4.20180606 Letter of direction response Signed.pdf

6 June 2018
Edward Prince
Resource Use Group
Waikato Regional Council
Private Bag 3038
Waikato Mail Centre
Hamilton 3240

Dear Edward,

RE: LETTER OF DIRECTION – Waikato WTP Audit 2018

I am writing in response to your Letter of Direction for Waikato Water Treatment Plant (WTP)
dated 2 May 2018, covering the period 1 July 2015 to 30 June 2017. Please be advised that
Watercare  Services  Limited  (Watercare)  takes  its  statutory  responsibilities  very  seriously.
This  includes  compliance  with  our  Resource  Consents.  While  we  agree  that  a  partial
compliance status must be addressed, Watercare believes that further discussion is needed
to clarify, confirm and address the points raised by the Waikato Regional Council (WRC).
Watercare  has  implemented  a  number  of  improvements  and  actions  to  address  the  partial
compliance issues with resource consents granted by the WRC. Watercare’s response to the
issues raised and further information requested by the WRC, are detailed in attached in Tables
1, 2, 3 and 4.
Watercare is committed to reducing its impact on the environment and improving the quality
of water in the Waikato River. Watercare has made concerted efforts to improve operational
processes  to  ensure  that  controls  are  appropriate  and  implemented,  to  minimise
environmental impact. Significant work has been undertaken to review operational procedures
and ensure that these procedures are adhered to at all times.
An upgrade of the chemical facilities at the Waikato WTP is in the early design phases and
targets the implementation of additional engineering controls to further reduce risks associated
with our chemical storage and handling systems. A key requirement of these upgrades is to
ensure ongoing compliance with our statutory obligations and the mitigation/minimisation of
potential adverse environmental impacts.
Watercare would like to propose that a meeting is arranged to clarify points raised by the WRC
and discuss actions taken/planned. We would also appreciate the opportunity to discuss the
water abstraction conditions, in particular, the net take and the 7-day rolling average flow at
Rangiriri.  Nolwenn  Lagadec  will  make  contact  with  you  to  discuss  potential  meeting
times/locations.
Please contact me directly if you require any further information or clarification.
Yours faithfully,

Priyan Perera
Operations Manager – Water Supply
Watercare Services Limited
1/7

Table 1: Response to the actions listed in the Site compliance report and Letter of Direction

Resource consent
Condition
Consent condition
Action Required
Status
Number
AUTH120246.01.02
3
The consent holder shall be responsible for all
Please ensure that all corrective
A number of corrective actions have been
contracted operations relating to the exercise of this  actions identified in the ICAM
completed. Full details are described in tables 2, 3
resource consent, and shall ensure contractors are  Investigation Report #9628760 are
and 4.
made aware of the conditions of this resource
implemented to reduce the likelihood
consent and ensure compliance with those
of a re-occurrence of this type of
conditions.
incident.
AUTH120246.01.02
6
Any discharge to the Waikato River shall comply
Investigate and take action to improve  Review of the training material has been carried
with the following limits:
the quality of the discharged process
out and all operators retrained. Signage has also
i)
pH of the discharge shall be
backwash to within compliant levels
been reviewed and improved. Since this time
between 6 and 9 pH units;
there have been no further instances of the
ii)
total residual chlorine of the
concentration of soluble aluminium in the
discharge of less than 0.5 grams per
discharge exceeded the consented limit.
cubic metre;

iii)
suspended solids of the discharge
The low pH result obtained was due to a failure to
of less than 50 grams per cubic
follow maintenance activity procedure. This issue
metre
has been addressed.
iv)
Total soluble aluminium of the

discharge of less than 5.0 grams per
cubic metre
AUTH137722.01.01
4
The total combined instantaneous take rate
Please investigate and take action to
Consent 137722 was granted in February 2017
pursuant to this resource consent and resource
reduce the abstraction rate to within
providing for a maximum instantaneous flow of
consent 960089 must not exceed 2,450 litres per
compliant limits.
2450 l/s. The maximum flows abstracted from the
second.
Waikato River have not exceeded this level.

Watercare believes that this warrants further
discussion with WRC staff to confirm consent and
current compliance status.
AUTH137722.01.01
5
Water must not be taken pursuant to this resource  Please explain the reason for the
Consent 137722 was granted in February 2017
consent when the Waikato River 7-day rolling
spikes in take volume during restricted  after the dates of the events raised by the WRC.
average flow at Rangiriri (Waikato Regional Council  water take conditions around 7
The graph provided by WRC displays flow rate
site number 1131.117, map reference NZTM
December 2015, 21 March 2016, 15
over a 15 minute period in m3/day as opposed to
1788389 E 5855059 N), as determined by the
June 2016 and 26 July 2016
daily net take. This has been discussed with WRC
Waikato Regional Council, is less than 328.3 cubic
and a calculation added to convert flow rate to
metres per second.
volume taken over a 15 minute period.  A request
2/7

Resource consent
Condition
Consent condition
Action Required
Status
Number
(No # CSR0001254) has been raised with
Watercare’s ECS team to create a new tag that
records the net take volume over a 15 minute
period. This will make the reporting of this
condition clearer and avoid any confusion in the
future. Figures 1 displays the daily net take for the
compliance reporting period and shows that no
water was taken above the 175,000 m3 limit.

Watercare believes that this warrants further
discussion with WRC staff to confirm consent and
current compliance status.
AUTH960089.01.03
3
The maximum rate of abstraction:
Take action to ensure that discharges  Condition 3 refers to abstraction.
1)
Rate of abstraction shall not exceed 2000  remain within compliant limits.
The maximum abstraction flow rate was exceeded
litres per second; and
twice during the reporting period. These
Net take volume – being the volume taken pursuant
exceedences were associated with abstraction
to this resource consent less the volume
system capacity confirmation testing and should
discharged into the Waikato River pursuant to
not reoccur.
resource consents 120246, 960101 and 960091

shall not exceed 150,000 cubic metres during any
The WTP was compliant with the total daily
24 hour period.
abstraction limit during each occurrence.

3/7

Table 2: Status update on corrective actions taken following HFA overflow

Recommended Actions following ICAM
Hierarchy
investigation
Responsibility
Status
Timeframe
of Control

High High Alarm to be activated for HFA tanks at Watercare.
Engineering
Watercare
Complete

Complete
Faulty Tank 1 telemetry gauge to be replaced
Engineering
Watercare
(all chemical tanks display have been

replaced)
Check materials of construction for compatibility with chemicals in
Engineering
Watercare
Complete

bunds/tanks
Out of Service vs out of operation - Check HH alarm operation for both
states (tbc on 20th July 2016.   Ensure that Cold state default start of
Engineering
Watercare
Complete

DNS has HH alarm activated
Additional risks have been
In progress- Identified risks in
identified, with the proposed
Review Risk Assessment for CoDe functionality with the aim to make
automating delivery volumes.
Admin
IXOM
system automation. Warrants
CoDe safe fill functionality mandatory for all fill calculations.
Label in the field by delivery point
further risk assessment prior roll-
displays "Safe Fill Level 10,000L=95%"
out.
Supplier procedures to be reviewed and measures put in place to
ensure the following is in place A) Version control    B) Lay out is
Admin
IXOM
Complete

optimised for driver use.    Actions from review to be entered in
Velocity for implementation
Period testing to be put in place for high level alarms, bund alarms and

Admin
Watercare
Complete
warning lights
Ensure procedure updates are provided to Watercare and Transport
Complete
Admin
IXOM

company – an acknowledgment/sign off is required.
Ensure sign off is documented
Procedure updated.
Pre delivery physical sign off of delivery quantity for each tank to be
Watercare Operators reminded delivery
implemented at all Watercare sites.   Operator and Driver agree and
Admin
Watercare
supervision is to be direct, in the field,

document tank level before delivery and planned delivery volume in
as far as practicable. To be included in
writing.  Watercare procedure to be update to include this step.
IXOM drivers induction.
Update Supplier procedure to require check and sign off of initial tank
level and planned fill level for each tank. In addition, what constitutes
Admin
IXOM
Complete

supervision of the delivery needs be clearly defined.

4/7

Table 3:    Following actions are based on internal discussions, and review of the incident with Waikato Regional Council.
Additional recommended actions
Status
Timeframe
Notify the Council immediately if an incident occurs, within 5-7 days in writing. This is currently not specified in the
Acknowledged by Service Delivery and

existing consent, however this is expected practice. New discharge consent will be amended to be more specific.
notified to Consents team
Repair equipment in the bund corroded by HFA.
Complete

Investigate design improvements. Look into minimising single points of failure and ensuring chemicals cannot gravitate
Complete

to the river. Define scope of work for chemical plant upgrade included in 175MLD upgrade project.
Update spill procedure (2009).
Complete. Spill procedure training material
Ensure consistent with Corporate Incident Management Plan as well as with Health and Safety Emergency Response

also updated.
Management Plan toolkit.
Complete.
Eliminate complacency around bund alarms. As rain enters the bunds, the alarms frequently trigger.
Incorporated in new chemical area concept

design.
Modify practices. Wrong practice has been adopted of placing chemical tank in "Out of service" mode, as "Standby" is
Complete. To be regularly audited.

not an available option.
Additional recommended actions
Status
Timeframe
Improve communication on faults.  Different operators were aware of different faults and thought some had been fixed.
Complete

Ensure maintenance takes place in a timely manner.
Ongoing. To be regularly audited.

5/7

Table 4:    The following actions were identified during the ICAM investigation as potential improvements requiring further investigation:
Potential improvements to be
Hierarchy of
Responsibility / Assigned to  Status
Timeframe
further investigated
Control
Covered during preliminary HAZOP on
Consider the installation of a new alarm on the
Engineering
Watercare
15/12/2016. Found not to be an appropriate

overflow pipe.
mitigation.
Where tank locations are not clearly

Revised and considered not necessary.
identified/add Aerial maps of customer
Admin

IXOM
Driver is to follow SOP.
facilities showing the location.
Watercare to consider including site orientation
Next driver induction
Admin
Watercare
Induction material reviewed.
for drivers in Induction program
booked in May 2018.
Establish feasibility of separate sensors for
Covered during preliminary HAZOP on
Engineering
Watercare

alarm and telemetry
15/12/2016.
Establish feasibility of installing a drop pipes in
Covered during preliminary HAZOP on
Engineering
Watercare

HFA tanks
15/12/2016.

6/7

Waikato WTP - Daily Net Take
200000
180000
160000
140000
120000
100000
80000
60000
40000
20000
0
01-Jul-15 00:00:00
17-Jan-16 00:00:00
04-Aug-16 00:00:00
20-Feb-17 00:00:00
Daily Net Take
150 MLD
175 MLD

Figure 1: Waikato WTP - daily net take July 2015 - June 2017
7/7