2.15 Water Quality Management. Introduction

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1 Introduction In May 2001, Government released a report entitled Source to Tap - Water Supplies in Newfoundland and Labrador (Source to Tap report). Te report was prepared in response to drinking water contamination tragedies in Canada wic prompted many Newfoundlanders and Labradorians to question te safety of teir public water supplies. Te report contained information on te status of public water supplies, presented Government s action plan to enance te protection of public water supplies, and outlined initiatives to ensure drinking water safety. A public water supply is a water supply operated by a community. Te May 2001 Source to Tap report identified tat approximately 83% of te Province s population received water from 607 public water supplies wit te remaining 17% receiving teir water from water supplies operated by private individuals or groups of individuals. Of te 83% receiving water from public water supplies, approximately 88% obtained teir water from 314 surface water sources (lakes, ponds, reservoirs, rivers and streams) wile te remaining 12% obtained teir water from 293 groundwater supplies (dug and drilled wells). Te number of public water supplies identified by te Department of Environment and Conservation as decreased from 607 as outlined in te May 2001 Source to Tap report to 532 in October Te number of public water supplies outlined in te Source to Tap report was a preliminary number based on surveys conducted by te Department of Environment and Conservation. Te decrease in October 2003 is a reflection of te Department gatering more detailed information on existing water supplies as well as te result of canges over time as communities abandon or commission water supplies. Te Province indicated in te Source to Tap report tat it ad adopted a multi-barrier approac to ensure tat its public water supplies provide clean and safe water. Te multi-barrier approac to drinking water quality refers only to public water supplies. Te main components of tis approac are: source protection; water treatment; water system operation and maintenance; water quality monitoring; water quality reporting; regulatory inspection and mitigation planning; and operator education and training. Wile te operation and maintenance of water supply systems and delivery of water to consumers is te responsibility of municipal governments, te Province also as responsibilities for public water supplies, wit tese responsibilities being sared between te following four departments: Environment and Conservation; Government Services; Healt and Community Services; and Municipal and Provincial Affairs, wit te Department of Environment and Conservation being te lead department for communications on water quality issues. Auditor General of Newfoundland and Labrador 249

2 Figure 1 Details of te responsibilities in relation to te components of te multibarrier approac are outlined in Figure 1. Responsibilities by Component of te Multi-Barrier Approac Component Responsibility Role Source Protection Environment and Conservation Designates protected water supply areas and regulates activities in suc areas Water Treatment Municipal governments Build and operate public water supply systems Water SystemOperation and Maintenance Water Quality Monitoring Water Quality Reporting Regulatory Inspection and Mitigation Planning Operator Education and Training - Environment and Conservation Municipal and Provincial Affairs Municipal governments Environment and Conservation Government Services Environment and Conservation Government Services Environment and Conservation Environment and Conservation Healt and Community Services Provides regulatory approval of water systems Provides funding for public water system infrastructure Build and operate public water supply systems Monitors cemical and pysical attributes of drinking water bot at tap and at source Monitors microbiological quality of drinking water at tap Reports to municipalities on its monitoring activities and to te House of Assembly on drinking water safety Reports to municipalities on its monitoring activities and to te House of Assembly troug te Department s annual report Inspects public water systems and identifies emerging issues and mitigation strategies Provides seminars and on-site training to assist wit operation and maintenance of water systems Assesses ealt impacts of contamination in water supplies and provides advice to avoid adverse ealt impacts Source: Department of Environment and Conservation 250 Auditor General of Newfoundland and Labrador

3 Scope and Objectives We completed our review of Water Quality Management in November Te objective of te review was to determine weter Government s commitments outlined in te May 2001 report Source to Tap - Water Supplies in Newfoundland and Labrador, ave been met. Our review covered te period from May 2001 to November Te review did not address areas for wic municipalities ave primary responsibilities - water treatment and water system operation and maintenance. Conclusions In May 2001, Government released a report entitled Source to Tap - Water Supplies in Newfoundland and Labrador (Source to Tap report). Te report was prepared in response to drinking water contamination tragedies in Canada and contained information on te status of public water supplies, presented Government s action plan to enance te protection of public water supplies, and outlined initiatives to ensure drinking water safety. Te report identified tat approximately 83% of te Province s population received water from 607 public water supplies wit te remaining 17% receiving teir water from water supplies operated by private individuals or groups of individuals. Te 607 public water supplies identified by te Department of Environment and Conservation in te May 2001 Source to Tap report was a preliminary number based on surveys conducted by te Department. As of October 2003, tis number ad decreased to 532. Te decrease is a reflection of te Department gatering more detailed information on existing water supplies as well as te result of canges over time as communities abandon or commission water supplies. Te Province indicated in te Source to Tap report tat it ad adopted a multi-barrier approac to ensure tat public water supplies provide clean and safe water. Te main responsibilities for Government under tis approac are: source protection; water quality monitoring; water quality reporting; regulatory inspection and mitigation planning; and operator education and training. Wile te Department of Environment and Conservation is te lead department on water quality issues, oter departments ave involvement as well. Our review indicated tat wile Government is making progress toward its commitments outlined in its Source to Tap report, it as not met all tese commitments and is not always complying wit Provincial standards for monitoring drinking water. Specifically: Auditor General of Newfoundland and Labrador 251

4 Source protection - Wile Government committed in te Source to Tap report to continue its efforts to protect te remaining public water supplies, as of October 2003, 256 of te 532 (48%) public water supplies were still not protected. Under te Water Resources Act, te Department of Environment and Conservation may designate areas around a public water source as protected, tereby proibiting or limiting activities witin te protected area tat ave te potential to impair te quality of te water or diminis te amount of water available. Water quality monitoring - Te Department of Environment and Conservation is not conducting Trialometanes (THM) and oter cemical water quality testing in accordance wit te commitment contained in te Source to Tap report or in accordance wit Provincial standards. Te number of communities and public water supplies in te Province known to ave THM levels above te maximum acceptable concentration (and te number of people exposed) is increasing. THMs are compounds formed in clorinated drinking water supplies. Teir possible adverse ealt effects ave received extensive media attention in recent years. Of te 25 water supplies we reviewed for cemical water quality testing, 4 were not tested wit te required frequency. Furtermore, of tese 25 water supplies reviewed, 23 were clorinated and required testing for THMs. Of tese 23, 7 were not tested wit te required frequency. As well, te Department of Government Services is not conducting microbiological water quality testing in accordance wit te Source to Tap report commitment or in accordance wit Provincial standards. Suc testing determines te total coliforms and escericia coli (E.coli) in water supplies. Of te 10 water supplies we reviewed for microbiological water quality testing, 7 were not tested wit te required frequency. Water quality reporting - Government as met te commitments made in te Source to Tap report regarding reporting of water quality data. Tese commitments include reporting annually to te House of Assembly, providing drinking water quality data to te public, and reporting annually to te operator of eac public water supply system in te Province. Regulatory inspection and mitigation planning - Te Department of Environment and Conservation is not inspecting water systems under te Water Resources Act in accordance wit te commitment contained in te Source to Tap report. Wile te commitment was to conduct tese inspections at least once eac year, Department officials indicated tat inspections are conducted only wen operational problems are encountered, relating to a proposed upgrade, or in response to infrastructure funding need assessment. 252 Auditor General of Newfoundland and Labrador

5 Operator education and training - Progress is being made on te commitments Government made in te Source to Tap report regarding education and training of water system operators; owever, certification of water system operators is currently on a voluntary basis wit mandatory certification being an area wic requires furter attention. Findings and Recommendations Te main components of te Province s multi-barrier approac for ensuring tat public water supplies provide clean and safe water are: source protection; water treatment; water system operation and maintenance; water quality monitoring; water quality reporting; regulatory inspection and mitigation planning; and operator education and training. Municipalities ave primary responsibility for water treatment and water system operation and maintenance, wit Government aving responsibility for: source protection; water quality monitoring; water quality reporting; regulatory inspection and mitigation planning; and operator education and training. Te following is an assessment of weter Government as met its commitments as outlined in te May 2001 Source to Tap. Findings are presented for eac component of te multi-barrier approac for wic Government as primary responsibility. Source Protection Under section 39(1) of te Water Resources Act, te Department of Environment and Conservation may designate areas around a public water source as protected. In order for a water supply to become protected, te municipality must apply to te Department. Wen areas ave been designated under te Act as protected, activities witin te protected area tat ave te potential to impair te quality of te water or diminis te amount of water available are proibited or limited. Source water protection is considered one of te first and best lines of defence in a multi-barrier approac to providing safe and clean drinking water to consumers. Te May 2001 Source to Tap report indicated tat a total of 244 of te total 607 public water supplies (40%) were protected under te Water Resources Act. Wile no specific details were provided, Government did commit in te report to continue to work wit municipalities to protect te remaining public water supplies. Auditor General of Newfoundland and Labrador 253

6 Figure 2 Protected Water Sources Figure 2 sows te breakdown of source protection by water supply type. Surface Water Sources Ground Water Sources Combined Sources May 2001 Oct 2003 May 2001 Oct 2003 May 2001 Oct 2003 # of protected sources Total# of sources %of sources protected 75% 80% 3% 10% 40% 52% Source: Department of Environment and Conservation As sown in Figure 2, as of October 2003, a total of 276 of 532 public water supplies (52%) were protected, representing an overall increase of 32 (276 less 244) protected water supplies from May However, 256 of te 532 (48%) public water supplies were still not protected. Tese 256 water supplies provide water to approximately 26% of te population serviced by public water supplies. As well, wile te overall number of protected water supplies as increased by 32, tere are far less ground water sources protected tan surface water sources. Water Quality Monitoring Tere are two main types of water quality monitoring - cemical monitoring and microbiological monitoring. Monitoring is based on an analysis of water samples. Cemical monitoring determines te level of various cemicals present in te Province s water supplies. Te main cemicals of concern are arsenic, lead, turbidity and trialometanes. Microbiological monitoring determines te presence of microbes, suc as bacteria, viruses or protozoan parasites, wic can cause illness in umans. Tese determinations are ten compared against acceptable limits to assess te quality of te water source. 254 Auditor General of Newfoundland and Labrador

7 Te departments of Environment and Conservation and Government Services sare te responsibility of monitoring drinking water quality in te Province. Te Department of Environment and Conservation is responsible for monitoring cemical contaminants and te Department of Government Services is responsible for monitoring microbiological contaminants. Wile tere is no Provincial legislation wic requires testing of drinking water quality or outlines te testing frequency, te acceptable cemical and microbiological limits and testing frequency of te Province s drinking water quality monitoring program are based on Guidelines for Canadian Drinking Water Quality publised by Healt Canada. Te Department of Environment and Conservation as compiled Provincial standards for te monitoring of drinking water based on tese national guidelines. 1. Cemical Monitoring - Department of Environment and Conservation (a) Water Quality Source Water Testing Frequency - Te May 2001 Source to Tap report did not provide a commitment relating to source water testing frequency. As well, at te time of our review tere was no Provincial standard or Healt Canada Guideline for te frequency of testing for source water quality. Source water sampling is taken from were te water enters te distribution system, generally a pond, lake or well, and can be a good indicator of te expected quality of water tat leaves te distribution system, i.e. tap water. Tap Water Testing Frequency - Government stated in its May 2001 Source to Tap report tat eac of te 607 public water supplies in te Province would be tested at tap at least twice eac year for all ealt related cemicals for wic maximum acceptable concentrations ave been establised. Tis is in accordance wit te Provincial standards (Healt Canada Guidelines) wic state tat all public drinking water supplies sould be tested semiannually for tap water quality. To determine weter Government is following its commitment for tap water testing frequency stated in te Source to Tap report and in existing Provincial standards (Healt Canada Guidelines), we reviewed te drinking water quality database maintained by te Department of Environment and Conservation. Te database sows tat wile eac of te 532 public water supplies ad been tested at least once during te year ended 31 Marc 2003, 38 (7%) Auditor General of Newfoundland and Labrador 255

8 of tese water supplies ad not been tested semi-annually as required. Figure 3 We also selected a sample of 25 of te 532 public water supplies in te Province and reviewed all cemical testing for te year ended 31 Marc Figure 3 sows tap water testing for te 25 public water supplies included in te sample. Summary of Results - Cemical Testing For te Year Ended 31 Marc 2003 Eastern Western Central Labrador Total Number of samples Less tan semi-annual tap water testing 0 1 (Francois) 0 3 (Port Hope Simpson, Rigolet, St. Lewis) 4 Possible adverse ealt effects discovered in samples 1 (Marysvale) 2 (St. George s, Trout River) 0 1 (Rigolet) 4 Description and quantity of contaminant Turbidity, 4.7 Lead, Lead, Turbidity, 2.1 Maximum acceptable concentration of contaminant Turbidity, 1.0 Lead, Turbidity, 1.0 Source: Department of Environment and Conservation Wile eac of te 25 sampled water supplies ad been tested at least once during te year, as Figure 3 sows, 4 of te 25 samples (16%) ad not been tested semi-annually as required. Of te 4 water supplies wic ad not been tested semi-annually, 1 was found to contain a cemical wit a possible adverse ealt effect. Tis water supply was in Rigolet, Labrador. At te time of our review in November 2003, no follow-up visit ad been made by te Department since te original test was conducted in July In summary, our review of te Department of Environment and Conservation s database and our review of a sample of public water supplies tested by te Department bot indicated tat te Department is not conducting cemical water quality testing in accordance wit te commitment contained in te Source to Tap report or in accordance wit Provincial standards. 256 Auditor General of Newfoundland and Labrador

9 Wile te May 2001 Source to Tap report did not provide a commitment relating to source water testing frequency and tere was no Provincial standard or Healt Canada Guideline for te frequency of testing for source water quality, we also reviewed te 25 samples to determine frequency of source water testing. Our review indicated tat altoug tere is no requirement relating to source water testing, 6 of te 25 samples cosen ad source water tested semi-annually. (b) Trialometanes Trialometanes (THMs) are compounds formed in clorinated drinking water supplies. Teir possible adverse ealt effects ave received extensive media attention in recent years. Government stated in its May 2001 Source to Tap report eac clorinated surface public water supply in te Province would be tested at least four times eac year for THMs to determine weter maximum acceptable concentrations ave been exceeded. Tis is in accordance wit te Provincial standards (Healt Canada Guidelines) wic state tat all clorinated public drinking water supplies sould be tested four times eac year for THMs. Figure 4 Figure 4 sows te number of public water supplies in te Province known to ave THM levels above te maximum acceptable concentration. THM Levels Total number of public water supplies Number of clorinated public water supplies Number of supplies wit THMs above acceptable concentration Percentage of clorinated water supplies Approximate number of people exposed May Not Available 59 Not Available 79,600 October % 93,000 Source: Department of Environment and Conservation As Figure 4 sows, te number of public water supplies in te Province known to ave THM levels above te maximum acceptable concentration (and te number of people exposed) is increasing. Auditor General of Newfoundland and Labrador 257

10 To determine weter Government is following its commitment for THM testing frequency stated in te Source to Tap report and in existing Provincial standards (Healt Canada Guidelines), we reviewed te drinking water quality database maintained by te Department of Environment and Conservation. Te database sows tat tere were approximately 400 clorinated public water supplies operating during te fiscal year ended 31 Marc We could not determine from te database te number of water supplies wic were never tested during te year; owever, we were able to determine tat 111 (33%) of te 336 water supplies tested were not tested at least four times as required. Of tese 111 supplies, 38 were tested only once, 54 twice and 19 tree times. It was noted tat some of te 111 water supplies may not ave operated trougout te entire year, due to existing water supplies being abandoned or new supplies being commissioned. Figure 5 We reviewed te same 25 public water supplies tat we tested for cemical contaminants to determine te frequency of THM testing for te year ended 31 Marc Figure 5 sows testing for te 25 public water supplies included in te sample. Summary of Results - THM Testing For te Year Ended 31 Marc 2003 Region Sources in Sample Number of sources requiring seasonal testing Sources wit iger tan acceptable THM levels Sources not tested four times during year Sources not tested four times and aving ig THM levels Eastern (Clarenville) Western (St. George s) Central (Lewisporte, New-Wes Valley) Labrador (Rigolet, St. Lewis) 2 (Holyrood - not tested during year, Marysvale - not tested during year) 1 (Pacquet - tested 3 times) 1 (Campbellton - not tested during year) 3 (Port Hope Simpson - tested once, Rigolet - tested once, St. Lewis - tested once) Not determinable as supplies not tested during year 0 Not determinable as supplies not tested during year 2 (Rigolet, St. Lewis) Total Source: Department of Environment and Conservation 258 Auditor General of Newfoundland and Labrador

11 As Figure 5 sows, te Department of Environment and Conservation is not conducting THM water quality testing as required. Specifically, for te 23 public water supplies in our sample requiring THM testing (two supplies were not clorinated), 7 (30%) were not tested 4 times per year as required. Of tese 7, 3 were not tested at all during te year. Furtermore, 2 of te 7 samples wic were not tested four times during te year were found to contain iger tan acceptable THM levels. In summary, our review of te Department of Environment and Conservation s database and our review of a sample of public water supplies bot indicated tat te Department is not conducting THM water quality testing in accordance wit te commitment contained in te Source to Tap report or in accordance wit Provincial standards. 2. Microbiological Monitoring - Department of Government Services Government stated in its 2001 Source to Tap report tat te number of samples taken for microbiological water quality testing would be expanded to meet te requirements of te Healt Canada Guidelines. Tese Guidelines provide guidance on frequency of testing and te acceptable levels of naturally occurring elements in drinking water. Te Department of Environment and Conservation as compiled Provincial standards for te monitoring of drinking water based on tese national guidelines. Te Provincial standards (Healt Canada Guidelines) recommend te frequency for microbiological testing based on population serviced by te water supply. Wile all public water supplies are to be tested montly, te recommended number of samples to be taken eac mont varies, as outlined in Figure 6. Auditor General of Newfoundland and Labrador 259

12 Figure 6 Metod of Determining Sample Size for Microbiological Testing Population Serviced Number of Samples per Mont Number of water supplies - October 2003 (total 532) Less tan sample 224 Between 101 and 5,000 4 samples 298 Between 5,001 and 90,000 Greater tan 90,000 1 additional sample per every 1,000 people between 5,000 and 90,000 people. 1 additional sample item per every additional 10,000 people above 90,000 people - 10 Source: Standards for Bacteriological Quality of Drinking Water Samples of drinking water are taken by te inspectors and tested at regional testing sites for evidence of total coliforms and escericia coli (E.coli). In te Source to Tap report, drinking water is considered safe if no more tan 10 total coliforms are found in a 100-ml sample and if tere is no evidence of E.coli. Te results of tese tests are reported to te municipality affected and are available on te Department s municipal information management system database. Action is recommended to te municipality based on te level of contamination identified in te test. Suc action could include cecking and adjusting clorine levels or flusing water mains. If tese actions do not remedy te contamination or if E.coli is present, te municipality must put a boil water advisory into effect. Officials at te Department of Environment and Conservation indicated tat no public database information was available wic would sow te frequency of testing for individual water supplies. We were, owever, able to determine te number of tests conducted during te year ended 31 Marc 2003 and te results of te testing. A total of 15,352 water samples were tested, wit 1,182 (8%) resulting in detection of coliforms, and 150 (1%) resulting in detection of E.coli. To determine weter Government is following its commitment stated in te Source to Tap report and is following Provincial standards (Healt Canada Guidelines), we selected a sample of 10 of te 532 public water supplies in te Province and reviewed all microbiological testing for te year ended 31 Marc Auditor General of Newfoundland and Labrador

13 Figure 7 Summary of Results - Microbiological Testing For te Year Ended 31 Marc 2003 Figure 7 sows microbiological water testing during te year ended 31 Marc 2003 for te 10 public water supplies included in our sample. Region Number of water supplies Did not meet Guidelines for 11 out of 12 monts Did not meet Guidelines between 6 and 11 monts Did not meet Guidelines between 1 and 5 monts Met Guidelines St. Jon s 2 1 (Conception Harbour) 1 (Clarke s Beac) Eastern 2 1 (Burin) 1 (Parker s Cove) Gander 2 2 (King s Point, Millertown) Western 3 2 (Pasadena, St. Antony) 1 (Upper Ferry) Labrador 1 1 (Happy Valley- Goose Bay) Total Source: Municipal Information Management System database As Figure 7 sows, te Department of Government Services is not conducting microbiological water testing in accordance wit te commitment contained in te Source to Tap report and in accordance wit Provincial standards (Healt Canada Guidelines). Specifically, for te 10 public water supplies in our sample requiring microbiological testing, 7 (70%) were not tested as required. Auditor General of Newfoundland and Labrador 261

14 Water Quality Reporting A goal of te multi-barrier approac to drinking water quality is to provide free access to drinking water quality data to te public. Government made tree main commitments in te Source to Tap report regarding reporting of water quality data. Tese commitments include: reporting annually to te House of Assembly on te state of water quality in te Province; providing drinking water quality data to te public on te Department of Environment and Conservation s website on a regular basis; and reporting annually to te operator of eac public water supply system in te Province, troug a consumer confidence report in January of te following year. Our review of weter Government met eac of tese commitments indicated te following: Reporting annually to te House of Assembly - Te first annual report was tabled in te House of Assembly in November 2002 for te fiscal year ending 31 Marc Department officials indicated tat te annual report for te fiscal year ending 31 Marc 2003 is expected to be tabled in te House of Assembly in te very near future. Providing drinking water quality data to te public - Te Department as revised its data management system in order to update its website quarterly wit results from eac sampling season. Te website was updated wit data from te summer 2003 sampling season in November As well, te Department maintains a listing of current boil water advisories in effect in te Province and regularly updates te website. Reporting annually to te operator of eac public water supply system - Consumer confidence reports are to be mailed to municipalities in January of eac year, covering te sampling data for te past calendar year. Te first annual report of tis kind was issued in Marc In addition, te Department as adopted a policy of issuing quarterly reports to te municipalities wit data from eac sampling season. Data for te fall sampling season is combined wit te annual report and is to be issued in January eac year. Tese new quarterly reports ave been issued since 262 Auditor General of Newfoundland and Labrador

15 25 Marc 2002 for te winter 2002 sampling season and ave been issued consistently witin 60 days of te sampling end date for eac season. Regulatory Inspection and Mitigation Planning Inspections of water supply systems are provided for under te Water Resources Act to ensure tat systems are being properly operated and maintained, tereby contributing to te overall integrity of public water supply systems and te safety of drinking water. Government committed in te Source to Tap report tat as part of routine regulatory inspections, Department of Environment and Conservation staff would visit all public water systems in te Province at least once eac year, or more tan once in te case of any reported operational problems. To determine te Department s progress in meeting tese commitments, we reviewed te frequency of inspection for water treatment plants, clorination facilities, water distribution systems and public groundwater wells. Our review indicated tat te Department is not meeting its commitments in tis area as follows: Water treatment plants will be inspected at least twice a year. As of November 2003, tere were 13 water treatment plants in te Province. Department officials indicated tat water treatment plants are only formally inspected wen tere are operational problems encountered, were tere as been a proposed upgrade, or in response to infrastructure funding need assessment. Tey also indicated tat trainers may note problem areas wen tey provide training to operators; owever, tis would not represent a formal inspection. Clorination facilities will be inspected at least tree times a year. As of November 2003, tere were 422 clorination facilities in te Province. As in te case of water treatment plants, Department officials indicated tat clorination facilities are only formally inspected wen operational problems are encountered, relating to a proposed upgrade, or in response to infrastructure funding need assessment. Auditor General of Newfoundland and Labrador 263

16 Water distribution systems will be inspected at least once a year to ensure water system flusing, cross-connection control, and leakage control. As of November 2003, tere were 403 water distribution systems in te Province. As in te case of water treatment plants and clorination facilities, Department officials indicated tat water distribution systems are only formally inspected wen operational problems are encountered, relating to a proposed upgrade, or in response to infrastructure funding need assessment. Public groundwater wells and oter selected wells will be inspected on a regular basis in order to ensure tat tese wells are constructed as per requirements of te Well Drilling Act and Regulations. As of November 2003, tere were 215 groundwater sources consisting of 213 wells and two springs. Tere are 285 public groundwater wells wic make up te 213 well sources. A Department official indicated tat public groundwater wells are inspected twice annually; owever, we were unable to confirm weter inspections were conducted as indicated since reports on inspections conducted to 31 Marc 2003 were verbal and no inspection report was created. Subsequent to 31 Marc 2003, 164 inspections of public groundwater well sources were conducted to November Operator Education and Training Te availability of trained and qualified operators is critical to te safe and sustainable operation of water systems. Government indicated in te May 2001 Source to Tap report tat a long-term strategic plan would be completed for te education and training of water system operators. Te plan was to consist of te following two pases: Pase I - classroom education and training of water system operators; and Pase II - on-site, ands-on training as a follow-up to education and training. 264 Auditor General of Newfoundland and Labrador

17 Te objectives of te plan were to offer educational seminars and on-site training to operators regarding proper operation and maintenance of water supply systems, ensuring public water supply systems are operated and maintained as per regulatory requirements, providing for te delivery of safe, clean drinking water, and restoring public confidence in drinking water quality. Te benefits to be derived from te plan were to include prolonging te life of water infrastructure and maximizing te return on capital investment, providing more efficient and safe operations of systems by educated, trained, and knowledgeable operators, minimizing te number of boil water advisories, and addressing related water quality problems. Our review indicated tat Government as met its main commitment to operator education and training. Details on te Department s activities regarding operator education and training are as follows: Education and training seminars - Wile te Department intended to conduct 54 seminars in and 72 in , te actual number of seminars conducted was 51 in and 66 in On-site training of water system operators - Tree operator trainers were ired in November 2002 and tree mobile training units were made available to te program in February Since February 2003, on-site training was provided to 333 of 403 operators in 297 communities. Wile Government as met its main commitment to educate and train operators, operator certification is one area wic requires furter attention. Te Province of Newfoundland and Labrador does not ave a legislative requirement for mandatory certification of water system operators; owever, officials of te Department of Environment and Conservation indicated tat consideration is currently being given to providing suc a requirement. Certification in te Province is currently on a voluntary basis utilizing te operator certification program offered troug te Atlantic Canada Water and Wastewater Voluntary Certification Board. Tere were 61 operators certified under te Program wen te May 2001Source to Tap report was released. According to Department officials, tere were 162 certified operators in te Province as of November Auditor General of Newfoundland and Labrador 265

18 Figure 8 Currently 7 of te 13 provinces and territories in Canada ave legislation wic requires mandatory certification of water system operators. According to Department officials, of te 6 provinces and territories tat do not ave mandatory operator certification legislation, 2 provinces are expected to ave suc legislation in place in te very near future. Figure 8 presents information for provinces and territories in relation to legislation requiring mandatory certification of water system operators. Operator Certification in Canada Provinces wit legislation requiring mandatory certification of water system operators Britis Columbia Alberta Saskatcewan Manitoba Ontario Quebec Nova Scotia Provinces and territories wit no legislation requiring mandatory certification of water system operators Yukon Territory Nortwest Territories Nunavut New Brunswick Prince Edward Island Newfoundland and Labrador Source: Department of Environment and Conservation As of October 2003, tere were 567 water supply systems in Newfoundland and Labrador. Water supply systems are classified according to te population tey service, wit some of te 532 public water supplies in te Province aving more tan one water supply system. Of te 567 water supply systems, 520 are classified as small systems, serving less tan 1,500 people. According to te Department, te majority of tese small systems are owned by Local Service Districts and small Community Councils and represent te greatest risk in terms of water quality and ealt issues due to te lack of financial and/or tecnical capacity to properly operate te systems. Mandatory certification would reduce te risk of water quality and ealt issues. Wile certification is not required in Newfoundland and Labrador, tere are over 400 classified water systems for wic trained water system operators would be required under mandatory certification. 266 Auditor General of Newfoundland and Labrador

19 Te Department as commenced a process of documenting te education and training of operators of eac classified water system, owever, it is in te initial stages only. As a result, it is not possible to compare te education and training obtained to te amount required to operate te classified water system. Operator certification would provide a mecanism to track qualified operators of water systems by class. Recommendations Government sould continue its work in meeting te commitments outlined in te Source to Tap report. Specifically: efforts sould continue to protect te remaining pubic water supplies in te Province troug designating areas around public water sources as protected under te Water Resources Act; Trialometanes (THM) and oter cemical water quality testing sould be conducted in accordance wit te commitment contained in te Source to Tap report and in accordance wit Provincial standards; microbiological water quality testing sould be conducted in accordance wit te commitment contained in te Source to Tap report and in accordance wit Provincial standards; and inspections of water systems under te Water Resources Act sould be conducted in accordance wit te commitment contained in te Source to Tap report. Government sould furter consider te issue of mandatory certification of water system operators. Department s Response By way of general comments, te title of tis report does not reflect te fact tat te review pertained only to drinking water, i.e. drinking water quality of public water supplies and not to water quality management overall. Te latter is a multi-faceted program wic includes ambient water quality monitoring, ydrologic modelling, protection of bodies of water, permitting of alterations and oter activities, many of wic integrate wit drinking water program elements. Auditor General of Newfoundland and Labrador 267

20 On te oter and, one of te most important determinants of drinking water quality is te municipality, wic as te primary responsibility for operation and maintenance of water supply systems. Te role of municipal governments is mentioned in te introduction of te review but teir crucial significance was not addressed. Considerable effort is being made to engage municipalities to be more proactive in managing drinking water and to ensure tat it is safe, clean and reliable. We suggest te role of municipalities be more strongly reflected in te report. My last general comment is tat te main basis for te comparative analysis of te review was te document "Source to Tap, Water Supplies in Newfoundland and Labrador, May Tis document laid out a proactive plan wic introduced te concept of a multi-barrier approac to clean and safe drinking water. It announced several new or enanced initiatives including a compreensive plan for cemical and microbiological drinking water quality monitoring, operator training, new legislation, integration of cross-departmental activities, source protection, water quality reporting and a review of te permitting aspects of water systems and teir operation. Wile some goals may not ave been acieved te significant point is tat tere is a solid plan and government is actively working in acieving all of its objectives. Te following are my comments regarding te recommendations of your review. Tis department, and I m sure tis applies to te oter departments wit teir role in safe and clean drinking water, will strive to not only meet te commitments in Source to Tap, but to adapt te multibarrier strategic action plan to existing and emerging issues in te area of drinking water safety in a manner tat is rational and uses existing resources efficiently and cost effectively. Protection of Water Supplies - As pointed out to te auditors, it is te responsibility of owners of water supply systems (municipal governments) to apply for watersed and wellead protection. Government cannot impose watersed designation of a municipal autority and some towns ave elected to not ave teir watersed designated as a protected watersed area. Wellead protection is a new initiative permitted under te Water Resources Act wic was passed in May 2002, and te department as written to 100 communities were risk analysis sowed tat protection would be a priority. A follow up letter was written later. So far only 27 communities responded of wic eigt declined. For tose communities tat did respond, teir applications were or are being processed. 268 Auditor General of Newfoundland and Labrador

21 Currently out of 308 surface water supplies, 255 are protected. Communities in tis category tat do not ave teir water supply protected ave been written to on several occasions but tey ave cosen not to take up te designation process. We will continue to remind tem of te benefits of watersed protection. Trialometanes (THMs) and oter Cemical Testing - We agree tat te water quality testing sould be carried out in accordance wit our provincial standards. Tese standards are derived from Healt Canada s "Guidelines for Canadian Drinking Water Quality and tey specify ow often a sample sould be collected. Tese guidelines are not prescriptive, rater tey allow for adaptation to local circumstances. Rater tan give a blanket commitment for water quality sampling, a detailed workplan as been prepared for tis task. It is publised on te department s website at: Water-SamplingScedule.asp To allow for resource and extenuating circumstances, we ave added te following qualifer: Please note tat wile every reasonable effort will be made to collect all of te drinking water quality samples listed in te scedule, circumstances suc as inaccessibility to te site, lack of necessary clorination, sample spoilage, staff travel restrictions or oter factors will result in a certain percentage of missed samples. Data gaps will be filled on a priority basis but tere will be limits placed on filling tese gaps due to cost efficiently considerations. THMs sampling frequency was reduced in special cases were groundwater is te water supply source. THMs formation requires bot clorine and organic compounds. Groundwater generally does not ave organic compounds, tus once it is sown tat te source is not under te influence of surface water, tere is little need to sample for THMs, especially on a seasonal basis. Several water supplies (Campbellton, Marysvale, Holyrood) wic were reported in te review fell into tis category. Source to Tap did not elaborate on tis but pages 4-6 of te report did not include groundwater supplies in te THMs sampling plans, only surface water supplies were included. Mictobiological Water Quality Testing - As discussed in te previous section, every effort is being made to collect and analyse water samples from every public water supply in te province as per te frequency stated in te provincial standard for drinking water quality. But as is te case for THMs and cemical sampling, circumstances may prevent te collection of samples from time to time. In addition, a water supply is not tested if it is Auditor General of Newfoundland and Labrador 269

22 currently under a boil water advisory. Tere is no point in doing so since te safety of te water is already sown to be compromised. Regular microbiological testing of water resumes once te reason for te boil water advisory is corrected. Inspections of Water Systems - We agree tat tere sould be frequent inspections of water supply systems. At issue is a discrepancy between wat was planned as per Source to Tap and wat constitutes a formal inspection in te opinion of te auditors. Tere are many opportunities for a site visit. Tese include wen source water inspections take place, wen te various samples are taken and wen on-site training is provided. All staff are instructed to note any canges to te system and to report tem to our Community Water and Wastewater Specialists along wit reporting of any potential problems wit te facilities. Operator Certification - Te Department of Environment and Conservation is considering mandatory certification of water system operators. Tis is someting tat will ave to be pased in since tere are many operators wo would not be able to meet te qualification requirements or pass te necessary tests witout training and upgrading. Training operators so tat tey can acieve certification is a long term training objective. In Source to Tap we reported tat tere were 61 certified operators in te province. Currently we ave increased tat number almost treefold to 173 certified operators. In closing, I would like to say tat Source to Tap was a uge initiative wic followed upon te crises in te drinking water sector following te Walkerton incident. Te multi-barrier approac as been successfully implemented on many fronts as sown in te two annual reports on drinking water safety in Newfoundland and Labrador publised since May Auditor General of Newfoundland and Labrador