Protection of water intakes in light of DWD 2020/2184

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A bit of history – development of the idea of risk analysis and risk management for water intake recharge areas

Water is one of the most important chemical compounds for life and the most widespread in nature, and the supply of water to the population is of fundamental and strategic importance. One of the first sentences of the Water Framework Directive reads, “Water is not a commercial product like any other, but rather a heritage that must be protected, defended and treated like a heritage.”

With the progress of civilization and the accompanying development of industry and construction, water pollution in rivers and reservoirs continues to increase. Man is able to reduce it, but cannot prevent it completely. For any water utility, the most important goal under the law is to provide a product that is safe for the health of consumers. Due to the great importance of drinking water quality for human health, it is necessary to meet Polish and European quality standards, which allows you to claim that the water is “clean and healthy.”

In recent decades, we have seen a dynamic change in the regulations defining the quality requirements for drinking water. Council Directive 98/83/EC of November 3, 1998. On the quality of water for human consumption, Article 11 of the “Review of Annexes” requires the European Commission to revise the records every five years, due to scientific and technological progress and environmental changes in the world. In October 2015. The European Union Commission has issued a new EU Directive 2015/1787 amending Annexes II and III of Council Directive 98/83/EC on the quality of water intended for human consumption. Already in the preamble, the new principles on which the production, distribution, monitoring and analysis of drinking water parameters are based are cited. These principles derive from the methodology embodied in the so-called “Theory of the World. “water supply security plans,” developed in 2004. by the World Health Organization (WHO), combined with risk assessment and risk management in accordance with the EN 15975-2 standard for safe drinking water supply. To control water quality, monitoring programs should operate effectively throughout the supply chain, taking into account the impact of indoor installations.

In Poland, this has translated into, among other things. On the changes introduced by the law of July 20, 2017. Water Law (effective January 1, 2018), requiring water utilities to conduct a risk analysis for the establishment of intermediate protection zones for water intakes within 3 years (by 2021). The law stipulates that the risk analysis should include an assessment of health risks, taking into account factors that adversely affect the quality of the intake water, carried out on the basis of hydrogeological or hydrological analyses and hydrogeological or hydrological documentation, the identification of sources of risk resulting from land use, and the results of a study of the quality of the intake water (Article 133(3)). Phrased in this way, it emphasizes that, from the perspective of the EOI Law, the assessment of health risks is the most important element in the development of a risk analysis.

Risk analysis for a water intake is a relatively new element of water conservation practice, under the provisions of the Law of July 20, 2017. Water Law (consolidated text: Journal of Laws 2020, item 310, as amended), which, according to the law, aims to:

  • Management of water resources to meet the needs of the population and the economy, and the protection of water and the aquatic environment associated with these resources, in particular in terms of: ensuring adequate quantity and quality of water for the population (Art. 10(1)), protecting water resources from pollution and improper or excessive exploitation (Art. 10(3));
  • Ensuring the quality of water abstracted for supplying the population with water for consumption and establishments requiring high-quality water, as well as protecting water resources – establishing protection zones for water intakes (Art. 120 item 1 of the aforementioned law).

The risk analysis for the water intake is a key document in the situation of the planned establishment of a protection zone, which consists of a direct protection area and an intermediate protection area. A risk analysis is not literally required for the planned establishment of a protection zone consisting only of a direct protection area, but it should be done to prove that an intermediate protection zone is not substantively justified.

In addition, EU Directive 2015/1787 resulted in the introduction of a new (still in effect) Decree of the Minister of Health dated December 7, 2017. on the quality of water intended for human consumption (Journal of Laws 2017 item 2294), which also recommends a new approach to water safety management, based on a risk assessment conducted in accordance with PN EN 15975 (PN-EN 15975-2:2013-12 Safety of drinking water supply – Guidelines for crisis and risk management. Part. 2 Risk management and EN 15975-1:2011 Safety of drinking water supply – Guides for crisis and risk management. Part. 1. Crisis Management). Entities that introduce this system can adjust the scope and frequency of monitored water quality parameters to individual needs based on risk assessment. This is the so-called. Flexible water quality monitoring system (addition/removal of parameters to be monitored and/or increase/decrease in frequency of sampling for testing) provided that the risk assessment process is properly conducted and depending on the results of the assessment. The risk assessment should use the provisions of EN 15975, part. 2.

The WHO Guidelines on Drinking Water Quality, in Chapter 4, introduce a methodology appropriate for risk assessment for water supply systems called Water Safety Plans (WSPs). Their implementation is recommended as the most effective tool for continuous water supply security. WSPs require a risk assessment covering all stages of procurement, followed by the implementation and monitoring of risk management control measures and continuous reporting and updating. WSPs are formed according to the principle of multiple guardrails, the principle of hazard analysis and critical control points, and other structured management methods.

According to the WHO, the three most important elements of WSP aimed at achieving health goals are:

  • System evaluation – determines whether the water supply system as a whole (from the source of supply to the point of consumption) can supply water of a quality that meets the stated objectives; also includes a classification of criteria for the design of new systems;
  • Water supply system control measures – are tools for identifying risk factors that together will ensure that the identified risks are controlled and health goals are achieved. For each control measure, appropriate means of operational monitoring should be identified to ensure that procedures are developed to minimize the effects of the risks that occur; moving from routinely inspecting water quality and taking corrective action as soon as a problem occurs to preventive risk management aimed at continuously identifying risks and minimizing them throughout the water supply chain, from intake to consumer, is the essence of the new approach to water safety;
  • Management and communication plans – describe actions to be taken during normal operations or in the event of an incident, documenting the evaluation of the system, including updates and improvements to planning, monitoring and communication projects and supporting programs.

The great advantage of WSP as a risk management tool is that it can be applied to all water supply systems regardless of their complexity, volume of production, treatment techniques or the type of water captured. However, this requires proficiency in identifying risks, conducting analyses and assessments, selecting appropriate control measures, and creating procedures and instructions. It is worth emphasizing the importance of multi-barrier protection, which continuously minimizes the risk of water pollution. Basing the water system’s safeguards solely on monitoring could result, in the event of contamination, in its consumption until laboratory results are available or the occurrence of illnesses is linked to water quality.

New Directive of the European Parliament and of the Council (EU) 2020/2184 of December 16, 2020. on the quality of water for human consumption aims to improve the health safety of water by bringing the list and values of tested parameters into line with the current state of knowledge and technological advances, as well as improving access to water, especially for vulnerable and marginalized groups. According to the new regulation, it becomes mandatory to carry out identification and risk assessment of water supplies throughout their chain. It seems extremely important to develop and implement an effective water safety management system, which should be based on risk management from the point of water intake, through its treatment, storage and distribution to the consumer’s point of use.

The directive in Art. 7 stipulates that member states shall ensure the application of a risk-based approach covering the entire supply chain in the area of water supply, abstraction, treatment, storage and distribution (…).

The directive indicates specific deadlines. Thus, risk assessment and risk management in supply areas for points of water intended for human consumption should be carried out for the first time by July 12, 2027. This risk assessment and risk management shall be reviewed at regular intervals of no more than six years, taking into account the requirements of Article 7 Directive 2000/60/EC, and are updated as necessary. In turn, risk assessment and risk management of the supply system and internal water supply systems should be carried out for the first time by January 12, 2029. They are subject to review at regular intervals, no longer than six years, and updated as necessary. Water supply management systems will be based on risk assessment, covering the entire process from intake to the water point, and the scope of quality testing and its frequency will be closely aligned with the actual risks to adequate water quality. The directive also expands the existing range of standard water testing parameters, introducing additional microbiological and chemical measurements. The scope of the required evaluation of water disinfection byproducts and many other parametric values has also been changed.

We are currently waiting for the provisions of the new CPD 2020/2184 to be implemented into national legislation. Transposition will involve updating such legal acts as the Law on Collective Water Supply and Collective Sewage Disposal, the Water Law, and the Regulations of the Minister of Health on the Quality of Water Intended for Human Consumption. Adapting to the new requirements posed by the directive will be a major challenge for the water and sewer industry, especially smaller water utilities.

Risk management at the City of Krakow Waterworks

At WMK SA, it was noted some time ago that the ISO 9000-series international quality management system used by the company is not sufficient, as it does not provide for the very important element of assessing individual water production risks and evaluating the risks, and relies only on adopting and following certain procedures, just as in other industrial production. The new ISO 9001:2015 standard, which has been implemented at WMK SA, already provides for risk assessment, but the proposed methodology is not as useful as the standard designed to ensure the safety of water supply systems, i.e. EN 15975, part. 2. In the Waterworks of the City of Krakow already in 2012. a comprehensive method for assessing and managing risks throughout the water supply chain has been introduced, following the methodology set forth in the WHO WSP guidelines and the aforementioned. new standard. A special role in WMK’s preventive risk management is the protection of water intakes.

Protection of water intakes

The supply of safe water, from the intake to the consumer’s tap, begins with effective protection of the source of water to be treated, which is the responsibility of water management units implementing the Water Framework Directive in Poland.

Water treatment plants supplying Krakow with water for consumption use mainly surface intakes (the Raba River – Dobczycki Reservoir, Rudawa River, Dłubnia River, Sanka River), which may cause a greater risk of disruption of technological processes, associated with incidental pollution of a natural nature (e.g., flooding, landslides, strong windstorms), anthropogenic (e.g., actions of terrorists, eutrophication of captured waters) or civilization (e.g., collisions of means of transport, fuel spills, industrial and construction disasters).

To protect against incidental contamination of Krakow’s water supply system, the following measures are used:

  • Sanitary protection of the catchment area – protection zones;
  • systematically organize reviews of sanitary protection zones;
  • shielding stations and remote data transmission system (early warning stations equipped with automatic analyzers of selected pollutants);
  • Backup raw water flow tanks;
  • Continuous measurement of basic physical and chemical parameters of water;
  • permanent duty of laboratory staff, including on holidays;
  • Alternative water treatment technologies (possibly with a periodic reduction in the amount of water supplied);
  • spare volume of treated water (drinking water tanks);
  • Reserve capacity of other water supply sources;
  • Services locating and securing the source of contamination;
  • Systematic analysis and statistical evaluation of test results to determine trends in changes in water quality.

All water intakes have established sanitary protection zones (direct and indirect protection), which were designated on the basis of multi-year analyses, taking into account elements of hazard assessment and detailed risk analysis. Direct protection zones are marked and fenced, and protected by authorized providers of security services for persons and property. The protection zones are subject to systematic reviews carried out jointly with inspectors of the WIOŚ, Sanitary Inspection, water police and representatives of the Municipality of Krakow.

Each intake is equipped with a shielding station that monitors the quality of the water before it goes into the treatment process. This allows, in the event of deterioration, for possible early preventive action. ZUW Raba has a floating cover station in the form of a buoy floating on the water surface. The station monitors chemical parameters of water: temperature, pH, conductivity, ammonia, chlorides, suspended solids, chlorophyll, concentration of petroleum substances, and also collects such meteorological data as wind direction and speed, air temperature and humidity, sunshine. In the event of a chemical contamination emergency, the dynamics of the spread of contamination in the Dobczycki Reservoir is predicted with the help of a cover station, based on mathematical modeling. Thus, the attendant has enough time to change the level of water intake if necessary. In addition, at the intake there is a system of continuous quality monitoring at various levels of the intake, and a technology laboratory operates at the plant around the clock. Monitoring data from shielding stations, as well as from tests conducted in our laboratories, are used on an ongoing basis to validate the risk management system.

An important factor in the high level of reliability of water production is the ability to combine individual components and facilities in parallel rather than only in series, which gives the chance to use them alternatively and create a large number of combinations bypassing faulty components or facilities. Thus, in case of deterioration of the quality of the water intake at the Rudawa Water Supply System, raw water can be taken directly from the intake in Szczyglicki, from the raw water reservoirs in Podkamyk or from the intake in Mydlniki. In addition, there is a cover station at the Rudawa ZUW intake that continuously monitors the quality of the intake water. ZUW Dłubnia has a cover station that conducts constant monitoring of water parameters (turbidity, pH, petroleum compounds, ammonium nitrogen, specific conductivity). If a situation were to occur where any of the parameters fall below the set alarm thresholds, the supply to the distribution chamber will be automatically cut off. In this case, water abstraction and the operation of the treatment plant are stopped, and the area is supplied with water diverted via the mains from the Raba ZUW. Water intake can be restarted only after analysis by the company’s Central Laboratory and relevant decisions. Independently of the protection zones, the Bielany Waterworks also has an early warning station, which continuously monitors selected parameters of the quality of water drawn from the Sanka River.

As part of the identification of risks to Krakow’s water supply system and for the purpose of planning countermeasures, two research and development projects were prepared and carried out, closely related to the Water Safety Plans. The first project, still being prepared in 2019, concerned the expansion of the Central Laboratory’s analytical capacity, necessary in connection with the draft of the new EU directive on drinking water quality (DWD) and the introduction of additional parameters from the group of “emerging contaminants” (“ECs”), among others. pharmaceuticals, endocrine compounds, microplastics, etc. The project called “Research and Development Center for the Waterworks of the City of Krakow S.A.” received funding from the European Regional Development Fund (MRPO 1.2.2), and in February 2020. Contract No. RPMP.01.02.02-0161/19-00 was signed. The second project, prepared in 2020 to counteract the identified risks associated with climate change and projected water deficits and threats to the quality of intake water, concerned the construction of a pilot plant at the Bielany UITP enabling effective treatment of water intake from the Vistula River. Application No.: POIR.01.01.01-00-1275/20 for the project “Innovative technology for the treatment of saline surface water in a closed-loop economy” was submitted in August 2020. to the National Center for Research and Development within the framework of the competition “6/1.1.1/2020 SS Large/MSP/JN 4”. The proposal received a high score, and the contract with NCBiR for the implementation of the above. The project was signed in 2021. In the same year, its implementation began.

Above that, the identified and assessed risks for individual areas of Krakow’s water supply system and the proposed countermeasures/measures formed the basis for the preparation of a new multi-year plan – the “Material and Financial Plan for 2021 – 2025 of the Waterworks of the City of Krakow”. The projects envisaged for implementation in the aforementioned area, based on preventive risk management in water supply systems, have been identified in functional programs covering modernization of water treatment plants and expansion of intake protection systems.


In anticipation of the implementation of the provisions of the new DWD 2020/2184 into the national legal system, some water utilities, based on current legislation, are conducting a risk analysis for the recharge areas of their water intakes, using both optional (resulting from the Regulation of the Minister of Health on the quality of water for human consumption) and mandatory (resulting from the Water Law) recommendations, which are mutually inconsistent. It should be expected that in the future the procedures used in the risk analysis that provides justification for the establishment of an intermediate protection zone for water intakes will be consistent or identical with the procedures for risk assessments carried out on the basis of the methodology of the so-called “intermediate protection zone”. Water Safety Plans or EN 15975, part. 2.

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