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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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