Terri-Jane Yuzda

APEGGA Takes Drinking Water Position to Provincial Minister

Editor's Note: The APEGGA Professional Practice Department provided The PEGG with the following discussion of the new APEGGA Position Paper on Drinking Water Quality.

Safe drinking water supply is a basic quality of life issue. Recent parasite and bacteria outbreaks in drinking water systems that occurred in Walkerton and to a lesser extent in North Battleford, Kelowna and Cranbrook, along with other places with boil-water orders, are indicators of inadequacy in the protection of public drinking water production and supply in Canada.

The APEGGA Environment Committee recently wrote a position paper outlining the Alberta regulatory framework and providing general as well as specific recommendations to strengthen the delivery of safe drinking water to Albertans. Council approved this position paper in February and consequently discussed our position with Enivronment Minister Lorne Taylor, March 17.

The position paper and subsequent discussion with the minister makes the following points:

Albertan Regulatory Framework

  • Alberta has a long history of effective regulation of municipal drinking water. Alberta and Quebec are the only provinces that comply with the Guidelines for Canadian Drinking Water Quality.

  • Alberta Environment manages its drinking water program to include the many elements as part of a multi-barrier approach to provide safe drinking water. Alberta regulations, supported by inspection, monitoring, abatement and enforcement activities provide a comprehensive program for ensuring safe and publicly acceptable water supply systems.

  • However, smaller municipal systems are vulnerable. The municipality is responsible for the facility, but is technically and financially limited in its ability to recognize and address issues.

Incremental Policy Changes Required

  • Incremental policy changes could further protect drinking water supply by expanding the utilization or role of the APEGGA Professional. With respect to source protection this could involve geoscientists in the protection and risk assessment of surface and ground water sources. With respect to operating facilities, this could involve professional engineers in the auditing of medium and smaller facilities, operating problem reviews and providing professional support as required.

Introduction of Qualified Person Concept

  • Other jurisdictions and regulators have introduced the concept of "qualified person" into their legislation. Directly specifying the involvement of a qualified person in the legislation was also discussed with the minister.

  • As a direct result of Walkerton, the Ontario Government passed the Sustainable Water and Sewage Systems Act, which recognizes the integral role of engineers in the operation of water and wastewater systems. Specifically, the bill includes the requirement that professional engineers must prepare "an inventory of and management plan for" the infrastructure of each of Ontario's water systems.

  • In response to misrepresentation of oil and gas reserves, the Alberta Securties Commission has defined the terms "qualified reserves evaluator" and "qualified reserves auditor" in the proposed Companion Policy NI51-101. These qualified persons must "possess professional qualifications and experience appropriate for the tasks contemplated…" and "be a member of good standing of a professional organization," namely a professional engineering association such as APEGGA.

General Recommendations by APEGGA
APEGGA has considered the recommendations of the Walkerton and North Battleford inquiries and the current Alberta drinking water regulatory framework. Alberta Environment has a good set of standards and the framework in place to provide safe drinking water. APEGGA makes the following recommendations to strengthen the delivery of safe drinking water:

  • Facilities, regardless of size, should meet all of Alberta Environment's drinking water design and quality standards for the production and delivery of drinking water. Over an appropriate period of time all existing facilities should be upgraded or optimized to reflect current standards.

  • All water utilities, regardless of size, should participate in source water protection, which may include monitoring of watershed sources.

  • All facilities, regardless of size, should be required to have enhanced monitoring, including, but not limited to, continuous monitoring of treated water turbidity and disinfectant residual. Standards should also be set for monitoring and reporting throughout the distribution system, including reservoirs.

  • All facilities, regardless of size, should be required to implement a quality management program that includes annual audits/assessments of the utility, its distribution system, and staff certification.

  • All facilities, regardless of size, should support the continued training and certification of the individuals involved in the production of drinking water.

APEGGA professionals recognize that these areas are affected by other factors outside of their direct control and may include: funding, manpower complement, thorough knowledge of linkages across water systems from source to distribution, system complexity (unfamiliarity) from operating and maintenance perspectives, and associated governing regulatory frameworks. It is readily evident that funding and manpower areas, especially in smaller communities, are difficult to influence. However, efforts must be made to implement the above recommendations.

Potential for Enhanced Role of the Professional in Protection of Drinking Water

  • Enhancing the protection of the drinking water source though watershed protection, risk assessment of surface and groundwater sources, and ongoing audit functions related to existing sources.

  • Increasing role in reviewing and implementing enhanced monitoring of water sources, plant operations and overall distribution systems resulting in simplicity of controls to yield better and safer quality of treated water.

  • Supporting and participating in the operator certification process by defining and ensuring the requirements of water system operation tasks are made clear at the various certification levels.

  • Enhancing and defining the roles and activities of the APEGGA professional throughout the operations of licensed water systems with specific emphasis on risk interpretation, policy review/input, and accountability.

  • Recommending and selecting the best available technology for these sized facilities from the perspectives of design, operations, maintenance and monitoring. (Each of these should be viewed with respect to process simplicity, automation and continuous operation/monitoring. Monitoring should be provided for treatment, storage, and distribution facilities, and source waters.)

  • Promoting training for water treatment facility operators in all aspects of the facility, including monitoring of supply sources.

  • Providing data analysis and facility trouble-shooting capability.

  • Supporting facility supervision.

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