) delivered via intranet

Yes. Ensure APAS List of Approved Products updated every 12 months on intranet

Education and awareness program for APAS List of Approved Products

Yes. Develop and implement education and awareness program

Private developer/capital works process: - Mandatory requirement for suppliers (i.e. designers, project managers, work supervisors, constructors) to retain copy of Products Manual

Yes. Introduce accreditation requirements for suppliers

Education and awareness program for Products Manual

Yes. Develop and implement education and awareness program

Auditing of Project Management Plans required for construction of private developer and capital works which identify sources of products/materials

Auditing of repair and maintenance works performed by Water Operations including period contractors to identify use of non approved products/materials/coatings

Yes. Develop and implement scheduled audit program to identify use of non-approved products/materials in repair and maintenance works

Project supervision by developer’s work supervisor and auditing by PW to identify use of non approved products/materials in private developer works

Yes. Develop and implement scheduled audit program to identify use of non-approved products/materials in private developer works

B-148

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

Project supervision by Superintendent’s work supervisor and auditing by PW to identify use of non approved products/materials in capital works

Yes. Develop and implement scheduled audit program to identify use of non-approved products/materials/coatings in capital works

Single supplier contract for supply of repairs and maintenance spares

Yes. Develop and implement periodic audit program at supplier’s warehouse to identify supply of non-approved products and materials


M Microbial growth

Contamination as a result of approved products, materials or coatings being used: Error in test results

Testing for potable water contact performed at accredited laboratory (e.g. NATA accredited)

1 5 5 Y Y <6

P Taste, odour

C Contaminants

1 4 4 Y N Y N <6

M Microbial growth

Contamination as a result of approved products, materials or coatings being used: Falsification or

misrepresentation of test results

Applicant required to submit copy of accredited laboratory test certificate demonstrating conformance (e.g. to AS/NZS 4020). APAS approved coatings listed in APAS List of Approved Products (issued annually)

1 5 5 Y Y <6

P

Taste, odour C

Contaminants

1 4 4 Y N Y N <6


M Microbial growth

Contamination as a result of approved products, materials or coatings being used without provision of acceptable form of potable water contact approval

Trained Water Standards personnel and WSAA appraisors

Checklist completed by project officer before approval certificate issued 1 5 5 Y Y <6

B-149

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

P

Taste, odour C

Contaminants

(i.e. potable water contact approval not obtained by product approval officer)

1 4 4 Y N Y N <6


P Taste, odour

C Contaminants

Contamination caused by materials/products as a result of breakdown in manufacturing process

Approval process for strategic products/materials used in contact with potable water including reliance upon WSAA Product Appraisal Process

1 3 3 Y N Y N <6

Manufacturer to have:

Third party certified quality system e.g ISO 9001 or meeting requirements of a quality system required by product certification scheme at point of manufacture

Organised type testing to potable water contact standard (e.g. to AS/NZS 4020) and submitted copy of accredited laboratory test certificate demonstrating conformance

Product/material certification thus encompassing ongoing conformance testing to potable water contact standard (e.g. AS/NZS 4020) at stipulated intervals/change of materials. Alternatively ISO 9001 certification with ITP identifying retesting to potable water contact standard at stipulated intervals/change of materials

Yes. Develop and implement procedure to be followed in the event of product recall by manufacturer

B-150

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

GWSWT-DWTC

C Contaminants

Contamination caused by drinking water treatment chemicals (DWTC) as a result of breakdown in manufacturing/supply process

Approval process for drinking water treatment chemicals to establish conformance to technical specification (e.g. AWWA standards)

Manufacturer to have: 1) Third party certified quality system e.g. ISO 9001 at point of manufacture

Yes. Review technical specifications, quality policy, compliance verification process etc.

Composition of chemicals does not meet technical specification and dispatched for use

Test certificate for each consignment delivered to confirm conformance of DWTC to technical specification

2) Production testing to confirm conformance of DWTC to technical specification 1 3 3 Y N N No

Yes. Investigate and review adherence to process. Develop and implement appropriate procedure including record storage

GWSWT-DWTC

M Pathogen

P Turbidity,

colour C

Contaminants

Contamination caused by drinking water treatment chemicals (DWTC) as a result of breakdown in supply process:

1) Incorrect chemicals delivered to WTP and used in water treatment

Inspection of received DWTC before acceptance of delivery

Documented procedure for acceptance of chemicals at time of delivery

2 4 8 Y N N No

2) Mix up leading to DWTC being used for incorrect application

Designated chemical storage areas, tanks etc.

Appropriate labelling of chemical storage areas/tanks etc.

1 3 3 Y N N No

Appropriate labelling of

hoppers, chutes, pipework, chemical packaging etc. to avoid confusion

3) Contamination of DWTC during transportation/handling (e.g. dirt/mud, chemical spillage or animal faecal matter)

Packaging for DWTC where practical

2 1 2 Y N Y Y No

Transportation in closed

containers/tanks where appropriate

Adherence to transportation guidelines/requirements stipulated by manufacturer

Trained transport personnel

B-151

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

GWSNM GWSEM GWSMat

M Pathogen

P Turbidity,

colour C

Contaminants

Contamination of product or material during transportation/handling (e.g. dirt/mud, chemical spillage or animal faecal matter)

Product packaging where practical

3 1 3 Y N N No

External transportation and exposure to UV light mitigates microbiological/chemical contamination

Adherence to transportation guidelines/requirements stipulated by manufacturer

Trained transport personnel

Inspection of received products and materials before installation

GWSNM GWSEM GWSMat

M Pathogen

P Turbidity,

colour C

Contaminants

Contamination of product or material during storage (e.g. dirt/mud, chemical spillage or animal faecal matter)

External storage and exposure to UV light mitigates microbiological/chemical contamination

4 1 4 Y N N No

Product packaging where practical

Adherence to product and materials storage guidelines/requirements in construction specification, standard operating procedures etc. (e.g. pipes strung)

Trained Water Operations personnel and contractors/constructors

B-152

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

GWSNM M (refer below)

Microbiological contamination caused by foreign inanimate objects (e.g. dirt, mud, timber supporting micro-organismsl), animals (e.g. rodents), polluted trench water, sewage during laying of new mains

Dewatering of trenches

Not all works involving new mains currently required to have bacteriological testing performed

P

Sediments Turbidity,

colour

Contamination caused by foreign inanimate objects (e.g. dirt, mud, timber, plastic) during laying of new mains

Capping of pipework at stoppages, end of shift etc. to prevent entry of contaminants

4 1 4 Y N N No

Note: Water quality testing would need to address physical characteristics to identify that levels are or will become unacceptable

Regular visual

inspections of laid pipework to ensure minimum contamination

Initial flushing of new mains followed by disinfection by chlorination of news mains

Swabbing of new mains

M Pathogen

Requirement for sampling and bacteriological testing of water in new mains before connection to existing works (private developer works only)

2 4 8 Y Y SP(HS) g

M Pathogen

Requirement for sampling and bacteriological testing of water in new mains before connection to existing works (capital works)

3 4 12 Y Y SP(HS) g

Trained

contractors/constructors Specialist disinfection contractors or disinfection by Water Operations personnel

B-153

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

GWSEM M Pathogen

Microbiological contamination caused by foreign inanimate objects (e.g. dirt, mud, timber supporting micro-organismsl), animals (e.g. rodents), polluted trench water, sewage during repair, alterations or connection of existing mains

Dewatering of trenches Disinfection of trenches where severe contamination

3 4 12 Y Y

SP(HS) h

P Sediments Turbidity,

colour Taste and

odour (from Cl2)

Contamination caused by foreign inanimate objects (e.g. dirt, mud, timber, plastic) during repair, alterations or connection to existing mains

Capping of pipework at stoppages, end of shift etc. to prevent entry of contaminants

2 2 4 Y N Y N <6

Note: Adherence to flushing procedure normally prevents level of physical contamination being or becoming unacceptable

C Excess Cl2

Excessive free chlorine residual following spot dosing

Regular visual inspections of laid pipework to ensure minimum contamination

2 2 4 Y N Y N <6

Standard operating procedure requiring swabbing of pipes/fittings/equipment with disinfectant solution

Auditing of adherence to standard operating procedures

Isolation of adjacent reticulation system during shutdown and repair

Individual isolation of customer service connections

Standard operating procedure requiring flushing after recharging to remove sources of contamination

SOP to include minimum flushing time, requirement to achieve minimum flushing velocity for pipe size, semi-objective turbidity/colour assessment (e.g. white bucket test)

Yes. Review procedure to ensure best practice

Spot chlorination of mains where severe contamination

Trained Water Operations personnel and contractors

B-154

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

Dedicated equipment used only for water supply work

Standard operating procedure requiring where possible repairs to be completed under pressure

Standard operating procedure and permit system for connecting to below ground hydrants

GWSEM C Contaminants

Contamination caused by exposure to chemicals (e.g. oil, petrol etc. from runoff caused by pipe burst near road or contaminated ground) during repair, alterations or connection to existing mains

1 4 4 Y N Y N <6

KWSDt C Contaminants

Contamination caused by permeation of chemicals through plastic pipes (e.g organics, petrol etc.)

Improved pipe selection requirement

1) Temporary accident causing spillage

2 2 4 Y N Y N <6

2) Undetected leakage from storage on private property

Reticulation water mains constructed on public land minimising proximity to sources of contamination

1 4 4 Y N Y N <6

KWSDt M Pathogen

Contamination caused (to consumer) by polluted water in hydrant outlet when accessing below ground hydrant

Standard operating procedure and permit system for connecting to below ground hydrants (i.e. disinfection of hydrant bowl)

4 1 4 Y Y

<6

Yes. Develop and implement procedure

P

Sediments Turbidity,

colour

4 1 4 Y Y

<6

KWSDt Contamination caused by:

M Pathogens

P Colour, taste and odour, sloughed biofilms

1) Biofilms and microbial regrowth on internal pipe surfaces

Maintenance of disinfection residual in reticulation system

Effective cross-connection control and backflow prevention program 2

2 3 3

6 6

Y Y

Y N

Y

N

SP(HS) j SP(A) b

Yes. Assess prevalence of biofilms

B-155

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

Appropriate design

requiring minimisation of dead ends in reticulation system

Nutrient removal via

coagulation, clarification and filtration

Prevention of microbial

intrusion preventing seeding of biofilms

Standard operating procedure requiring swabbing of pipes/fittings/equipment with disinfectant solution preventing seeding of biofilms

M

Pathogens P

Sediments, colour

2) Suspension/resuspension of sediments (i.e. organic and inorganic) transported/disturbed throughout system (e.g. by change in seasonal usage, flushing/maintenance)

Transmission, distribution and reticulation system flushing/cleaning program

25 22 4 10 YY NN YY NN

<6(M) SP(A) b

(P)

M Iron/sulphur

bacteria C

Contaminants P

Colour, odour

3) Other deposits (e.g. iron/manganese sludge/tubercles) on internal pipe surfaces (e.g. disturbed by change in seasonal usage, flushing/maintenance, water hammer)

Standard operating procedure for mains flushing

Alternative cleaning techniques to remove deposits/sludges 1

1 4

1 2 2

1 2

10

Y Y Y

N N N

N Y Y

N N

No (M) No (C) SP(A) b

(P)

C

Contaminants e.g. Cu

P Colour

e.g. blue water

4) Corrosion products leaching from approved products and materials used in infrastructure

Approval process for strategic products/materials used in contact with potable water including reliance upon WSAA Product Appraisal Process (eliminates products that support biofilm formation and or produce excessive corrosion products)

23 2 2

4 6

Y Y

N N

Y Y NN

<6 (C) SP(A) b

(P)

B-156

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Code Hazard Type




Score 1 2 3 4

CCP or

NCCP Action

Schedule

P Milky appearance of water in distribution system caused by air entrainment (e.g. associated with mains break)

Standard operating procedure for mains flushing after repair

3 2 6 Y N Y N SP(A) b

(P)

GWSI

M Pathogen

C Contaminants

P Sediments

Contamination caused by negative or low pressure transient resulting in intrusion of foreign materials (e.g. through submerged air valves, submerged faulty fire hydrants, faulty pipe seals, submerged faulty mains etc.)

Minimum 15 m supply pressure Design requirement for 10 m minimum residual head under fire fighting conditions

Water supply leakage detection program

2 2

4 3

8 6 YY YN

Y N

SP(HS) I (M)

SSP(HS) I

(P,C)

Routine inspection and maintenance program to detect/repair leaking below ground fire hydrants/valves

Modelling of systems to determine vulnerability to transients

Contingency plan for operating distribution system when town flooded to maintain positive pressure

Design guidelines requiring substantial physical separation of sewers from water reticulation mains, where possible

Above ground air valve design

Maintenance of disinfection residual in reticulation system

KWSDt P Temperature

Ambient temperature of (cold) water unpleasant for bathing and drinking

5 1 5 N N <6

No. Temperature is impractical to control as largely influenced by ambient air temperature

Notes: 1. Shading of diagram code cell indicates diagram included in HACCP Plan.

B-157

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

CCP, NCCP and SP Summary Information Schedule

Main Related CCP NCCP

SP No Diagram Code

Headworks/ Distribution

Works Production

Process Production

Sub-process

Significant Operational

WQ Hazardous Threat

Contamination/Hazard Comment

KWS CCP 1/1

1/2 KWSE Source extraction –surface water Rapid variations in raw water

quality Surface water unable to be treated effectively. Switch to groundwater supply

KWST

SP(HS) c Cross-connection and backflow

Cross-connections to polluted water sources containing microbiological and chemical hazards. Pathogens expected to be eliminated by disinfection process

SP(A) d

GWSBf


Cross-connections to polluted water sources containing physical hazards

SP(HS) e Materials/products: – utilisation

Use of unapproved materials and products supporting the formation of biofilms and growth of micro-organisms, leaching of chemical contaminants etc.

SP(A) f

GWSMat

Materials/products: – utilisation

Use of unapproved materials and products resulting in physical contaminants etc.

SP(HS)

I GWSI

Transmission

Intrusion

Intrusion of microbiological, physical and chemical hazards via orifices caused by transitionary pressure events. Pathogens expected to be eliminated by disinfection process

CCP 2/1 KWSWT Failure of monitoring equipment and alarms

Inability to control/monitor treatment process and determine water quality including safety

SP(HS) e Materials/products: – utilisation

Use of unapproved materials and products supporting the formation of biofilms and growth of micro-organismsl, leaching of chemical contaminants etc.

SP(A) f

GWSMat Treatment



CCP 2/2 KWSwtCF Sub-process is an effective means of reduction of specific and indicator organisms. Excessive turbidity shielding micro-organismsl from subsequent disinfection

SP(HS) j (j refer below)

Presence of sediments, deposits and or biofims causing microbiological hazards in distribution system

Sub-process is an effective means of mitigating threat

NCCP A

Headworks

Treatment Coagulation and flocculation

Excessive turbidity adversely affecting aesthetic properties in finished product

B-158

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


SP No Diagram Code


Works Production

Process Production

Sub-process


WQ Hazardous Threat


CCP 2/3 KWSwtC Sub-process is an effective means of reduction of specific and indicator organisms. Excessive turbidity shielding micro-organismsl from subsequent disinfection

SP(HS) j (j refer below)



NCCP B

Treatment Clarification


CCP 2/4 KWSwtFi

Sub-process is an effective means of reduction of specific and indicator organisms. Excessive turbidity shielding micro-organismsl from subsequent disinfection

SP(HS)

j (j refer below)



NCCP C

Treatment Filtration


CCP 2/5 KWSwtDf Sub-process breakthrough with associated pathogen contamination

SP(HS) j (j refer below) Treatment Disinfection



SP(HS) a KWSSC Vermin/bird entry

Exposure to microbiological hazards not associated with deliberate contamination e.g. vermin. Use of unapproved materials and products supporting the formation of biofilms and growth of micro-organismsl, leaching of chemical contaminants etc. Control of storage tank levels is also important in preventing backflow and intrusion

CCP 3/1 c GWSBf Cross-connection and backflow Positive pressure mitigating backflow

SP(HS) SP(A) e GWSMat

Distribution works Storage (closed)



B-159

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


SP No Diagram Code


Works Production

Process Production

Sub-process


WQ Hazardous Threat


CCP 3/1 I GWSI Intrusion Positive pressure mitgating intrusion

SP(HS) j KWSSC (j refer below)

Presence of sediments, deposits and or biofims causing microbiological hazards

Mitigated by regular cleaning of closed storages

f GWSMat Materials/products: – utilisation

Use of unapproved materials and products resulting in physical contaminants etc. SP(A)

d GWSBf Cross-connection and backflow Positive pressure mitigating backflow

SP(A) b KWSDt Delivery/distribution Presence of sediments, deposits and or biofims causing dirty water complaints

Disturbance of sediments/deposits by various causes leading to physical degradation

SP(HS) c Cross-connections to polluted water sources containing microbiological and chemical hazards

SP(A) d

GWSBf Delivery/distribution Cross-connection and backflow Cross-connections to polluted water sources

containing physical hazards

SP(HS) e Use of unapproved materials and products supporting the formation of biofilms and growth of micro-organismsl, leaching of chemical contaminants etc.

SP(A) f

GWSMat Delivery/distribution Materials/products: – utilisation


SP(HS) g GWSNM New mains: – construction Exposure to microbiological hazards

e GWSMat Materials/products: – utilisation

Use of unapproved materials and products supporting the formation of biofilms and growth of micro-organismsl, leaching of chemical contaminants etc. SP(HS)

c GWSBf Cross-connection and backflow

New mains are a potential source of polluted water and can be cross-connected to existing mains during normal construction activities



SP(A) d GWSBf

Delivery/distribution


New mains are a potential source of polluted water and can be cross-connected to existing mains during normal construction activities

SP(HS) h

GWSEM Delivery/distribution Existing mains: – alterations, connections, repairs Exposure to microbiological hazards

B-160

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


SP No Diagram Code


Works Production

Process Production

Sub-process


WQ Hazardous Threat


e GWSMat Materials/products: – utilisation


c GWSBf Cross-connection and backflow

Repairs not performed under pressure and pipe breaks resulting in loss of pressure provide the opportunity for backsiphonage



SP(A) d GWSBf Cross-connection and

backflow Repairs not performed under pressure and pipe breaks resulting in loss of pressure provide the opportunity for backsiphonage

SP(SH) I

GWSI Delivery/distribution Intrusion Intrusion of microbiological, physical and chemical hazards via orifices caused by transitionary pressure events

KWSwtCF Coagulation and flocculation

KWSwtC Clarification KWSwtFi Filtration KWSwtDf Disinfection

GWSBf Cross-connection and backflow

GWSEM Existing mains: – alterations, connections, repairs

SP(HS)

j

GWSI

Preservation

Intrusion

Listed production sub-processes and prevention of identified significant operational threats are primary controls for reducing microbial regrowth and biofilms

Notes: 1. Shading of diagram code cell indicates diagram included in HACCP Plan. 2. ‘Related’ means the related threat is controlled at the nominated step(s) or production process/sub-process(es) (indicated by shading) and or the related threat is an activity/procedure that can occur at more than one point in the water supply process.

B-161

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

CCP and NCCP Detailed Information Schedule

Critical Limits No Step

Diagram Code

Potentially Hazardous

Event Target Action Monitoring Reference Corrective Action Records Action

Schedule

KWS

CCP 1/1 Surface Water Extraction KWSSE


COLTS monitoring turbidity & DO of raw surface water and data monitored via SCADA system linked to DSS (note turbidity equipment suitability has resulted in use as initial warning mechanism only, rather than continuous information monitoring. DO equipment is not currently operating)

Rostered duty officer(s) to take appropriate corrective action including: 1) Verify surface water conditions 2) Verify turbidity and DO instrument readings 3) Shut down surface water extraction 4) Maintain supply from existing reserves in closed storage tanks 5) If necessary replenish reserves in closed storage tanks with groundwater

SCADA system reports not currently produced

Review turbidity instrumentation requirements at WTP and Donkey Camp Ensure DO equipment returned to operational condition Ensure SCADA system reports produced and retained Investigate DO limits

KWS

CCP ½ Surface Water Extraction

KWSSE


Surface water turbidity < 250 NTU Surface water DO 85% - 120%

Surface water turbidity ≥ 250 NTU Surface water DO < 85%

Scheduled weekly inspection of Donkey Camp pool intake area Turbidity of surface water measured daily at WTP inlet

SOP 106 – Turbidity Analysis

Turbidity of surface water at WTP inlet recorded on hard copy Daily Water Test sheet

Develop excursion report to record excursions, incidents and corrective actions

0 minutes loss of SCADA monitoring due to monitoring equipment failure

60 minutes loss of SCADA monitoring due to monitoring equipment failure

Monitoring equipment failure will trigger low level alarm – refer below for SCADA system and EDAC system operation

Rostered duty officer(s) to take appropriate corrective action including: 1) Investigating cause of problem 2) Scheduling repairs/replacement as required

B-162

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

0 minutes loss of SCADA monitoring due to power outage

Within 60 minutes loss of SCADA monitoring due to power outage

Refer below for SCADA system and EDAC system operation

Rostered duty officer(s) to take appropriate corrective action including: 1) Contacting System Control to establish if Katherine Gorge electrical feeder out of service and expected duration of outage 2) Investigating other possible causes

CCP 2/1 Treatment KWSWT


WTP is manned: 1) Monday to Friday, excluding public holidays during normal working hours (7:00 am – 4:00 pm) 2) Sundays for a period of 4 hours during periods when plant requires chemical dosing (i.e. wet season)

Rostered duty officer(s) responsible for ensuring: 1) SCADA system continues operating


EDAC auto dialler messaging system is operational when plant is not manned. Voice messages categorising alarm type and criticality are automatically transmitted to mobile phone of rostered duty officer(s) who investigates

2) Backup generator starts

2) Major SCADA equipment failure (e.g. PLC, server)

0 minutes loss of SCADA monitoring due to loss of mains electricity


SCADA system has a 60 minute UPS


0 test start failure of UPS


?? UPS is tested every xxxx to ensure availability in event of mains electricity failure. Testing and planned maintenance of UPS is scheduled via WIMS

Rostered duty officer(s) is responsible for actioning unplanned maintenance of UPS

WIMS used to record UPS test pass or fail and maintenance performed

Yes. Verify WIMS is being used to schedule testing/planned maintenance

B-163

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

0 minutes loss of SCADA monitoring due to equipment failure


SCADA system is not visually monitored 24 hours a day

?? SCADA system records all

alarms and results ?? SCADA system

reports produced ??

CCP 2/2 NCCP A Coagulation and Flocculation

KWSwtCF

Ineffective treatment sub-process

Flocculation mode (filtrate): Turbidity ≤ 1

NTU

Flocculation mode (filtrate):

Turbidity > 1

NTU

Turbidity of treated water leaving the reactivator is not currently monitored continuously on-line. Critical limit is based upon turbidity of treated water passed through filter which is monitored continuously on-line

SCADA system reports

Review turbidity instrumentation requirements at WTP and install equipment upstream of flash mixer and downstream of reactivator. Review chosen critical limits

Turbidity of surface water measured daily at WTP inlet and outlet


Turbidity of surface water at WTP inlet and outlet recorded on hard copy Daily Water Test sheet

TBA TBA Coagulation Control System (CCS) equipment installed, however, not currently being used to for process monitoring purposes and to full potential

No SCADA system reports currently produced

Investigate potential for CCS to control coagulant dosing process (e.g. continuous on-line monitoring with trigger alarm indicating over/under dosing of coagulant) and whether CCS outputs are appropriate critical limit parameters

B-164

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

Dosed water 6.2 ≤ pH ≤-

6.3

Dosed water pH < 5.9 or >

6.5

COLTS monitoring pH of water in flash mixer and data monitored via SCADA system linked to DSS

Rostered duty officer(s) adjust dosing rates of aluminium sulphate and/or sodium carbonate as appropriate

SCADA system reports??

Investigate pH limits for: 1) Optimum coagulation and flocculation and determine staged/escalated response process for exceedances

High pH causing ineffective disinfection

Dosed water pH > 8.0

Rostered duty officer(s) to take appropriate corrective action including: 1) WTP shutdown and problem investigation 2) Changeover to groundwater supply

Twice daily sample taken from flash mixer and pH measured then jar test performed to determine dose rates. Second set of samples taken twice daily from flash mixer after dosing rates set and pH determined

SOP 123 – Setting Chemical Dosing for Coagulation

Jar test results recorded on hard copy forms

Review jar test results form

pH measured of all test samples during jar test

SOP 101 – Daily pH Testing

CCP 2/3 NCCP B Clarification

KWSwtC

Ineffective treatment sub-process

Flocculation mode (filtrate): Turbidity ≤ 1

NTU


Turbidity > 1 NTU

Turbidity of treated water leaving the reactivator is not currently monitored continuously on-line. Critical limit is based upon turbidity of treated water passed through filter which is monitored continuously on-line


Review turbidity instrumentation requirements at WTP and install equipment upstream of flash mixer and downstream of reactivator. Review critical limits and base upon clarified water turbidity

B-165

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

Twice daily sludge volume determination test and visual examination of sludge volume depth

SOP 124 – Sludge Volume Determination in Reactivator

Rostered duty officer(s) to make adjustments to agitator speed and/or sludge valve opening time to optimise sludge volume in reactivator

??

CCP 2/4 NCCP C Filtration

KWSwtFi

Sand filter breakthrough

Flocculation mode: Turbidity ≤ 1

NTU

Filtration mode:

Turbidity ≤ 1.5 NTU

Flocculation mode:

Turbidity > 1

NTU

Filtration mode:

Turbidity > 1.5 NTU

COLTS monitoring turbidity and data monitored by SCADA system and linked to DSS Turbidity measured daily at outlet of WTP (and at other points in distribution system)


Rostered duty officer(s) to instigate filter backwashing

SCADA system reports Turbidity at WTP outlet recorded on hard copy Daily Water Test Sheet

Review operation of current filters. Investigate costs/benefits of upgraded filters. Investigate abandoning operation of WTP in filtration mode

Time elapsed since last backwash < 72 hours

Time elapsed since last filter backwash ≥ 72 hours

?? ?? Investigate installing duplicate on-line turbidity meters

Filter

headloss < 1 m

Filter headloss ≥ 1 m

?? Filter headloss recorded on hard copy Daily Water Log sheet

Filter

throughput (24 hours) < 10 ML

Filter throughput (24 hours) ≥ 10 ML

?? Filter throughput recorded on hard copy Daily Water Log sheet

No short

circuiting observed

Short circuiting observed

?? ??

CCP 2/5 Disinfection KWSwtDf

?? Rostered duty officer(s) responsible for:

Corrective actions are recorded in ?????

Develop documentation addressing disinfection procedure at WTP

B-166

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

1.0–1.5 mg/L

Free chlorine residual

< 1.0 or > 1.5 mg/L

Free chlorine residual

COLTS monitoring free chlorine residual, alarmed and data monitored by SCADA system and linked to DSS. C.t not monitored by operators and therefore not used as critical limit

Free chlorine residual set points are recorded in ????

1) Investigate cause of alarm 2) Ensuring SCADA system is operating correctly


3) Initiating shutdown of plant and changeover to storage tanks (after 60 minutes) or groundwater if raw surface water quality unacceptable 4) Adjusting/reviewing set points or dosing levels

0.2-0.5 mg/L Free chlorine

residual in reticulation

system

< 0.2 mg/L Free chlorine

residual in reticulation

system

Routine daily testing of free chlorine residual at WTP outlet and in reticulation system by field measurement

SOP – 103 Daily Free Chlorine Analysis

Rostered duty officer responsible for adjusting/reviewing set points or dosing levels

Free chlorine residual at WTP outlet recorded on hard copy Daily Water Test sheet

CCP 3/1 Proposed Storage (closed)

KWSSC

Microbiological contamination of closed storage not associated with a deliberate security breach

TBA Free chlorine residual in mg/L


COLTS monitoring free chlorine residual at this location not currently installed

Yes. Investigate installation of COLTS monitoring free chlorine residual on outlet of closed storages and data monitored by SCADA

0 minutes Loss of SCADA monitoring due to loss of mains electricity

0 minutes Loss of SCADA monitoring due to loss of mains electricity

Target and action limits to be determined. Review daily water test schedule and modify to include measurement of free chlorine residual at storage tank outlets

B-167

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule



CCP 3/1 Storage (Closed)/ Backflow

KWSSC GWSBf

Backflow event causing microbiological, physical or chemical contamination. This can be mitigated through maintenance of a minimum system pressure

? level in storage tanks

≥15 m

minimum network

head

? level

in storage tanks

< 20 m network

head

COLTS monitoring tank levels and data monitored via SCADA system linked to DSS system


Model water supply system to confirm maintenance of adequate supply pressure. Undertake pressure recording to confirm model results

CCP 3/1 Storage (Closed)/ Intrusion

KWSSC GWSI

Contamination caused by negative or low pressure transient resulting in intrusion of foreign materials (e.g. through submerged air valves, submerged faulty fire hydrants, faulty pipe seals, submerged faulty mains etc.). This can mitigated through maintenance of a minimum system pressure

As above As above Customer Call Centre directs customer reports of low pressure to Water Operations who respond as and when required. ????Test undertaken to establish static network pressure.

??Evidence of complaint logged in database ?? Network test pressure record

Yes. Ensure monitoring is being performed and corrective actions can be recorded

Notes: 1. Shading of diagram code cell indicates diagram included in HACCP Plan.

B-168

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

SP Detailed Information Schedule

Performance Limits No Step

Diagram Code



Schedule

SP(HS) a Storage closed

KWSSC


0 entry points for birds, vermin etc. detected

1 entry point for birds, vermin etc. detected

Water Operations personnel required to undertake inspections during site visits. The frequency of these inspections is as specified in the Water Supply Scheduled Operation and Maintenance Program and are as follows: 1) Routine daily walk over/visual inspection 2) Periodic detailed inspection every year initiated by WIMS as part of SOP to clean tanks

SOP 115-117 Standard operating procedure for cleaning of 4.5 ML, 9 ML and 12 ML storage tanks

Any breaches are notified to the Water Coordinator Arrange temporary/permanent repair of entry point Consultation may occur with Water Quality personnel on appropriate corrective action including:

Water Operation personnel use personal diaries to record daily inspections Discovery of entry points or actual breaches recorded in daily treatment plant log along with corrective actions. Maintenance order recorded in WIMS along. ????Storage Tank Inspection Form

Yes. SOP 115-117 schedules cleaning of storages every two years whereas current practice is yearly-resolve inconsistency. Verify WIMS being used to schedule tank cleaning

1) Isolation/bypassing of storage

2) Increase disinfection dosing

3) Spot dosing of affected storage

4) Scour contaminated water

5) Scour contaminated

water, clean/disinfect storage

Water Use

Restrictions Policy

6) Implement water restrictions

B-169

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

SP(HS) b Distribution KWSDt

Presence of sediments, deposits and or biofilms causing dirty water complaints

0 complaints

1 complaint

Customer Call Centre directs reports of dirty water complaints to Water Operations who respond to all complaints

Water Operations respond accordingly: 1) Investigate possible cause 2) Flush mains if problem not associated with on-site plumbing

Complaint details recorded on FIS sheet by Water Operations (not currently implemented in Katherine) WIMS works order generated if Water Operations attend

Yes. Current process (across Water Services) could be reviewed to identify areas of improvement e.g. categorisation of complaints, review of complaints. Katherine to implement use of FIS sheets to record water quality complaints

> 15 complaints

in 24 hr period

Following personnel to be contacted 1) MWF 2) SET 3) WQS1

Formal review of customer

complaints as part of HACCP Plan verification activities

?? Yes. Need to develop review process

SP(HS) c SP(A) d Backflow

GWSBf

Backflow event causing microbiological, physical or chemical contamination

100% of all containment devices installed on new services, where required

1 containment BPD not installed on a new service, where required

Building owner/installer required to submit hazard identification and control plan, as well as certify all devices installed. Field audit of 100% sites requiring containment protection

Copy of hazard identification and control plan retained by Water Engineering on job file

BPD required to be installed before meter provided

Hazard identification and control plan Installation certification advice Field audit installation confirmation

Yes. Traceable process to implemented to enable auditing

Copy of installation certification advice retained by Water Engineering on job file

B-170

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

Copy of field audit installation confirmation retained by Water Engineering on job file



100%

of devices installed in plumbing systems to protect high hazards

1

device not installed in plumbing systems to protect high hazards

Building owner/installer required to submit hazard identification and control plan, as well as certify all devices installed. Field audit program of sites with high hazards applied by plumbing regulator


Regulator issues building owner compliance notice to install BPDs within specified time frame Water supply shut down to protect adjacent customers

Hazard identification and control plan

Yes. MOU required with DIPE addressing auditing of plumbing works


Installation certification advice

Copy of plumbing regulator’s compliance report(s) retained by Water Engineering on file

Plumbing regulator’s compliance report(s)



100%

of devices installed in plumbing systems to protect medium and low hazards

1

device not installed in plumbing systems to protect medium and low hazards

Building owner/installer required to submit hazard identification and control plan, as well as certify devices installed. Field audit program of sites with medium and low hazards applied by plumbing regulator


Regulator issues building owner compliance notice to install BPDs within specified time frame

Hazard identification and control plan

Yes. MOU required with DIPE addressing auditing of plumbing works

B-171

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule


Installation certification advice

Copy of plumbing regulator’s compliance report(s) retained by Water Engineering on file

Plumbing regulator’s compliance report(s)



0

testable containment BPD not tested

1

testable containment BPD not tested

Customer (i.e. building owner) required to undertake testing of containment BPD every 12 months All incidents of customers failing to submit annual test certificate to be actioned by Water Operations Compliance report on completed tests/failures produced by Customer Services and reviewed monthly by HACCP Co-ordination Group/Water Operations

1) Copy of annual request letter retained by Customer Services 2) Annual test certificate retained by Customer Services

Customer to clear/repair/retest or replace BPD upon failure within specified timeframes Water Operations to respond if customer fails to submit annual test certificate or complete corrective action within specified time frames

1) Annual letter requesting test 2) Annual test certificate submitted to Customer Services

Yes. Policy to be introduced requiring periodic testing of testable BPDs

0 failures of testable

containment BPD

1 failure of testable

containment BPD

3) Compliance report on completed tests/failures produced by Customer Services and reviewed monthly by HACCP Co-ordination Group/Water Operations

B-172

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule



0

unautho-rised cross-connection w/o BPD

0

unautho-rised cross-connection w/o BPD

Routine observations performed by field personnel from Water Engineering and Water Operations

Unauthorised cross-connection reports retained by Water Operations on file

Water Operations to disconnect unauthorised cross-connections

Unauthorised cross-connection report

Yes. Traceable process to be implemented to enable auditing

SP(HS) e SP(A) f Materials/ Products Utilisation


0 situations involving

non approved products

1 situation involving


Project supervision by developer’s work supervisor and auditing by PW to identify use of non approved products/materials in private developer works Project supervision by Superintendent’s work supervisor and auditing by PW to identify use of non approved products/materials in capital works

Non compliance report including photographic evidence retained by Water Standards on product approval file

Private developer works: Developer to receive written advice from Land Development of non compliance within x days

Non compliance report including photographic evidence

Yes. Formalisation of processes required

Copy of non compliance letter retained on project file

Non compliance standard letter

Capital works: Contractor to receive written advice from Land Development of non compliance within x days

New works to be isolated and not connected or commissioned by Water Operations until situation resolved

B-173

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

Works acceptance clearance report retained on product approval file by Water Standards and copy issued to/retained by Land Development on project file

Water Standards to investigate, resolve and then prepare works acceptance clearance report

Works acceptance clearance report

SP(HS) g New Mains-Construct-ion

GWSNM

Microbiological contamination caused by foreign inanimate objects (e.g. dirt, mud, timber supporting micro-organismsl), animals (e.g. rodents), polluted trench water during laying of new mains

0 E.coli (CFU/100 mL) in any sample

1 E.coli (CFU/100 mL) in any sample

Constructor/contractor undertakes sampling and provides sample to laboratory for bacteriological testing Independent laboratory (not NATA accredited) undertakes testing and produces test report

Laboratory test report(s) retained by Water Engineering on project files

Constructor/contractor responsible for works undertakes corrective action including: 1) Further flushing or swabbing of mains 2) Re-disinfect new mains

Laboratory test report

Yes. Review current process e.g: 1) To ensure sampling undertaken only by independent laboratory personnel

Disinfection procedures –Hydraulic Master Specification and Land Development Customer Information Handout No 5

2) Submission of laboratory test results (e.g. only copies of laboratory results accepted not translation of results)

Approved products: Water and Sewage Infrastructure Products Manual, Connection Code standard construction drawings etc.

3) Clarify water quality acceptance criteria e.g. to include physical parameters

B-174

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

Develop process checklist to ensure new works not connected before successful disinfection performed

Yes. Review construction specification (Water and Sewage Infrastructure Construction Specification) to incorporate bacteriological testing

0-10 Heterotro-phic plate count (CFU/ mL) (i.e. 0 – 1000 CFU/100 mL)

>10 Heterotro-phic plate count (CFU/ mL) (i.e. 1000 CFU/100 mL)

Water Engineering compiles quarterly report on bacteriological testing performed and submits to HACCP Co-ordination Group

Bacteriological testing compliance report retained by Water Engineering/ HACCP Co-ordination Group on file

Bacteriological testing compliance report

Yes. Review current process to ensure Power and Water advised of failed tests and corrective actions

Yes. Implement procedure to produce bacteriological testing compliance report

B-175

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

SP(HS) h Existing Mains Repairs etc.

GWSEM

Microbiological contamination caused by foreign inanimate objects (e.g. dirt, mud, timber supporting micro-organismsl), animals (e.g. rodents), polluted trench water during repair, alterations or connection of existing mains

0.2-0.5 mg/L Free chlorine residual Downstream residual ≥ upstream residual

< 0.2 mg/L Free chlorine residual

Chlorine residual is measured using hand held analyser

WS-SP-W02 – Repairs to Rising Mains and Reticulation Services

Power and Water personnel/contractor responsible for works undertakes corrective action including: 1) Repeat disinfection

WIMS records Yes. Review WS-SP-W02: 1) Procedure

requires free chlorine residual to be ≥ 0.2 mg/L

> 0.5 mg/L Free chlorine residual

2) Further flushing 2) Procedure does not address corrective action if free chlorine residual > 0.5 mg/L

SP(HS) I Distribution network-Intrusion

GWSI

Contamination caused by negative or low pressure transient resulting in intrusion of foreign materials (e.g. through submerged air valves, submerged fire hydrants, faulty seals, submerged mains, damaged mains etc.)

Customer Call Centre directs reports of network leaks to Water Operations who respond as and when required Incident bacteriological monitoring ??Routine inspection and maintenance program to detect leaking below ground fire hydrants

Power and Water personnel/contractor undertakes corrective action including: 1) Repair/replacement of hydrants

Repair orders generated in WIMS

Yes. Customer complaints system requires implementation in Katherine

0 leaking below ground hydrants/ valves

1 leaking below ground hydrant/ valve

2) Repair/replacement of pipes/fittings etc.

B-176

©2006 A

ww

aRF

. All R

igh

ts Reserved

.


Diagram Code



Schedule

0 leaks detected in below ground network

1 leak detected in below ground network

KWSwtCF KWSwtC KWSwtFi KWSwtDf

SP(HS) j Distribution network-Regrowth/biofilms

KWSDt

Microbiological contamination caused by regrowth/biofilms within network

< 1000 Hetero-trophic plate count (CFU/ 100 mL)

≥ 1000 Hetero-trophic plate count (CFU/ 100 mL)

Routine bacterialogical operational monitoring is performed as part of Drinking Water Monitoring Program

SOP – 114 Flushing Water Mains SOP – 115 – 117 Tank Cleaning

Power and Water personnel responsible for corrective action including: 1) Further flushing or swabbing of mains 2) Storage cleaning

Laboratory test report Evidence of flushing activity recorded on Water Losses sheet

Investigate requirement for COLTS for free chlorine residual within distribution system (i.e. closed storage tank outlets and reticulation) ??Review existing procedure for disinfection

3) Spot disinfection Notes: 1. Shading of diagram code cell indicates diagram included in HACCP Plan.

B-177

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Validation Schedule for CCPs/NCCPs (Critical Limits)

Diagram Critical Limits No Step Code

Potentially Hazardous Event Target Action Validation

KWS CCP 1/1 Surface Water Extraction

KWSSE


Surface water turbidity < 250 NTU Surface water DO 85% - 120%

Surface water turbidity ≥ 250 NTU Surface water DO < 85%

For effective operation of the WTP it must receive raw water with a specification that is within the operating limits of the plant. Australian and New Zealand Guidelines for Fresh and Marine Water Quality (2000), Table 3.3.4.

KWS CCP ½ Surface Water Extraction KWSSE




CCP 2/1 Treat-ment KWSWT





Electrical power is essential for the operation of the SCADA system. The UPS will commence operation immediately upon a loss of mains electrical power.

2) Major SCADA equipment

failure (e.g. PLC, server) 0

test start failure of UPS


Operation of the UPS is critical to maintaining operation of the SCADA system in the event of loss of mains electrical power. Any failure of the UPS when tested requires rectification of the equipment problem.




CCP 2/2 NCCP A Coagul-ation and

KWSwtCF Ineffective treatment sub-process, over dosing of coagulants


Flocculation mode

(filtrate):

ADWG (2003) sets out that > 1 NTU may shield some micro-organisms from disinfection (page 10-24) and that < 1 NTU desirable for effective disinfection (page 10-24). Note ADWG (1996) sets out that ≤ 1 NTU required for effective disinfection (page 5-6, Table 5.1) and < 1 NTU desirable for effective disinfection (page GL-7).

B-178

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Floccul- ation

Turbidity ≤ 1 NTU

Turbidity > 1 NTU

TBA TBA TBA (Input validation for critical limits chosen for CCS when equipment is fully operational)

Dosed water

6.2 ≤ pH ≤ 6.3

Dosed water pH < 5.9 or >

6.5

SOP 123 Setting Chemical Dose Rates for Coagulation specifies current target values. pH during alum coagulation should be kept above pH 5.5, Demsey, Ganho, et al. (1984) and Randtke, (1988).

Dosed water pH > 8.0

ADWG (2003) and ADWG (1996) set out that pH > 8 progressively reduces the efficiency of chlorination (page 10-24 and page GL-7 respectively). ADWG (1996) also sets out that pH < 8 required for disinfection (page 5-6).

CCP 2/3 NCCP B Clarific-ation

KWSwtC

Ineffective treatment sub-process Flocculation mode (filtrate): Turbidity ≤ 1

NTU

Flocculation mode

(filtrate):

Turbidity > 1 NTU

ADWG (2003) sets out that > 1 NTU may shield some micro-organisms from disinfection (page 10-24) and that < 1 NTU desirable for effective disinfection (page 10-24). Note ADWG (1996) sets out that ≤ 1 NTU for effective disinfection (page 5-6, Table 5.1) and < 1 NTU desirable for effective disinfection (page GL-7).

CCP 2/4 NCCP C Filtration

KWSwtFi

Sand filter breakthrough

Flocculation mode:

Turbidity ≤ 1

NTU

Filtration mode:

Turbidity ≤ 1.5 NTU

Flocculation

mode:

Turbidity > 1 NTU

Filtration

mode:

Turbidity > 1.5 NTU

ADWG (2003) sets out that > 1 NTU may shield some micro-organisms from disinfection (page 10-24) and that < 1 NTU desirable for effective disinfection (page 10-24). Note ADWG (1996) sets out that ≤ 1 NTU for effective disinfection (page 5-6, Table 5.1) and < 1 NTU desirable for effective disinfection (page GL-7). Historical practice has shown that with plant operating in filtration mode the microbiological safety of the water can be maintained if the turbidity of filtered water ≤ 1.5 NTU.

Time elapsed since last filter backwash < 72 hours

Time elapsed since last filter backwash ≥ 72 hours

WTP design parameter.

Filter

headloss < 1 m

Filter headloss ≥ 1 m

WTP design parameter.

Filter

throughput (24 hours) < 10 ML

Filter throughput (24 hours) ≥ 10 ML

Current WTP operation is such that ≥ 10 ML throughput in 24 hour period requires backwashing of filter.

No short

circuiting observed

Short circuiting observed

Operation of WTP requires backwashing of filter if short circuiting observed.

CCP 2/5 Disin-fection Preser-vation

KWSDf

1.0 – 1.5 mg/L Free

chlorine residual at WTP outlet

< 1.0 or > 1.5 mg/L

Free chlorine residual at WTP outlet

Under normal chlorination conditions with a free chlorine residual ≥ 0.5 mg/L , a contact time of 30 minutes, pH less than 8.0 and turbidity less than 1.0 NTU then microbial control will be sufficient but not for parasitic protozoa, WHO Drinking Water Guidelines (1994), 2 nd edition, Volume 2, Section 11.2.9 and ADWG (2003), page PS-6.

B-179

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



0.2 – 0.5 mg/L

Free chlorine residual in water reticulation system

< 0.2 or > 0.5 mg/L

Free chlorine residual in

water reticulation

system

ADWG (2003) indicate that a residual chlorine concentration ≥ 0.2 mg/L in the reticulation system needs to be present to limit bacterial regrowth.

CCP 3/1 Proposed Storage (closed)

KWSSC Microbiological contamination of closed storage not associated with a deliberate security breach



COLTS monitoring free chlorine residual concentration at storage tank outlets is not installed, although this equipment is programmed to be undertaken. At present no operational sampling and testing for free chlorine residual is performed at these locations.



Currently NA.



Currently NA.

CCP 3/1 Storage (Closed)/ Backflow

KWSSC GWSBf

Backflow event causing microbioloical, physical or chemical contamination. These can be mitigated through maintenance of a minimum system pressure



Distribution network modelling and pressure recording has verified that the minium network pressure can be maintained when the storage levels are managed within operational limits.

≥ 15 m

minimum network

head

< 20 m network

head

The minimum network head of 15 metres is consistent with overseas practices for preventing or mitigating pathogen intrusion problems e.g. Recommended Standards for Water Works (Ten State Standards) (1997) nominate the minimum supply pressure as 20 psi (140 kPa).

CCP 3/1 Storage/ Intrusion

KWSSC GWSI

Contamination caused by negative or low pressure transient resulting in intrusion of foreign materials (e.g. through submerged air valves, submerged fire hydrants, faulty hydrants, faulty seals, submerged mains, damaged mains etc.). These can be mitigated through maintenance of a minimum system pressure

As above As above As above.

B-180

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Validation Schedule for SPs (Performance Limits)

Diagram Performance Limits No Step Code


SP(HS) a Storage (closed)

KWSSC


0 Entry points for birds, vermin etc. detected

1 Entry point for birds, vermin etc. detected

Waterborne pathogens harmful to humans may be excreted in the faeces from humans and other warm or cold blooded blooded animals. The most common cause of pathogens entering a closed storage tank is from birds gaining access to nest, drink and bath in the water. Other forms of vermin may also cause pathogen contamination. To minimise such events, all storages are roofed, however, birds may still gain access through ventilators, ridge/edge vents, roofing gaps etc. These access points are normally sealed and regular inspections are carried out to ensure their integrity. Any breach in a barrier is actioned immediately by initiating temporary repairs/permanent repairs. Thermotolerant coliforms and E. coli are normally used as indicators that pathogenic organisms may be present in the water supply system. Power and Water routinely sample and test for E. coli at locations in the reticulation system to verify the provision of safe potable water to consumers. Further operational sampling and testing for free chlorine residual is performed to understand the operation of the water supply system and limit the extent of a potential contamination event. The above is based upon well understood scientific knowledge and operational experience.

SP(HS) b Distri-bution

KWSDt Presence of sediments, deposits and or biofilms causing dirty water complaints

0 complaints

1 complaint

Power and Water has adopted the policy/standard that any complaint regarding water quality is unacceptable and requires investigation and resolution.

> 15

complaints in 24 hr period

Power and Water has adopted this response protocol in its draft Emergency Plan (Emergency Plan Contamination of Potable Water Supply – Hazard Identification)

SP(HS) c Backflow

GWSBf

Backflow event causing microbiological or chemical contamination

100% of all containment devices installed on new services

1 containment BPD not installed on a new service

Performance of plumbing works to AS/NZS 3500.1.2 requires that a BPD be installed upon identification of a hazard. Power and Water has adopted the policy/standard that when BPDs have been identified as being required the BPDs are required to be installed before water will be supplied to a customer.

SP(A) d Backflow

Backflow event causing physical contamination

100% of devices installed in plumbing systems to protect high hazards

1 device not installed in plumbing systems to protect high hazards


100% of devices installed in plumbing systems to protect medium and

1 device not installed in plumbing systems to protect medium and


B-181

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



low hazards low hazards

0 failures of testable containment device

1 failure of testable containment device

AS/NZS 3500.1.2 recognises that all testable devices require retesting at an interval not exceeding twelve months. Power and Water has adopted the policy/standard of implementing corrective actions upon any failure of a testable containment device.

SP(HS) e SP(A) f Materials/ Products Utilisation

GWSMat


0 situations involving


1 situation involving


Power and Water policy is not to accept water supply works which incorporate non approved products, materials, coatings etc. that do not possess appropriate potable water contact certification or approval.

SP(HS) g New Mains – Construct-ion

GWSNM

Microbiological contamination caused by foreign inanimate objects e.g. dirt, mud, timber supporting micro-organismsl, animals e.g. rodents, polluted water during laying of new mains

0 E.coli (CFU/100 mL)

0-10 Hetero-trophic plate count (CFU/ mL) (i.e. 0-1000 CFU/100 mL)

1 E.coli (CFU/100 mL)

>10 Hetero-trophic plate count (CFU/ mL) (i.e. >1000 CFU/100 mL)

Potable water within Power and Water’s reticulation system is required to meet ADWG (2003) microbiological requirements. The ADWG (2003) require that a sample when tested contain no E.coli (or alternatively thermotolerant coliforms). The ADWG (2003) are recognised as national guidelines and set limits for various characteristics collectively describing good quality potable water that is safe to drink and aesthetically acceptable. Thermotolerant coliforms and E. coli are normally used as indicators that pathogenic organisms may be present in the water supply system. To minimise the likelihood of non compliance with the ADWG (2003) microbiological requirements, Power and Water, requires the demonstration that the contents of all newly constructed mains are safe before the newly constructed main can be connected to the existing water supply system. This requirement is consistent with practices described in WSAA Water Supply Code of Australia and ANSI/AWWA C651-99. The monitoring parameters and their performance limits have been drawn from the WSAA Water Supply Code of Australia, however, the total coliforms parameter and its performance limit have not been included. The WSAA Code includes acceptability criteria for both faecal coliforms (or E.coli) and total coliforms (page 170, Table 19.2) which are consistent with the monitoring intent adopted in the ADWG (1996). As mentioned above, the monitored parameters for which critical limits have been set do not include total coliforms as this parameter has been dropped from the ADWG (2003) as an indicator of the microbiological safety of water. The WSAA Code includes a HPC bacteria count (page 170, Table 19.2). New material does not typically contain coliforms but does typically contain HPC bacteria. The inclusion of a HPC bacteria count is consistent with the procedure described in ANSI/AWWA C651-99 (1999’) for determining the bacteriological quality of water contained in newly constructed mains.

SP(HS) h Existing Mains

Repairs etc.

GWSEM

Microbiological contamination caused by foreign inanimate objects e.g. dirt, mud, timber supporting micro-organismsl, animals e.g. rodents, polluted water during repair, alterations or connection of existing mains

0.2 – 0.5 mg/L Free chlorine residual Downstream residual ≥ upstream residual

< 0.2 mg/L Free chlorine residual

To minimise the likelihood of non compliance with the ADWG (2003) microbiological requirements, Power and Water, requires that all repairs, connections, alterations etc. on existing mains be performed by Power and Water personnel or its contractors in accordance with standard operating procedures. The standard operating procedure for repairing mains breaks requires the measured residual chlorine level to be ≥ 0.2 mg/L which is consistent with the ADWG (2003) requirement for preventing recontamination.

B-182

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



> 0.5 mg/L Free chlorine residual

ADWG (2003) and ADWG (1996) set out that the odour threshold is generally 0.6 mg/L (pages 10-25 and GL-8).

SP(HS) I Distri-bution Network –Intrusion

GWSI

Contamination caused by negative or low pressure transient resulting in intrusion of foreign materials (e.g. through submerged air valves, submerged fire hydrants, faulty seals, submerged mains, damaged mains etc.)

0 leaking below ground hydrants/ valves

1 leaking below ground hydrant/ valve

No standard or recognised requirement. Power and Water has a policy/standard of rectifying any leak detected from a hydrant or valve, as these points may be a pathway for contamination.

0 leaks detected in below ground network

1 leak detected in below ground network

No standard or recognised requirement. Power and Water has a policy/standard of rectifying any leak detected from the network, as these points may be a pathway for contamination.

SP(HS) j Distri-bution Network – Regrowth

KWSwtCF KWSwtC KWSwtFi KWSwtDf

Microbiological contamination caused by regrowth/biofilms within network

< 1000 Hetero-trophic plate count (CFU/ 100 mL)

≥ 1000 Hetero-trophic plate count (CFU/ 100 mL)

ADWG (1996) state that colony counts would be: 1) < 100 CFU/mL in a disinfected supply and 2) < 500 CFU/mL in an undisinfected supply, in well maintained supplies (page 2-15). This equates to: 1) < 10 000 CFU / 100 mL in a disinfected supply and 2) 50 000 CFU / 100 mL in an undisinfected supply. An operational target of < 1000 CFU / 100 mL is an order of magnitude 10 x less than that nominated in the ADWG (1996).

B-183

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Verification Schedule for HACCP Plan

Activity Description Frequency Responsible Party Records Water Operations: WTP Operator/Service Worker

WIMS work order Sampling and bacteriological testing is undertaken at five locations within the distribution system 3 samples per week Water Facilities:

WQS2 or WQO 1) Laboratory test reports (hard copies) 2) Water quality database 3) Daily water quality exception reports

Water Operations: WTP Operator/Service Worker

WIMS work order

Sampling and general physical/chemical testing is undertaken at: 1) two locations within the distribution system and 2) Donkey Camp

Biannually (March, November) Water Facilities:

WQS2 or WQO 1) Laboratory test reports (hard copies) 2) Water quality database


WIMS work order

Sampling and TOC/DOC testing is undertaken at: 1) WTP outlet and 2) Donkey Camp Annually (January) Water Facilities:


Water Operations: WTP Operstor/Service Worker

WIMS work order

Sampling and testing for THMs is undertaken at two locations within distribution system Annually (January) Water Facilities:



WIMS work order

Sampling and general physical/chemical testing is undertaken at all production bores Annually Water Facilities:


Performance of compliance water quality monitoring program


WIMS work order

Sampling and testing for metals is undertaken at: 1) all production bores, 2) Donkey Camp and 3) two locations within distribution system Every second year Water Facilities:



WIMS work order

Sampling and testing for pesticides is undertaken at: 1) all production bores and 2) Donkey Camp Anually Water Facilities:



WIMS work order

Sampling and testing is undertaken from two locations within distribution system for Giardia and Cryptosporidium

Not performed Water Facilities: WQS2 or WQO

1) Laboratory test reports (hard copies) 2) Water quality database


WIMS work order

Sampling and radiological testing is undertaken at: 1) single point in reticulation system and 2) all production bores Every second year Water Facilities:


Review and preparation of Drinking Water Monitoring Program Six monthly

Water Facilities: SET WQS1 WQS2 or WQO

Drinking Water Monitoring Program

Analysis of bacteriological test results from compliance monitoring program

Analysis of individual results from any one sample to determine compliance with ADWG (2003). Weekly

Water Facilities: WQS2 or WQO

Daily water quality exception reports

B-184

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Activity Description Frequency Responsible Party Records Analysis of results to determine compliance of total monitoring program with ADWG (2003). Annually


Annual drinking water quality report

Analysis of individual results from any one sample to determine compliance with ADWG (2003). As completed


Laboratory test reports (hard copies) Analysis of physical, chemical, radiological etc. results from compliance monitoring program Analysis of results to determine compliance of total

monitoring program with ADWG (2003). Annually Water Facilities: WQS2 or WQO

Annual drinking water quality report

Performance of operational water quality monitoring program

Sampling and testing using various hand held equipment is undertaken at: 1) five locations within the distribution system, 2) WTP inlet and 3) WTP outlet. Parameters tested: free chlorine residual, turbidity, pH, conductivity, alkalinity, hardness, fluoride, temperature although not all at all locations

Daily

Water Operations: Rostered WTP operator

Daily Water Tests sheet

Analysis of results from operational water quality monitoring program

Analysis of individual results to verify satisfactory operation of WTP Daily

Water Operations: Rostered WTP operator

Daily Water Tests sheet

Water Operations: WC (Katherine)

Review of customer complaints received

Analysis of customer complaints received to identify possible trends/deficiencies in water distribution system, changing customer requirements and hence changes to HACCP system

Continually and formal review monthly

Water Facilities: WQS1

1) Monthly customer complaints report 2) Emails

Periodic review of HACCP Plan records Review of monitoring and corrective action records to ensure HACCP system and critical limits are being complied with

Operational water quality monitoring records for critical limits

1) Free chlorine residual testing within the distribution system using hand held equipment Daily Water Operations:

Rostered WTP operator Daily Water Tests sheet

2) Turbidity measurements within the distribution system using hand held equipment Daily Water Operations:

Rostered WTP operator Daily Water Tests sheet

3) SCADA systems reports, diary records etc. At least weekly Water Operations: Rostered WTP operator

Diary records, CDs etc.

Audit (internal) of HACCP Plan To verify activities comply with the HACCP Plan and identify areas for improvement Six monthly

Audit collection of HACCP Plan records Audit collection of monitoring and corrective action records to ensure requirements of HACCP Plan are being complied with

Quarterly

Water Facilities: 1) PM HACCP (Internal auditor)

1) Audit schedule 2) Audit reports

Periodic internal review of HACCP Plan Review of risk assessment specifically:

1) Identification of potential or emerging hazardous events and associated control measures

2) Reconsider risk analysis based upon new/additional studies or information

3) Implementation, audit outcomes etc.

Six monthly

Water Facilities/Operations: 1) PM HACCP (Internal auditor) 2) HACCP team

members/technical experts

1) HACCP Plan 2) Meeting minutes 3) Other records

B-185

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Activity Description Frequency Responsible Party Records

Validation of critical limits Values of critical limits to be reviewed to ensure they are still appropriate: 1) Limits for microbiological, chemical and physical

parameters are set to achieve potable water which is safe to drink and aesthetically acceptable

2) Limits for system operational parameters are set to maintain process control/mitigate potential risks

Six monthly

1) PM HACCP (Internal auditor) 2) HACCP team

members/technical experts

1) Audit Schedule 2) Audit Reports 3) HACCP Plan

Potable Water Quality Improvement and Protection Action Schedule

Review progress towards objectives Quarterly HACCP Steering Group HACCP team , PM HACCP, other action officers

Potable Water Quality Improvement and Protection Action Report

Calibration of equipment Analysing and testing equipment to be maintained and calibrated in accordance with equipment maintenance schedules

Equipment specific (generally fortnightly,

monthly)

Water Operations: IC

Calibration certificates Instrument calibration report

B-186

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Potable Water Quality Improvement and Protection Action Schedule Water Engineering

Item No

Priority Objective Action Required Accountable Officer

Timeframe

1 H Reduce risk of contamination from backflow 1) Develop a traceable process for all building development work where new or

altered property service connections are constructed to ensure installation of BPDs

MWE MLD

< 12 months

2) Review DN 20-50 property service connection drawings to ensure clear division of responsibility for provision of containment BPD by building owner

MWE MITP

< 12 months

3) Lobby/engage with DIPE to resolve historical impasse regarding implementation of AS/NZS 3500 requirements

MWE < 12 months

4) Review current standard for domestic meters and determine whether

appropriate to change to meters with integral BPDs for protection against low hazards

MWE MITP

< 12 months

5) Review appropriateness of BPD shown on std drg W1-2-07 used for hydrostatic testing of water mains

MWE MITP

< 12 months

2 L Reduce risk of contamination from use of unapproved products, materials and coatings

1) Release updated version of Water and Sewage Infrastructure Products Manual MWE MITP

< 12 months

2) Implement strategies to improve adoption of Water and Sewage Infrastructure

Products Manual and other standards e.g. mandatory requirement for suppliers involved in private developer works to utilise, training program including Water Operations

MWE MITP MLD

< 12 months

3) Develop coating specifications for maintenance/repair e.g. painting of steel pipe specials, storage tanks

MWE MITP

< 2 years

4) Update Water Standards intranet site to include latest version of APAS List of Approved Products

MWE MITP

< 6 months

5) Develop and implement scheduled audit program to identify use/supply of non-

approved products/materials/coatings. Program to address PWC supply contract and private developer works (consider extending to capital works and repairs and maintenance)

MWE MITP MLD

< 2 years

3 H Reduce risk of microbiological contamination from new mains construction

1) Review Hydraulic Master Specification to incorporate requirement for bacteriological test. Consider adoption of testing for acceptable physical characteristics as per WSAA code

MWE MITP

< 12 months

2) Review current Customer Handout No 5 allowing collection of samples by

contractor to permit only laboratory personnel to collect sample MWE MITP MLD

< 6 months

3) Ensure current and or proposed processes only permit laboratory reports as

evidence of bacteriological testing MWE MITP MLD

< 6 months

4) Ensure current and or proposed processes require notification of failed

bacteriological tests MWE MITP MLD

< 6 months

5) Implement report enabling monitoring of bacteriological test results to establish possible unsatisfactory trends/areas for improvement

MWE MLD

< 12 months

4 L Improve representation in appropriate forums influencing catchment development and management

Identify appropriate forums and participate MWE MLD

Continuous

B-187

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Water Facilities Item No


Timeframe

1 L

Minimise camping, swimming and boating activity at Donkey Camp pool

1) Confirm whether Donkey Camp pool falls within the definition of a ‘reservoir/dam’ pursuant to section 99 of WSSSA

2) Investigate whether appropriate fencing and placing of obstacles at current boat launch sites/access tracks should be undertaken (investigate land tenure/right to install) and install if recommended

3) Review/establish geographical extent of Water Management Zone (document, educate community etc.)

4) Ensure fishing is not promoted (e.g. remove recommendations from tourist publications)

5) Consider communication/networking strategies to discourage camping

SRP <24 months

2 L Minimise potential for and mitigate effects of sewage handling spill from tourist cruise boats operating on Katherine Gorge

Initiate dialogue with Parks and Wildlife and tourist boat operators to investigate current control measures used by tourist boat operators to minimise sewage spillages and implement improvements

SRP <24 months

3 L

Minimise potential for and mitigate effects of sewage spill from Katherine Gorge tourist park sewage pumping station

Initiate dialogue with Parks and Wildlife to: 1) Investigate current control measures used by Parks and Wildlife to minimise

sewage spillages and implement improvements 2) Establish whether an MOU covering response to pollution incidents is warranted

and implement if determined necessary

SRP <24 months

4 L Improve representation in appropriate forums influencing catchment development and management

Identify appropriate forums and participate SRP Continuous

5 L Investigate risk Donkey Camp pool is being contaminated by local discharges from septic tanks/drains

1) Undertake survey to determine extent of potential contamination sources 2) Review water quality monitoring program to determine if testing for faecal

coliforms in surface water is warranted and implement if necessary

SRP SET WQS1

< 12 months

6 L Investigate risk that Donkey Camp pool is being contaminated by faeces from birds, native and feral animals

1) Investigate requirement for feral animal control program and implement if necessary

2) Consider faecal sterol analysis of surface water to determine dominant faecal inputs

SRP SET WQS1

< 24 months < 12 months

7 L Investigate risk that Donkey Camp pool is being contaminated by faeces from grazing animals

1) Investigate as required e.g. density of and identify predominant grazing animals 2) Establish programs to minimise risk if warranted e.g. planting of vegetation

buffer zones/strips

SRP < 24 months

8 L Minimise potential for development of anoxic conditions in Donkey Camp pool

Engage with regulator to ensure environmental flows considered SRP < 24 months

9 L Minimise potential for contamination of raw water resources and sources by pesticides used by industry

Engage with appropriate regulators to develop strategies to work towards best practice usage of pesticides by improving regulation, usage etc.

SRP < 24 months

10 L Minimise potential for contamination of raw water resources by rubbish dumps and landfills

Investigate presence of pollution sources and waste management practices SRP < 24 months

11 L Minimise potential for contamination of groundwater resources by ingress of contaminants via uncapped/poorly sealed private bores

Investigate strategies for minimising risks SRP < 24 months

12 L Minimise potential for contamination of groundwater in aerator

Investigate need for roof structure or other alternatives SET WQS1

<12 months

13 H Minimise potential for sand filter breakthrough 1) Investigate costs/benefits of constructing larger capacity/more efficient filters

2) Review use of filtration mode at WTP 3) Review operation of WTP annually

SET WQS1

<12 months Annually

14 H Upgrade disinfection equipment Design and construction of new chlorination facility WQS1 < 18 months

B-188

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Water Facilities Item No


Timeframe

15 L Improve operational monitoring to prevent fluoride over dosing

Review current sampling location for daily fluoride testing WQS1 < 6 months

16 L Minimise potential for fluoride over dosing Investigate dosing pump size and determine if over dosing can occur WQS1 < 6 months

17 L

Improve procurement processes for DWTC Develop standard template specification for supply of DWTC addressing: • Quality assurance format for specification • Third party ISO 9001 certification for DWTC manufacturer and compliance

verification of same at time of tender assessment • DWTC compliance verification at time of tender assessment and at time of

delivery of DWTC batches

SET WQS1

< 18 months

18 L Develop verification activities to support HACCP Plan Develop review process for water quality complaints SET WQS1

< 12 months

19 L Investigate risk that Donkey Camp pool is being contaminated by pesticides from horticultural activity

Investigate usage of pesticides by local mango growers and sample where appropriate SRP < 12 months

Water Operations Item No


Timeframe

1 L Minimise swimming and boating activity in Donkey Camp pool

1) Review signage (i.e. locations and message) 2) Investigate whether appropriate fencing and placing of obstacles at current boat

launch sites/access tracks should be undertaken (investigate land tenure/right to install) and install if recommended

WC (Katherine) < 24 months

2 H Improve reliability of operational monitoring equipment installed to warn of change in surface water quality at Donkey Camp pool

1) Replace turbidity equipment at Donkey Camp pool 2) Ensure DO equipment is operational 3) Ensure data is monitored by SCADA and reports collected 4) Ensure instruments calibrated at appropriate intervals

WC (Katherine) WTP Operator

< 6 months

3 L Minimise potential for contamination of raw water resources and sources by pesticides used by Power and Water

1) Develop SOP addressing use of pesticides 2) Ensure relevant staff are trained in the use of pesticides

MWO AMC

< 12 months

4 H

Improve operational monitoring of coagulation, flocculation and clarification processes at WTP

1) Investigate installation of additional turbidity metering equipment upstream of flash mixer and downstream of clarifier and if warranted install

2) Complete installation of Coagulation Control System (CCS) 3) Ensure data is monitored by SCADA and reports collected 4) Ensure instruments calibrated at appropriate intervals

WC (Katherine) WTP Operator IC

< 6 months

5 L Minimise potential for structural collapse of aerator 1) Organise inspection and condition report

2) Use WIMS to schedule periodic inspection WC (Katherine) WTP Operator

< 12 months

6 H Minimise potential for failure of rake and or agitator 1) Review maintenance history

2) Use WIMS to schedule periodic inspection 3) Review spares inventory


< 12 months

7 L Maintain up to date WTP documentation Produce current process, piping and instrumentation diagram for WTP and closed storage tanks (treated water)

WC (Katherine) < 12 months

B-189

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Water Operations Item No


Timeframe

8 L Minimise potential for filter backwash water being returned to WTP

Investigate decommissioning options for relevant pipework/pumps WC (Katherine) WTP Operator

< 12 months

9 H Improve operational monitoring of filtration process 1) Investigate installation of duplicate turbidity metering equipment downstream of

filter 2) Ensure instruments calibrated at appropriate intervals


< 6 months

10 H

Improve operational monitoring of disinfection process 1) Investigate installation of chlorine analysers on outlets of closed storage tanks and within reticulation system

2) Ensure data is monitored by SCADA and reports collected 3) Ensure instruments calibrated at appropriate intervals 4) Review current form specifying locations for recording chlorine residuals


< 6 months

11 H Maintain up to date WTP documentation Prepare operating manual for WTP outlining general operational philosophy AMC


< 18 months

12 L

Minimise potential for accidental and deliberate physical contamination of flash mixer and reactivator

Review: 1) Physical access to stairs/platform 2) Platform design 3) Railing design and upgrade where warranted

WSA WC (Katherine) WTP Operator

< 18 months

13 L Improve security of closed storages Undertake sanitary inspection in conjunction with cleaning program. Develop tank inspection form to be used when tanks inspected/cleaned

AMC WC (Katherine)

< 12 months

14 H Reduce the risk of contamination from backflow Review current processes/procedures for permitting authorised temporary cross-connections (e.g. pools filled from fire hydrants, tankers using hydrants etc.)

MWO AMC

< 12 months

15 L Improve procurement processes for DWTC Review need for and if appropriate develop SOP for delivery/acceptance of DWTC MWO AMC

<18 months

16 H Reduce risk of contamination from existing mains repairs Review current SOP for mains flushing against best practice procedure (e.g. to include

minimum flushing duration, velocity and semi-objective turbidity/colour assessment (e.g. white bucket test)

MWO AMC

< 12 months

17 H Improve WTP record collection and management Review current forms used for recording status of WTP, daily operational water quality

monitoring tests, etc. and retention periods WTP Operator WQS1 PM HACCP

< 6 months

1) Implement system (i.e. use of FIS) currently used in Darwin/Alice Springs in Katherine

MWO WC (Katherine)

< 6 months

18 H

Improve system for monitoring customer complaints

2) Review data collection for appropriateness SET WQS1

< 12 months

19 L Continually improve by reviewing customer service standards Review current arrangement by which finished water hardness is maintained below 100 mg/L by agreement with RAAF

SET WQS1

< 24 months

B-190

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Acceptance Schedule by HACCP Team for HACCP Plan Work Telephone Work Facsimile Name


Position Role Signature Date Work E-mail


Kathryn Clarkson 08 8924 7059 Power and Water Corporation 08 89 24 7161

WQS1 Team member/technical expert

[email protected]


Simon Copley 08 8924 5047 Power and Water Corporation 08 89 24 5033

AMC Team member

[email protected]



MWO Team member/manage-ment commitment

[email protected]


TBA 08 8924 7096 Power and Water Corporation 08 89 24 7161

WQS2 or WQO Team member/technical expert

TBA


Paul Heaton 08 8924 7359 Power and Water Corporation 08 89 24 7161

MWF Team member/manage-ment commitment

[email protected]



WTP Operator Team member

[email protected]


Noel McCarthy 08 89 24 7177 Power and Water Corporation 08 89 24 7161

PM HACCP Team member/technical expert

[email protected]




Team member/technical expert

[email protected]



WC (Katherine) Team member

[email protected]


Declan Page 08 8924 7942 Power and Water Corporation 08 89 24 7161

SRP Team member/technical expert

[email protected]


B-191

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

B-192

References American Water Works Association (1998a). ANSI/AWWA B403-98 AWWA Standard for Aluminum Sulfate – Liquid, Ground, or Lump. Denver, Colorado: AWWA. American Water Works Association (1998b). ANSI/AWWA B201-98 AWWA Standard for Soda Ash. Denver, Colarado: AWWA. American Water Works Association (1999a). ANSI/AWWA C651-99 AWWA Standard for Disinfecting Water Mains. Denver, Colarado: AWWA. American Water Works Association (1999b). ANSI/AWWA B300-99 AWWA Standard for Hypochlorites. Denver, Colarado: AWWA. American Water Works Association (1999c). ANSI/AWWA B301-99 AWWA Standard for Liquid Chlorine. Denver, Colarado: AWWA. American Water Works Association (2000). ANSI/AWWA B703-00 AWWA Standard for Fluorosilic Acid. Denver, Colarado: AWWA. Australia New Zealand Food Authority (ANZFA) (1999a). Development of Uniform Food Acts for Australia and New Zealand, Volume 1 - Explanatory Paper, Regulatory Impact Assessment and Implementation Agreement. Australia: ANZFA. Australia New Zealand Food Authority (ANZFA) (1999b). Development of Uniform Food Acts for Australia and New Zealand, Volume 2 – Exposure Draft Food Bill. Australia: ANZFA. Australian and New Zealand Environment and Conservation Council (ANZECC)/Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ) (2000). Australian and New Zealand Guidelines for Fresh and Marine Water Quality. Australia: ANZECC/ARMCANZ. Codex Alimentarius Commission (1996). Report of the twenty-ninth session of the codex committee on food hygiene, (Alinorm 97/13A). Rome: Codex Alimentarius Commission Joint FAO/WHO Food Standards Programmme. Codex Alimentarius Commission (?1999). Recommended International Code of Practice General Principles of Food Hygiene, (CAC/RCP 1-1969, Rev. 3 – 1997, Amd (1999)). Rome: Codex Alimentarius Commission Joint FAO/WHO Food Standards Programmme. Dempsey, B. A., Ganho, R. M., et al. (1984). The Coagulation of Humic Substances by Means of Aluminium Salts. Amercian Water Water Association, 40 (?), pp 141-150. Great Lakes Upper Mississippi River Board of State Public Heath & Environmental Managers (1997). Recommended Standards for Water Works. Albany, NY: Health Education Services.


B-193

National Health and Medical Research Council (NHMRC)/Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ) (1996). Australian Drinking Water Guidelines 1996. Canberra: NHMRC/ARMCANZ. National Health and Medical Research Council (NHMRC)/Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ) Co-ordinating Group (1999). Framework for Drinking Water Quality Management. Canberra: NHMRC/ARMCANZ. National Health and Medical Research Council (NHMRC)/Natural Resource Management Ministerial Council (NRMMC) (2002). Australian Drinking Water Guidelines Draft – June 2002. Canberra: NHMRC/NRMMC. National Health and Medical Research Council (NHMRC)/Natural Resource Management Ministerial Council (NRMMC) (2003). Australian Drinking Water Guidelines Draft – February 2003. Canberra: NHMRC/NRMMC. Northern Territory Parliament (2000). Water Supply and Sewerage Services Act,(as in force 7 November 2002). [Online]. Northern Territory Government. Available: http://notes.nt.gov.au/dcm/legislat/legislat.nsf/d989974724db65b1482561cf0017cbd2/fb1ec118fc4e471469256c6e007c4fd1?OpenDocument [Accessed 16 February 2004]. Power and Water Corporation (2003). Water Quality Report 2003. Darwin, NT: Power and Water Corporation. Power and Water Corporation (2003). Emergency Plan Contamination of Potable Water Supply Hazard Identification, (Draft). Darwin, NT: Power and Water Corporation. Power and Water Corporation (2004). Drinking Water Monitoring Program 2004 – 2005, (Draft). Darwin, NT: Power and Water Corporation. Randtke, S. J. (1988). Organic Contaminant Removal by Coagulation and Process Combinations. American Water Works Association, 80, pp 40-55. Standards Australia and Standards New Zealand (1999). AS/NZS 4360: 1999 Risk Management. Strathfield, NSW: Standards Association of Australia. Standards Australia and Standards New Zealand (2000a). AS/NZS ISO 9001: 2000 Quality Management Systems – Requirements. Sydney, NSW/Wellington, NZ: Standards Australia International Ltd/Standards New Zealand. Standards Australia and Standards New Zealand (2000b). AS/NZS ISO 9000: 2000 Quality Management Systems – Fundamentals and Vocabulary. Sydney, NSW/Wellington, NZ: Standards Australia International Ltd/Standards New Zealand. Water Services Association of Australia Inc (2002). Water Supply Code of Australia WSA 03-2002, (Second Edition). Melbourne, VIC: WSAA.


B-194

World Health Organisation (WHO) (1993). Guidelines for Drinking Water Quality, (Second Edition). Geneva, Switzerland: WHO.


B-195

Referenced Standard Operating Procedures

No Katherine Water Treatment Plant SOP 101 Daily pH Testing SOP 103 Daily Free Chlorine Analysis SOP 106 Turbidity Analysis SOP 114 Flushing Water Mains SOP 115 Emptying and Cleaning the 4.5 megalitre Water Storage Tank SOP 116 Emptying and Cleaning the 9 megalitre Water Storage Tank SOP 117 Emptying and Cleaning the 12 megalitre Water Storage Tank SOP 123 Setting Chemical Dosing Rates for Coagulation SOP 124 Sludge Volume Determination in Reactivator

No Generic WS-SP-WO2 Repair to Rising Mains and Reticulation Services


Appendices Appendix 1

Raw Water Specification Donkey Camp – Physical Quality

Characteristic ADWG Health

Guideline

ADWG Aesthetic Guideline#

ANZECC Guideline Unit Spec Single

Data Min

Historical Max

Historical σ

Historical UCL 95 th

% Mean

Historical LCL

5 th % Comments

Physical Alkalinity as CaCO32 No set

value mg/L TBA NA 2 54 5.8 22.8 12.1 5.2

Conductivity2 20 - 250 μS/cm TBA NA 16 180 10 52 33 21 Dissolved oxygen ** >85 > 80 (rec) % TBA TBA TBA TBA TBA TBA TBA TBA Hardness as CaCO3

** 200 5000 (rec) mg/L TBA TBA 3 24 3.2 14 8.7 3.4

pH * 6.5-8.5 6 - 7.5 TBA TBA 5.5 8.1 0.4 7.2 6.5 6.0 Taste and odour

** Accept- able to majority

No set value NA NA NA NA NA NA NA NA

Temperature ** No set value

No set value °C NA NA NA NA NA NA NA NA

Total dissolved solids ** 500 10,000

(rec) mg/L TBA TBA 16 60 7 46 34 23

True colour ** 15 HU TBA TBA TBA TBA TBA TBA TBA TBA Turbidity * 5 2 - 15 NTU TBA TBA 0.78 137 18 58.9 26 5.3

B-196

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Raw Water Specification Donkey Camp (cont) – Chemical Quality


Guideline

ADWG Aesthetic# Guideline


Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

Chemical/ Compounds

Aluminium (total) * 0.2 0.55 / 0.2 (rec) mg/L NA NA 0.19 4.45 1.99 2.29 1.11 0.27

Ammonia (as NH3) * 0.5 6 / 0.1 (rec) mg/L NA NA NA NA NA NA NA NA

Antimony 0.003 ID mg/L NA 0.0005 NA NA NA NA NA NA Arsenic 0.007 0.24 / 0.5

(rec) mg/L TBA 0.005 TBA TBA TBA TBA TBA TBA

Asbestos * ID mg/L NA NA NA NA NA NA NA NA Barium 0.7 10 (rec) mg/L TBA 12 TBA TBA TBA TBA TBA TBA Beryllium * 10 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Boron 0.3 3.7 mg/L TBA 0.05 TBA TBA TBA TBA TBA TBA Cadmium 0.002 0.002 /

0.05 (rec) mg/L NA 0.002 NA NA NA NA NA NA

Calcium2 No set

value mg/L NA 1 (NA) 0.9 143 1.0 3.8 1.7 0.9

Chloride ** 250 300 / 4000 (rec) mg/L NA 3 (NA) 1 8 1.9 8.2 4.8 2.3

Chromium (as Cr(VI)) 0.05 0.01 / 0.5 (rec) mg/L NA 0.001 NA NA NA NA NA NA

Copper 2 1 0.014 / 10 (rec) mg/L NA 0.06 NA NA NA NA NA NA

Cyanide 0.08 0.07 / 0.1 (rec) mg/L NA NA NA NA NA NA NA NA

Fluoride 1.5 No set value mg/L NA < 0.1

(NA) 0.03 0.5 0.1 0.4 0.2 0.07

Hydrogen sulfide * 0.05 0.01 mg/L NA NA NA NA NA NA NA NA Iodide 0.1 No set

value mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Iron * 0.3 ID / 3 (rec) mg/L NA 0.2 (NA) 0.09 7.7 0.8 2.4 0.9 0.1

B-197

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

Lead 0.01 0.034 / 0.5 (rec) mg/L NA 0.0061 NA NA NA NA NA NA

Magnesium2 No set

value mg/L NA 1 (NA) 1 2 0.2 1.5 1.2 1

Manganese 0.5 0.1 19 / 1 (rec) mg/L NA 50 NA NA NA NA NA NA

Mercury 0.001 0.0006B / 0.1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Molybdenum 0.05 ID mg/L TBA 0.2 TBA TBA TBA TBA TBA TBA Nickel 0.02 0.011 / 1

(rec) mg/L NA 0.9 NA NA NA NA NA NA

Nitrate (as nitrate) 50 30 / 100 (rec) mg/L NA < 1 (NA) 1 2 0.1 1.4 1.1 1

Nitrite (as nitrite) 3 ID / 10 (rec) mg/L NA NA NA NA NA NA NA NA

Potassium3 No set

value mg/L NA 1 (NA) 0.4 2 0.6 2.3 1.0 0.4

Selenium 0.01 0.011B mg/L TBA 0.05 TBA TBA TBA TBA TBA TBA Silica2

No set value mg/L NA 11 (NA) 5 15 2.8 15.8 11 6.8

Silver 0.1 0.005 / 0.5 (rec) mg/L TBA 0.1 TBA TBA TBA TBA TBA TBA

Sodium ** 180 3000 (rec) mg/L NA 2 1 33 1.6 6 3 1.2 Sulfate 500 250 4000 (rec) mg/L NA < 1 (NA) 1 35 6.5 20 7.4 1.3 Tin ** ID mg/L TBA 0.1 TBA TBA TBA TBA TBA TBA Zinc * 3 0.08 / 50

(rec) mg/L NA 0.2 NA NA NA NA NA NA

Organic Compounds

Acrylamide 0.0002 ID mg/L NA NA NA NA NA NA NA NA Benzene 0.001 9 / 0.1

(rec) mg/L NST NST NST NST NST NST NST NST

Carbon tetrachloride 0.003 ID / 0.03 (rec) mg/L NA NA NA NA NA NA NA NA

B-198

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

Chlorobenzene 0.3 0.01 ID mg/L NST NST NST NST NST NST NST NST Dichlorobenzenes 1,2- dichlorobenzenes (1,2-DCB)

1.5 0.001 1.6 mg/L NST NST NST NST NST NST NST NST

1,3- dichlorobenzenes (1,3-DCB)

* 0.02 2.6 mg/L NST NST NST NST NST NST NST NST


0.04 0.0003 0.6 mg/L NST NST NST NST NST NST NST NST

Dichloroethanes 1,1-dichloroethane * ID / 0.003

(rec) mg/L NST NST NST NST NST NST NST NST

1,2-dichloroethane 0.003 ID / 0.1 (rec) mg/L NST NST NST NST NST NST NST NST

Dichloroethenes 1,1-dichloroethene (1,1-DCE) 0.03 ID mg/L NST NST NST NST NST NST NST NST

1,2-dichloroethene (1,2-DCE) 0.06 ID mg/L NST NST NST NST NST NST NST NST

Dichloromethane (methylene chloride) 0.004 ID mg/L NST NST NST NST NST NST NST NST

Epichlorohydrin 0.0005*** ID mg/L NA NA NA NA NA NA NA NA Ethylbenzene 0.3 0.003 ID mg/L NST NST NST NST NST NST NST NST Ethylenediamine tetraacetic acid 0.25 ID mg/L NST NST NST NST NST NST NST NST

Hexachlorobutadiene 0.0007 ID mg/L NST NST NST NST NST NST NST NST Nitrilotriacetic acid 0.2 ID mg/L NST NST NST NST NST NST NST NST Organotins dialkyltins * ID mg/L NST NST NST NST NST NST NST NST Tributyltin oxide 0.001 ID mg/L NST NST NST NST NST NST NST NST Plasticisers

B-199

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

di(2-ethyhexyl) phthalate 0.01 ID mg/L NA NA NA NA NA NA NA NA

di(2-ethyhexyl) adipate * ID mg/L NA NA NA NA NA NA NA NA

Polycyclic aromatic hydrocarbons (PAHs)

Benzo-(a)-pyrene 0.00001

IDB / 0.0001 (rec)

mg/L NA NA NA NA NA NA NA NA

Styrene (vinylbenzene) 0.03 0.004 ID mg/L NST NST NST NST NST NST NST NST

Tetrachloroethene 0.05 ID / 0.1 (rec) mg/L NST NST NST NST NST NST NST NST

Toluene 0.8 0.025 ID mg/L NA NA NA NA NA NA NA NA Trichlorobenzenes (total) 0.03 0.005 0.1B mg/L NST NST NST NST NST NST NST NST

1,1,1-Trichloroethane * ID / 0.3 (rec) mg/L NST NST NST NST NST NST NST NST

Trichloroethylene * ID mg/L NST NST NST NST NST NST NST NST Vinyl chloride 0.0003 ID mg/L NST NST NST NST NST NST NST NST Xylene 0.6 0.02 2 mg/L NA NA NA NA NA NA NA NA # Aesthetic values are not listed if the chemical/compound does not cause aesthetic problems, or if the value determined from health considerations is lower. * Insufficient data to set a guideline value based on health considerations. ** No health-based guideline value is considered necessary. *** The guideline value is below the limit of determination. Improved analytical procedures are required for this compound. ID Insufficient data to derive a reliable trigger value. Users advised to check if a low reliability value or an ECL is given in Section 8.3.7 of ANZECC WQG (2000). NA Not applicable. Testing of this characteristic in raw water is not considered necessary (refer ADWG) for water quality compliance or operational monitoring purposes. NST No scheduled test. Testing of this characteristic in raw water is not considered necessary based upon previous experience. Notes: 1. All values are as “total” unless otherwise stated. 2. Not a characteristic required to demonstrate compliance with the ADWG. A = Figure may not protect key test species from acute toxicity (and chronic) — check Section 8.3.7 for spread of data and its significance. ‘A’ indicates

that trigger value > acute toxicity figure; note that trigger value should be <1/3 of acute figure (Section 8.3.4.4) of ANZECC WQG (2000). B = Chemicals for which possible bioaccumulation and secondary poisoning effects should be considered (see Sections 8.3.3.4 and 8.3.5.7) of ANZECC WQG (2000).

B-200

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

C = Figure may not protect key test species from chronic toxicity (this refers to experimental chronic figures or geometric mean for species) — check Section 8.3.7 for spread of data and its significance. Where grey shading and ‘C’ coincide, refer to text in Section 8.3.7 of ANZECC WQG (2000).


Characteristic ADWG Guideline1

ADWG Health

Guideline2


Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

Pesticides Acephate 0.01 0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Aldicarb 0.001 0.001 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Aldrin3 (and dieldrin) 0.00001 0.0003 0.01 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Ametryn 0.005 0.05 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Amitrole3 0.001 0.01 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Asulam 0.05 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Atrazine3 0.0005 0.02 0.13 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Azinphos-methyl 0.002 0.003 0.0002 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Benomyl 0.1 2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bentazone 0.03 4 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bioresmethrin 0.1 0.6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bromacil 0.01 0.3 6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bromophos-ethyl 0.01 0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bromoxynil 0.03 0.3 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbaryl 0.005 0.03 0.6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbendazim 0.1 2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Carbofuran 0.005 0.01 0.012A / 0.3 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Carbophenothion 0.0005 0.01 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carboxin 0.002 0.3 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Chlordane3 0.00001 0.001 0.0008 / 0.06 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-201

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health

Guideline2


Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

Chlorfenvinphos 0.005 0.1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorothalonil 0.0001 0.03 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chloroxuron 0.01 0.3 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorpyrifos3 0.01 0.0001B mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorsulfuron 0.1 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Clopyralid 1 1 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA

2,4-D3 0.0001 0.03 2.8 / 1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

DDT3 0.00006 0.02 0.0001 / 0.03 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Diazinon 0.001 0.003 0.0001 / 0.01 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Dicamba 0.1 3 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dichlobenil 0.01 0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dichlorvos 0.001 0.001 0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diclofop-methyl 0.005 0.03 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dicofol 0.003 1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dieldrin3 (see Aldrin) 0.00001 0.0003 0.01 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Difenzoquat 0.1 2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dimethoate 0.05 0.0015 / 1

(rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Diphenamid 0.002 0.3 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diquat3

0.0005 0.005 0.014 / 0.1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Disulfotan 0.001 0.003 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diuron3 0.03 0.4 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA DPA (2,2-DPA) 0.5 5 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA EDB 0.001 0.001 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Endosulfan3


Endothal 0.01 0.1 6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA EPTC 0.001 0.03 0.6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Ethion 0.003 0.06 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-202

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health

Guideline2


Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

Ethoprophos 0.001 0.001 0.01 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Etridiazole 0.0001 0.1 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenamiphos 0.0003 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenarimol 0.001 0.03 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenchlorphos 0.03 0.6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenitrothion 0.01 0.002 /

0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Fenoprop 0.01 0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fensulfothion 0.01 0.01 0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenvalerate 0.05 0.4 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Flamprop-methyl 0.003 0.06 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fluometuron 0.05 1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Formothion 0.05 1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fosamine3 0.03 30 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Glyphosate 0.01 1 12 / 2


Heptachlor3 (including its epoxide)

0.00005 0.0003 0.0009B / 0.03 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Hexaflurate 0.03 0.6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Hexazinone3 0.002 0.3 6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Lindane3


Maldison 0.05 1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methidathion 0.03 0.6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methiocarb 0.005 0.005 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methomyl 0.005 0.03 0.035 /


Methoxychlor 0.0002 0.3 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Metolachlor 0.002 0.3 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Metribuzin 0.001 0.05 0.05 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Metsulfuron-methyl 0.03 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Mevinphos 0.005 0.005 0.06 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-203

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health

Guideline2


Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

Molinate3 0.0005 0.005 0.034 /


Monocrotophos 0.001 0.02 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Napropamide 0.001 1 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Nitralin 0.5 10 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Norflurazon 0.002 0.05 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Oryzalin 0.3 0.6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Oxamyl 0.005 0.1 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Paraquat3 0.001 0.03 0.4 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Parathion 0.01 0.00004 /


Parathion methyl 0.0003 0.1 0.06 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pebulate 0.0005 0.03 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pendimethalin 0.3 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pentachlorophenol 0.00001 0.01 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Permethrin 0.001 0.1 3 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Picloram3 0.3 0.3 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Piperonyl butoxide 0.1 2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pirimicarb 0.005 1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pirimiphos-ethyl 0.0005 0.01 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pirimiphos-methyl 0.05 0.6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Profenofos 0.0003 0.006


Promecarb 0.03 0.6 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propachlor 0.001 0.05 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propanil 0.0001 0.5 10 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propargite 0.05 10 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propazine 0.0005 0.05 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propiconazole3 0.0001 0.1 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propyzamide 0.002 0.3 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pyrazophos 0.03 10 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Quintozene 0.03 0.06 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Simazine 0.0005 0.02 0.032 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Sulprofos 0.01 0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-204

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health

Guideline2


Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

Silvex (see Fenoprop) 0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

2,4,5-T 0.00005 0.1 0.36 / 0.02 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Temephos3 0.3 0.3 0.3 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Terbacil 0.01 0.03 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Terbufos 0.0005 0.0005 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Terbutryn 0.001 0.3 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Tetrachlorvinphos 0.002 0.1 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiobencarb 0.03 0.028 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiometon 0.003 0.02 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiophanate 0.005 1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiram 0.003 0.002 /


Triadimefon 0.1 0.002 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA Trichlorfon 0.005 0.1 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Triclopyr 0.01 0.2 (rec) mg/L TBA TBA TBA TBA TBA TBA TBA TBA Trifluralin 0.0001 0.05 0.044 / 5


Vernolate 0.0005 0.03 ID mg/L TBA TBA TBA TBA TBA TBA TBA TBA ID Insufficient data to derive a reliable trigger value. Users advised to check if a low reliability value or an ECL is given in Section 8.3.7 of ANZECC WQG (2000). Notes: 1.These are generally based on the analytical limit of determination (the level at which the pesticide can be reliably detected using practicable readily available and

validated analytical methods). If a pesticide is detected at or above this value the source should be identified and action taken to prevent further contamination. 2.Based upon 10% of Acceptable Daily Intake (ADI). 3.These pesticides have either been detected on occasions in Australian drinking water or their likely use would indicate that they may occasionally be detected. A = Figure may not protect key test species from acute toxicity (and chronic) — check Section 8.3.7 for spread of data and its significance. ‘A’ indicates

that trigger value > acute toxicity figure; note that trigger value should be <1/3 of acute figure (Section 8.3.4.4) of ANZECC WQG (2000). B = Chemicals for which possible bioaccumulation and secondary poisoning effects should be considered (see Sections 8.3.3.4 and 8.3.5.7) of ANZECC WQG (2000). C = Figure may not protect key test species from chronic toxicity (this refers to experimental chronic figures or geometric mean for species) — check

Section 8.3.7 for spread of data and its significance. Where grey shading and ‘C’ coincide, refer to text in Section 8.3.7 of ANZECC WQG (2000).

B-205

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Raw Water Specification Donkey Camp (cont) – Radiological Quality


Guideline ADWG

AestheticGuideline# ANZECC Guideline Unit Spec Single

Data Min

Historical Max

Historical σ


% Mean

Historical

LCL 5 th %

Comments

Radiological Gross alpha activity concentration

0.5 ID / 0.1 (rec) Bq/L NST NST NST NST

Gross beta activity concentration

0.5 ID / 0.1 (rec) Bq/L NST NST NST NST

Radium 226 activity concentration

0.5 ID Bq/L NST NST NST NST


0.5 ID Bq/L NST NST NST NST

Radon 222 100 ID Bq/L NST NST NST NST Uranium

0.02 ID mg/L TBA TBA TBA TBA Sampled and tested annually as part of metals group

Unspecified alpha- & beta-emitters

0.1 ID mSv NST NST NST NST

# Aesthetic values are not listed if the chemical/compound does not cause aesthetic problems, or if the value determined from health considerations is lower. * Insufficient data to set a guideline value based on health considerations. ** No health-based guideline value is considered necessary. ID Insufficient data to derive a reliable trigger value. Users advised to check if a low reliability value or an ECL is given in Section 8.3.7 of ANZECC WQG (2000). NA Not applicable. Testing of this characteristic in raw water is not considered necessary (refer ADWG) for water quality compliance or operational monitoring purposes. NST No scheduled test. Testing of this characteristic in raw water is not considered necessary based upon previous experience. Notes: 1. All values are as “total” unless otherwise stated. 2. Not a characteristic required to demonstrate compliance with the ADWG.

B-206

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Raw Water Specification RN 6983 – Physical Quality


Guideline

ADWG Aesthetic Guideline

Unit Spec Single Data

Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Physical Alkalinity as CaCO32 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Conductivity2 μS/cm TBA TBA TBA TBA TBA TBA TBA TBA Dissolved oxygen ** >85 % NST NST NST NST NST NST NST NST Hardness as CaCO3 ** 200 mg/L TBA TBA TBA TBA TBA TBA TBA TBA pH * 6.5-8.5 TBA TBA TBA TBA TBA TBA TBA TBA Taste and odour ** Acceptable

to majority NA NA NA NA NA NA NA NA

Temperature ** No set value °C NA NA NA NA NA NA NA NA

Total dissolved solids ** 500 mg/L TBA TBA TBA TBA TBA TBA TBA TBA True colour ** 15 HU NST NST NST NST NST NST NST NST Turbidity * 5 NTU NST NST NST NST NST NST NST NST

Raw Water Specification RN 6983 (cont) – Chemical Quality


Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Chemical/Compounds Aluminium (acid-soluable) * 0.2 mg/L NA NA NA NA NA NA NA NA Ammonia (as NH3) * 0.5 mg/L NA NA NA NA NA NA NA NA Antimony 0.003 mg/L NA NA NA NA NA NA NA NA Arsenic 0.007 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Asbestos * mg/L NA NA NA NA NA NA NA NA Barium 0.7 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Beryllium * mg/L TBA TBA TBA TBA TBA TBA TBA TBA Boron 4 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Cadmium 0.002 mg/L NA NA NA NA NA NA NA NA Calcium2 mg/L NA NA NA NA NA NA NA NA Chloride ** 250 mg/L NA NA NA NA NA NA NA NA Chromium (as Cr(VI)) 0.05 mg/L NA NA NA NA NA NA NA NA Copper 2 1 mg/L NA NA NA NA NA NA NA NA

B-207

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Cyanide 0.08 mg/L NA NA NA NA NA NA NA NA Fluoride 1.5 mg/L NA NA NA NA NA NA NA NA Hydrogen sulfide * 0.05 mg/L NA NA NA NA NA NA NA NA Iodide 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Iron * 0.3 mg/L NA NA NA NA NA NA NA NA Lead 0.01 mg/L NA NA NA NA NA NA NA NA Magnesium2 mg/L NA NA NA NA NA NA NA NA Manganese 0.5 0.1 mg/L NA NA NA NA NA NA NA NA Mercury 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Molybdenum 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Nickel 0.02 mg/L NA NA NA NA NA NA NA NA Nitrate (as nitrate) 50 mg/L NA NA NA NA NA NA NA NA Nitrite (as nitrite) 3 mg/L NA NA NA NA NA NA NA NA Potassium3 mg/L NA NA NA NA NA NA NA NA Selenium 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Silica2 mg/L NA NA NA NA NA NA NA NA Silver 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Sodium ** 180 mg/L NA NA NA NA NA NA NA NA Sulfate 500 250 mg/L NA NA NA NA NA NA NA NA Tin ** mg/L TBA TBA TBA TBA TBA TBA TBA TBA Zinc * 3 mg/L NA NA NA NA NA NA NA NA Organic Compounds Acrylamide 0.0002 mg/L NA NA NA NA NA NA NA NA

Benzene 0.001 mg/L NST NST NST NST NST NST NST NST Carbon tetrachloride 0.003 mg/L NA NA NA NA NA NA NA NA Chlorobenzene 0.3 0.01 mg/L NST NST NST NST NST NST NST NST Dichlorobenzenes 1,2- dichlorobenzenes (1,2-DCB) 1.5 0.001 mg/L NST NST NST NST NST NST NST NST

1,3- dichlorobenzenes (1,3-DCB) * 0.02 mg/L NST NST NST NST NST NST NST NST

1,4- dichlorobenzenes (1,4-DCB) 0.04 0.0003 mg/L NST NST NST NST NST NST NST NST

Dichloroethanes

B-208

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

1,1-dichloroethane * mg/L NST NST NST NST NST NST NST NST 1,2-dichloroethane 0.003 mg/L NST NST NST NST NST NST NST NST Dichloroethenes 1,1-dichloroethene (1,1-DCE) 0.03 mg/L NST NST NST NST NST NST NST NST

1,2-dichloroethene (1,2-DCE) 0.06 mg/L NST NST NST NST NST NST NST NST

Dichloromethane (methylene chloride) 0.004 mg/L NST NST NST NST NST NST NST NST

Epichlorohydrin 0.0005*** mg/L NA NA NA NA NA NA NA NA Ethylbenzene 0.3 0.003 mg/L NST NST NST NST NST NST NST NST Ethylenediamine tetraacetic acid 0.25 mg/L NST NST NST NST NST NST NST NST

Hexachlorobutadiene 0.0007 mg/L NST NST NST NST NST NST NST NST Nitrilotriacetic acid 0.2 mg/L NST NST NST NST NST NST NST NST Organotins dialkyltins * mg/L NST NST NST NST NST NST NST NST Tributyltin oxide 0.001 mg/L NST NST NST NST NST NST NST NST Plasticisers di(2-ethyhexyl) phthalate 0.01 mg/L NA NA NA NA NA NA NA NA di(2-ethyhexyl) adipate * mg/L NA NA NA NA NA NA NA NA Polycyclic aromatic hydrocarbons (PAHs)

Benzo-(a)-pyrene 0.00001 mg/L NA NA NA NA NA NA NA NA Styrene (vinylbenzene) 0.03 0.004 mg/L NST NST NST NST NST NST NST NST Tetrachloroethene 0.05 mg/L NST NST NST NST NST NST NST NST Toluene 0.8 0.025 mg/L NA NA NA NA NA NA NA NA Trichlorobenzenes (total) 0.03 0.005 mg/L NST NST NST NST NST NST NST NST 1,1,1-Trichloroethane * mg/L NST NST NST NST NST NST NST NST Trichloroethylene * mg/L NST NST NST NST NST NST NST NST Vinyl chloride 0.0003 mg/L NST NST NST NST NST NST NST NST Xylene 0.6 0.02 mg/L NA NA NA NA NA NA NA NA # Aesthetic values are not listed if the chemical/compound does not cause aesthetic problems, or if the value determined from health considerations is lower. * Insufficient data to set a guideline value based on health considerations. ** No health-based guideline value is considered necessary.

B-209

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

*** The guideline value is below the limit of determination. Improved analytical procedures are required for this compound. NA Not applicable. Testing of this characteristic in raw water is not considered necessary (refer ADWG) for water quality compliance or operational monitoring purposes. NST No scheduled test. Testing of this characteristic in raw water is not considered necessary based upon previous experience. Notes: 1. All values are as “total” unless otherwise stated. 2. Not a characteristic required to demonstrate compliance with the ADWG.



ADWG Health

Guideline2 Unit Spec Single

Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Pesticides Acephate 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Aldicarb 0.001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Aldrin3 (and dieldrin) 0.00001 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Ametryn 0.005 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Amitrole3 0.001 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Asulam 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Atrazine3 0.0005 0.02 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Azinphos-methyl 0.002 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Benomyl 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bentazone 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bioresmethrin 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bromacil 0.01 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bromophos-ethyl 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bromoxynil 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbaryl 0.005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbendazim 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbofuran 0.005 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbophenothion 0.0005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carboxin 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlordane3 0.00001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorfenvinphos 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-210

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health


Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Chlorothalonil 0.0001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chloroxuron 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorpyrifos3 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorsulfuron 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Clopyralid 1 1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA 2,4-D3 0.0001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA DDT3 0.00006 0.02 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diazinon 0.001 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dicamba 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dichlobenil 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dichlorvos 0.001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diclofop-methyl 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dicofol 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dieldrin3 (see Aldrin) 0.00001 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Difenzoquat 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dimethoate 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diphenamid 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diquat3 0.0005 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Disulfotan 0.001 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diuron3 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA DPA (2,2-DPA) 0.5 mg/L TBA TBA TBA TBA TBA TBA TBA TBA EDB 0.001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Endosulfan3 0.00005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Endothal 0.01 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA EPTC 0.001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Ethion 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Ethoprophos 0.001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Etridiazole 0.0001 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenamiphos 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenarimol 0.001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenchlorphos 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenitrothion 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenoprop 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fensulfothion 0.01 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-211

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health


Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Fenvalerate 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Flamprop-methyl 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fluometuron 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Formothion 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fosamine3 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Glyphosate 0.01 1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Heptachlor3 (including its epoxide) 0.00005 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Hexaflurate 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Hexazinone3 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Lindane3 0.00005 0.02 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Maldison 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methidathion 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methiocarb 0.005 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methomyl 0.005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methoxychlor 0.0002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Metolachlor 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Metribuzin 0.001 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Metsulfuron-methyl 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Mevinphos 0.005 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Molinate3 0.0005 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Monocrotophos 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Napropamide 0.001 1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Nitralin 0.5 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Norflurazon 0.002 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Oryzalin 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Oxamyl 0.005 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Paraquat3 0.001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Parathion 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Parathion methyl 0.0003 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pebulate 0.0005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pendimethalin 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pentachlorophenol 0.00001 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Permethrin 0.001 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-212

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health


Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Picloram3 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Piperonyl butoxide 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pirimicarb 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pirimiphos-ethyl 0.0005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pirimiphos-methyl 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Profenofos 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Promecarb 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propachlor 0.001 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propanil 0.0001 0.5 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propargite 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propazine 0.0005 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propiconazole3 0.0001 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propyzamide 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pyrazophos 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Quintozene 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Simazine 0.0005 0.02 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Sulprofos 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Silvex (see Fenoprop) mg/L TBA TBA TBA TBA TBA TBA TBA TBA 2,4,5-T 0.00005 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Temephos3 0.3 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Terbacil 0.01 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Terbufos 0.0005 0.0005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Terbutryn 0.001 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Tetrachlorvinphos 0.002 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiobencarb 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiometon 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiophanate 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiram 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Triadimefon 0.1 0.002 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Trichlorfon 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Triclopyr 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Trifluralin 0.0001 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Vernolate 0.0005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-213

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health


Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Notes: 1.These are generally based on the analytical limit of determination (the level at which the pesticide can be reliably detected using practicable readily available and validated analytical methods). If a pesticide is detected at or above this value the source should be identified and action taken to prevent further contamination.

2.Based upon 10% of Acceptable Daily Intake (ADI). 3.These pesticides have either been detected on occasions in Australian drinking water or their likely use would indicate that they may occasionally be detected.

Raw Water Specification RN 6983 (cont) – Radiological Quality


Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Radiological Gross alpha activity concentration 0.5 Bq/L TBA TBA TBA TBA TBA TBA TBA TBA

Gross beta activity concentration 0.5 Bq/L TBA TBA TBA TBA TBA TBA TBA TBA

Radium 226 activity concentration 0.5 Bq/L TBA TBA TBA TBA TBA TBA TBA TBA

Radium 228 activity concentration 0.5 Bq/L TBA TBA TBA TBA TBA TBA TBA TBA

Radon 222 100 Bq/L NST NST NST NST NST NST NST NST Uranium

0.02 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Sampled and tested annually as part of metals group

Unspecified alpha- & beta-emitters 0.1 mSv NST NST NST NST NST NST NST NST

# Aesthetic values are not listed if the chemical/compound does not cause aesthetic problems, or if the value determined from health considerations is lower. * Insufficient data to set a guideline value based on health considerations. ** No health-based guideline value is considered necessary. NA Not applicable. Testing of this characteristic in raw water is not considered necessary (refer ADWG) for water quality compliance or operational monitoring purposes. NST No scheduled test. Testing of this characteristic in raw water is not considered necessary based upon previous experience. Notes: 1. All values are as “total” unless otherwise stated. 2. Not a characteristic required to demonstrate compliance with the ADWG.

B-214

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Raw Water Specification RN 7807 – Physical Quality


Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Physical Alkalinity as CaCO32 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Conductivity2 μS/cm NA NA NA NA NA NA NA NA Dissolved oxygen ** >85 % NST NST NST NST NST NST NST NST Hardness as CaCO3 ** 200 mg/L TBA TBA TBA TBA TBA TBA TBA TBA pH * 6.5-8.5 TBA TBA TBA TBA TBA TBA TBA TBA Taste and odour ** Acceptable

to majority NA NA NA NA NA NA NA NA


°C NA NA NA NA NA NA NA NA

Total dissolved solids ** 500 mg/L NA NA NA NA NA NA NA NA True colour ** 15 HU NST NST NST NST NST NST NST NST Turbidity * 5 NTU NST NST NST NST NST NST NST NST



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Chemical/Compounds Aluminium (acid-soluable) * 0.2 mg/L NA NA NA NA NA NA NA NA Ammonia (as NH3) * 0.5 mg/L NA NA NA NA NA NA NA NA Antimony 0.003 mg/L NA NA NA NA NA NA NA NA Arsenic 0.007 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Asbestos * mg/L NA NA NA NA NA NA NA NA Barium 0.7 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Beryllium * mg/L TBA TBA TBA TBA TBA TBA TBA TBA Boron 4 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Cadmium 0.002 mg/L NA NA NA NA NA NA NA NA Calcium2 mg/L NA NA NA NA NA NA NA NA Chloride ** 250 mg/L NA 3 NA NA NA NA NA NA Chromium (as Cr(VI)) 0.05 mg/L NA NA NA NA NA NA NA NA Copper 2 1 mg/L NA NA NA NA NA NA NA NA

B-215

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Cyanide 0.08 mg/L NA NA NA NA NA NA NA NA Fluoride 1.5 mg/L NA NA NA NA NA NA NA NA Hydrogen sulfide * 0.05 mg/L NA NA NA NA NA NA NA NA Iodide 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Iron * 0.3 mg/L NA NA NA NA NA NA NA NA Lead 0.01 mg/L NA NA NA NA NA NA NA NA Magnesium2 mg/L NA NA NA NA NA NA NA NA Manganese 0.5 0.1 mg/L NA NA NA NA NA NA NA NA Mercury 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Molybdenum 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Nickel 0.02 mg/L NA NA NA NA NA NA NA NA Nitrate (as nitrate) 50 mg/L NA NA NA NA NA NA NA NA Nitrite (as nitrite) 3 mg/L NA NA NA NA NA NA NA NA Potassium3 mg/L NA NA NA NA NA NA NA NA Selenium 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Silica2 mg/L NA NA NA NA NA NA NA NA Silver 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Sodium ** 180 mg/L NA NA NA NA NA NA NA NA Sulfate 500 250 mg/L NA NA NA NA NA NA NA NA Tin ** mg/L TBA TBA TBA TBA TBA TBA TBA TBA Zinc * 3 mg/L NA NA NA NA NA NA NA NA Organic Compounds Acrylamide 0.0002 mg/L NA NA NA NA NA NA NA NA Benzene 0.001 mg/L NST NST NST NST NST NST NST NST Carbon tetrachloride 0.003 mg/L NA NA NA NA NA NA NA NA Chlorobenzene 0.3 0.01 mg/L NST NST NST NST NST NST NST NST Dichlorobenzenes 1,2- dichlorobenzenes (1,2-DCB)

1.5 0.001 mg/L NST NST NST NST NST NST NST NST


* 0.02 mg/L NST NST NST NST NST NST NST NST


0.04 0.0003 mg/L NST NST NST NST NST NST NST NST

Dichloroethanes 1,1-dichloroethane * mg/L NST NST NST NST NST NST NST NST

B-216

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

1,2-dichloroethane 0.003 mg/L NST NST NST NST NST NST NST NST Dichloroethenes 1,1-dichloroethene (1,1-DCE)

0.03 mg/L NST NST NST NST NST NST NST NST

1,2-dichloroethene (1,2-DCE)


Dichloromethane (methylene chloride)


Epichlorohydrin 0.0005*** mg/L NA NA NA NA NA NA NA NA Ethylbenzene 0.3 0.003 mg/L NST NST NST NST NST NST NST NST Ethylenediamine tetraacetic acid


Hexachlorobutadiene 0.0007 mg/L NST NST NST NST NST NST NST NST Nitrilotriacetic acid 0.2 mg/L NST NST NST NST NST NST NST NST Organotins dialkyltins * mg/L NST NST NST NST NST NST NST NST Tributyltin oxide 0.001 mg/L NST NST NST NST NST NST NST NST Plasticisers di(2-ethyhexyl) phthalate 0.01 mg/L NA NA NA NA NA NA NA NA di(2-ethyhexyl) adipate * mg/L NA NA NA NA NA NA NA NA Polycyclic aromatic hydrocarbons (PAHs)

Benzo-(a)-pyrene 0.00001 mg/L NA NA NA NA NA NA NA NA Styrene (vinylbenzene) 0.03 0.004 mg/L NST NST NST NST NST NST NST NST Tetrachloroethene 0.05 mg/L NST NST NST NST NST NST NST NST Toluene 0.8 0.025 mg/L NA NA NA NA NA NA NA NA Trichlorobenzenes (total) 0.03 0.005 mg/L NST NST NST NST NST NST NST NST 1,1,1-Trichloroethane * mg/L NST NST NST NST NST NST NST NST Trichloroethylene * mg/L NST NST NST NST NST NST NST NST Vinyl chloride 0.0003 mg/L NST NST NST NST NST NST NST NST Xylene 0.6 0.02 mg/L NA NA NA NA NA NA NA NA # Aesthetic values are not listed if the chemical/compound does not cause aesthetic problems, or if the value determined from health considerations is lower. * Insufficient data to set a guideline value based on health considerations. ** No health-based guideline value is considered necessary. *** The guideline value is below the limit of determination. Improved analytical procedures are required for this compound.

B-217

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

NA Not applicable. Testing of this characteristic in raw water is not considered necessary (refer ADWG) for water quality compliance or operational monitoring purposes. NST No scheduled test. Testing of this characteristic in raw water is not considered necessary based upon previous experience. Notes: 1. All values are as “total” unless otherwise stated. 2. Not a characteristic required to demonstrate compliance with the ADWG.



ADWG Health


Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Pesticides Acephate 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Aldicarb 0.001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Aldrin3 (and dieldrin) 0.00001 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Ametryn 0.005 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Amitrole3 0.001 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Asulam 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Atrazine3 0.0005 0.02 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Azinphos-methyl 0.002 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Benomyl 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bentazone 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bioresmethrin 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bromacil 0.01 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bromophos-ethyl 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Bromoxynil 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbaryl 0.005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbendazim 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbofuran 0.005 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carbophenothion 0.0005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Carboxin 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlordane3 0.00001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorfenvinphos 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorothalonil 0.0001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-218

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health


Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Chloroxuron 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorpyrifos3 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Chlorsulfuron 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Clopyralid 1 1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA 2,4-D3 0.0001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA DDT3 0.00006 0.02 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diazinon 0.001 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dicamba 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dichlobenil 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dichlorvos 0.001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diclofop-methyl 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dicofol 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dieldrin3 (see Aldrin) 0.00001 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Difenzoquat 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Dimethoate 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diphenamid 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diquat3 0.0005 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Disulfotan 0.001 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Diuron3 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA DPA (2,2-DPA) 0.5 mg/L TBA TBA TBA TBA TBA TBA TBA TBA EDB 0.001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Endosulfan3 0.00005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Endothal 0.01 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA EPTC 0.001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Ethion 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Ethoprophos 0.001 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Etridiazole 0.0001 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenamiphos 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenarimol 0.001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenchlorphos 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenitrothion 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenoprop 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fensulfothion 0.01 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fenvalerate 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-219

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health


Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Flamprop-methyl 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fluometuron 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Formothion 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Fosamine3 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Glyphosate 0.01 1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Heptachlor3 (including its epoxide)

0.00005 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA

Hexaflurate 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Hexazinone3 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Lindane3 0.00005 0.02 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Maldison 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methidathion 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methiocarb 0.005 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methomyl 0.005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Methoxychlor 0.0002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Metolachlor 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Metribuzin 0.001 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Metsulfuron-methyl 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Mevinphos 0.005 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Molinate3 0.0005 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Monocrotophos 0.001 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Napropamide 0.001 1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Nitralin 0.5 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Norflurazon 0.002 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Oryzalin 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Oxamyl 0.005 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Paraquat3 0.001 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Parathion 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Parathion methyl 0.0003 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pebulate 0.0005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pendimethalin 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pentachlorophenol 0.00001 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Permethrin 0.001 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Picloram3 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA

B-220

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health


Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Piperonyl butoxide 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pirimicarb 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pirimiphos-ethyl 0.0005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pirimiphos-methyl 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Profenofos 0.0003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Promecarb 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propachlor 0.001 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propanil 0.0001 0.5 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propargite 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propazine 0.0005 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propiconazole3 0.0001 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Propyzamide 0.002 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Pyrazophos 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Quintozene 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Simazine 0.0005 0.02 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Sulprofos 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Silvex (see Fenoprop) mg/L TBA TBA TBA TBA TBA TBA TBA TBA 2,4,5-T 0.00005 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Temephos3 0.3 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Terbacil 0.01 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Terbufos 0.0005 0.0005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Terbutryn 0.001 0.3 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Tetrachlorvinphos 0.002 0.1 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiobencarb 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiometon 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiophanate 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Thiram 0.003 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Triadimefon 0.1 0.002 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Trichlorfon 0.005 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Triclopyr 0.01 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Trifluralin 0.0001 0.05 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Vernolate 0.0005 0.03 mg/L TBA TBA TBA TBA TBA TBA TBA TBA Notes: 1.These are generally based on the analytical limit of determination (the level at which the pesticide can be reliably detected using practicable readily available and

validated analytical methods). If a pesticide is detected at or above this value the source should be identified and action taken to prevent further contamination.

B-221

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



ADWG Health


Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

2.Based upon 10% of Acceptable Daily Intake (ADI). 3.These pesticides have either been detected on occasions in Australian drinking water or their likely use would indicate that they may occasionally be detected.

B-222

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Raw Water Specification RN 7807 (cont) – Radiological Quality


Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments


0.5 Bq/L TBA TBA TBA TBA TBA TBA TBA TBA







Radon 222 100 Bq/L NST NST NST NST NST NST NST NST Uranium 0.02 mg/L

TBA TBA TBA TBA TBA TBA TBA TBA Sampled and tested annually as part of metals group

Unspecified alpha- & beta-emitters

0.1 mSv NST NST NST NST NST NST NST NST

# Aesthetic values are not listed if the chemical/compound does not cause aesthetic problems, or if the value determined from health considerations is lower. * Insufficient data to set a guideline value based on health considerations. ** No health-based guideline value is considered necessary. NA Not applicable. Testing of this characteristic in raw water is not considered necessary (refer ADWG) for water quality compliance or operational monitoring purposes. NST No scheduled test. Testing of this characteristic in raw water is not considered necessary based upon previous experience. Notes: 1. All values are as “total” unless otherwise stated. 2. Not a characteristic required to demonstrate compliance with the ADWG.

B-223

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Appendix 2

Finished Product Specification – Microbiological Quality

Characteristic ADWG Guideline Unit Spec Single

Data Min

Historical Max

Historical σ


% Mean

Historical LCL

5 th % Comments

Indicator micro-organism

E. coli

None detected in minimum 98% of scheduled samples

org/ 100 mL

98% 98.8%3 TBA TBA TBA TBA TBA TBA

Monitored for and reported against for compliance purposes

Hetero-trophic plate count (HPC) CFU/100 mL < 1000

CFU/ 100 mL


Monitoring undertaken for operational purposes only and not for compliance purposes. Reported3 as 95.7% < 1000 CFU/100 mL. ADWG (1996) recommendation.

Total coliforms


org/ 100 mL


Monitoring of this characteristic for compliance purposes is not included in ADWG (2003). Monitoring continuing during 2003/2004 for operational purposes

Thermotolerant coliforms (i.e. faecal coliforms)


org/ 100 mL

98% TBA TBA TBA TBA TBA TBA TBA

Monitored for operational purposes

B-224

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Finished Product Specification (cont) – Physical Quality


Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Physical Alkalinity as CaCO32 mg/L TBA 983 TBA TBA TBA TBA TBA TBA Conductivity2 μS/cm TBA 2153 TBA TBA TBA TBA TBA TBA Dissolved oxygen ** >85 % >85 TBA TBA TBA TBA TBA TBA TBA Hardness as CaCO3 ** 200 mg/L ≤ 100 1003 TBA TBA TBA TBA TBA TBA pH * 6.5-8.5 ≥ 6.5 ≤

8.5 7.23 TBA TBA TBA TBA TBA TBA

Taste and odour ** Acceptable to majority

- - - - - - - -


°C - TBA TBA TBA TBA TBA TBA TBA

Total dissolved solids ** 500 mg/L ≤ 500 1253 TBA TBA TBA TBA TBA TBA True colour ** 15 HU ≤ 15 TBA TBA TBA TBA TBA TBA TBA Turbidity * 5 NTU ≤ 5 TBA TBA TBA TBA TBA TBA TBA

Finished Product Specification (cont) – Chemical Quality


Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Chemical/Compounds Aluminium (acid-soluable) * 0.2 mg/L ≤ 0.2 0.023 TBA TBA TBA TBA TBA TBA Ammonia (as NH3) * 0.5 mg/L - NST NST NST NST NST NST NST Antimony 0.003 mg/L ≤ 0.003 0.0013 TBA TBA TBA TBA TBA TBA Arsenic 0.007 mg/L ≤ 0.007 0.00053 TBA TBA TBA TBA TBA TBA Asbestos * mg/L - NST NST NST NST NST NST NST Barium 0.7 mg/L ≤ 0.7 0.023 TBA TBA TBA TBA TBA TBA Beryllium * mg/L - 0.00053 TBA TBA TBA TBA TBA TBA Boron 4 mg/L ≤ 4 0.013 TBA TBA TBA TBA TBA TBA Bromide2 mg/L - 0.843 TBA TBA TBA TBA TBA TBA Calcium2 mg/L - 23.03 TBA TBA TBA TBA TBA TBA Cadmium 0.002 mg/L ≤ 0.002 0.00013 TBA TBA TBA TBA TBA TBA

B-225

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Chloride ** 250 mg/L ≤ 250 53 TBA TBA TBA TBA TBA TBA Chromium (as Cr(VI)) 0.05 mg/L ≤ 0.05 0.0023 TBA TBA TBA TBA TBA TBA Copper 2 1 mg/L ≤ 1 0.0153 TBA TBA TBA TBA TBA TBA Cyanide 0.08 mg/L - NST NST NST NST NST NST NST Fluoride 1.5 mg/L ≤ 1.5 0.63 TBA TBA TBA TBA TBA TBA Hydrogen sulfide * 0.05 mg/L - NST NST NST NST NST NST NST Iodide 0.1 mg/L ≤ 0.1 0.053 TBA TBA TBA TBA TBA TBA Iron * 0.3 mg/L ≤ 0.3 0.0753 TBA TBA TBA TBA TBA TBA Lead 0.01 mg/L ≤ 0.01 0.0013 TBA TBA TBA TBA TBA TBA Magnesium2 mg/L - 10.03 TBA TBA TBA TBA TBA TBA Manganese 0.5 0.1 mg/L ≤ 0.1 0.0023 TBA TBA TBA TBA TBA TBA Mercury 0.001 mg/L ≤ 0.001 0.000053 TBA TBA TBA TBA TBA TBA Molybdenum 0.05 mg/L ≤ 0.05 0.0023 TBA TBA TBA TBA TBA TBA Nickel 0.02 mg/L ≤ 0.02 0.00013 TBA TBA TBA TBA TBA TBA Nitrate (as nitrate) 50 mg/L ≤ 50 0.83 TBA TBA TBA TBA TBA TBA Nitrite (as nitrite) 3 mg/L - DNA - - - - - - Potassium2 mg/L - 1.03 TBA TBA TBA TBA TBA TBA Selenium 0.01 mg/L ≤ 0.01 0.00053 TBA TBA TBA TBA TBA TBA Silica2 mg/L - 12.53 TBA TBA TBA TBA TBA TBA Silver 0.1 mg/L ≤ 0.1 0.0033 TBA TBA TBA TBA TBA TBA Sodium ** 180 mg/L ≤ 180 9.03 TBA TBA TBA TBA TBA TBA Sulfate 500 250 mg/L ≤ 250 9.53 TBA TBA TBA TBA TBA TBA Tin ** mg/L - 0.00053 TBA TBA TBA TBA TBA TBA Zinc * 3 mg/L ≤ 3 0.013 TBA TBA TBA TBA TBA TBA Organic compounds Acrylamide 0.0002 mg/L - NST NST NST NST NST NST NST Benzene 0.001 mg/L - NA NA NA NA NA NA NA Carbon tetrachloride 0.003 mg/L - NST NST NST NST NST NST NST Chlorobenzene 0.3 0.01 mg/L - NA NA NA NA NA NA NA Dichlorobenzenes 1,2- dichlorobenzenes (1,2-DCB)

1.5 0.001 mg/L - NA NA NA NA NA NA NA


* 0.02 mg/L - NA NA NA NA NA NA NA

B-226

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments


0.04 0.0003 mg/L - NA NA NA NA NA NA NA

Dichloroethanes 1,1-dichloroethane * mg/L - NA NA NA NA NA NA NA 1,2-dichloroethane 0.003 mg/L - NA NA NA NA NA NA NA Dichloroethenes 1,1-dichloroethene (1,1-DCE)

0.03 mg/L - NA NA NA NA NA NA NA

1,2-dichloroethene (1,2-DCE)


Dichloromethane (methylene chloride)


Epichlorohydrin 0.0005*** mg/L - NST NST NST NST NST NST NST Ethylbenzene 0.3 0.003 mg/L - NA NA NA NA NA NA NA Ethylenediamine tetraacetic acid


Hexachlorobutadiene 0.0007 mg/L - NA NA NA NA NA NA NA Nitrilotriacetic acid 0.2 mg/L - NA NA NA NA NA NA NA Organotins dialkyltins * mg/L - NA NA NA NA NA NA NA Tributyltin oxide 0.001 mg/L - NA NA NA NA NA NA NA Plasticisers di(2-ethyhexyl) phthalate 0.01 mg/L - NST NST NST NST NST NST NST di(2-ethyhexyl) adipate * mg/L - NST NST NST NST NST NST NST Polycyclic aromatic hydrocarbons (PAHs)

Benzo-(a)-pyrene 0.00001 mg/L - NST NST NST NST NST NST NST Styrene (vinylbenzene) 0.03 0.004 mg/L - NA NA NA NA NA NA NA Tetrachloroethene 0.05 mg/L - NA NA NA NA NA NA NA Toluene 0.8 0.025 mg/L - NST NST NST NST NST NST NST Trichlorobenzenes (total) 0.03 0.005 mg/L - NA NA NA NA NA NA NA 1,1,1-Trichloroethane * mg/L - NA NA NA NA NA NA NA Trichloroethylene * mg/L - NA NA NA NA NA NA NA Vinyl chloride 0.0003 mg/L - NA NA NA NA NA NA NA Xylene 0.6 0.02 mg/L - NST NST NST NST NST NST NST

B-227

©2006 A

ww

aRF

. All R

igh

ts Reserved

.



Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments

Disinfection agents/inorganic by-products

Resulting from chlorination

Chlorine 5 0.6 mg/L ≤ 0.6 TBA TBA TBA TBA TBA TBA TBA Organic disinfection by-products

Resulting from

chlorination

Chlorinated furanones * mg/L - NST NST NST NST NST NST NST Chloroacetic acids chloroacetic acid 0.15 mg/L - NST NST NST NST NST NST NST dichloroacetic acid 0.1 mg/L - NST NST NST NST NST NST NST trichloroacetic acid 0.1 mg/L - NST NST NST NST NST NST NST Chloroketones 1,1-dichloropropanone * mg/L - NST NST NST NST NST NST NST 1,3-dichloropropanone * mg/L - NST NST NST NST NST NST NST 1,1,1-trichloropropanone * mg/L - NST NST NST NST NST NST NST 1,1,3-trichloropropanone * mg/L - NST NST NST NST NST NST NST Chlorophenols 2-chlorophenol 0.3 0.0001 mg/L - NST NST NST NST NST NST NST 2,4-dichlorophenol 0.2 0.0003 mg/L - NST NST NST NST NST NST NST 2,4,6-trichlorophenol 0.02 0.002 mg/L - NST NST NST NST NST NST NST Chloropicrin * mg/L - NST NST NST NST NST NST NST Haloacetonitriles dichloroacetonitrile * mg/L - NST NST NST NST NST NST NST trichloroacetonitrile * mg/L - NST NST NST NST NST NST NST dibromoacetonitrile * mg/L - NST NST NST NST NST NST NST bromochloroacetonitrile * mg/L - NST NST NST NST NST NST NST Trichloroacetaldehyde (chloral hydrate) 0.02 mg/L - NST NST NST NST NST NST NST

Trihalommethanes 0.25 mg/L - 0.043 TBA TBA TBA TBA TBA TBA

B-228

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Finished Product Specification (cont) – Radiological Quality


Guideline



Min Historical

Max Historical

σ Historical

UCL 95 th

% Mean

Historical LCL

5 th % Comments









Radon 222 100 Bq/L NST NST NST NST NST NST NST NST Uranium 0.02 mg/L ≤ 0.02 0.00013 TBA TBA TBA TBA TBA TBA Unspecified alpha- & beta-emitters

0.1 mSv NST NST NST NST NST NST NST NST

# Aesthetic values are not listed if the chemical/compound does not cause aesthetic problems, or if the value determined from health considerations is lower. * Insufficient data to set a guideline value based on health considerations. ** No health-based guideline value is considered necessary. NA Not applicable. Testing of this characteristic in the finished product is not considered necessary (refer ADWG) for water quality compliance or operational monitoring

purposes. NST No scheduled test. Testing of this characteristic in the finished product is not considered necessary based upon previous experience. Notes: 1. All values are as “total” unless otherwise stated. 2. Not a characteristic required to demonstrate compliance with the ADWG. 3. Average value reported inPower and Water Water Quality Report 2003.

B-229

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Appendix 3

Workshops Work Telephone Attended Work Facsimile


Name Organisation

Organisation Position Expertise/Knowledge

1 2 Work E-mail Jason Bird 08 8973 8731 Power and Water Corporation 08 8973 8733

Service Worker Katherine water supply system operation Y Y

[email protected]


Doug Bridson 08 8924 5102 Power and Water Corporation 08 8924 5166

AME Standard operating procedure development Y N

[email protected]



WQS1 Water quality, water quality monitoring Y Y

[email protected]


Simon Copley 08 8924 5047 Power and Water Corporation 08 8924 5033

AMC N N

[email protected]



MWO Y Y

[email protected]


Darryl Day 08 8924 7002 Power and Water Corporation 08 8924 7161

GMWS Y N

[email protected]


Daniel Deere 02 9871 1353 CRCWQT Program Leader 02 9871 7009 Sydney Catchment Authority (formerly)

Principal Scientist and Manager, Science and Research

Drinking water risk management Drinking water microbiology Application of HACCP methodology to drinking water Quantitative microbiological risk assessment Y N [email protected]

32 Sirius Street DUNDAS NSW 2117 Sydney

Pritha Hariram 08 8924 7096 Power and Water Corporation 08 8924 7161

WQO Y N

[email protected]



MWF Y Y

[email protected]


B-230

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Workshops Work Telephone

Attended Work Facsimile Name Organisation

Organisation Position Expertise/Knowledge

1 2 Work E-mail



Katherine WTP operation Katherine water supply system operation Y Y

[email protected]



PM HACCP Strategic products and materials Cross-connection control and backflow prevention Quality management systems/documentation, specification writing

Y Y [email protected]




Environmental health Y Y

[email protected]


Joanne Mullenger 03 9552 3740 CRCWQT Project Engineer 03 9552 3625 South East Water Ltd Engineer Asset

Planning

Development, implementation and management of HACCP plans Quality management systems Y N

[email protected]

P O Box 1382 MOORABBIN VIC 3189 Melbourne


WC (Katherine) Katherine water supply system operation and management Y Y

[email protected]



SRP Y N

[email protected]


Melita Stevens 03 9235 7220 CRCWQT Co-Principal

Investigator & Project Manager

03 9235 7226

Mellbourne Water Corporation Principal Scientist

Drinking water risk management Drinking water microbiology Application of HACCP methodology to drinking water Y N

[email protected]

P O Box 4342 MELBOURNE VIC 3001 Melbourne

Table 12: Katherine HACCP Workshop Attendees

B-231

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

B-232

Appendix 4 Project Responsibilities HACCP Project Sponsor The responsibilities of the HACCP Project Sponsor are: Be chief champion of the project Have accountability for the project and ongoing accountability for the outcomes Chair the project Steering Group Advocate the project internally and externally Facilitate and support policy and funding recommendations Provide overview and direction for the project Resolve issues identified by the project manager when requested and agreed Support the project manager in carrying out the project Monitor the project budget Ensure the deliberations of the project are adequately recorded and available to appropriate parties

HACCP Project Steering Group Specific responsibilities of the HACCP Project Steering Group are to: Direct attention to the HACCP project at a strategic level Receive reports from the HACCP Project Co-ordination Group and project manager Make strategic decisions where required Ensure appropriate resourcing of the HACCP project Provide guidance to the project manager Resolve policy issues Escalate issues where required Consider and approve individual HACCP plans Review HACCP project implementation progress and issues with the project manager Monitor project expenditure Ensure the alignment of other supporting programs with the HACCP project Report on the progress of development and implementation of supporting programs Ensure the strategic integration of the HACCP system with other management systems (e.g. ISO 9001)

Clients Clients are required to: Participate as a member of the HACCP Project Steering Group Ensure that client needs are addressed to satisfaction in the project

Project Manager Specific responsibilities of the Project Manager HACCP are to:


B-233

Prepare a detailed project plan addressing the uptake of HACCP by Water Services Identify project risks and plan for their management Once approved and implemented monitor performance against the project plan(s) Manage project schedule and highlight areas of slippage and identify/initiate corrective actions Ensure the operational integration of the HACCP system with other management systems (e.g. ISO

9001) Ensure the project’s overall objectives, targets at various key stages, and individuals’ responsibilities

are clearly understood by all concerned Direct and manage HACCP team members Ensure project meets requirements and objectives Prepare project status reports and change requests for the HACCP Steering Group Negotiate and resolve issues as they arise across areas of the project and where they impact on other

Water Services activities, systems and projects Report strategic issues from the project Co-ordination Group to the Steering Group Take advice from the Steering Group to the project Co-ordination Group Organise and chair HACCP project Co-ordination Group meetings, as appropriate Organise and facilitate HACCP team meetings, as appropriate Ensure appropriate communication between/to project participants including sponsor, clients, members

of the 1) HACCP teams 2) HACCP Co-ordination Group, as well as other project stakeholders and involved parties

Maintain project documentation Assist with development and refinement of HACCP plans prepared by HACCP teams Coordinate auditing of the HACCP system including all HACCP plans Consider the results of audit reports and initiate action upon recommendations Coordinate the review of HACCP plans

Auditors Auditors are required to: Undertake the auditing HACCP plans or specifically use of systems, procedures etc. Provide advice on controls

HACCP Project Co-ordination Group HACCP Project Co-ordination Group members shall: Bring operational issues from their areas to the Co-ordination Group meetings Disseminate needed information and undertake actions resulting from the Co-ordination Group

meetings to their areas Monitor HACCP system development and implementation within the water industry Keep abreast of research, major work and systems enhancement being undertaken in the area of

maintaining water quality in water supply systems Identify areas of investigation supporting risk analysis Initiate development and improvement of supporting programs Facilitate organisational education and training needs to support the usage of HACCP


B-234

HACCP Team HACCP team members shall: Contribute as required to the development and documentation of the HACCP plan Input of areas of technical expertise Implement the requirements of the HACCP plan where required Perform verification tasks where required Undertake the review of the HACCP plan


C- 1

APPENDIX C

CITY OF AUSTIN PILOT STUDY REPORT


C-2

AWWARF PROJECT # 2856 – FINAL REPORT

APPLICATION OF HACCP FOR DISTRIBUTION SYSTEM PROTECTION

(January 18, 2005)

Prepared and Submitted By:

City of Austin Austin Water Utility

Environmental and Regulatory Services Division Staff Contact: Dan W Pedersen

512-972-0074


C-3

AWWARF PROJECT # 2856 – FINAL REPORT APPLICATION OF HACCP FOR

DISTRIBUTION SYSTEM PROTECTION Introduction In March 2002, the American Water Works Association Research Foundation (AWWARF) released a request for proposal entitled Application of Hazard Analysis and Critical Control Points (HACCP) for Distribution System Protection. The objective of the research is to evaluate the HACCP model for application in protecting and maintaining distribution system water quality. The first major task in the research project is to review previous HACCP plans to see how they were tailored to meet the unique needs of the users and then modifying HACCP for use in the distribution system. The next task is to develop a model HACCP approach and have it reviewed by Utilities with an emphasis on the ability to implement the HACCP. The final tasks are to develop and implement a HACCP plan based on the model and adjust the model as necessary based on implementation results. The Utility was approached by the lead researcher, Economic and Engineering Services, Inc., and asked to participate as a research team member. Tasks that the Utility will be involved with, include participating in a HACCP workshop, developing a HACCP plan based on the model, implementing the HACCP plan in a portion of our distribution system, assembling system records, and performing monitoring and analysis activities. The Utility agreed to participate because a better understanding of the critical control points in the distribution system will assist in optimizing the operation of the distribution system. The Southwest C Pressure Zone is located on the periphery of the Utility’s distribution system and was selected as a manageable area in which to pilot the HACCP plan. On May 21, 2003 the Utility participated in a HACCP workshop that was facilitated by the lead researcher. Workshop participants identified 12 potential hazards to the distribution system and, because of their higher risk factor, decided to focus on two of them – unprotected cross-connections and hazards at new construction sites. These hazards respectively had seven and five control measures that are mentioned in more detail later in this report. Following the workshop, the Utility pulled together a multidisciplinary team to develop, verify and implement a HACCP plan. Team members are shown in Table 1 and a copy of the plan is attached as Appendix A. Implementation of the HACCP plan began on October 1, 2003 and ended on September 30, 2004, which coincides with the Utility’s 2003-04 Fiscal Year.


C-4

TABLE 1 -- AUSTIN HACCP TEAM

Name Position Role and Responsibility Barrios, Rosie Water Laboratory Supervisor Laboratory and analysis expert

Bennett, Tony TCEQ Regulatory Manager State regulator

Bohr, Onnie Infrastructure Superintendent Field operations and maintenance expert

Burazer, Jane Asst. Director of Treatment Treatment expert

Kuhn, Robert Cross Connection Control Supervisor Cross connection expert

Lutes, Teresa Engineer/Planner Systems planning expert

Ojeda, Edward Construction Inspector Construction inspection expert

Pedersen, Dan Water Quality Manager Team leader

The Project Team developed evaluation criteria to determine if HACCP is an effective system for reducing risks. In brief, it is difficult to ascertain whether or not the HACCP plan improved water quality, improved public health protection, or improved customer satisfaction. The evaluation criteria and the Utility’s response to them are attached in Appendix B. UNPROTECTED CROSS-CONNECTIONS Critical control points for this hazard are each connection to a potential hazard within the customer’s plumbing system and the Utility’s distribution system. Control Measure – Identify Cross-Connections and Install Backflow Prevention Assemblies & Devices Status: At the end of the pilot study period, there were a total of 125 backflow assemblies within the Southwest C Pressure Zone. (Note: the total number of backflow assemblies is less than the number mentioned in the interim report because of a double counting of assemblies from a manual examination of the WPTS Database). Approximately 17 devices are considered to be protecting high hazard locations that would require an annual inspection. During the pilot study period 35 new backflow assemblies were installed in the


C-5

zone. Control Measure – Repair Failed Backflow Assemblies Status: During the pilot study period, three of the 52 backflow assemblies in either new or high hazard situations failed their test and were repaired. Control Measure – Require Annual Inspection of Backflow Assemblies in High Hazard Situations Status: The City’s Cross Connection Ordinance and the Utility’s HACCP plan requires inspection of backflow assemblies upon installation and the annual review of backflow assemblies in high hazard situations such as commercial and industrial customers, and residential customers with pools. During the pilot study period, 52 backflow assemblies, either new or in high hazard situations, within the zone were inspected. Control Measure – Inspect plumbing of New Customers Status: the City’s Watershed Protection and Development Review Department perform Plumbing inspections. There are six plumbing inspectors, five residential and one commercial, with territory within the Southwest C Pressure Zone. Inspections occur after obtaining a plumbing permit. In addition to assuring that the construction is up to code, inspections also identify a high hazard situation that might require a backflow assembly. Individual inspections include plumbing rough, plumbing top out, plumbing gas, plumbing sewer, and plumbing final. There were a total of 7458 individual plumbing inspections conducted during the pilot study period. Control Measure – Check for Cross-Connections Upon Customer Request or Unusual Complaint Status: The Utility’s WPTS Database, which tracks cross connection related work shows no complaints in the zone necessitating a cross connection inspection during the pilot study period. Additionally, the Utility operates and maintains a Hansen (CMMS V 7.5) system for tracking the work of field crews, including service requests for calls from customers. A review of 274 service requests in the Hansen system for streets in the zone from October 2003 to July 2004 shows work done in the zone (inspections, meter repairs, meter leaks, low flows, etc.). None of the customer service requests were of a type that might necessitate a cross connection inspection.


C-6

Control Measure – Maintain Distribution System Pressure Status: The Utility’s Pumping Division continuously tracks water pressure in the various pressure zones, including the Southwest C Zone, through an on-line SCADA system. The HACCP plan, which is based on state regulations, calls for a minimum pressure of 35 psi under normal conditions and 20 psi during emergencies. The highest ground elevation in the zone, which is the point expected to show the lowest pressure, is 1122’ and occurs near the Thomas Springs Tank. SCADA records for the pilot study period show that the water level in the Thomas Springs Tank ranged from 1213’ to 1236’. This equates to 39 to 49 psi at the point of lowest pressure. Recent AWWARF research highlighted pressure transients as a potential water quality concern. Pressure waves (water hammer) can propagate within a distribution system as a result of rapid valve closings or rapid pump starts/stops. Theoretically pressure waves may be large enough to cause negative pressures at certain locations that, if a water main were resting in water, could potentially draw in that water and associated contaminants. For a two-week period, the Utility installed a highly sensitive pressure transducer and data recorder on the discharge side of the Leuthan Lane Pump Station feeding the zone. Unfortunately after several attempts, it has not been possible to retrieve the data from the recorder. HACCP Team staff has however retrieved data from the Utility’s SCADA system that does show periodic pressure drops (0 to 9 per month). Through September 2004, sixteen of these were severe enough to potentially cause a negative pressure at the high point of the zone, if indeed the pressure wave were able to propagate through more than six miles of water main with bends and pass a storage tank that floats on the system. Control Measure – Monitor On-Site Septic Facilities For Failure Status: The Utility operates and maintains a Hansen (CMMS V 7.5) system for tracking the work of field crews, including inspection of on-site septic facilities. System wide during the pilot study period, there were a total of 321 inspections of on-site septic facilities. Of these, two inspections occurred within the zone. One inspection passed and the other inspection was for the abandonment of the facility with a simultaneous connection to the Utility’s sewer system. NEW CONSTRUCTION Control Measure – No Unauthorized Valve Operation (at new construction sites) Status: The Zone is relatively small compared to the Utility’s entire system. Additionally, water main construction, where unauthorized valve operation is likely to be most problematic, within the zone is limited to two subdivisions with active construction inspection. As evidenced by a lack of superchlorinated water complaints, taste and odor complaints, or boundary zone violations, no known unauthorized valve operation has occurred during the pilot study period.


C-7

Control Measure – Disinfection of Water Lines Status: Because of its size, new water main construction occurs infrequently in the zone. Currently there are two subdivisions (Covered Bridge and Travis Country West) where new mains are under construction. Queries of the Utility’s System for Laboratory Information Management show that construction inspectors for the area periodically bring in water samples from new mains as a final check of the disinfection process. Samples are checked for bacteria and free chlorine and chloramine residuals to assure that the water is typical of the Utility’s distribution system. Samples with results outside of acceptable ranges are not cleared accepted by the Utility. The reporting format for these construction inspection samples is in an Excel spreadsheet. Known water main construction must be checked manually to assure that all new water mains within the zone were sampled and had acceptable results prior to being placed in service. Records show that within the zone during the pilot study period, a main on Fenton Drive was constructed and yielded two sets of acceptable samples before being placed into service. Mains on Old Bee Caves Road Scenic Brook Drive were also constructed. Prior to being placed into service, these mains were sampled, then flushed and resampled because of a positive total coliform result and water containing free chlorine, respectively. Control Measure – Intact Pressure Zone Boundaries Status: The Utility’s Pumping Division continuously tracks water pressure in the various pressure zones through an on-line SCADA system. Violations of pressure zone boundaries are characterized by sudden and sustained drops in pressure or in the rapid depletion of water in a storage tank. In addition to the Pumping Division’s continuous monitoring, the HACCP team reviewed pressure point data (at the discharge side of the Leuthan Lane Pump Station) and water levels in an elevated storage tank (Thomas Springs Reservoir) in the Southwest C Pressure Zone during the pilot study period. Neither the pressure point data nor tank level data show curve shapes consistent with a boundary zone violation. Control Measure – Contractors to Contact One-Call to Avoid Accidentally Hitting Water Mains While Performing Their Work Status: Contractors are required to contact One-Call for water and sewer utility locations prior to digging. If construction is still active, contractors are required to renew their On-Call tickets after 30 days. Based on calls received, line locators mark water main locations, including those in the zone. City wide, the Utility receives between 150 and 250 calls per day, which are tracked in a Line Locator Database (Access). The database was developed for the purpose of tracking calls and whether or not a call was responded to in a timely manner. The database was not set up to track calls by City Grid, Mapsco Grid, or pressure zone and this data is not in the database. Theoretically, it is possible to track calls by street. However in practice this was not possible. Street names may be entered into the database


C-8

incorrectly or may be similar in name to streets outside of the zone. Efforts to extract the number of One-Calls within the zone have twice caused the Line Locator Database to crash. While One-calls and line locations did occur within the zone, it has not been possible to track the exact number of One-Calls. Control Measure – Inspector Training Status: In conjunction with regularly scheduled training for bacteriological sampling procedures for construction inspectors, HACCP Team staff scheduled training on water main disinfection requirements for September 2004. Forms submitted with the samples have changed and the training date was postponed so that construction inspectors can be trained with the new forms. The new date is tentatively scheduled for December 2004. Water Quality Indicators Water quality in the zone during the HACCP plan implementation period was typical for our system and is described in the table below. Information for the Ullrich Water Treatment Plant and the Leuthan Lane Reservoir, although not located in the zone, are included in the table for comparison purposes because water in the zone originates at this plant and passes through this reservoir.

Location PH mHPC cfu/100ml

Total Coliform Chloramine mg/l

Hardness mg/l

TTHMs ug/l

Blue2 prehaccp - cg 0 of 12 positive 1.03-2.09 - - Blue2 haccp - - 0 of 12 positive 1.41-2.12 - - Blue11 prehaccp - - 0 of 12 positive 0.96-2.11 - - Blue11 haccp 9.7 95 0 of 12 positive 1.54-2.11 94 - Blue14 prehaccp - 110 0 of 12 positive 1.68-2.21 - - Blue14 haccp 9.4 - 1 of 12 positive 1.78-2.34 91 - Blue19 prehaccp - 170 0 of 12 positive 0.96-2.05 - - Blue19 haccp 9.3-9.6 3-cg 0 of 12 positive 1.46-2.18 - 12.9-19.4 Maroon1 prehaccp 5 0 of 12 positive 1.48-2.12 - - Maroon1 haccp 9.4-9.6 5-56 0 of 12 positive 1.46-2.23 - - Thomas Springs Res prehaccp - - 0 of 12 positive 0.95-2.00 - - Thomas Springs Res haccp - - 0 of 11 positive 1.40-2.10 - - Leuthan Lane Res prehaccp - - 1 of 12 positive 1.80-2.20 - - Leuthan Lane Res haccp - - 0 of 8 positive 1.10-2.10 - - Ullrich WTP prehaccp 9.3-9.8 - 1 of 245 positive 1.65-2.50 82-108 15.4-34.3 Ullrich WTP haccp 9.4-10.0 - 1 of 251 positive 1.85-2.55 78-108 11.2-26.4 cg – confluent growth


C-9

Lessons Learned HACCP is more complex than initially envisioned. Originally, the Utility thought that HACCP would involve identifying critical flow paths within the distribution system and monitoring them more intensively. Our HACCP plan focused instead on operation and maintenance activities that occur in the distribution system, which adds layers of complexity to the monitoring. HACCP has shown, and made the Utility more aware, of pressure transients. Further study is needed to investigate impact and mitigation, which is outside the scope of this project. The Southwest C Pressure Zone was selected for the HACCP pilot because of two boil water advisories issued within the zone prior to the HACCP pilot. Those advisories were precautionary in nature and occurred when a boundary zone violation and a main break caused pressure to fall below the state’s minimum 20 psi pressure and mains to be drained. Because the zone is the highest in that area of the system and contains one relatively small tank, a boundary zone violation or a main break rapidly depletes the tank. The HACCP pilot raised the awareness of the need for quick response to main breaks in the area. The HACCP workshop held in the early part of the HACCP pilot brought together a wide variety of Utility personnel with different backgrounds, responsibilities, experiences, and expertise. Part of the workshop included a brainstorming session on water quality threats to the distribution system. During this part of the workshop, participants were able to gain a better understanding of the threats to the distribution system and the importance of their work in minimizing and prevent risks due to these threats. The workshop also improved communication by reintroducing people from different parts of the Utility that interact infrequently. Data Management Strategies Existing databases will need to be modified to facilitate the implementation of HACCP system wide. Databases that track plumbing inspections, cross-connection inspections, waterline disinfection, One-Calls, etc., were not set up with HACCP in mind. Most, but not all can recall data by street and City grid, but not by pressure zone. Therefore data retrieval must be undertaken manually and is cumbersome. In the case of One-Calls, it was not possible. Modification of databases and automated report generation is needed if HACCP is to be adopted system wide by the Utility.


D-1

APPENDIX D SYDNEY WATER MANAGEMENT PLANS


D-2

MANAGEMENT PLAN FOR

DISCOLOURED WATER


D-3

MANAGEMENT PLAN FOR PHYSICAL RISKS IN THE DISTRIBUTION (Discolored Water - Al, Mn, Fe) Background: Discolored water is caused primarily by changes to the normal flow patterns within water main re-suspending sediment that has accumulated over time. These flow changes can be caused by operational changes made to allow maintenance work to be carried out, water main failures resulting in greatly increased flows in the adjoining pipes and occasional shifts in demand causing flow changes. The changes can be exacerbated by poor work practices or human error. Water treatment failures may also cause elevated levels of metals to enter the system and cause discoloured water problems. Critical activities include:

• Identification and operation of valves • Mains cleaning – flushing and swabbing • Repair of main breaks • Chlorination of reservoirs and new mains • Service connections • Under pressure drilling • De watering mains

Hazard: Physical/chemical effect of discoloured water. This may include an effect on system disinfection and customer dissatisfaction.

Existing Management Strategies: Civil Maintenance have job method statements for all their activities while Water Operations have SOP’s which are found in the QA system. Reference the following procedures of discoloured water:

• WP-QMS0033 System water quality performance assessment • WP-QMS0025 Planning of Flushing programs • WP-QMS0044 Notification of system operational changes • WP-QMS0162 Managing Drinking water quality customer complaints • WP-QMS0174 Managing water quality during the planned isolation of trunk mains • WP-QMS0230 Procedure for customer notification of system changes • WP-QMS0239 Isolation and rezoning • WP-QMS0241 Identification of Reticulation Water mains for Investigation and Renewal • WP-QMS0256 Prevention of water quality contamination following water main breaks • WP-QMS0021 Discharge protocols • WP-QMS0041 Manual disinfection of service reservoirs • WP-QMS0027 Disinfecting new water mains • WP-QMS0031 Procedure for planning of swabbing programs • WP-QMS0031.2R1 – Coordinating of swabbing activities checklist


D-4

• WP-QMS0274 Exception trigger tables • WP-QMS0221 Bulkwater supply protocols • WP-QMS0228 Drinking Water quality Event Management • Asset Operational/Shutdown Manuals • Shutdown procedures prepared by Water Operations

Critical Control Points and Limits • WFP (Refer Bulkwater Supply Protocols WP-QMS0221)

Critical Control Measure and Limits • Mains (Refer Exceptions trigger table WP-QMS0274) • Distribution (Refer Exceptions trigger table WP-QMS0274) • Customer complaint numbers (monthly report summary and Managing Drinking Water

Quality Customer Complaints WPQMS0162_R9 Preventive Measures Discoloured water incidents/events/complaints have reduced significantly over the past few years due to improvements in:

• Raw water quality (Refer Bulkwater Supply Protocols WP-QMS0221) • Improved water filtration plant (WFP) performance • Main cleaning programs • Reservoir cleaning programs

Monitoring Protocols/Plan Discoloured complaints are reviewed on a monthly basis. The data is presented in several formats in the Water Operations Quarterly Drinking water Quality report. The WPQMS procedures are audited both internally and externally to ensure they reflect current work practices. Water quality performance is monitored both online and through grab sampling programs and reviewed continuously. Validation/Verification Plan Small scale audits linked to the current WP-QMS internal audit plan to ensure all participants are aware of the relevant procedures for the Distribution HACCP plan for discoloured water in the Woronora Distribution System. Prior to the audits, a refresher training package should be delivered to all involved in the operation of the distribution system including civil maintenance. Maintenance activities checked via WAMs and Maximo work databases. Reports are run monthly and reviewed at the Water Operation and Civil Maintenance link meetings. Previous audits conducted on Civil Maintenance covered swabbing, flushing and chlorinating activities. Documentation and Records

• Job cards • Water quality performance reports • Customer complaint reports • Training programs


D-5

MANAGEMENT PLAN FOR

DISINFECTION IN THE SYSTEM


D-6

MANAGEMENT PLAN FOR DISINFECTION / NITIRIFCATION (Biological hazard) IN THE WORONORA DELIVERY SYSTEM Background: The Woronora Delivery System serves a population of 220,000, with 6 water pumping stations, 21 service reservoirs at 13 sites and ~ 1000kms of mains. Woronora Delivery System can be separated into three Distribution Systems, Woronora, Helensburgh and Sutherland. The Sutherland Distribution System can alternate between water supplied from Woronora or Prospect or a combination of both. The Woronora Delivery System is chloraminated. The chlorine residual is controlled at the Woronora Water Filtration Plant. The plant was built under Build Own and Operate Contracts and General Water Australia has been contracted to operate the plant for 25 years, from 1996 to 2021. The plant operates under a winter and summer dosing regime in order to assist in the management of nitrification within the distribution system. The chlorine to ammonia ratio has been found to be one of the critical issues in the management of nitrification and additional chlorine is added at appropriate storage reservoirs within the distribution system to “lock up” any free ammonia. Nitrification is a bacterially mediated process whereby ammonia is first oxidised to nitrite and then sometimes further oxidised to nitrate. The presence of nitrite can then accelerate the decay of chloramine thereby increasing the regrowth risk of bacteria within the distribution system. These problems can frequently lead to non-conformances in relation to drinking water quality. Hazard: Biological contamination of the system due to loss of chlorine, increased biological activity, excess nitrate Existing Management Strategies: A quality assurance matrix has been developed for the management of disinfection residual in the Woronora System (Appendix1). Following are disinfection procedures which can be referenced within the Quality Assurance System:

• WP-QMS0033 System water quality performance assessment • WP-QMS0041 Manual disinfection of service reservoirs • WP-QMS0087 Online monitoring of reservoirs using chlorine residual analysers • WP-QMS0175 Quality assurance of Hypochlorites

Other relevant documents include:

• Woronora Water Treatment Management Plan (subplan) • Service Level Agreement (monitoring programmes) between Water System Services &

Water Product Delivery • Regular meetings are held with all concerned – Sydney Water team – Distribution &

Water Filtration team, Sydney Catchment Authority, General Water Australia


D-7

Critical Control Limits Nitrite: >0.01mg/L Nitrate: >0.3mg/L Loss of chloramine level: 20% deterioration from the normal levels within the distribution system HPC (Heterotrophic plate counts): <100 HPC20 Ammoniacal nitrogen: +/-20% throughout the system from the target value +/- 20% target value at the WFP outlet. Corresponding Cl2:NH3 ratio. Chlorine:ammonia ratio: 3.5:1 to 4:1 Water age: Where hydraulic turnover is compromised ie isolating part of the system, reducing reservoir cycling times, increasing the capacity of a reservoir, returning an isolated asset back into service, etc then an investigation should be performed to determine the presence / absence of nitrification. Temperature: Nitrification becomes prominent when water temperatures increase to around 17°C. Some systems also experience nitrification throughout the winter months when water temperatures are around 13°C. Early spring and in particular autumn are the periods that pose the greatest risk in terms of intensifying nitrification activity. It should be noted that a single trigger or more than likely a combination of the above triggers could signal the presence of nitrification. These triggers could vary from system to system or be different for each event. Critical Control Points Woronora Water Filtration Plant HWO1 – Raw water HWO2 – Downstream CWT SV3 - Section Valve 3 Helensburgh reservoir R348 inlet & outlet Heathcote reservoir R047 inlet & outlet Menai reservoir R268 outlet Mainabar reservoir R227 inlet & outlet Illawong reservoir R270 inlet & outlet Critical Control Measures 12 Clough Ave Illawong 10 Bombora Ave Bundeena


D-8

Preventive Measures • Reservoir optimisation • Disinfection Strategy • Optimisation of the chlorine to ammonia ratio • Mainscleaning Monitoring Protocols/Plan System performance with regards to the disinfection residual and nitrification parameters is reviewed on a regular basis (via on-line measurements IICATS and routine monitoring programs). Sodium hypochlorite tablet dosing worksheets submitted by field staff are reviewed on a daily basis. Chlorine residual exceptions are investigated. The data is also used to develop graphs for performance trending purposes to help in the management of the system operations. There are also alarms in IICATS for parameters such as total chlorine and at some locations for turbidity, pH, redox and free chlorine. Sydney Water also audits the WFP on a regular basis. Validation/Verification Plan There are small scale audits linked to the current WP-QMS internal audit plan to ensure all participants are aware of the relevant procedures for the Distribution HACCP plan for disinfection in the Woronora Delivery System. All work is being performed under the existing ISO9002 System


D-9

Appendix 1:

Critical control points & limits disinfection management chloramination regime quality assurance matrix The following information was based on experience gained through successive chloramination commissioning trials and literature reviews related to chloramination and nitrification issues. This management strategy tried to address all known issues that could impact on chloramination / nitrification from the catchment to the customer’s tap. This strategy is considered as being a “live” document and will be updated on a continuous basis as more knowledge and developments become available. Routine monitoring in the system will be carried out as per the existing Operational Monitoring Plan and the Compliance Monitoring Program. 1. Total System Performance Limits

Addresses parameters and associated levels at the broader level ie. raw water, bulkwater and reticulation.

2. Trigger Points Level 1

To assess the tablet dosing regime/results from the DPD colorimeter measurements sent on twice/thrice a week after dosing. If there is change of more than a 20% decrease in chlorine, then review the need for Level 2 monitoring on a case by case basis.

To assess the temperature from the compliance runs based on the information of trending on reservoir and zones from compliance and ongoing standard operational monitoring. If the temperature increases to >20°C in critical sites noted, then check total chlorine levels from DPD colorimeter measurements to assess chlorine decay. If there is a decay then implement Level 2 monitoring where required.

Using the above two trigger points, review the set point at the WFP and also the tablet dosing regime (may need to consider Level 2 ammonia testing to optimise tablet dosing regime).

Level 2 Level 2 monitoring is performed if the variability of the Level 1 control limits cannot be used to

verify the cause in rectifying the issue. If the Level 2 trigger points are exceeded in total or in part, additional monitoring to assess the

corrective action will be carried out, based on the standard project briefs. If Illawong, Heathcote and Helensburgh zones move towards the following parameter levels: NO2

>0.01mg/L and NO3 >0.30mg/L and HPC20 >100cfu/mL (for more than a week and widespread from other compliance data) and total chlorine decreases by 20% when measured against the standard project briefs at reservoirs and reticulation sites, (increasing temperature also to be assessed), then changeover to free chlorination.

Note: In order to achieve maximum efficiency and optimise resourcing, routine compliance and operational monitoring will be integrated wherever possible.

3. Standard Maintenance Protocols

Unidirectional flushing, dead end flushing, reservoir cleaning and swabbing to be carried out as per normal work plan programme

Tablet dosing regime Flushing program (systematic and dead end) - Not specific for chloramination only. For Water

Quality improvements in general, as per DWQMS SOPs.


D-10

4. Drought Strategy Depending on the level of water restrictions in force, flushing may not be allowable to varying degrees. Under these circumstances, other operational activities must be reviewed and implemented to ensure the integrity of the system is maintained. If nitrification becomes established and water restrictions are still in place, then a decision must be made on whether the system can maintain the chlorine residuals >1.0mg/L using existing maintenance protocols or if flushing needs to be implemented to remove the problem. The tablet dosing regime also needs to be reviewed based on these circumstances, however the regime for either a 1.6 or 1.75mg/L set point should be used as a baseline .


Based on set point dosing at WFP – 1.75mg/L (Summer)/ 1.60mg/L (Winter)

Control Points

Control Limits Level 1


Operational protocols Exception management checklist

HWO1 - Raw Water

< 16°C Same Exceeding > 16°C for >5 days - assess the impact on nitrification potential Check temperature in zones Assess the potential to use lower temperature raw water

HWO2 – Downstream of Clear Water Tanks Compliance/ hand over point

Total Chlorine Online 1.75 +/- 0.2 mg/L (summer/winter)

HPC20, NH3, speciation of total chlorine with titrator, NO2 , NO3 - every other day for two weeks HPC20 = 0cfu/mL NH3 +/-10% of target value Cl2:NH3 ratio between 3.5:1 and 4:1 NO2 < 0.01mg/L NO3 < 0.3 mg/L > 95% monochloramine If the lower temperature profile is used with a change in extraction level - assess manganese and iron levels in consultation with WFP.

Check WFP - Plant Operation/Calibration If total chlorine levels are low and variable consistently for over 5 days and ratio is outside specified range – more frequent monitoring to assess whether nitrification is occurring Exceeding > 20°C for more than five days assess the impact on nitrification potential Check the raw water temp Assess the potential to use lower temperature raw water

SV3 – Section Valve 3

Total Chlorine Online 1.5 +/- 0.2mg/L

HPC20, NH3 , speciation of total chlorine with titrator, NO2, NO3 – weekly for two weeks HPC20 < 100 cfu/mL NH3 +/-10% of target value Cl2:NH3 ratio between 3.5:1 and 4:1 NO2 < 0.01 mg/L NO3 < 0.3 mg/L > 95% monochloramine

If there is a lowering trend in the total chlorine regime below 20% check WFP operation and Woronora pipe line operation/demand of the system Check calibration at the same time Investigate the cause as per DWQIMP and review improvements

D-11

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Engadine reservoirs R362 inlet & R258 outlet

Total chlorine hand held DPD measurement 1.5 +/- 0.2 mg/L

HPC20, NH3, speciation of total chlorine with titrator, NO2, NO3 – weekly for two weeks HPC20 < 100 cfu/mL NH3 +/-10% of target value Cl2:NH3 ratio between 3.5:1 and 4:1 NO2 < 0.01mg/L NO3 < 0.3mg/L > 95% monochloramine

Twice a week tablet dosing winter Twice a week tablet dosing summer except R258 to be done 3 x due to historically performing less than R362 for HPC20

Check WFP operation. Increase tablet dosing frequency if chlorine levels are low for > 5 days

Control Points




Heathcote Reservoir R47 inlet & outlet


HPC20, NH3, speciation of total chlorine with titrator, NO2, NO3 - on an exception basis from Level 1 HPC20 < 100 cfu/mL NH3 <0.3mg/L (review level to be considered with other nitrogen species) Cl2:NH3 ratio between 3.5:1 and 4:1 NO2 < 0.01mg/L NO3 < 0.3mg/L > 95% monochloramine

Twice a week tablet dosing winter Thrice a week tablet dosing summer Pumping from Engadine to fill in the night to maximise cycling. Cycle reservoir between 50% and 75% during summer

Check hydraulics and demand profiles Check cycling of the reservoir Check inlet status If total chlorine levels are lower consistently over 5 days and variable – more frequent monitoring to assess whether nitrification is occurring

Menai Reservoir R268 outlet


HPC20, NH3, speciation of total chlorine with titrator, NO2, NO3 - on an exception basis HPC20 < 100 cfu/mL NH3 <0.3mg/L (review level to be considered with other nitrogen species) Cl2:NH3 ratio between 3.5:1 and 4:1 NO2 < 0.01mg/L NO3 < 0.3mg/L > 95% monochloramine

Twice a week tablet dosing winter Thrice a week tablet dosing summer Provide information on the water quality feeding Illawong reservoir and determine the status of tablet dosing requirements


D-12

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Maianbar Reservoir R227 inlet & outlet

Total Chlorine hand held DPD measurement 1.2 +/- 0.2 mg/L

HPC20, NH3, speciation of total chlorine with titrator, NO2 , NO3 - on an exception basis HPC20 < 1000 cfu/mL NH3 <0.3mg/L (review level to be considered with other nitrogen species)

Cl2:NH3 ratio between 3.5:1 and 4:1 NO2 < 0.015mg/L NO3 < 0.12mg/L > 95% monochloramine

Twice a week tablet dosing winter Ammonia levels are to be kept in check. If ratio is <3:1 dose half amount tablets then sample reservoir & reticulation site at a later date to confirm improved ratio Summer profile - deep cycling to 50% weekly. Dose twice a week


Illawong Reservoir R270 inlet & outlet


HPC20, NH3, speciation of total chlorine with titrator, NO2, NO3 - on an exception basis HPC20 < 100 cfu/mL NH3 <0.3mg/L (review level to be considered with other nitrogen species) Cl2:NH3 ratio between 3.5:1 and 4:1 NO2 < 0.01mg/L NO3 < 0.3mg/L > 95% monochloramine

Illawong to be dosed once a week, ensure ammonia levels kept in check. Winter Profile – consider isolation Summer profile - deep cycling to 50% (usually weekly) If ratio <3:1 tablet dose after reservoir scoured and follow up sampling in the reservoir and reticulation site to confirm improved ratio Scour the zone when isolated and when reservoir is put back on line


D-13

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Control Points




10 Bombora Ave Bundeena

Compliance measurement Total chlorine ≥0.6mg/L (95% monochloramine) measured by titration

HPC20, NH3 , speciation of total chlorine with titrator, NO2 , NO3 - on an exception basis HPC20 < 100 cfu/mL NH3 <0.3mg/L (review level to be considered with other nitrogen species) Cl2:NH3 ratio between 3.5:1 and 4:1 NO2 < 0.01mg/L NO3 < 0.3mg/L > 95% monochloramine

If ratio <3:1 dose reservoir accordingly and follow up sampling of reservoir and site

If total chlorine levels are lower consistently over 5 days and variable – more frequent monitoring to assess whether nitrification is occurring

12 Clough Ave Illawong

Compliance measurement Total chlorine ≥0.6mg/L (95% monochloramine) measured by titration

HPC20, NH3 , speciation of total chlorine with titrator, NO2 , NO3 - on an exception basis HPC20 < 100 cfu/mL NH3 <0.3mg/L (review level to be considered with other nitrogen species) Cl2:NH3 ratio between 3.5:1 and 4:1 NO2 < 0.01mg/L NO3 < 0.3mg/L > 95% monochloramine

If ratio <3:1 dose reservoir accordingly and follow up sampling of reservoir and site

If total chlorine levels are lower consistently over 5 days and variable – more frequent monitoring to assess whether nitrification is occurring

D-14

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Total System Performance Points & Limits

Control Points Operational Trigger Level

Exception management /comments

Raw Water True colour Check abstraction point and dam profile. Turbidity Temperature Refer Raw Water All parameters should be reviewed simultaneously and the best balance of water quality chosen. HPC 20 Trigger levels in Total Iron DWQM This balance should directly consider the capability of the WFP and monitoring at its outlet should be

reviewed. Filterable Iron Incident Total Manganese Management Plans This is particularly important when sudden changes to water quality occur eg wet weather events, dam

turnover etc Filterable Manganese It is important that parameters at the outlet of the plant are also taken into consideration prior to making a final decision. Water Filtration Cl2:NH3 ratio (manual & online calculations)

3.8:1 Check plant performance - 4:1 desirable level. If on line check instrumentation.

Temperature > 16°C Check drawoff from raw water HPC 20 Review level Check raw water quality & filter performance/on line chlorine demand and pre chlorination level after

filters. Online chlorine demand

10% increase Check raw water quality and plant performance

Chlorine (manual &/or on line)

+/-10% of set point Check chlorine demand, flow changes, alarms, WFP NCR’s, SOC. Check chlorine speciation (should be no free or dichloramine). Contact Contract Services if problem verified.

Ammoniacal nitrogen +/- 10% of set point Check for alarms, flow changes, SOC, WFP NCR’s. Contact Contract Services especially if not flow related. Check trend of ammonia flow meter on IICATS.

On line free ammonia >0.2 mg/L for > 30 minutes

Check for alarms, flow changes, SOC, WFP NCR’s. Contact Contract Services especially if not flow related. Check trend of ammonia flow meter on IICATS.

On line pH +/- 0.3 units of set point Check for alarms, flow changes, SOC, WFP NCR’s. Check extent of pH problem (level and duration) and contact Contract Services if necessary.

On line turbidity >0.1 NTU Check for alarms, flow changes, SOC, WFP NCR’s. Check on line pH to see whether it is related to a lime dosing issue. Contact Contract Services if necessary.

D-15

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Control Points

Operational Trigger

Level

Preventive/Corrective Action/comments

Bulkwater supply – Reservoirs & trunk mainsCl2:NH3 ratio 3.8:1 Check plant performance, flow regime, tablet dosing (see schedule):

- Engadine & then all the reservoir (tablet dosing assessment and exception monitoring) - assess performance and if Cl2:NH3 < 3.5:1 (exception monitoring)

if it drops below 3:1 ratio in all reservoir zones then assess total chlorine trend and HPC20 Check if caused by problems associated with ammonia or chlorine levels

Total chlorine <1.0 mg/L Re-test chlorine & at reservoir tablet dose as per requirements Nitrate >0.12 mg/L Check reservoir performance & assess the need to monitor further especially background NO3 level at

HWO2 >0.3 mg/L If widespread - change over to chlorination from the WFP

If not widespread - further assessment and consider breakpoint chlorination within reservoirs Nitrite >0.025mg/L Increase monitoring & improve reservoir cycling if possible

Increase tablet dosing & if not responding after trialling reservoir cycling/where possible breakpoint chlorination move towards free chlorination for the total system

Ammoniacal Nitrogen Loss is more than 10% or spike > 10%

Review chlorine : ammonia ratio Check WFP performance Review the operation of the total system Check & verify that system is not in breakpoint chlorination

Temperature > 16-25°C Check temperature in drawoff level into WFP. Check other reservoirs / zones in same system. HPC 20 >1000 cfu/mL Level depends on reservoir. Review tablet dosing program, assess reservoir performance, exception

monitoring, reservoir cycling, inlet to the reservoir etc Reticulation supply Cl2:NH3 ratio < 3.0:1 Check turn over of reservoirs / cycling - initiate tablet dosing - (see reservoirs). Check if caused by

problems associated with ammonia or chlorine levels Total chlorine Decreasing trend > 20% If in conjunction with increasing HPC20 trend > 1000 cfu/mL:

- increase the potential to do tablet dosing, improved reservoir cycling implement unidirectional flushing if isolated to few areas in zones & consider breakpoint chlorination for those zones - If widespread - change over to chlorination from the WFP if nitrification is occurring Only for decreasing trend for total chlorine: - check reservoir performance & assess the need to monitor further

Nitrate >0.12 mg/L Check reservoir performance & assess the need to monitor further for exceptions

D-16

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Control Points

Operational Trigger

Level

Preventive/Corrective Action/comments

Nitrate >0.30 mg/L Implement unidirectional flushing if isolated to few areas in zones & consider breakpoint chlorination for those zones If widespread - change over to chlorination from the WFP

Nitrite >0.010 mg/L Increase tablet dosing, reservoir cycling, exception monitoring, cycling of reservoirs & WFP operation Implement unidirectional flushing if isolated to few areas in zones & consider breakpoint chlorination for those zones If widespread - change over to chlorination from the WFP

Ammoniacal Nitrogen If loss is > 10% of the measured value within

zone

Verify if loss is occurring from nitrification (by reviewing other data) or from other processes eg reaction with organic compounds found in the system. If required increase monitoring.

Temperature > 16 - 25°C Check draw off point of Raw Water

HPC20 >1000cfu/mL Review tablet dosing program, verify reservoir performance, exception monitoring (see total chlorine note)

• The chlorine to ammonia ratio is to be calculated using the total chlorine divided by the ammoniacal nitrogen expressed as NH3 • It is assumed that all on line instrumentation data has been verified ie. instruments checked and calibrated. • Number of tablets for each reservoir refer to DWQMS R024 – Reservoir disinfection

D-17

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

D-18

Sampling sites – comprehensive list

LOCATION SITE DETAILS ZONE Raw Water HWO1 - Water Filtration Plant HWO1-1 After filters before chlorine dosing - Bulkwater Supply – Woronora HWO2 – 1st pt after WFP on Woronora pipeline - HWO4 – Helensburgh main - SV3 – Section Valve 3 Engadine - R362 – Engadine inlet 258 R258 – Engadine outlet 258 R171 – Loftus outlet 171 R227 – Maianbar inlet (Loftus) 227 R227 – Maianbar inlet A (Burraneer ) 227 R227 – Maianbar outlet 227 R047 – Heathcote outlet 047 R348 – Helensburgh inlet/outlet 048 R458 – Hargrave Heights outlet 202 R202 – Hargrave Heights depth 202 R229 – Stanwell Park outlet 229 R161 – Lucas Heights outlet 161 R268 – Menai outlet 268 R270 – Illawong inlet R270 – Illawong outlet 270 Bulkwater supply - Sutherland SV4 – Section Valve 4 - R175N – Sutherland outlet 156 Reticulation supply - Woronora 5 Second Ave. Loftus 171 5 Dernancourt Ave Engadine (1st customer) 258 3 McAuley Pl. Heathcote 047 4 Foster St. Helensburgh 048 PRV at lower Helensburgh reservoir 048 7 Georges Rd. Otford 202 14 Tamarind Pl. Alfords Point 268 10 Pacific Cres Maianbar 227 10 Bombora Ave Bundeena 227 12 Clough Ave. Illawong 270 Reticulation supply - Sutherland 7 Cremona Rd. Como 156 29 Grays Point Rd. Grays Point 156 24 Beauford Ave. Caringbah 225

• Depending on the requirements for sampling, sub samples within this list can be used. This list is a baseline to work from and others can be added if required.


D-19

Tablet Dosing Regime under 1.75mg/L total chlorine set point Reservoir Res Frequency No. Engadine R258 Mon, Wed & Fri 15Engadine R362 Mon & Fri 15 Heathcote R47 Mon, Wed, Fri 20 Loftus R171 Mon, Fri 25 Maianbar R227 Mon & Fri (Cl2 tested, check with PDW if dosing required based on NH3 & Cl2) 5 Lucas Hts R161 Mon, Wed, Fri 15 Menai R268 Mon, Wed, Fri 25 Illawong R270 Thurs (Cl2 tested, check with PDW if dosing required based on NH3 & Cl2) 5 Helensburgh R348 Tues & Fri 10 Helensburgh R048 Tues & Fri (reservoir offline indefinitely) Cl2 being maintained 3 Hargrave Hts R202 Tues & Fri 1 Hargrave Hts R458 Tues & Fri 1 Caringbah R020 Wed (dose depends on Cl2 level) 0 - 10 Caringbah R225 Wed (dose depends on Cl2 level) 0 - 5 Kurnell R199 Wed (dose depends on Cl2 level) 0 - 30

Tablet Dosing Regime under 1.6mg/L total chlorine set point (as of 24/06/02) Reservoir Res No. Frequency No.

TabletsEngadine R258 Mon, Wed & Fri 10 Engadine R362 Mon, Wed & Fri 10 Heathcote R47 Mon, Wed, Fri 15 Loftus R171 Mon, Wed, Fri 15 Maianbar R227 Mon & Fri

(Cl2 tested, check with PDW if dosing required based on NH3 & Cl2) 5

Lucas Heights R161 Mon, Wed, Fri 10 Menai R268 Mon, Wed, Fri 20 Illawong R270 Monday & Friday

(Cl2 tested, check with PDW if dosing required based on NH3 & Cl2) 5

Helensburgh R348 Tues & Fri 10 Helensburgh R048 Tues & Fri 3 Hargrave Hts R202 Tues & Fri 1 Hargrave Hts R458 Tues & Fri 1 Sutherland R156 Wed (Cl2 tested only) Nil Sutherland R175N & S Wed (Cl2 tested only) Nil


D-20

MANAGEMENT PLAN FOR

HYDRAULICS AND AGE


D-21

MANAGEMENT PLAN FOR PHYSICAL RISKS IN THE DISTRIBUTION (hydraulics and water age) Background: The Woronora water supply system comprises of approximately 1000km of water mains with 8 pumping stations and 22 reservoirs. The system is generally supplied from Woronora Dam via Woronora Water Filtration Plant, however it is possible to supply at least 60% (in normal operating mode) of the system from Warragamba Dam via Prospect Water Filtration Plant. The pumping stations and the reservoirs are essential assets within the supply network, however, they also retard the movement of water to the customer with their operation being determined by system demand. This retardation of the water movement therefore ages the water, which in turn contributes to the disinfection decay that occurs. There are a number of issues that need to be considered when operating these assets, which include:

• Pressure in the supply zone • Operating costs, in particular electricity usage • Demand variations on primary assets such as the water filtration plant • Existing system configuration limitations • Security of supply • Minimising travel time through the system

Hazard: The longer the period of time for the water to travel from the water filtration plant to the customer the increased extent of disinfection decay which can occur which in turn increases the risk of biological contamination. Existing Management Strategies: The operating protocol for pumping stations and reservoirs and the water supply system in general is the responsibility of Water Operations. The procedures and guidelines under which these assets are operated are detailed in the Standard Operating Procedures (SOP), which are found within the accredited “Water Quality – Quality Management System”. Reference to the following SOP’s for operating the water system:

• WP-QMS0216 IICATS Water System Optimisation • WP-QMS0266 System Optimisation • WP-QMS0236 Operational Settings for Reservoirs • WP-QMS0210 IICATS Alarm Analysis and Review of System Operational Trends • WP-QMS0021 Discharge Protocols • WP-QMS0041 Manual Disinfection of Service Reservoirs • WP-QMS0239 Isolation and Rezoning • WP-QMS0033 System Water Quality Performance Assessment


D-22

• WP-QMS0265 Avoidance & Management of Nitrification in Chloraminated Systems Critical Control Points and Limits

• Refer to monitoring plan as detailed in appendix

Critical Control Measure and Limits • Refer to monitoring plan as detailed in appendix

Preventive Measures Reduction in water travel time through the system has been significantly reduced over the past few years due to improvements in:

• The implementation of IICATS to better understand the interrelationship between the key assets and to provide enhanced monitoring and control

• Improved control over the operational key assets within the system • Limiting detention time by taking off-line non-critical assets especially during the winter

low demand period • Operating some pumps over a longer period but at a reduced flowrate • Moving operating windows at the reservoirs to reduce the storage volume of the

reservoirs during lower demand periods such as winter • Reviewing system operation in conjunction with water quality data • Capital improvements to reconfigure critical sites so that flowpaths can be better

controlled • Monitored and adjusted chlorine tablet dosing at key reservoirs

Monitoring Protocols/Plan System operation is reviewed against the performance parameters as detailed in the appendix on a monthly basis. System performance is reviewed immediately upon notification of water quality exceptions. Validation/Verification Plan Water quality sampling taken, within the distribution zone, is undertaken when implementing system changes to determine the impact of such changes. Trending of water quality data is utilised to identify those assets which are not performing satisfactorily. This will enable early intervention in the operation protocols of those assets to rectify adverse trends. Documentation and Records

• Monthly report sheets as detailed in the appendix • Water quality exceptions review against performance requirements • Water quality trend review against performance requirements and asset operational

arrangement


D-23

Asset Parameter being monitored Priority Comment

Helensburgh WS048 Reservoir level > 60% Operating window = approximately 15%

High Medium

* Reservoir level below 60% difficulties supplying to Waterfall * Operating window to coincide with pumping time from WP319 (Note 1)

Helensburgh WS348 Reservoir level > 60% Operating window = approximately 15%

High Medium

* Reservoir level below 60% difficulties supplying to Waterfall * Operating window to coincide with pumping time from WP319 (Note 1)

Hargrave Heights WS202 No monitoring N/A Acts as break pressure tank Dependant on WS348 & WS048 water quality

Hargrave Heights WS458 No monitoring N/A Acts as break pressure tank Dependant on WS348 & WS048 water quality

Stanwell Park WS229 No monitoring N/A Acts as break pressure tank Dependant on WS348 & WS048 water quality

Garrawarra WS406 No monitoring N/A Privately owned (Garrawarra Aged Care Centre)

Garrawarra No.2 No monitoring N/A Privately owned (Garrawarra Aged Care Centre)

Engadine WS258 Reservoir level > 40% Operating window = approximately 20%

High Medium

* Reservoir level below 40% low pressure in zone * Operating window to coincide with pumping time from WP320

Engadine WS362 Reservoir level > 40% Operating window = approximately 20%

High Medium

* Reservoir level below 40% low pressure in zone * Operating window to coincide with pumping time from WP320

Heathcote WS047 Filling during evening/night Reservoir level > 40%

Medium High

* Common inlet/outlet receives water from WP071 * Reservoir level below 40% creates suction pressure problems at WP116

Heathcote WS151 No monitoring N/A Primary role to maintain pressure in zone and supply WP341. Dependant on WS047 water quality.

Loftus WS171 Reservoir level > 80% High * Reservoir level below 80% supply problems to Maianbar reservoir WS227

Maianbar WS227 Supply from Loftus > 12hrs/d Pump time from WP324 > 1hr/d

High High

2 sources of supply: * From Loftus, main detains 0.57ML (42% of ADD) * From Burraneer Point WP324, main detains 0.226ML (17% of ADD)


D-24

Asset Parameter being monitored Priority Comment Lucas Heights WS161 Reservoir level > 30%

Reservoir level > 60%

High Medium

* Reservoir level below 30% pressure problems in zone * Large zone for reservoir size causes quick turnover

Menai WS268 Reservoir level > 40% Reservoir level < 80%

High Medium

* Reservoir level below 40% pressure problems in zone * Small zone for reservoir size. Can keep operating window lower

Illawong WS270 Reservoir on by-pass from May to October When Illawong Reservoir on-line fill during low demand periods ie evening/night

High Medium

* Very small zone for reservoir size * Inlet main to reservoir is also Menai zone distribution main

Sutherland WS156 Supply from Woronora WFP > 1hr/d WP123 pump > 3hrs/d Reservoir level > 40%

High High High

2 sources of supply: * From Woronora WFP, main detains 5ML (8% of ADD) * From Allawah WP123, main detains 11.5ML (19% of ADD) * Reservoir level below 40% can cause low pressure in zone

Sutherland WS175 Supply from Woronora WFP > 1hr/d WP123 pump > 3hrs/d Reservoir level > 40%

High High High

2 sources of supply: * From Woronora WFP detains 5ML (8% of ADD) * From Allawah WP123 detains 11.5ML (19% of ADD) * Reservoir level below 40% can cause low pressure in zone

Caringbah WS020 Reservoir filling > once/2 days If on-line is WS224 off-line

Medium Medium

* Poor existing hydraulic arrangement. Available for WP045 * In parallel with WS224 only one reservoir required

Caringbah WS224 Reservoir filling > once/2 days If on-line is WS020 off-line

Medium Medium

* Poor existing hydraulic arrangement. Available for WP045 * In parallel with WS020 only one reservoir required

Caringbah WS225 Reservoir filling > once/2 days High * to be available during high demand periods

Kurnell WS199 Reservoir filling > once/2 days Low * To be available during high demand periods

Helensburgh WP319 Pump time < 12 hrs/d (Note 1) No. of pumps operating = 1 pump

Medium Medium

* Pumps for 12 hrs/day, main detains 1.2ML (40%) of ADD * Utilises one pump. 2 pumps can cause “dirty


D-25

Asset Parameter being monitored Priority Comment water”

Woronora-Engadine WP320

Pump time < 12hrs/d No. of pumps operating = 1 pump WP320 operation providing uniform draw off from WFP

Low Medium High

* Pumps for 14-18 hrs/day, main detains 0.6ML (4%) of ADD * Utilises one pump * Operate to balance draw off WFP

Engadine WP071 Pump time = 12 hrs/d Pump during evening/night

Low Medium

* Pumps for 12 hrs/day detaining 0.02ML (<1%) of ADD * Common inlet/outlet to WS047 (night time pumping optimises WS047 turnover)

Heathcote WP116 No monitoring N/A * Pumps for 4-6 hrs/day detaining 0.007ML (<1%) of ADD

Heathcote Booster WP341 No monitoring N/A Boosts zone pressure Dependant on WS151 water quality

Lucas Heights WP173 No monitoring N/A Only used if backfeeding from WS175 (emergency operation)

Gymea Booster WP030 No monitoring N/A Boosts zone pressure occasionally Dependant on WS175 water quality

Caringbah WP045 No monitoring (Note 2) N/A Currently only used to replenish elevated reservoir WS225 occasionally

Burraneer Point WP324 Pump time > 1hr/d High * Alternating supply to WS227 requires min 1 hr/day to turnover delivery main. Detains 0.226ML (17%) of ADD

ADD – Average Daily Demand Note 1 – Once capital works at reservoir completed creating dedicated inlet and outlet mains will need to review parameter to possibly >20hrs/d Note 2 – Once capital works at reservoir have been completed creating a dedicated Caringbah zone will need to review parameter to possibly pump operation to WS225 >= once/d


D-26

MONITORING PLAN

WORONORA SYSTEM

ASSET PARAMETER __/__/__ Further Action Status Helensburgh WS048

Reservoir level > 60% Operating window = 12hrsxpump rate

Helensburgh WS348

Reservoir level > 60% Operating window = 12hrsxpump rate

Engadine WS258 Reservoir level > 40% Operating window = 14hrsxpump rate

Engadine WS362 Reservoir level > 40% Operating window = 14hrsxpump rate

Heathcote WS047

Filling during evening/night Reservoir level > 40%

Loftus WS171 Reservoir level > 80% Maianbar WS227

Supply from Loftus > 12hrs/d Pump time from WP324 > 1hr/d

Lucas Heights WS161

Reservoir level > 30% Reservoir level > 60%

Menai WS268 Reservoir level > 40% Reservoir level < 80%

Illawong WS270 Reservoir on by-pass from May to October When Illawong Reservoir on-line fill during low demand periods ie evening/night

Sutherland WS156

Supply from Woronora WFP > 1hr/d


D-27

ASSET PARAMETER __/__/__ Further Action Status WP123 pump > 3hrs/d Reservoir level > 40%

Sutherland WS175

Supply from Woronora WFP > 1hr/d WP123 pump > 3hrs/d Reservoir level > 40%

Caringbah WS020

Reservoir filling > once/2 days If on-line is WS224 off-line

Caringbah WS224

Reservoir filling > once/2 days If on-line is WS020 off-line

Caringbah WS225

Reservoir filling > once/2 days

Kurnell WS199 Reservoir filling > once/2 days

Helensburgh WP319

Pump time < 12 hrs/d (Note 1) No. of pumps operating = 1 pump

Woronora-Engadine WP320

Pump time < 12hrs/d No. of pumps operating = 1 pump WP320 operation providing uniform draw off from WFP

Engadine WP071 Pump time = 12 hrs/d Pump during evening/night

Burraneer Point WP324

Pump time > 1hr/d


D-28

MANAGEMENT PLAN FOR

MAINTENANCE ACTIVITIES


D-29

MANAGEMENT PLAN FOR PHYSICAL & CHEMICAL RISKS IN THE DISTRIBUTION THROUGH MAINTENANCE ACTIVITIES Background: Discoloured water complaints are caused primarily by changes to the normal flow patterns within watermains re-suspending sediment that has accumulated over time. These flow changes can be caused by operational changes made to allow maintenance work to be carried out such as opening and closing valves, bringing mains back into service, water main breaks resulting in greatly increased flows in the adjoining pipes and occasional shifts in demand causing flow changes. The changes can be exacerbated by poor work practices or human error. Critical activities include:

• Identification and operation of valves • Mains cleaning – flushing and swabbing • Repair of main breaks • Chlorination of reservoirs and new mains • Service connections • Under pressure drilling • De watering mains

Hazard: Physical contamination of the system due to maintenance activities, poor work practices or human error. Chemical overdosing during chlorination of mains. Existing Management Strategies: Civil Maintenance

Job method statements: • Flush water main • Swab water main 150mm and over (cut and load) • Swab water main under 150mm with swab launcher • Disinfect mains with hypochlorite (1%) • Disinfect reservoir with reservoir dosing unit (RDU) • Disinfect main with sodium hypochlorite and mains dosing unit (MDU) • Disinfect reservoir with calcium hypochlorite tablets • Repair replace sections of water main • Rezone water supply • Determine cause of poor water supply (systemic) • Manage water incident site • Sample water • Provide temporary supply

Skills matrix Job cards

Water Operations

• Asset Operational/Shutdown Manuals


D-30

• Shutdown procedures prepared by Water Operations • WP-QMS0021 Discharge protocols • WP-QMS0041 Manual disinfection of service reservoirs • WP-QMS0027 Disinfecting new water mains • WP-QMS0044 Notification of system operational changes • WP-QMS0256 Prevention of water quality contamination following water mainbreaks • WP-QMS0239 Isolation and rezoning • WP-QMS0025 Planning of Flushing programs • WP-QMS0031 Procedure for planning of swabbing programs • WP-QMS0031.2R1 – Coordinating of swabbing activities checklist

Critical Control Points and Limits • Refer to Civil Maintenance audits, checklists and quality control points (if any noted in

CM QA Systems). Critical Control Measures

• customer complaints • compliance and operational monitoring programs • analysis of the audit outcomes

Preventive Measures

• Civil Maintenance QA system • Improved work practices • Continuous training programs

Monitoring Protocols/Plan The current Civil Maintenance job method statements are under review. The final draft due out shortly. Audit process for these procedures is not clear. WP-QMS procedures have Civil Maintenance interfaces with internal checklists that can be audited. Validation/Verification Plan Maintenance activities checked via WAMs and Maximo work databases. Reports are run monthly and reviewed at the Water Operation and Civil Maintenance link meetings. Previous audits conducted on Civil Maintenance covered swabbing, flushing and chlorinating activities. Documentation and Records


D-31

MANAGEMENT PLAN FOR

RESERVOIRS


D-32

MANAGEMENT PLAN FOR BIOLOGICAL, PHYSICAL AND CHEMICAL HAZARDS IN RESERVOIRS Background: There are twenty reservoirs at 13 key locations in the Woronora Delivery System. This includes the seven reservoirs within the Sutherland Distribution System. During the risk assessment of the Woronora Delivery System risk related to intrusion into the reservoirs was ranked as critical. The remoteness and the location of some of the reservoirs within the system resulted in some of these reservoirs assessed as higher risk. Hazard:

• Terrorists, vandals and/or outsiders/employees • Vermin ingress • Roof water due to rain • Falling off of general painting • Deterioration of the relining inside of tank • Contamination during reservoir cleaning

Existing Management Strategies:

• WP-QMS0041 – Manual disinfection of service reservoirs • WP-QMS0042 – Inspection of cleaning of service reservoir by divers • WP-QMS0087 – Online monitoring of reservoirs using chlorine residual analysers • WP-QMS0174 – Managing water quality during the planned isolation of trunk mains

(inlet & outlet) • WP-QMS0177 – Investigation faecal coliform / faecal streptococcal exceptions

Present level of risk:

• Refer reservoir list below Critical Control Points and Limits All reservoirs are rated Low or High Reservoir will be rated High on the advise of the Water Operators using the following criteria and are to be considered as the CCP: • Critical supply to a system • Single supply to reservoir site • Combined inlet and outlet to reservoir • Inadequate chlorine mixing • Remoteness • Any other operational activities or unique characteristics to the reservoirs/sites. Eg. relined

tank, painting, minor/major capital works, work that could be detrimental to the water quality.


D-33

Timeframe: High - one inspection a month Low - one inspection every three months (this would coincide with site security inspection which has a large influence on water quality) Critical Control Points High Caringbah Surface WS020 Caringbah Surface WS224 Caringbah Elevated WS225 Engadine Surface WS258 Engadine Surface WS362 Lucas Heights Surface WS161 Helensburgh Surface WS048 Helensburgh Surface WS348 Sutherland Surface WS156 Sutherland Surface WS175N Sutherland Surface WS175S Critical Control Measures Low Illawong Surface WS270 Kurnell Surface WS199 Loftus Surface WS171 Maianbar Surface WS227 Menai Surface WS268 Hargrave Heights Surface WS202 Hargrave Heights Surface WS458 Heathcote Surface WS047 Heathcote Elevated WS151 Stanwell Park Surface WS229 Critical limits – no limits applicable. Reservoirs ranked according the criteria listed above and refer completed check list after inspection and the exceptions summary. Preventive Measures • Routine reservoir inspections • Operational Monitoring Programs • Reservoir cleaning programs • Disinfection Strategy Monitoring Protocols/Plan A reservoir checklist was developed for security and water quality inspections. Refer to attachment below. The inspections will be carried out on either a monthly or 3 monthly basis depending on the rating of the reservoir.


D-34

Validation/Verification Plan • Audit the checklist: eg. every six months • Audit the activities on the checklist: eg. every twelve months or if new activity is added,

whichever comes first • Audit the person or persons doing the audit on site: eg. every six months or when new person

is brought in, whichever comes first • Audit reservoir sites: eg. every twelve months with an up to date plan (Hydra) or when new

work is completed References • Form WR4 - water pumping station and site inspection checklist • Form WR5 - reservoir and site inspection checklist (that contains certain tasks for water

quality) • Form G12 - for site security inspections - Civil Maintenance (from the security manual) • WPQMS R104 – Security Inspection forms


WORONORA HACCP - RESERVOIR CHECKLIST FOR SECURITY & WATER QUALITY

Date of Inspection: / / Work Order:___________ Asset No. & Name:__________________

Inspected by (Print name):__________________________ Signature:___________________________ Security

Task No.

Task Description Satisfactory (Y/N/NA)

Comment

1. Check access roads / easements (clear of obstruction / any erosion / access is available etc.)

2. Check signage for adequacy, visibility or condition.

3. Check site perimeter fence (for holes, any other damage etc.)

4. Check all access gates (operational, holes, any other damage etc.)

5. Check building access doors (locked, corrosion, broken hinges, any other damage etc.)

6. Check all structures (tanks, buildings, chambers etc) for graffiti

7. Check condition of grounds (grass height, vegetation, holes etc.) buildings for (broken windows, gutters, holes in walls, etc)

8. Check for signs of leaks within grounds

9. Check all hydrants (possible tampering, any other damage etc).

10. Safety (Any Hazards or Issues)

11. Other (Specify)

D-35

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

Water Quality Task No. Task Description Satisfactory

(Y/N/NA) Comments

12. Check if mixer is operating

13. Check inlet water sample tap & box (any kind of damage)

14. Check inlet chorine level (reading = mg/L)

15. Check outlet water sample tap & box (any kind of damage)

16. Check outlet chorine level (reading = mg/L)

17. Check reservoir ladder gate is secure (locked, hinges not broken, any corrosion, any other damage etc)

18. Check vents are bird proof and waterproof

19. Check condition of hatches (hinges not broken, any corrosion, holes, locks missing, any other damage etc)

20. Check condition of davit (any corrosion, any other damage etc)

21. Check condition of roof (missing screws, bolts, holes, any other damage etc)

22. Check condition of railings and walkways (any corrosion, holes, missing sections, any other damage etc)

23. Check if rainwater can enter tank by any other means not covered (kick rail to close, backing up of rubbish, any other damage etc)

24. Check condition of valve and gauge floats (any corrosion, any other damage etc)

25. Safety (Any Hazards or Issues)

26. Other (Specify)

D-36

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

D-37

MANAGEMENT PLAN FOR

TREATMENT


D-38

MANAGEMENT PLAN FOR WATER TREATMENT 1. Introduction Woronora Water Filtration Plant is one of the four Water Filtration Plants built under Build Own and Operate Contracts with private sector participation. General Water Australia has been contracted to operate the plant for 25 years, from 1996 to 2021. The plant is designed to operate on a fully automated mode. Each treatment process was considered as critical and process equipments were built with required stand-by capability. Quality management system and quality assurance processes are in place to ensure compliance with agreed quality standards. 2. Quality Assurance The operation of the plant is achieved through a Quality Management System developed on the basis of international standards ISO 9002. Performance of each process is monitored through plant SCADA system within which control are built in to raise alarms during quality variation. 3. Existing Management Strategies:

1. Water Filtration Agreement define the performance parameters, compliance requirements, testing requirements and management processes to meet the compliance standards

2. Water Filtration Plant Quality Management System implemented in the plant was developed on the basis of international standards, ISO 9002, and certified by an authorised certifying body.

3. Output quality is monitored through on-line monitoring system, both by plant SCADA and SWC IICATS. In addition, quality monitoring is carried through SWC’s monitoring and sampling program.

4. Review / Audit Protocols and procedures are in place to manage plant performance and these procedures are reviewed and updated on a periodic basis. External auditors for the compliance to certification standards and requirements audit management system on an annual basis. Plant performance with regards to compliance to Water Filtration Agreement requirements is audited on a bi-annual basis. Audit includes the monitoring, instrument calibration, water quality testing, testing methods, maintenance of all plants and equipment etc. Quality variation on a day- to-day basis is checked through the on-line monitoring trends and communicated through early warning / event notification.


D-39

5. Critical Control Points and Limits of Quality Assurance 5.1 Catchment and Storage Sydney Catchment Authority (SCA) manages water quality within catchment and storage. SCA adopt multi-barrier approach in ensuring the quality standards specified within Bulk Water Supply Agreement to supply water to SWC. SCA has got plans and process in place to reduce pollutant within the catchment and to monitor water quality and its variation within storage. Limits for water quality parameters, to obtain best possible water for treatment, are specified in the Bulk Water Supply Agreement. 5.2 Pre-treatment The plant design incorporated dosing of potassium permanganate as an oxidising agent to remove iron and manganese as well as to improve colour. Carbon dioxide in combination with lime is used to recarbonate the raw water and to increase pH levels desired for optimum coagulation process. Limits on dosage level requirements are dependent on the levels of iron, manganese and colour of raw water. The results of daily sampling are used to determine the dose rate requirements. 5.3 Coagulation and Flocculation Any mineral and organic compounds present in the water must be bound together to facilitate their removal by filtration. The particles are destabilised (Coagulation) in a flash mixer and then agglomerated, by adding ferric chloride in combination with a cationic polymer, into bulky floccules, called “flocs” inside a coagulation tank (flocculation). The determination of type and amount of coagulant to be added to water is made by jar testing. Continued monitoring of coagulation process performance, evaluation of water quality conditions, checking and adjusting process equipments and controls and visually inspecting the process operation are few controls applied in the operation of coagulation process. Control limits to determine coagulant dosage and process performance are water quality indicators of coagulated water. These limits include the monitoring of turbidity, temperature, alkalinity, pH, colour and chlorine demand. 5.4 Filtration Flocculated water is passed through a filter, to remove the impurities. A non-ionic polymer is added in a low energy mixer to act as a filter aid, this slows the penetration of very fine flocs into filter bed. The control for the measure of efficiency is the target set for the output turbidity. The selected effluent turbidity for this plant is 0.1 NTU. The filters are operated to achieve this target. However, filter removal efficiency depends on factors such as quality of water being treated, the effectiveness of pre-treatment processes in conditioning the suspended particles for removal and filter operation itself. Filter unit design and filter media type and thickness also play a role in


D-40

determining filter removal efficiency but are less important than water quality and pre-treatment considerations. Controls applied in the form of specification for raw water supplied by SCA, optimal operation of processes before filtration, operating protocols and procedures for each processes, monitoring of effluent quality from filters and optimal operation of filters including backwashing are to ensure the compliance with the effluent quality target levels. Other controls applied on a day-to-day basis are:

• Continued monitoring of process performance • Monitoring for abnormal conditions such as;

Mudballs in filter media Media cracking and shrinkage Media boils during backwash Excess media loss or visible disturbance Short filter runs Filters that will not come clean during backwash, and Algae on walls and media

• Evaluation of water quality conditions and making appropriate process changes • Checking and adjusting process equipment (change chemical feed rates) • Measurement of head loss build up • Rate of increase in effluent turbidity • Elapsed run time between back washes • Backwashing of filters • Periodic evaluation of filter media conditions (media loss, mudballs, cracking),

and • Visually inspecting facilities.

6. Controls 6.1 Monitoring and Analysis Monitoring processes such as online monitors, daily manual sampling by plant operators and sampling by third part testing laboratory are the initial controls applied to ensure compliance with output quality. Abrupt changes in water quality indicators such as turbidity, pH, alkalinity, colour, odour, chlorine demand (source water), chlorine residuals are signals that the operator take immediate action to review the performance of filter performance and other processes. 6.2 Automation Plant is totally automated by using Supervisory Control and Data Acquisition System. An on-call system generates alarms to ensure that operators are warned if any problems arise. Using a laptop computer, the operator is able to control the functioning of the plant from any location. The plant operators to troubleshoot on 24-hour basis use this method and variations are corrected before it impact on the water supplied to consumers. The table below details the control points and limits.


CRITICAL CONTROL POINTS AND LIMITS

CCP/Process Indicator Controls/Process 1. Source

Management (Catchment Storage)

Physical • Turbidity • Colour • Temperature • Taste & Odour Chemical • Inorganics • Organics Biological • Bacteria • Protozoa • Spores • Viruses • Cysts etc. Nutrients (Phosphate, Nitrate and organic nitrogen compounds) Algal blooms leading to:

- Taste & odour - Shortened filter run - Increased pH - Dissolved oxygen depletion - Organic loading

On line monitors Monthly sampling Monitoring plan Change of off-take procedure

Monitoring plan Change of off-take procedure

Catchment Management Plan Pollution Control Plan Monitoring Plan Risk Assessment Plan

• Protection of catchment • Reduction of human activities within catchments • Pollution Control Plan • Destratification/Aeration • Monitoring Plan (Treatment by WFP)

2. Pre-Treatment

Coliform or microbial contamination

Pre-chlorination (followed by coagulation/flocculation/filtration/Disinfection)

D-41

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

CCP/Process Indicator Controls/Process 2. Pre Treatment (cont)

Iron and Manganese

Hardness (Softness)

• Oxidation with chlorine • Oxidation with permanganate • Addition of carbon-dioxide and lime.

3. Coagulation and Flocculation

Removal of particulate impurities – unsettled solids and colour Normal Operation Abnormal Operation: Sudden changes in Turbidity, pH, alkalinity, Temperature and chlorine demand

• Process Guidelines • Operating Procedures • Monitoring of process performance • Evaluation of water quality conditions • Checking and adjusting process controls • Inspection of facilities. • Verification of effectiveness of coagulant chemical

and dose rate. • Jar test • Inspection of flash mixing intensity • Inspection of condition of flocs-dispersion, size and

floc strength. • Changes in water temperature and adjusting mixing

intensity. • Checking the rate of filter-aid dose rate. • Process change procedure • Laboratory analysis/jar test procedures • Communication protocol • Event Reporting • Incident Management Plan/Procedures • Safety Procedures

D-42

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

CCP/Process Indicator Controls/Process

• Sampling and analysis procedures • Equipment Operation and Maintenance Procedures.

4. Filtration

Design considerations: • Chemical characteristics of water being

treated • Nature of suspension • Types and degree of treatment • Filter type and operation Operation: • Effluent turbidity

• Filter layout • Filter production and filtration rate • Filtration efficiency • Selection of media • Head Loss • Back Washing • Mode of filtration • On-line monitoring • Requirements under Water Filtration Agreement

(WFA) • Requirement for <0.1 NTU at filter outlets. • Daily sampling as per WFA • Alarms and response procedure • Process guidelines • Operating procedures. Operational Actions • Monitor process performance • Evaluate Water quality condition and make process

changes. • Check and adjust process changes • Backwash of filters • Evaluate filter media condition • Visually inspect process.

D-43

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

CCP/Process Indicator Controls/Process 4. Filtration (cont)

Effluent turbidity (cont).

Control Limits for Back Washing - Evaluation of head loss - Monitoring of effluent turbidity variation - Elapsed run time between backwashes

Variations in turbidity (Influent/Effluent) Increase in colour Increased Head Loss

• Increase sampling frequence • Perform Jar Test • Make necessary process changes

- Change coagulant - Adjust coagulant dose rate - Adjust flash – mixing intensity - Change chlorine dose rate - Change filtration rate - Backwash filters

Back washing: • Media boils • Media expansion • Media carryover • Clarity of wash water

• Changing backwash rate • Changing backwash cycle time • Adjust surface wash rate • Inspections of filter media depth

Abnormal Operation: Water Quality Indicators: • Increase in turbidity, pH, alkalinity,

chlorine demand and decrease in chlorine residual.

Other Indicators • Mudballs • Media cracking or shrinkage

Procedures and Processes for: • Determination of filtration removal efficiency • Checking of coagulation and flocculation chemical

dosage rate • Checking of filter aid dose rate (under or over) • Checking of changes in raw water conditions

D-44

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

CCP/Process Indicator Controls/Process • Media boils during backwash • Excessive media loss • Short filter runs • Algae on walls and media • Shorter filter run due to air binding • Excessive headloss after back wash • Turbidity breakthrough

• Checking on increased solid dosing • Checking of filter nozzle failures • Maintenance of equipment

5. Management Systems and Processes

• Non conformance with quality objectives and targets

• Non availability/failure of process. • Reduction of warranted capacity due to

failures • Non conformance with quality assurance

requirements • Variation in raw water quality • Events/Incidents/Crisis

• Compliance requirements in WFA and contractual penalties for non-conformance

• Plant operational management system • Plant maintenance management systems and

procedures • Process Unit guidelines • Standard Operating Procedures • Communications Protocol • Change Management Procedure • Variations/event reporting and management

system/process/protocols. • Incident management Plans • Quality Management Plan • Quality Assurance procedures/Requirements under

WFA. • Water Quality Monitoring plan • Water quality testing and auditing requirements under

WFA. • Periodic auditing of overall performances by SWC. • Bulk Water Supply Agreement (between SWC and

SCA) requirement to provide best available raw water to WFP.

D-45

©2006 A

ww

aRF

. All R

igh

ts Reserved

.

6666 West Quincy AvenueDenver, CO 80235-3098 USAP 303.347.6100www.awwarf.orgemail: [email protected]

Sponsors Research

Develops Knowledge

Promotes Collaboration

1P-3.75C-91131-07/06-NH