Program 1 Newsletter - Issue 13 - March 1999
In this Issue:
Sydney Water Inquiry Concludes
Fourth Report
Prospect Water Filtration Plant tender process and contract arrangements
The Conclusions of the Inquiry
Final Report
The Recommendations of the Inquiry
UK Cryptosporidium Report
Changes to US water regulations
News Items
From the Literature
Contact Information
Sydney Water Inquiry Concludes
The Sydney Water Inquiry delivered its final two reports to the New South Wales State Premier on 15 December 1998. These reports complete the task of the Head of the Inquiry, Mr Peter McClellan (Queens Council), in investigating the water contamination events which occurred in Sydney in July, August and September last year.
The work of the Inquiry has drawn on the expertise of Australian and international experts in water supply and treatment, water testing, public health, and epidemiology. Over 200 submissions were received from organisations and individuals, and more than 130 people were interviewed by the Inquiry. Estimates of the cost of the investigation range from $2 to $5 million.
Public and media response to the reports has been relatively low key, perhaps because the Inquiry did not find a simple explanation for the events nor assign blame to any of the parties involved. Indeed, the outcomes of Inquiry have clearly illustrated the complexity of the issues and the limitations of current scientific and medical knowledge about protozoa in water supplies.
According to newspaper reports, about 9,000 businesses have registered compensation claims under a class action scheme approved in December by the Federal Court. Payouts under this scheme are expected to amount to several million dollars, with claimants being mainly from the food and hospitality industries. These claims are in addition to settlements totalling about $700,00 already paid to 3,000 businesses and individuals by Sydney Water.
More than 100 people have opted out of the class action scheme, and will pursue individual law suits for business losses. It is also believed that some claimants will take action for illnesses allegedly caused by the water contamination events, despite the findings of the Inquiry that it was "most unlikely that any person suffered illness because of ingesting Cryptosporidium or Giardia in any of these events".
The New South Wales State Parliament adjourned for the Christmas recess early in December, and will not sit again until April, after the State election on March 28. The water contamination events have not featured prominently in the election campaign of either major party, although the Opposition has stated it will conduct a review of the McClellan Inquiry if it is elected to office.
In this issue we summarise the Fourth Report and the Final Report of the Inquiry, and its many recommendations for the future management of Sydney's water supplies.
Fourth Report: Prospect Water Filtration Plant tender process and contract arrangements
This report deals with the processes which led up to Australian Water Services (AWS) (1) being chosen as the preferred tenderer, and the environmental assessment process prior to establishment of the Prospect plant. In order to provide the legal authority to obtain access to much of the commercially sensitive evidence cited in this report, the New South Wales State Government raised the Sydney Water Inquiry to the status of a Royal Commission.
The Inquiry was charged with investigating:
1) the process of calling and evaluating tenders and awarding the contract for the construction of Prospect Water Filtration Plant, and
2) the preparation and terms of the contract
These matters were to be investigated "to the extent relevant" to two of the original Terms of Reference of the Inquiry (refer to Health Stream Issue 11 - September 1998):
v) determine whether the current arrangements for water treatment are appropriate; and
vi) determine who is responsible for the current arrangements and whether their actions were appropriate.
The need for Filtration Plants
The Inquiry noted that the Water Board (2) had commissioned a number of reports on filtration plants since the mid-1960s, and by the late 1980s a Drinking Water Program (DWP) was developed incorporating plans to build water treatment plants to serve Sydney at Prospect, Macarthur, Woronora and Illawara.
There was some resistance to the plan within the Water Board and the State Government, based on concerns over how the projects could be financed and the perceived lack of evidence of significant finished water quality problems. However, deteriorating raw water quality, rising consumer complaints about "dirty water", and the expectation of increasingly strict water quality guidelines being developed by the NHMRC, led to eventual acceptance of the plan.
By this time, government policy allowed such projects to be financed by the private sector under the Build Own Operate Transfer (BOOT) scheme, and it was decided that the water treatment plants would be established under this mechanism with a 25 year contract. A BOOT Management Team of senior Water Board personnel was set up to manage the tender process.
The Tender Process
From 17 Expressions of Interest (EOIs) received, four were deemed non-conforming and the remaining thirteen underwent a two stage evaluation process. Seven proposals were found to be satisfactory on initial evaluation of Operations, Project Delivery, and Commercial /Financial and Legal aspects. Two of the seven consortia were eliminated after the interview stage of the assessment.
The Water Board then decided that the contracts should be "packaged" to combine the small Woronora and Illawarra plants, and the successful tenderer for the Prospect plant (by far the largest of the four) could not win the tender for any of the other plants. The nature of the projects was also changed from BOOT to BOO (Build Own Operate), following consideration of taxation and other implications.
Three of the remaining five consortia submitted tenders for the Prospect plant, while four submitted tenders for Macarthur and Illawarra/Woronora. AWS submitted a bid only for Prospect, while the other four consortia bid for all three packages.
The Prospect Concept Design
A Concept Design study by independent engineering consultants was completed in early 1992, with a recommendation that the plant be designed for pre-chlorination and contact filtration at a rate of 25 megalitres per hour, with a mean filter run time of 8 hours between backwashes. It was envisaged that the plant would use dual media sand /anthracite filter beds. Water quality goals for the plant were based on the (then current) 1987 NHMRC Australian Drinking Water Guidelines, with allowance for anticipated increases in stringency. These goals were incorporated in the draft contract as a series of "Objectives" (essentially voluntary) and "Criteria" (subject to financial penalty if not met).
The draft contract did not include requirements for removal of Cryptosporidium and Giardia, but set a Turbidity Objective of 0.3 NTU and a Criterion of 0.5 NTU. This contrasted with the NHMRC 1987 Guideline values of up to 5 NTU for turbidity, with 1 NTU deemed desirable to ensure adequate disinfection.
The Assessment of Tenders
A detailed technical assessment of the tenders was carried out by Water Board personnel, followed by tests of the proposed filtration processes using pilot and prototype plants.
The AWS filtration process differed from that proposed by the other tenderers Wyuna (3), and CRI Bechtel (4) by the use of a single sand medium rather than dual anthracite /sand media. This offered a substantial saving in capital costs due to more rapid backwashing, smaller backwash water volume and smaller backwash pump capacity.
However, during test runs of the prototype plant in October and November 1992, the AWS process did not achieve the required duration of filter runs (8 hours) under "dirty" raw water conditions, although filtered water quality was acceptable. In contrast, the processes of the two other tenderers were able to meet both run time and filtered water quality criteria.
The Water Board advised AWS that further tests were required with the medium intended for the full scale plant. AWS agreed to do further testing, and also offered an undertaking that if the proposed process did not meet the performance criteria, the medium would be replaced with anthracite at no change in cost to the tender. This guarantee convinced the Water Board that AWS would be able meet the performance requirements for the plant, although some technical personnel still had concerns over the filtration process.
The financial assessment of the tenderers considered "benchmark tenders" based on the Concept Design and draft contract. The AWS benchmark tender for the Prospect plant was $299 million, while that from Wyuna was $325 million and from CRI-Bechtel $509 million. AWS also submitted an alternative tender proposing the use of lime for pH adjustment of raw water which lowered cost by a further $14 million.
(1) AWS was at that time called NSW Water Services and represented a consortium of Lend Lease Corporation Ltd, P&O Australia Ltd and Lyonnaise des Eaux-Dumez SA.
(2) The Water Board was a statutory authority which supplied Sydney's water until 1995, when the present Sydney Water Corporation was established.
(3) Wyuna represented the Compagnie Generale des Eaux.
(4) CRI Bechtel represented the American Water Works Company.
The decision on the successful tenderer
Consideration of the technical and financial assessments resulted in the BOO Management Team presenting five options to a meeting of the Operating Executive on 16 November 1992. In four of the options, AWS was the preferred tenderer for the Prospect plant.
The Inquiry noted that under normal circumstances the decision on a preferred tenderer would have been taken by the Appointed Board or a Board sub-committee, however at this time the term of the Appointed Board had expired, and a new Board had not yet been appointed.
The meeting endorsed the recommendation of the BOO Management Team to award the contract for the Prospect plant to AWS, the Macarthur contract to North West Water Transfield and the Illawarra /Woronoa contract to Wyuna. This combination gave a total cost slightly above the lowest possible cost, but was felt to provide competitive advantages in assigning the tenders to 3 different companies, and incorporating both French and UK technology. The decision was announced by the State Government on 18 November 1992.
The Inquiry notes that at the time the tender was awarded to AWS, the ability of the proposed filtration process to meet the performance requirements in the contract had not been demonstrated to the satisfaction of the Water Board. In addition, written confirmation of the guarantee by AWS to replace the sand medium with anthracite if the sand filters failed to meet performance requirements was apparently not received until on or after 10 December 1992.
In June 1993, AWS forwarded a report on its continuing testing program to the Water Board, stating that the crushed sand media "exhibit bed capacities slightly higher than the dual media over the full range of expected raw water quality" as specified in the Concept Design report. The Water Board accepted this report, but did not seek independent verification of the results.
The Inquiry was unable to find any written report communicating the AWS test results to the Operating Executive of the Water Board, and according to the recollections of the people involved it appears that none was prepared. Similarly, there appears to have been no formal written record that a number of specific technical concerns (regarding filter run times, hydraulic mixing, and the effects of temperature on the process) had been satisfactorily resolved.
The environmental assessment and the Prospect contract
The Inquiry noted that the Water Board first began to consider the issue of protozoa in water supplies in about 1986, initially in relation to Giardia and later extending to Cryptosporidium. However with no recorded outbreaks of Giardiasis or cryptosporidiosis from Australian public water supplies, and a general belief that Australian climatic conditions would adversely affect these organisms, concerns in the water industry remained low for some years.
In 1992 while the proposals for the filtration plants were being developed, the Water Board commissioned a preliminary survey on Cryptosporidium and Giardia in their catchments. The results of this survey were delivered to the Drinking Water Program in October 1992 (the Hutton Report), showing the presence of Cryptosporidium in some raw water samples in levels up to 143 oocysts /10 litres, although Giardia was detected in only one sample. Desktop reports on Risk Analysis and a Review of Water Treatment Options were also carried out by different consultants.
The Environmental Impact Statement
Preparation and consideration of an EIS (generally known as a Clause 64 report) is required by State legislation for projects which could have a significant impact on the environment. The Inquiry found that the Environmental Management Unit (EMU) of the Water Board was not aware of the existence of the Hutton report until February 1993, some months after it had completed the EIS for the Prospect plant in November 1992.
The EIS contained only a brief mention of Cryptosporidium and Giardia, and although the removal of cyst size particles by treatment plants was referred to, there was no comment on the efficiency of removal that might be needed. The EIS also stated that "no data are yet available" about the presence of Cryptosporidium or Giardia in Sydney's water supply.
The Inquiry concluded that there was clear evidence of "considerable and unproductive tensions" between the engineers of the DWP and the environmental scientists of the EMU, evidenced by DWP failing to forward the Hutton Report promptly to the EMU. These tensions were partly attributable to the time pressures imposed by contractual arrangements which would result in financial penalties on the Water Board if the plant was delayed, but also to feelings of antipathy between the two groups.
The EIS Determination and the final contract
The differences between the DWP and EMU continued during discussions to formulate a determination in response to the EIS, with the various parties giving differing accounts of what was decided at meetings. There was considerable discussion as to the ability of the treatment plant to remove cysts/oocysts, and whether a requirement to remove these organisms should be included in the performance requirements. The EMU was particularly concerned that recycling backwash waters to the head of the plant should not compromise overall performance.
It appears that some of the parties believed that a requirement for 3 log removal of Cryptosporidium should be specified, while others believed that the existing performance criteria (turbidity) would ensure this was achieved without imposing additional requirements. The Inquiry concluded that the relevant section in the final Clause 64 Report was intended by the EMU to impose a performance standard of 3 log removal, but that the wording was unclear and subject to different interpretations.
During negotiation of the final contract, the AWS solicitors submitted a proposed schedule which specifically stated that the plant had "not been designed to ensure a minimum 3 log removal of inactivation of pathogens" and that the design "does not include disinfection of backwash supernatant". These statements were not included in the final contract, however the Inquiry found it was clear that "neither party intended that AWS would be bound to achieve 99.9% (3 log) removal or inactivation of pathogens".
Why was a requirement for Cryptosporidium and Giardia removal not included?
The Water Board personnel interviewed by the Inquiry have advanced a number of reasons why the contract did not include requirements for the removal of Cryptosporidium and Giardia:
1) The efficiency of removal or inactivation could not be effectively measured.
2) There was a standard for turbidity in the contract, and this was an appropriate surrogate measure.
3) They were confident that the plant would achieve a 3 log removal or inactivation.
4) They were awaiting directions from health authorities.
The Inquiry found that none of the reasons provided an entirely satisfactory explanation, and in some cases it appeared that the scientific evidence available at the time was misunderstood or misinterpreted.
A decision was also made not to require disinfection of backwash water before return to the head of the plant. The contract did specify that the backwash was to be subjected to polymer enhanced sedimentation which was expected to remove 2 logs of cysts/oocysts.
The new Appointed Board took office in February 1993, and received a detailed presentation in the proposed water filtration plants in early April. The minutes of the meeting concentrate on the financial aspects of the projects, and do not record any discussion of the removal of pathogens. The agreement for the Prospect plant was approved by the Board on 19 August, then signed by the Minister on 10 September 1993.
The Conclusions of the Inquiry
In its consideration of the "process of calling and evaluating tenders and awarding the contract for the construction of Prospect Water Filtration Plant", the Inquiry found that the "process was undertaken with integrity" and that it was "done with honesty and without influence from any inappropriate source".
However as noted above, the Inquiry found several instances during the tender assessment process where written documentation of procedures and decision making appeared to be inadequate. The decision by the Water Board not to seek independent verification of AWS filtration test results was considered to be "not appropriate". The Inquiry also found the packaging of the contracts and exclusion of the successful Prospect tenderer from other contracts, "had the potential to inhibit the Water Board from achieving a fully competitive tender process". It also noted that the lower cost of the AWS tender was clearly a significant factor in the selection process.
In respect of "the preparation and terms of the contract", the Inquiry found that the development of the EIS by the EMU was conducted rigourously, but that some of the engineers in the DWP did not always appreciate the obligations imposed by the relevant environmental legislation. The EIS Determination included a clause which the Inquiry believes was intended by EMU to include a requirement for 3 log removal or inactivation of pathogens, but the wording was not effective to impose a legal obligation. It was not clear whether the Managing Director who oversighted the draft contract had directed that a 3 log reduction should be included, and this issue does not seem to have been discussed with his successor who took office in April 1993 prior to the contract being finalised.
The Inquiry concluded that in the light of subsequent knowledge, an attempt to impose such a requirement under the contract would have been ineffective, as it would not have been possible to audit compliance (due to uncertainties of testing methods). The imposition of such a requirement would also have led to a large increase in costs for the plant, and this was not justified on the basis of available information at the time. The turbidity requirements imposed by the contract were appropriate with regard to the contempory circumstances and were in line with world's best practice at the time.
Final Report
This report draws together the work of the Inquiry and incorporates substantial amounts of material from each of the four earlier reports. The Executive Summary, Introduction, and Recommendations and Actions have been published separately as Volume 1 (41p), with the remainder of the report in Volume 2. The Final report consists of 16 chapters and 19 appendices, and is more than 200 pages in length.
The report includes some new information, which is summarised below:
Sources of Cryptosporidium and Giardia
Attempts were made to determine whether the Cryptosporidium oocysts recovered from water were of human or animal origin. It is understood that oocysts were sent to laboratories in Australia and the UK for DNA typing, which could have indicated whether oocysts were of Type 1H (transmissible only between humans) or Type 2C (transmissible between cattle and humans). However the tests were unsuccessful, possibly because many of the oocysts were degraded and may not have contained DNA.
Prototype plant experiments The Inquiry commissioned some seeding experiments at the Prospect prototype plant by US and UK consultants. This plant has a single filter bed of one square metre, in contrast to the Prospect plant with 24 filters, each 240 square metres in area.
These experiments used natural low turbidity raw water from the Warragamba pipeline, and a high turbidity water made by mixing very turbid water pumped from deep in the Warragamba reservoir with the low turbidity water to give a turbidity of 10 NTU. Two replicate experiments were done for each type of water.
The results indicated that Cryptosporidium removal ranged from 3 to 6 logs with a higher degree of removal in high turbidity water. Although turbidity and particle counts in filtered water were higher during filter ripening, removal of Cryptosporidium, algae and spores remained high. Near the end of one trial, Cryptosporidium removal dropped to less than 3 logs. The Inquiry suggests that this may indicate a drop in removal efficiency occurs towards the end of long filter runs and this warrants further investigation.
The Inquiry notes that the prototype plant cannot exactly replicate all the conditions at the full scale Prospect plant, and the "killed" oocysts used in these tests may behave differently from naturally occurring oocysts in water. It is also postulated that variations in pH (which were not examined in the seeding tests) may affect the behaviour of oocysts and their removal by filtration.
Laboratory results In discussing the laboratory tests carried out during the incidents, the Inquiry notes that Australian Water Technologies (Sydney Water's testing laboratory) had detailed discussions with the Inquiry and submitted additional material following the release of the Third report. This has caused the Inquiry to revise some of its interim findings on the quality of the laboratory data and causes of the events.
Both AWT and Macquarie University laboratories were required to process large numbers of water samples during the events, and both experienced difficulties with quality control. Sydney Water was made aware of these problems and in the words of the Inquiry "was prepared to accept data for which the quality control was inadequate".
Nevertheless, the Inquiry believes that AWT did not take appropriate action to correct identified problems. It has confirmed its recommendation regarding the establishment of a suitably qualified independent laboratory for protozoa testing.
The health effects of the contamination events The report summarises the enhanced surveillance system implemented by the NSW Health Department to investigate whether the events led to an increase in gastrointestinal illness in the community. The results led the Inquiry to conclude it was unlikely that there was any increase in infection with Cryptosporidium and Giardia during any of the events.
Solicitors Slater and Gordon have challenged this conclusion, and have argued that the surveillance results are not sufficient to rule out an increase in illness rates. However the Inquiry did not find these arguments convincing, and has confirmed its earlier finding.
The report also reviews and comments on international best practice on boil water alerts, public health response, public information reporting, and the Interim Response Protocol developed by the NSW Health department.
The Recommendations of the Inquiry
The Sydney Water Inquiry has made 91 recommendations over a broad range of areas. A number of these recommendations have already been implemented, including those relating to incident management and public health alerts. Legislation has been passed to establish a Catchment Authority, and change the status of both Sydney Water and the Hunter Water Corporations to provide more Ministerial control. Requirements have also been introduced for regular consumer confidence reports on drinking water quality, and annual reports to Parliament by the Chief Health Officer.
The recommendations are summarised below:
Management of the incident by Sydney Water and NSW Health
A comprehensive Incident Management Plan must be developed, backed up by refined procedures and staff training.
Public health alerts
The authority to declare public health alerts in relation to drinking water incidents must rest with NSW Health, and the existing Memorandum of Understanding with Sydney Water must be improved to ensure better operation and improved communications. There should be a single spokesperson for public health alerts. The Interim Health Protocol developed during the incidents should be retained until national guidelines are developed.
Community education
There is a need for improved community education to develop an informed understanding of water quality issues, the risks to public health, and the limitations of testing methods. The public education campaign must include communication strategies for ethnic communities and health groups with special needs. A ministerial advisory committee should be established to advise the Minister for Health on public information issues associated with Cryptosporidium and Giardia.
Water quality data
Government agencies need to improve co-ordination of data collection and on-line access for regulatory agencies should be developed. There is also a need for greater public transparency in reporting water quality data to restore public confidence in Sydney Water.
Ministerial control over Sydney Water
Government powers should be reviewed to ensure they are sufficient to obtain information and, if needed, to give directions in the public interest.
Catchment protection - minimising sources of contamination and establishing a catchment authority
A regional plan for the catchment that gives priority to water quality The Government must provide clear direction and adequately resource efforts to bring together the relevant state, local government and community interests, and ensure that water quality is the primary consideration in decision making affecting the catchment.
The Healthy Rivers Commission should undertake an expedited inquiry to identify water quality objectives and broad strategic goals for the Hawkesbury Nepean catchment. This should include consultation with the community, Government agencies and councils which will be responsible for implementation.
The objectives and strategies should be given statutory force by inclusion in a Regional Environmental Plan (REP) for the catchment. A State Environmental Planning Policy (SEPP) should be developed immediately as an interim measure for the hydrological catchment. This should provide the parameters for acceptable development based on current water quality information, and define approval mechanisms.
An REP should be developed for the Warragamba and Upper Nepean hydrological catchment, covering both Inner and Outer Catchment areas.
Establish a catchment authority A catchment authority should be established that is responsible for providing water quality of a prescribed standard and controlling relevant infrastructure. This authority should be responsible for the Inner Catchment (managed by the National Parks and Wildlife Service), with enhanced regulatory and enforcement powers in both the Inner and Outer catchments. It should also undertake research on the health of the catchment, and own and maintain the relevant infrastructure. The catchment authority should be accountable to a Minister and be subject to performance audit by the restructured Licence Regulator.
Protection of the Inner Catchment The Government should urgently release and implement the Special Areas Strategic Plan of Management proposed by Sydney Water and the National Parks and Wildlife Service (NPWS). These plans should be enforced through the REP. The NPWS should be adequately resourced to manage the Special Areas for both water quality and broader ecological considerations.
Assessment of the state of the catchment The catchment authority should conduct a full assessment of the present state of the catchment, incorporating ecological information and an evaluation of development pressures. The catchment authority should be responsible for water quality monitoring in the catchment under EPA supervision, and should report to Parliament.
Regulating the catchment The EPA should be the primary environmental regulator in the catchment, and should be given a strong mandate and resources to address both point source and diffuse pollution sources within the catchment. The EPA should provide primary assistance to the Healthy Rivers Commission in the development of clear water quality objectives within a prescribed timeframe for incorporation within the proposed REP. Consideration should be given to unifying the environmental health responsibilities of NSW Health and the EPA to ensure better co-ordination based on agreed water quality data
Improvement of regulatory and enforcement powers in the inner catchment The catchment authority should be able to draw upon the enforcement powers of regulatory agencies, such as the Department of Land and Water Conservation, EPA and National Parks and Wildlife Service and to allow officers of those agencies to enforce the authority's regulations.
Community involvement and the role of catchment committees Government suopport should continue for Catchment Management Committees in their work to improve current agricultural and other land use practices impacting on the catchment. The Committees should be adequately resourced and should represent a balance of the competing interests.
The catchment authority should consider establishing a forum with the Hawkesbury-Nepean Catchment Management Trust and the individual Catchment Management Committees to provide advice on specific issues as well as its general work program.
Water Auditor There must be an independent audit body which has the ability to critically review and report on the performance of all parties in meeting the endorsed water quality objectives and the catchment-wide strategies incorporated in the proposed REP. The Licence Regulator should be restructured, provided with the necessary resources to undertake this role, and given a clear set of operating objectives.
Provision of sufficient resources for catchment protection The Government should initiate an inquiry by the Independent Pricing and Regulatory Tribunal to ensure that there is adequate funding provided to the catchment authority to enable it to meet its primary objective of ensuring water quality.
The science
A suitably qualified and adequately resourced independent laboratory should be established to provide accurate data for regulatory authorities. Laboratories providing parasite analysis should be accredited by National Association of Testing Authorities (NATA), utilising an approach similar to that implemented by the US EPA.
Health impacts
The community should be informed about the potential health impacts of Cryptosporidium and Giardia by a public education campaign explaining the agreed scientific facts and the gaps that exist. NSW Health should advise the irnrnuno-compromised community to boil tap water before drinking, and quality controls should be introduced for bottled water and home filters
An information and education program for medical practitioners should be undertaken, focusing on advice for the immuno-compromised.
Additional epidemiological studies should be undertaken into the relationship between Cryptosporidium and Giardia in drinking water and public health.
Regulation of Sydney Water and the Sydney Catchment Authority
Operating Licence New Operating Licenses for Sydney Water and the Sydney Catchment Authority should be developed concurrently, providing clearly defined obligations for customer and operating/health and environmental outcomes. These Licenses should include the actions to be taken and sanctions applied in the event that obligations are not met, together with audit and review provisions.
Licence regulator The role of the License Regulator should be strengthened, and it should carry out annual performance audits of Sydney Water, the Sydney Catchment Authority, and privately owned parts of the treatment and distribution system (such as water treatment plants). The License Regulator should be adequately resourced for these responsibilities and should report to Parliament. It is suggested the License Regulator should be renamed the "Water Auditor", and its relationship with the shareholding, Operating Licence and regulatory Ministers should be reviewed to remove any conflicts of interests.
Memoranda of Understanding The Operating Licence should be amended to require that MoUs include targets, timelines and review provisions, and specifically require the Water Auditor to audit their contents. The existing MoUs between Sydney Water and its regulators should be reviewed to reflect these new requirements as a matter of urgency. The same scrutiny should be extended to the proposed MoUs between the Sydney Catchment Authority and its regulators and other agencies.
Complaint mechanisms Sydney Water should be required to join or establish an independent industry based dispute resolution scheme.
A mandatory water quality level for Cryptosporidium and Giardia
Mandatory health based standards are not appropriate given the present limitations of scientific knowledge, and public health action should not be based solely on the detection of cysts or oocysts in water. Decisions on public health measures should also take into consideration other factors including the number of oo/cysts, volume of water in which oo/cysts are detected, frequency of testing of samples, detection methodology, and recovery efficiency of the testing procedure.
Nevertheless, consideration should be given to setting operational standards for Cryptosporidium and Giardia, and an investigation of this option (including a cost/benefit analysis) should be undertaken with a view to imposing an operational water quality standard at the end of 1999. Water treatment plants should be operated at optimum levels, and operators should undertake comprehensive monitoring programs for raw water quality and treatment plant performance.
Protocols should be developed between NSW Health, Department of Land and Water Conservation, EPA and country water suppliers to ensure effective public health outcomes.
Monitoring
A comprehensive monitoring program is required to establish background levels of raw water contamination, and set trigger levels for operational and public health response to "events" which result in increased contamination. Monitoring programs should also assess the performance of treatment plants in removing contaminants, and the monitoring programs should be regulalry reviewed by a panel comprising representatives from Sydney Water, NSW Health, EPA, AWS and the Sydney Catchment Authority.
The efficiency of the filtration plants
The prototype plant should be maintained and utilised for a thorough testing regime. A research program should be conducted to better define the effect of various paramenters on parasite removal, and to optimise treatment and monitoring methods.
Future improvements
Augmentation of the Prospect plant (eg addition of ozone treatment or membrane filtration) is not justified at this stage. The operations of the plant should be improved to ensure a turbidity standard of 0.1 NTU is maintained, coagulant dosing should be optimised, and on-line particle counters and short filter runs should be used. Backwash water should be treated by deep bed filtration and returned to the head of the plant, and the feasibility of using the Prospect reservoir as an alternative storage area should be assessed.
Effective catchment management, improved operation of the water storages, and measures to prevent build up of contaminants in the distribution system should be implemented. The need for plant augmentation should be reviewed if contamination events recur in future.
A comprehensive improvement package should be developed, including future research and planning by Sydney Water, AWS and the Sydney Catchment Authority, and introducing quality assurance procedures as a framework for guiding water quality protection.
Contract for Prospect Water Filtration Plant
The Government should consult with the parties with a view to releasing the details of the contract for the Prospect plant, excluding only matters which would damage the ongoing commercial interests of either party.
Research agenda
Priority areas for research should be identified and research undertaken as funds permit including: - understanding the organisms and the testing methods (including quality assurance), the issue of viability of pathogens, specific detection of C.parvum, genotyping of Cryptosporidium isolates, catchment and dam management, treatment plant processes and efficiency, the health impacts of Cryptosporidium and Giardia, and the protection of water quality within the distribution system.
Editors Comment
The events and the Inquiry have had a profound impact on the Australian water industry over the last several months. Key industry figures have been involved in the investigations and provision of information to the Inquiry, while at the same time responding to public, media and political demands on their individual organisations.
Many Australian water utilities have catchments which are to some degree compromised by human activity, and these events have focussed attention on their potential vulnerability to such incidents. Health authorities have also been heavily involved in reviewing incident response protocols, licensing and reporting requirements, and lines of communication with water utilities.
The recommendations of the Sydney Water Inquiry, if implemented by State and Federal governments, will have a crucial influence on future developments in the Australian water industry, and the nature of its regulation. It is to be hoped that such developments will be based on rational and considered debate on the best available evidence to balance public health benefits, water quality management options, and costs to the Australian public.
UK Cryptosporidium Report
The UK Expert Group on Cryptosporidium in Water Supplies recently delivered its 3rd report to the British Government. The group was originally chaired by Sir John Badenoch (now deceased) and delivered its previous reports in 1990 and 1995. The Expert Group was reconvened in 1997 under the chairmanship of Professor Ian Bouchier following a large Cryptosporidium outbreak on the outskirts of London (see Health Stream Issue 5).
The terms of reference of the Group included:
- a review of recent research;
- an assessment of the lessons learnt from suspected waterborne outbreaks;
- consideration of the need for further advice on protection of water resources, additional water treatment, monitoring programs and strategies, and outbreak management;
- determination of further research needs.
As the London Cryptosporidium outbreak was attributed to a groundwater source, the Report includes a detailed examination of contamination risks for groundwater supplies, and methods which may be used to assess the integrity of the source. Groundwater provides over 30% of public water supplies in England and Wales, but a lesser amount in Scotland (5%) and Northern Ireland (8%).
The major findings of the Expert Group may be summarised as follows:
- there is a strong correlation between outbreaks and inadequacies or operational problems in water treatment.
- situations associated with outbreaks are also likely to be associated with passage of turbidity peaks in treated water. Improved monitoring of turbidity would allow better assessment of treatment effectiveness.
- groundwater sources have varying degrees of risk for Cryptosporidium contamination.
- removal of Cryptosporidium must rely on physical barriers, and conventional treatment is effective if operated within design capacity and not bypassed.
- it is not possible to recommend a health-related standard for Cryptosporidium in drinking water.
- there is currently no effective medical treatment for Cryptosporidium infection. Due to the serious effects of infection in immunocompromised people, they should be advised to boil tap and bottled water before drinking.
- effective reponse to outbreaks requires local working partnerships and good communication, planning and rehearsals.
- epidemiological investigation of outbreaks needs to be improved and standardised. There is also a need for public education that sources other than drinking water contribute to Cryptosporidium infections (food, milk, swimming pools, animal contact and human to human transmission).
- designation of cryptosporidiosis as a laboratory reportable disease would assist in earlier identification of outbreaks.
- further research is needed into monitoring techniques, analysis methods, water treatment and disinfection efficiency, transport and fate of oocysts in groundwater systems, and patient therapy.
The report includes 51 recommendations which have been accepted by the British Government. The Expert Group also made some observations relating to the consultation paper "Preventing Cryptosporidium getting into Public Drinking Water Supplies" which was released by the Department of the Environment, Transport and the Regions in 1998, although this paper was not officially referred for consideration.
- the proposed standard for oocysts in filtered water (1/10L) is understood to be based on monitoring results which indicate that this level can be achieved by well operated plants.
- the infective concentration is probably at least 10-fold higher than the proposed standard.
- the analysis of outbreaks linked to groundwater suggests that some groundwater sources should also be covered by the regulations on a risk assessment basis.
- the Expert Group agreed that random spot sampling is ineffective for measuring Cryptosporidium oocysts in water, and noted that preliminary trials have shown the proposed continuous sampling technique to be technically feasible.
The Group did not comment further on the proposed regulations (ie it did not express a positive or negative opinion).
In relation to monitoring, the Expert Group recommended that sites which are assessed as high risk should include continuous turbidity monitoring for each filter and for finished water, with instruments able to detect changes of less than 0.1 NTU. Turbidity fluctuations which would trigger a response should be defined for each treatment works, and the use of particle counters was also recommended.
The Group further recommended that "water utilities operating sites assessed as being high risk give consideration to either:
(a) continuous sampling for Cryptosporidium with analysis times linked to turbidity monitoring results; or
(b) sampling triggered by turbidity events."
The Expert Group also recommended that it should reconvene in two years to review new developments and consider the need for further advice and research.
Changes to US water regulations
The US EPA has released the final versions of the Interim Enhanced Surface Water Treatment Rule (IESW) and the Stage 1 Disinfectants / Disinfection By-products Rule (D/DBP).
The IESW Rule sets a Maximum Contaminant Level Goal (MCLG) of zero for Cryptosporidium, but defines complicance in terms of treatment plant performance rather than by measurement of oocysts in water. Surface water supplies serving more than 10,000 people will be required to comply with the rule by December 2001.
Water treatment plants covered by the rule are required to achieve a 2 log removal of Cryptosporidium oocysts, and systems of all sizes are required to carry out regular sanitary surveys of catchments, and to cover all new treated water reservoirs.
Turbidity requirements have been tightened to require continuous monitoring of individual filters, and the average monthly turbidity limit for combined filter effluent has been reduced from 0.5 to 0.3 NTU. Maximum permissible turbidity has been reduced from 5 NTU to 1 NTU.
Systems with unfiltered surface water supplies will be required to include Cryptosporidium control measures in their watershed protection programs.
The rule applies to all Cryptosporidium species, not only C. parvum (the only species known to cause illness in people) as it is recognised that detection techniques are not yet reliable enough to provide identification of oocyst species.
The D/DBP Rule reduces total THM limits and establishes new limits for other DBPs and for disinfectant residuals:
- total trihalomethane level reduced to 0.08 mg/L
- new limits for 5 haloacetic acids (0.060 mg/L), chlorite (1.0mg/L) and bromate (0.010 mg/L)
- new limits for chlorine (4.0 mg/L), chloramines (4.0 mg/L) and chlorine dioxide (0.8 mg/L)
The EPA has not implemented its proposal to relax the chloroform MCLG from 0 to 0.3 mg/L, and will await a report from the Science Advisory Board later this year before reconsidering the issue. MCLG levels for both chlorite and chloramines have been set at 0.8 mg/L.
Surface water systems serving more than 10,000 people must comply with the rule by December 2001. The compliance date for smaller surface water systems and all ground water systems is December 2003.
News Items
Water maps for central Australia
The Australian Geological Survey Organisation is using satellite imaging to construct comprehensive maps of water sources across a large area of northern Australia. The AGSO is cooperating with State and local governments and Aboriginal councils to identify traditional surface water sources as well as bores and wells. More than 70,000 square kilometres of the Northern Territory has already been mapped, and the work has now extended into South Australia. The project aims to provide Aboriginal communities with improved access to potable water sources, but it may also help stranded travellers to locate life saving water supplies in emergencies.
Israel and Jordan in water dispute
A severe drought may lead to a breach of the peace treaty between Israel and Jordan, if the Israeli government decides to cut water supplies to its neighbour. Under the terms of the 1994 treaty, Israel provides 50 million cubic litres of water annually to Jordan, but the treaty does not provide for variations in the event of drought situations. Israel has already reduced supplies to its own farming areas by 25% and major water sources are at a 20 year low, forcing the government to consider reducing the supply of water to Jordan.
Cryptosporidium in Water Conference
The Proceedings of Cryptosporidium in Water: A Consensus Conference held in Melbourne on 5 & 6 October 1998 are now available from the CRCWQT. The conference was attended by 290 Australian and international delegates. The Proceedings include abstracts, and summaries of the three specialist workshops (Parasitology and Genetic Typing, Epidemiology, Risk Assessment and Management) and their outcomes.
Fax: Rosemary Williams +61 8 8259 0228
Cost: AUD$30 + $6 P&P
Water cap may reduce brain damage
Doctors in New Zealand and British hospitals are collaborating in a multicentre trial of a water cooled cap to reduce brain damage in babies suffering oxygen deprivation at birth. The cap has already shown promising results, and will now be formally tested in a randomised trial of 250 "at risk" babies.
Recent evidence suggests that brain cell damage from oxygen deprivation occurs more slowly than previously thought. It is theorised that the cap works by reducing the rate of chemical reactions which ultimately lead to cell death. The effect of the cap will be assessed by comparing intellectual test results of two groups of babies at 18 months of age - both groups will have received normal intensive care at birth, but one group will also have been treated with the cooling cap.
First payout on oyster outbreak
The Australian Federal court recently awarded $30,000 to a victim of the 1997 Wallis Lake oyster Hepatitis outbreak. One person died and more than 440 became ill with Hepatitis A after eating oysters from waters contaminated with human waste. The Court found the NSW State Government, Great Lakes Council and Graham Barclay Oysters Pty Ltd were equally culpable, and the lake was poorly managed with evidence of widespread human faecal pollution. It is expected the ruling will open the way for more successful claims, with a possible total payout of up to $7.5 million.
False positive Crypto tests in US
Investigation of an unexplained rise in positive tests for Cryptosporidium in faecal specimens in several US states has revealed problems with a widely used brand of ELISA test kit. Ten batches of the enzyme linked immunosorbent assay test kits were found to give "non-specific reactions" with some faecal specimens. The problems were reported in five states and resulted in unnecessary public health investigations of water supplies and other potential outbreak sources.
The Centres for Disease Control and Prevention notes that the ELISA method is favoured by some labs because it requires less technical skill and is more convenient for processing large numbers of specimens, than microscopic methods. However problems with test kits or operator error may lead to false positive results which pass unrecognised unless confirmatory testing is carried out. Some states require labs using ELISA to store faecal specimens or slides for up to 1 year, so that confirmatory tests can be performed if required. MMWR 48 (1) p4-8, January 1999.
Tourists to walk on water
Tourism operators have announced plans to build a 70 metre long platform just below the surface of the Sea of Galilee. Visitors will be able to walk along the platform in the location where Jesus is reputed to have walked on water almost 2,000 years ago. The platform, described as an "absurd theme park gimmick" by a leading Israeli religious scholar, will be completed in time for the Millenium celebrations at the end of the year when larger than usual numbers of tourists are expected to visit the Middle East.
Yangtse protests in China
Tens of thousands of Chinese villagers have signed petitions protesting at plans for their forced relocation to make way for the Three Gorges Dam project. More than 1.3 million people will be relocated at a cost of $5 billion before the 16 year project is completed. Fears are rising that violence will erupt as people resist relocation from the fertile Yangtse valley to areas that are seen as remote and inhospitable.
The government has promoted the project as a means of controlling floods and providing cheap electricity, but many are critical of the location of the 660 km long reservoir on a fault line. There are also serious concerns that corruption among administrators and contractors may result in use of inferior construction materials and methods, increasing the risk of a future disaster.
Contact Information
The printed version of Health Stream is available free of charge - to be added to our mailing list please contact Pam Lightbody (email above or fax + 61 3 9903 0576). Past issues can be found under Publications.