Water Corporation - Department of Healthww2.health.wa.gov.au/~/media/Files/Corporate/general documents... · Water Corporation for Recycled Water ... wastewater treatment plant and

MOU 2010 v1

Memorandum of Understanding between the

Department of Health

and

Water Corporation

for

Recycled Water

July 2010

Memorandum of Understanding for Recycled Water

MOU 2010 v1 Printed on 10-Aug-10

Healthy Workforce•Healthy Hospitals•Healthy Partnerships•Healthy Communities•Healthy Resources•Healthy Leadership

CONTENTS 1. RECITALS ................................................................................................................................................................... 1 2. DEFINITIONS .............................................................................................................................................................. 2 3. BACKGROUND ........................................................................................................................................................... 3 4. FORWARD................................................................................................................................................................... 4 5. COMMITMENT TO RECYCLED WATER QUALITY.................................................................................................... 5

5.1 Resource the Agreement................................................................................................................................... 5 5.2 Identify Responsible Officers ............................................................................................................................. 5 5.3 Establishment of a Health Advisory Committee for GWRT................................................................................ 5 5.4 Develop Recycled Water Quality Regulation ..................................................................................................... 5 5.5 Work to Manage Recycled Water Source.......................................................................................................... 5

6. ROLE OF THE DEPARTMENT OF HEALTH .............................................................................................................. 6 6.1 Role ................................................................................................................................................................... 6 6.2 As Regulator ...................................................................................................................................................... 6 6.3 As Adviser to the Corporation............................................................................................................................ 6 6.4 As Auditor .......................................................................................................................................................... 6 6.5 As Adviser to the Public..................................................................................................................................... 6

7. ADMINISTRATION OF RECYCLED WATER QUALITY.............................................................................................. 7 7.1 Recycled Water Quality Parameters and Recycled Water Quality Indicators .................................................... 7 7.2 Variations to Recycled Water Quality Parameters and Recycled Water Quality Indicators ............................... 7 7.3 Additional Management and Quality Criteria...................................................................................................... 7 7.4 Exemptions........................................................................................................................................................ 7 7.5 Schedules to the MoU ....................................................................................................................................... 7 7.6 Approval to Vary Recycled Water Quality Parameters and Indicators ............................................................... 7 7.7 Corporation Quality Obligation........................................................................................................................... 7 7.8 Safe Water......................................................................................................................................................... 7

8. IMPLEMENTING THE GUIDELINES........................................................................................................................... 8 8.1 Implementation of Management Framework...................................................................................................... 8 8.2 Review............................................................................................................................................................... 8

9. SYSTEMS ANALYSIS AND MANAGEMENT .............................................................................................................. 8 9.1 Monitoring Programs ......................................................................................................................................... 8 9.2 Recycled Water Quality Management Processes and Procedures.................................................................... 8 9.3 GWRT Catchment Protection ............................................................................................................................ 8 9.4 Monitoring Programs ......................................................................................................................................... 8 9.5 Recycled Water Analysis ................................................................................................................................... 8

10. DATA EXCHANGE ...................................................................................................................................................... 9 10.1 Corporation Data ............................................................................................................................................... 9 10.2 Department Data ............................................................................................................................................... 9 10.3 Special Investigations ........................................................................................................................................ 9 10.4 Information Exchange........................................................................................................................................ 9 10.5 Confidentiality .................................................................................................................................................... 9 10.6 Reporting Formats ............................................................................................................................................. 9

11. EVENTS OF OPERATIONAL SIGNIFICANCE............................................................................................................ 9 11.1 Events................................................................................................................................................................ 9 11.2 Corporation to Report ...................................................................................................................................... 10 11.3 Department to Respond................................................................................................................................... 10

12. EMERGING ISSUES ................................................................................................................................................. 10 13. PUBLIC EDUCATION AND INFORMATION ............................................................................................................. 10

13.1 Public Education .............................................................................................................................................. 10 13.2 Corporation GWRT Annual Recycled Water Quality Report............................................................................ 10 13.3 Department Annual Recycled Water Quality Report Response....................................................................... 10

14. MATERIALS AND CHEMICALS ................................................................................................................................ 10 14.1 Materials in Contact with Recycled Water........................................................................................................ 10 14.2 Chemicals Approved for Addition to Recycled Water. ..................................................................................... 10 14.3 Chemicals Used to the Maintain Recycled Water Treatment System.............................................................. 11 14.4 Seeking Approval............................................................................................................................................. 11

15. TERM REVIEW AND AMENDMENT ......................................................................................................................... 11 15.1 Term ................................................................................................................................................................ 11 15.2 Amendments to the MoU ................................................................................................................................. 11 15.3 Amendment of GWRT Binding Protocols and Schedules ................................................................................ 11

16. ENDORSEMENTS..................................................................................................................................................... 12


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THIS MEMORANDUM OF UNDERSTANDING is entered into on the day of 2010.

BETWEEN THE WATER CORPORATION ("the Corporation")

AND THE DEPARTMENT OF HEALTH ("the Department")

1. RECITALS

A. The Groundwater Replenishment Trial is a research and development project undertaken to gather water quality data and develop systems and processes to assess the viability of groundwater replenishment as a future drinking water source option.

B. This Memorandum of Understanding (MoU) relates to the operational and recycled water quality requirements of the Groundwater Replenishment Trial Project (GWRT) over the Term of the Agreement.

C. The GWRT will be designed, constructed, commissioned and operated generally in accordance with the Australian Guidelines for Water Recycling: Managing Health and Environmental Risks (Phase 1) and the Australian Guidelines for Water Recycling: Managing Health and Environmental Risks (Phase 2) Augmentation of Drinking Water Supplies.

D. The Corporation is a corporatised body under the Water Corporation Act 1995. The Corporation has the responsibility for execution of the GWRT Project in such a way that is low risk to human health and the environment.

E. The Department is the regulatory agency for drinking water quality and recycled water quality in Western Australia and has a role in providing advice to the Government on standards in relation to recycled water quality and associated risks to public health.

F. The Department and the Corporation have entered into a Memorandum of Understanding for Drinking Water. This GWRT MOU has no affect on the drinking water Memorandum of Understanding, drinking water management or regulation.

G. The Department also has certain responsibilities in relation to the protection of public health under the Health Act 1911; Health (Treatment of Sewerage and Disposal of Effluent and Liquid Waste) Regulations 1974 and other relevant legislation.

H. This MoU does not intend to monitor or regulate wastewater beyond existing legislative or regulatory provisions.

I. The Department, the Corporation, the Department of Water and the Department of Environment and Conservation have collectively entered into an Inter Agency Agreement to support the GWRT and developed criteria which will form the basis of assessment of groundwater replenishment as a future water source option.

J. Nothing in this MoU shall create any relationship between the Corporation and the Department amounting to a partnership, agency, trust or joint venture.


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2. DEFINITIONS

Corporation means the Water Corporation;

Department means the Department of Health;

Drinking Water means Water intended primarily for human consumption, which also has other domestic uses;

Beenyup WWTP means the Beenyup Wastewater Treatment Plant located at 922 Reef Road, Craigie, WA, 6025;

Environmental values of the Leederville aquifer in the vicinity of the GWRT have been identified by the Departments of Water, Health and Environment and Conservation and Water Corporation and are documented in the “Trial Environmental Values for the Leederville Aquifer for the Groundwater Replenishment Trial (February, 2008)”;

Groundwater replenishment means storing high quality recycled water in groundwater for future use including as a raw drinking water source;

Guidelines means the 2006 Australian Guidelines for Water Recycling: Managing Health and Environmental Risk (Phase 1) and the 2008 Australian Guidelines for Water Recycling: Managing Health and Environmental Risks (Phase 2) Augmentation of Drinking Water Supplies published by National Health and Medical Research Council;

GWRT means the Groundwater Replenishment Trial to be undertaken by the Corporation and which involves the planning, approval, design, construction, commissioning, recharge, operation, sampling, monitoring and review of an advanced water treatment plant, generally consisting of membrane filtration, reverse osmosis and ultra violet disinfection, at the Corporation’s Beenyup site;

GWRT Catchment means the system that delivers inflows to the Beenyup wastewater treatment plant and includes wastewater from homes, businesses, industry and hospitals;

GWRT Source means for the purpose of the Groundwater Replenishment Trial the Beenyup Wastewater Treatment Plant;

Hazard Analysis and Critical Control Point (HACCP) is a systematic methodology to control safety hazards in a process by applying a two-part technique; first an analysis that identifies hazards and their severity and likelihood of occurrence; and second, identification of critical control points and their monitoring criteria to establish controls that will reduce, prevent, or eliminate the identified hazards;

MoU means this GWRT Memorandum of Understanding between the Department and the Corporation;

Receiving Aquifer means the Leederville Aquifer;


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Recycled Water means water produced by the Groundwater Replenishment Trial advanced water treatment plant and recharged to the Leederville Aquifer;

Recycled Water Quality Parameters means the parameters specified by the Department and as set out in Schedule 1;

Recycled Water Quality Indicators are chemicals or pathogens that best represent a larger group of chemical or microbiological hazards identified by the Recycled Water Quality Parameters. The Indicators have been specified by the Department and provided in Schedule 1; and

Term is as defined in clause 15.1.

3. BACKGROUND

The use of recycled water to increase raw drinking water groundwater resources in Western Australia, may allow less sustainable drinking water source options to be deferred, reduce wastewater disposal to the marine environment, free up other water resources for public and private use and improve water levels in lakes, rivers and wetlands and provide water for vegetation. Treated wastewater from the Beenyup WWTP is a significant resource which could be used (after appropriate treatment) to replenish groundwater, thus improving groundwater levels and allowing groundwater allocations for drinking water to be maintained. 2007 inflows to the Beenyup WWTP were approximately 40 GL/year. Based on a 75% recovery rate from advanced treatment processes, current volumes from the Beenyup WWTP could represent an additional 25-30 GL/year source to the drinking water supply system and would increase the amount of wastewater recycling in the metropolitan area to approximately 35%. In 2005 the Environmental Protection Authority (EPA) assessed the potential for groundwater replenishment to be conducted in the Perth metropolitan area. The EPA supported further investigation of the approach on a staged basis “starting with trials and projects of low risk1”.

In April 2005 the Corporation released its “Source Development Plan for the Integrated Water Supply Scheme” which recognised that storing high quality recycled water in groundwater supplies could provide a drinking water source option into the future. In January 2008 the Corporation approved the implementation of the GWRT to trial injecting high quality recycled water into groundwater. The purpose of the trial is to build knowledge of the technical, health, environmental and social issues associated with groundwater replenishment and collect sufficient information to assess and determine if groundwater replenishment is a safe, viable and sustainable drinking water source option.

1. Strategic Advice on Managed Aquifer Recharge Using Treated Wastewater on the Swan Coastal Plain, Environmental

Protection Authority, Bulletin 1199, October 2005


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The State Water Recycling Strategy – An Overview released in June 2008 set out initiatives to achieve 30% recycling by 2030. The Corporation has committed to the State Water Recycling Strategy. Recycled water for drinking and the GWRT are included as specific items under the strategy direction. The Department and the Corporation have committed to applying the Australian Guidelines for Water Recycling (Phase 1 and Phase 2) to the GWRT and assessing the application of the Guidelines to any subsequent large scale groundwater replenishment scheme.

4. FORWARD

This MoU continues the strong co-operative relationship, for managing water quality in Western Australia that exists between the Corporation and the Department.

The foremost role of the Department in this MoU is its role of regulator of drinking water and recycled water quality in the State. This MoU enables the Department to assess and audit the GWRT Recycled Water quality, management and reporting systems to ensure ongoing satisfactory performance. Both the Department and the Corporation recognise that the practices and processes used to establish and maintain high levels of Recycled Water quality need to be open and transparent to the community. Both organisations commit to ensuring that performance will be reported in a timely manner and will be open to public scrutiny. This MoU has been designed to respond to change, as recycled water quality and management issues continue to emerge, both in Australia and around the world. Both the Department and the Corporation are committed to using a multi barrier approach to managing recycled water quality. The identification of barriers will be based on risk assessment using the HACCP methodology from catchment to recharge and will be supported by proactive management from source to recharge. Risk based assessment will identify the key risks to be managed and may identify areas for further assessment or investigation. The key objectives of the GWRT are:

• Technical feasibility To assess, determine and demonstrate if the amalgamation of established treatment technologies can reliably deliver water quality requirements and a new, safe, sustainable and viable drinking water source option, and to

To develop systems that ensure Recycled Water produced meets the requirements of safety, regulations and needs.

• Community engagement and acceptance To demonstrate groundwater replenishment in an area of low risk and impact, and build community understanding and confidence in the approach via a comprehensive communications package.


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• Policy and Regulation In collaboration with regulators and researchers, acquire the knowledge to enable assessment, and if appropriate, approval of a large scale scheme, provide a context for regulators to generate health, environmental and water allocation policy and regulations on the issue of indirect potable reuse via aquifers.

The overriding objective of GWRT is to produce safe recycled water for recharge to the Leederville Aquifer.

5. COMMITMENT TO RECYCLED WATER QUALITY

The Corporation and Department are committed to ensuring that recycled water will only be used where it is safe.

5.1 Resource the Agreement

The Corporation and Department agree to provide adequate resources to meet the requirements of this MoU.

5.2 Identify Responsible Officers

An officer will be identified within each organisation who will be responsible for monitoring, facilitating and reporting to their relevant chief executive officer on the implementation of this MoU. The responsible officers for the Corporation and Department are identified in Binding Protocol 1.

5.3 Establishment of a Health Advisory Committee for GWRT

A Health Advisory Committee for GWRT will be established and shall develop over the next six months its terms of reference. The Department will Chair the Advisory Committee. Both organisations are committed to the ongoing work of this Committee to deliver the objectives of GWRT and ensure safe Recycled Water.

5.4 Develop Recycled Water Quality Regulation

The Department and Corporation will work cooperatively to develop health based Recycled Water regulation for application to any future groundwater replenishment scheme intended to supplement groundwater as a raw drinking water source option in Western Australia.

5.5 Work to Manage Recycled Water Source

The Department and the Corporation will cooperate in areas of mutual interest to ensure adequate consideration is given to manage the GWRT Catchment and GWRT Source recognising that any future groundwater replenishment scheme may need to consider the upstream inflow to the wastewater Catchment as part of the Source.

5.6 Aquifer storage protection The Department and the Corporation recognise their responsibility in source protection and will carry out hazard identification and risk assessment where required to ensure that the environmental values of the Leederville aquifer are protected, including the continued use of the Leederville aquifer to provide a drinking water source.


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6. ROLE OF THE DEPARTMENT OF HEALTH

6.1 Role

(a) The Department’s roles are to:

(i) minimise human exposure to environmental health hazards that pose or have the potential to pose a health risk;

(ii) reduce the incidence and impact of communicable disease, and (iii) meet the Department’s Inter-agency Working Group commitments as

listed in Schedule 6.

6.2 As Regulator

The Department is the regulator of Recycled Water quality. During the Term, the Corporation and the Department will work together to develop health regulatory requirements associated with Recycled Water delivered for groundwater replenishment.

6.3 As Adviser to the Corporation

The Department shall provide advice to the Corporation on matters regarding the production and quality of recycled water.

6.4 As Auditor

(a) The Department may audit the Corporation’s systems and databases used to manage and report Recycled Water quality as required.

(b) The audit scope will be prepared by the Department and discussed with the

Corporation. The audit report will include recommendations for improvements where appropriate. The responsible officers shall provide regular progress reports of improvements undertaken to the Department.

(c) The cost of the audit shall be borne by the Corporation.

6.5 As Adviser to the Public

In consultation with the Corporation, the Department will provide comment and advice to the public, including media, with respect to recycled water quality issues.


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7. ADMINISTRATION OF RECYCLED WATER QUALITY

7.1 Recycled Water Quality Parameters and Recycled Water Quality Indicators

The Department will specify the Recycled Water Quality Parameters and Recycled Water Quality Indicators for Recycled Water and the Department’s requirements are contained within Schedule 1. Achievement of Recycled Water Quality Parameters will be demonstrated using the Recycled Water Quality Indicators.

7.2 Variations to Recycled Water Quality Parameters and Recycled Water Quality Indicators

Recycled Water Quality Parameters and Recycled Water Quality Indicators may be varied where evidence from either research literature or from the GWRT provides just cause.

7.3 Additional Management and Quality Criteria

The Department may recommend or set additional Recycled Water management and quality criteria for the Corporation to comply with or make interpretations where the parties believe the Guidelines lack relevant detail or sufficient clarity. The Department shall consult with the Corporation before taking such action. Any additional management or quality criteria are identified in Schedule 2.

7.4 Exemptions

The Department may grant exemptions for certain parameters and criteria. Exemptions granted by the Department are set out in Schedule 2.

7.5 Schedules to the MoU

The Department and the Corporation shall regularly review the schedules and will develop additional schedules to this MoU on an as needs basis. The Schedules are intended to provide supporting information to this MoU.

7.6 Approval to Vary Recycled Water Quality Parameters and Indicators

Variations, additions or exemptions to Recycled Water Quality Parameters and Recycled Water Quality Indicators as specified in sections 7.1, 7.2, 7.3 and 7.4 shall be approved by the Minister for Health.

7.7 Corporation Quality Obligation

Under this MoU, the Corporation will provide Recycled Water that complies with the Department’s requirements in sections 7.1, 7.2, 7.3 and 7.4 prior to it being recharged to the Receiving Aquifer.

7.8 Safe Water

The parties agree that Recycled Water that complies with the Recycled Water Quality Parameters is safe for recharge to the Leederville Aquifer.


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8. IMPLEMENTING THE GUIDELINES

8.1 Implementation of Management Framework

(a) The Guidelines incorporate an integrated quality assurance framework that is designed to manage recycled water quality from catchment to tap. This approach is similar to the existing 2004 Australian Drinking Water Guidelines management structure and requires the adoption of a multi agency continual improvement system.

(b) The Department and the Corporation will work cooperatively with other

stakeholders to implement the Guidelines during the Term of this MoU.

8.2 Review

At least annually during the Term, the Corporation will conduct a review of the GWRT Framework and associated management system. The results of the review will be provided to the Health Advisory Committee for GWRT.

9. SYSTEMS ANALYSIS AND MANAGEMENT

The Corporation and the Department shall maintain and apply an effective system to manage Recycled Water quality. To facilitate this, the Corporation and the Department will develop:

9.1 Monitoring Programs

In consultation with the Department, the Corporation shall during the Term develop, maintain and implement a Recycled Water sampling and monitoring program for GWRT.

9.2 Recycled Water Quality Management Processes and Procedures

In consultation with the Department, the Corporation shall develop, maintain and review its Recycled Water quality management processes and procedures in accordance with the Guidelines. Processes and procedures that have been endorsed by the Department are set out in Binding Protocol 2.

9.3 GWRT Catchment Protection

The Corporation and the Department recognise their responsibility in GWRT Catchment protection and will develop agreed processes to carry out hazard identification and risk assessment where required to ensure quality of Recycled Water. Where unacceptable risks are identified, the Corporation and the Department will take action to reduce the risks.

9.4 Monitoring Programs

The Department may develop and undertake monitoring programs itself in special circumstances.

9.5 Recycled Water Analysis

(a) All samples for analysis and testing shall be submitted to laboratories that are registered by the National Association of Testing Authorities unless otherwise agreed with the Department.

(b) All samples tested shall use methods accredited by the National Association of Testing Authorities unless otherwise agreed with the Department.


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10. DATA EXCHANGE

10.1 Corporation Data

The Corporation shall make available all monitoring and sample results to the Department.

10.2 Department Data

The Department will provide the Corporation with reports and studies it undertakes which are relevant to those activities of the Corporation which may impact on public health or the success of the GWRT.

10.3 Special Investigations

The Corporation will provide access to reports and studies undertaken by the Corporation as part of its assessment of groundwater replenishment which are relevant to public health.

10.4 Information Exchange

Each party may provide an annual program of their respective public health related research and development activities associated with recycled water.

10.5 Confidentiality

Either party can place confidentiality constraints on the information and data that it provides. Information provided by one party to the other shall not be published by the receiving party without the prior written approval of the issuing party.

10.6 Reporting Formats

The Department and the Corporation will work cooperatively to develop, establish and improve reporting formats.

11. EVENTS OF OPERATIONAL SIGNIFICANCE

11.1 Events

(a) From time to time it may be necessary for the Corporation to notify the Department of events that may affect recycled water quality.

(b) A joint response from both parties may or may not be necessary or appropriate

depending upon the nature of the event and any potential adverse impact the event may have on public health. Communication processes associated with Events are provided in Binding Protocol 3.

(c) There are two levels of response to events that affect the recycled water

quality:

(i) Events Level 1 – medium level Recycled Water quality impact requiring notification to the Department within 24 hours of the event; and

(ii) Events Level 2 – low level Recycled Water quality impact requiring exception reporting to the Department monthly at the Health Advisory Committee for GWRT.

Events are described in Binding Protocol 4.


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11.2 Corporation to Report

The Corporation shall report to the Director Environmental Health any Event within its Recycled Water production system which may affect Recycled Water in accordance with Binding Protocol 4.

11.3 Department to Respond

The Department will provide a 24 hour point of contact for the reporting of any such Events, in order that the Director Environmental Health can determine whether any action should be taken in accordance with Binding Protocol 4.

12. EMERGING ISSUES

The Department and Corporation will monitor and discuss emerging issues that are not currently addressed by the Guidelines or this MoU that may be of public health interest or significance.

13. PUBLIC EDUCATION AND INFORMATION

13.1 Public Education

The Department and Corporation shall develop and implement public education programs relating to Recycled Water quality as required. Where appropriate the Department and the Corporation will jointly develop and or support development of educational information and programs.

13.2 Corporation GWRT Annual Recycled Water Quality Report

The Corporation shall prepare a report for the Department each year that lists GWRT Recycled Water quality testing conducted and their results in an agreed format.

13.3 Department Annual Recycled Water Quality Report Response

The Department shall prepare a response to the Corporation’s annual Recycled Water quality report provided under clause 13.2.

14. MATERIALS AND CHEMICALS

14.1 Materials in Contact with Recycled Water

(a) The Corporation shall only use materials in production of Recycled Water that have been approved by the Department. Materials approved for use in the production of Recycled Water are listed in Schedule 3.

(b) Materials that have been submitted to the Department but have not been

approved are also listed in Schedule 3.

14.2 Chemicals Approved for Addition to Recycled Water

The Corporation shall only use chemicals in the production of Recycled Water that have been approved for use by the Department. Chemicals that have been approved by the Department are listed in Schedule 4.


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14.3 Chemicals Used to the Maintain Recycled Water Treatment System

The Corporation shall only use chemicals to maintain the Recycled Water treatment system that have been approved by the Department. Approved chemicals are listed in Schedule 5.

14.4 Seeking Approval

(a) The Corporation may seek advice from the Department with respect to the suitability of materials, chemicals and procedures described in sections 14.1, 14.2 and 14.3.

(b) The Corporation may request the addition of a chemical or material for the

purposes outlined in sections 14.1, 14.2 and 14.3 and the Department will consider that request and provide its response as soon as reasonably practicable.

15. TERM REVIEW AND AMENDMENT

15.1 Term

The term of this MoU shall be three (3) years or such other period as may be agreed in writing.

15.2 Amendments to the MoU

The CEO Water Corporation and the Director-General Department of Health can amend this MoU at any time by agreement in writing.

15.3 Amendment of GWRT Binding Protocols and Schedules

The responsible officers can amend the Binding Protocols and Schedules to this Agreement at any time by agreement in writing.


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16. ENDORSEMENTS

Signed DIRECTOR-GENERAL DEPARTMENT OF HEALTH Date:

Signed

CHIEF EXECUTIVE OFFICER WATER CORPORATION Date:

Documents

Water Corporation - Department of Healthww2.health.wa.gov.au/~/media/Files/Corporate/general documents... · Water Corporation for Recycled Water ... wastewater treatment plant and