DIRECTORATE-GENERAL
ENVIRONMENT
Directorate C - Quality of Life, Water & Air
ENV.C.1 - Water
Draft minutes of the Workshop of the Extended Drafting Group
On the Guidance Document on Water Reuse
17-18 March 2016
(Malta Sustainable Energy and Water Conservation Unit (Ministry for Energy and Health), Auberge de Castille, Valletta, Malta)
1.opening
Greetings by Malta
Daniel Azzopardi (Chief Executive Officerof the Unit) welcomed all participants (see Annex II) to Malta. Malta is a small island with significant water stress, so reuse is a major topic. The New Water project aims to take reuse to the next level –reuse of water that would have been discharged to the sea. This will provide a new water source and give the aquifer a breathing space.
Water and water reuse in Malta
Manuel Sapiano gave a presentation on water management and consideration for reuse in Malta.
Malta is small, has high population density, high urban land cover, low rainfall, etc. which results in 70m3/person/d water availability. So reuse is important to address different uses. Treatment is important also to protect coastal waters (a source for desalinated water).
Water demand in 2014 was 62 million m3, the aquifer is over-exploited, but new sources are available. So the 2ndRBMP aims to reduce water use through increased efficiency (public buildings, domestic sector, agriculture) and recycling greywater at the point of use. The aim is to adopt a strategy of conjunctive use of current water sources, supported through a series of measures in the context of the New Water project. Thus reuse is not a solution on its own, but is part of a package of measures. The aim is to reduce aquifer abstraction and achieve good quantitative status by 2021 (quality, especially nitrate, will take longer due to the natural long response times of the aquifer systems). This is a challenging task. The measures in the RBMP will cost €156 million and draw on a suite of EU funding instruments. Actions include 3 polishing plants with a capacity of 7 million m3/y, along with a branding strategy, information, pilot demonstration sites for agriculture, etc. To achieve this requires clear guidelines and quality standards.
Thomas Petitguyot (DG ENV) (TP) thanked Malta for the welcome, organisation and logistics and support for the reuse activity under the CIS. The presentation highlighted how to consider reuse – in the context of wider water management, achieving good status, etc. It is not the only solution and the analysis in MT shows this and that other measures such as on efficiency and raising awareness of the public are important.
A tour de tablewas held, with participants indicating their interests in relation to reuse.
The agenda (Annex I) was agreed without amendment.
2.Policy Background
Update about European Commission's activities on water reuse and presentation of the mandate of the ATG
TP gave a presentation, explaining the background to the EU level work on reuse, starting with the 2012 Blueprint and the commitment to act on the issue. There have been studies, policy options assessed, a public consultation, and inclusion in the Circular Economy Action Plan in December 2015.The latter included actions on reuse, including legislation on minimum requirements (to be proposed in 2017), guidance, inclusion of industrial reuse in relevant BREFs, support to innovation and investments (all from 2016).
Development of the guidance document aims to promote a common understanding of reuse in the context of the WFD and promote good practice. The intention was to develop it by mid 2016 under the CIS.
On the legislative proposal, the aim is to address the main barriers identified at EU level – it will focus on 2 uses of relevance at EU level: agriculture (due to the single market) and on GW recharge (due to links with WFD/GWD). Any legislative proposal at EU level would require a positive conclusion of an Impact Assessment, agreed by the regulatory scrutiny board. Once proposed by the Commission, formal discussion would take place by Council and European Parliament. So discussion at this meeting is at an early stage of the process and, therefore, input by participants is very welcome. DG ENV has mandated JRC to develop the technical proposal by the end of 2016 and to consult closely with the independent scientific committee on health and environmental risks, managed by DG SANTE.
On industrial reuse, this is industry specific, so the best place to take this forward is under the Industrial Emissions Directive (IED) and the BREFs process. These are developed for each industrial sector and how to take this forward is still being addressed (e.g. as a horizontal BREF or sector by sector). This is not under the WFD, but IED has its own regulatory committee encompassing this issue. However, it would be valuable to have information exchange with the CIS work.
On innovation support this will include support to several groups under EIP Water. There are also several funds which can provide opportunities for funding support.
The proposal was to set up an ad-hoc task group (ATG) under the CIS. This was discussed in WG PoM. An ATG was agreed by SCG and included in the new CIS Work Programme. The ATG is not a WG, as it is there for a specific task, rather than an ongoing activity. The draft TOR is for it to focus on the standards work and guidance actions of the CE package and have information exchange on the other activities. The aim is to support the work to 2017 when a proposal is due to be published by the Commission. The co-leads are MT, ES and EC. A call for interest in participation was issued and a good level of response received. There is a dedicated group folder on CIRCABC, which includes earlier background documents.
Discussion
NL asked what might change before the next SCG in May. TP replied that there were two main points at the last SCG. The first was on the wording of the TOR – it was not clear and there is a need to harmonise the language and structure with the TORs for the other 2 ATGs. Also there is a need to clarify that the focus of the ATG is the two items of the legislative proposal and the guidance, but information exchange on the other three CE actions. The other point relates to co-ordination between the two main items and this needs to be better explained.
DE asked why the two strands of work are disconnected. TP explained that the process for legislation takes a long time. Less than a year and half would be a challenge. To adopt something would likely take 3 years. The scope of the guidance is also quite different. There is much to say about integrating in existing water management, as illustrated in Malta. The guidance includes uses which should be subject to quality control (e.g. urban uses) which are not part of the JRC work. There is clear interest in a number of MS for the guidance and there is no justification to postpone it for several years.
NL noted that it is not acceptable to wait till 2019-2020 for the guidance and it would then not be able to inform the development of the 3rd RBMPs. So, it should be agreed this year.
MT noted that the aim of the guidance is to guide the sector. The guidance can help MS explore the opportunities for reuse to contribute to water management objectives. The legislative proposal can help deliver acceptability and safeguard investments.
JRC noted that legislation will help MS to harmonise quality standards.
3.Development of minimum quality requirements for water reuse
Presentation of the technical development by the JRC
Simona Tavezzi (ST) (JRC) gave a presentation on the document previously circulated, drawn up with input from several experts. The legal framework is the WFD and the UWWTD and the policy framework is the Blueprint. There are national legal frameworks for quality of water for reuse which diverge on specific parameters and specific standards. As a result the JRC has been tasked to develop a technical report on minimum quality requirements for reuse for agricultural irrigation and for aquifer recharge to ensure environmental and health protection. The document draws on the risk assessment frameworks of the WHO and Australia, leading to preventive measures based on the multi-barrier approach.
The document draws conclusions on pathogen reduction targets based on tolerable risk. From this the document proposes recommendations for irrigation quality for 3 categories of crops (food crops eaten raw, processed food crops and non-food crops). The parameters are microbiological and physico-chemical parameters (to show secondary treatment effectiveness). On aquifer recharge there are two subcategories – those aquifers used as potable water sources and those not used as potable sources. For non-potable GW, the starting point is the GWD. One issue is contaminants of emerging concern, so the report proposes a watch list similar to that of the EQSD.
Discussion
MT agreed that a quality-based approach rather than a treatment-type approach is correct. On agriculture, it is positive that reference is made to FAO as there needs to be a balance of minerals (ultra pure water is not as good as water with mineral content for farmers). On recharge, the focus should be on the prevent and limit approach of the GWD and this is adaptable to substances present in nature, such as sulphates and chlorides. On emerging contaminants, the list is so large that they are difficult to analyse. Perhaps have something other than a watch list is possible, e.g. if specific levels are exceeded, some form of investigation is triggered. On the DWD, to treat to meet the DWD objectives it is not enough to meet the annex standards, Art 8 requires MS to monitor for other substances which might be an issue. So, this might need consideration. ST replied that this would be taken into account.
ECPA noted that there is legislation for surface and groundwatersin place and a parallel watch list is not needed. A first watch list has just been finalised and there is ongoing work on GW, with further analysis on priority substances, etc.
EUWMAnoted that for irrigation, the less treatment that is necessary, the better for sustainability, as soils/crops cope with most inputs. It is also important to allow for innovation, e.g. if a system were to be developed that could remove pathogens without removing nutrients.
ES asked about the role of this group in this process. Is the document for comment? What is the link with SCG? TP replied that the Commission is working to propose legislation to Council and EP, which is the Commission’s responsibility (it is not a CIS process). It is not yet decided how to share the Impact Assessment, but the Commission wants to be transparent, hence it asked the JRC to present the work. In the Autumn there will be another meeting to discuss a further draft. It is important to express feedback and this will be considered by the JRC.
IT noted that Table 8 does not take account of different soil ecologies. It needs some adjustment to take account of the ecological consequences. On potable aquifer recharge, is it suggested to use DW quality for recharge? ST noted that the former would be considered. On DW quality, this was what was selected.
IT stated that E. coli, as an indicator, decays very quickly and other indicators may be more useful. ST agreed, noting that there is work ongoing on further microbiological parameters.
Presentation on chemical issues by the NEREUS COST Action
Celia Menaia reported that the NEREUS COST network includes EU countries, neighbouring countries and the wider world. So this provides a strong background of scientists and stakeholders on reuse. It has a series of WGs on various health issues in order to discuss the current challenges regarding public health.
Antibiotic resistance is a serious public health problem. The problem occurs across Europe, but tends to be greater in southern Europe. Unlike chemicals, pathogens can proliferate. Antibiotic resistant bacteria are not pathogens, so removing pathogens in treatment might not be sufficient, so the proposal is for maximal admissible values of antibiotic resistant E coli resistant to tetracycline and to cephalosporins. In future it might be possible to test for antibiotic resistance genes.
Jaroslav Slobodnik reported on indicators of occurrence of contaminants of emerging concern in reused water. No legislation around the world includes requirements on antibiotic resistance, but the scientific basis is clearer now. Bioassays are better at assessing mixtures of pollutants than tests for individual substances. They are also fast and cost effective. As a result it is good to use a smart combination of chemical and biological analyses. To get bioassays into legislations requires trigger values and the JRC document proposes these.
On potable aquifer recharge, the DWD 2015 amendment includes the concept of water safety plans and, therefore, allows compounds of emerging concern to be addressed. On non-potable aquifers, there are the WFD, EQSD, GWD requirements. The pollution profiles for countries are different from each other and so local conditions are important. So the proposal is to have a watch list to help generate a minimum list of pollutants for a policy instrument, following the same approach under the EQSD/GWD.
On a minimum list of pollutants and indicators, a harmonised prioritisation schemes to select these at EU level is suggested. Huge efforts have already been made on PNEC values to have a harmonised and transparent approach across MS.
Discussion
ECPA noted that some threshold values are set on the basis of analytical capabilities which change, so as technology develops the threshold values go below concentrations of concern. Also it is important to consider the relevance of metabolites. JS replied that detection limits based on detection ability comes from DW sector, rather than environment. On metabolites, bioassays cover the mode of action, so if a metabolite has this mode, it is included.
ES asked about the cost of bioassays. JS noted that for oestrogenic screening the cost of chemical and bioassay analysis per analysis is about the same, but if there are many analyses, bioassays can be an order of magnitude cheaper.
ES asked whether a legal obligation for bioassays would require a lot of expertise to implement. JS noted that there is quite some experience in their application and further information could be provided on the ease of use.
IT asked if the document should also look at the frequency and cost of monitoring.JS agreed with this.
ECPA noted that JRC was already looking at sampling needs for the next round of priority substances and this information could be drawn upon.
MT noted that treatment is based on membrane technology, but this may change in the future. So in developing an indicator list, there is a need to take into account the rejection ratio in each particular treatment process.
ES was not sure a watch list should be considered here as watch lists are considered for water bodies. NL agreed and stated that the watch list efforts under EQSD and GWD should be sufficient.JS replied that there is a need to have a minimum list of substances to define the minimum quality of reused water. A watch list is a mechanism to get to such a list.
MT stated that MT has a list of 6-8 indicator substances to check GW safety. So MT would favour a short indicator list. A watch list guides something for the future, but we already know some categories of substances are in waste water and we can base indicators on this.JS replied that the final goal is the minimum list. MS are welcome to go beyond this list. MThighlighted that a key concern is to avoid requirements to monitor something that is not there.
ST noted that the final list of microbiological parameters is not yet defined.
NL asked if the source of water is the same as UWWTD, as the report seems to exclude industrial sources. ST replied that the document refers to the UWWTD and the WHO guidelines, so this is the framework being applied. NL stated that this, therefore, should be clarified.
NL noted that some of the concentrations in table 8 are quite high as they are not to be discharged to surface water. COPA COGECA agreed as a key concern for agriculture is the long-term effect of accumulation in soil ecosystems. ST stated that this will be looked into.
MT and EUWMA noted that the congress in Montpellier in October will have a session on reuse for groundwater recharge. Participants will be sent information on this.
4.Water reuse in water planning and management
Water reuse in Spanish RBMPs
ConchitaMarcuello gave a presentation on how reuse is considered within RBMPs in Spain.
Regulation of water reuse in RBMPs: river basins in Spain have different administrative contexts, depending on whether river basins lie in one, or more than one, autonomous community. The regulation for hydrological planning was adopted in 2007. Reuse is taken into account as a source in water balances for different uses. Spain does not have separate water scarcity plans – the issue is integrated within RBMPs. The main uses of reused water are irrigation and environment, but some is used for recreation (golf courses) and aquifer recharge in Catalonia. Some regions have developed plans for waste water treatment and reuse. RBMPs define resource exploitation systems leading to a balance of resources against demands, taking account of minimum requirements for eflows. POMs include appropriate measures relating to reuse.