Jupiters RWMP Scheme Number SRN00005 Annual Report for … · Turbidity Clarity Daily *

Jupiters RWMP Scheme Number SRN00005

Annual Report for FY14/15

Prepared by Jupiters Limited

December 2015

Overview of following annual report

Jupiters RWMP (Scheme Number SRN00005) was approved with regulatory conditions on 11th March 2011.

One of the conditions of Jupiters approved RWMP is that it must submit an annual report to the Queensland Water Supply

Regulator, Department of Energy and Water Supply

This annual report contains data for both Jupiters’ Recycle and Reverse Osmosis Water Treatment Plant. The report includes incidents where testing data has been unable to be carried out. Each incident is identified along with a reason for its

omission.

In accordance with Jupiters approved RWMP conditions it arranged for a 2 yearly regular internal audit of its RWMP. This annual report contains details of the audit which was undertaken on 4th March 2015.

Report Prepared By:

Stephen Gibson – Jupiters Hotel & Casino

Recycle Water Plant

Annual Data

During this reporting period there were 44 variances in the required weekly testing and 324 variances in the required taking

of the daily testing samples. A breakdown of the incidents causing the variations are shown on the next page

Frequency Value Samples

Required

Actual

TakenVariance Actual Value Min Max Mean

Escherichia coli Bacteria Weekly * <1 cfu/100mL 52 8 44 8 x <1 cfu/100mL <1 <1 <1

Free Chlorine Sufficient chlorine levels Daily * >0.5mg/L 365 41 324 41 x >0.5mg/L 0.77 1.88 0.99

Turbidity Clarity Daily * <2.0 NTU 366 41 324 41 x <2.0 NTU 0.01 1.76 0.47

R e c y c l e W a t e r P l a n tAnnual Report

1st July 2014 - 30th June 2015

Below is a snapshot of the weekly and daily water samples taken between 1st July 2014 - 30th June 2015

Parameters tested as per Water Quality Criteria For Production of Recycled Water

Parameter Indicator

Testing Requirements Testing Results Statistical Values

* PFU means Plaque Forming Unit * CFU means Colony Forming Unit * NTU means nephelometric turbidity units * mg/L means milligrams per litre

Variances

44 x Weekly Testing Variances and the 324 Daily Testing Variances were made up of 6 x incidents

Incident #1

Gold Coast Water was unable to supply Jupiters consistant flow and acceptable conductivity levels of recycled water from July 1 - April 12 (inclusive) resulting in

a non-consecutive total of 286 consecutive non-operational days

Corrective Action Taken

The Recycled Water Plant was turned off during the non-consecutive 286 non-operational days and it's recycle water supply was replaced with potable water

Corrective Action Taken to Stop Reoccurrences

No corrective action required by Jupiters Hotel & Casino

Incident #2

Gold Coast Water was unable to supply Jupiters consistant flow levels of recycled water from April 20 - April 24 (inclusive) resulting in 5 non-operational days


The Recycled Water Plant was turned off during the 5 non-operational days and it's recycle water supply was replaced with potable water



Incident #3

Gold Coast Water was unable to supply Jupiters consistant flow levels of recycled water from May 2 - May 6 (inclusive) resulting in 5 non-operational days





Incident #4






Variances (cont.)

Incident #5

Gold Coast Water was unable to supply Jupiters consistant flow levels of recycled water from June 2 - June 21 (inclusive) resulting in 20 non-operational days





Incident #6






Reverse Osmosis Plant

Annual Data

During this reporting period there were 47 variances in the required weekly testing and 336 variances in the required taking

of the daily testing samples. A breakdown of the incidents causing the variations are shown on the next page

Frequency Value Samples

Required

Actual

TakenVariance Actual Value Min Max Mean

Somatic coliphages Viruses Weekly * <1 pfu/100mL 52 5 47 5 x <1 pfu/100mL <1 <1 <1

F-RNA bacteriophages Viruses Weekly * <1 pfu/100mL 52 5 47 5 x <1 pfu/100mL <1 <1 <1

Escherichia coli Bacteria Weekly * <1 cfu/100mL 52 5 47 5 x <1 cfu/100mL <1 <1 <1

Clostridium perfringens Protozoa & Helmiths Weekly * <1 cfu/100mL 52 5 47 5 x <1 cfu/100mL <1 <1 <1

Free Chlorine Sufficient chlorine levels Daily * >0.5mg/L 365 29 336 29 x >0.5mg/L 1.17 2.70 1.78

Turbidity Clarity Daily * <2.0 NTU 365 29 336 29 x <2.0 NTU 0.01 0.40 0.01

R e v e r s e O s m o s i s W a t e r P l a n tAnnual Report

1st July 2014 - 30th June 2015

Below is a snapshot of the weekly and daily water samples taken between 1st July 2014 - 30th June 2015

Parameters tested as per Water Quality Criteria For Production of Recycled Water

Parameter Indicator

Testing Requirements Testing Results Statistical Values

* PFU means Plaque Forming Unit * CFU means Colony Forming Unit * NTU means nephelometric turbidity units * mg/L means milligrams per litre

Variances

47 x Weekly Testing Variances and the 336 Daily Testing Variances were made up of 5 x incidents

Incident #1

Gold Coast Water was unable to supply Jupiters consistant flow and acceptable conductivity levels of recycled water from July 1 - April 13 (inclusive) resulting in

a non-consecutive total of 287 consecutive non-operational days


The Reverse Osmosis Plant was turned off during the non-consecutive 287 non-operational days and it's recycle water supply was replaced with potable water



Incident #2

Gold Coast Water was unable to supply Jupiters consistant flow levels of recycled water from April 17 - May 4 (inclusive) resulting in 18 non-operational days


The Reverse Osmosis Plant was turned off during the 18 non-operational days and it's recycle water supply was replaced with potable water



Incident #3






Incident #4






Incident #5






2 Yearly Regular Internal Audit

MWH Consultants was engaged to undertake a 2 Yearly Regular Internal Audit of the Jupiters Limited Recycled Water

Management Plan. The audit was undertaken on 4th March 2015 and covered the level of compliance with the approved

RWMP and associated documents and procedures, legislation and regulatory guidelines and notices issued by the Department

of Energy and Water Supply. The audit also reviewed the non-compliances that were raised during the 3 Yearly External

Audit which was undertaken by Viridis Consultants Pty Ltd on 18th February 2014

The audit found 2 items of minor non-compliance and 4 compliant observations. The audit also included recommendations to

address each of the minor non-conformances and observations. The audit, along with an Action Plan stating how Jupiters

proposes to implement all recommendations stated in the audit was submitted to DEWS on 16th April 2015.

The following tables are extracts from the Action Plan submitted to DEWS outlining recommendations for the 2 items of

minor non-compliance, the 4 compliant observations and how they were actioned. Note, when the Action Plan was submitted

to DEWS minor compliance number 1 & observation number 2 & 4 were already completed.

Issue 1 Minor Non-conformance 1 Approval condition 6.4 identifies a summary of regular reviews is to be included in the annual report for the year that the review is completed

Reference RWMP Approval with Regulator Conditions - condition 6.4 Regular Reviews

Findings

A review of the Jupiter’s RWMP was undertaken following the 2013 internal audit and included in RWMP v6 (and subsequently v7). However, a summary of the review was not sighted in the FY2013/14 Annual Report on the Jupiters Limited website. It should be noted that a summary of the External Audit (Feb, 2014) was included in the Annual Report

Recommendations Ensure that all future reviews are summarised in the Annual Report

Jupiters Response Jupiters to create a re-occurring job in its AMPRO maintenance program that will flag all future reviews are to be summarised in its annual reports

Target Date Completed

Issue 2 Minor Non-conformance 2 Approval condition 6.5 identifies the water quality criteria required for open space irrigation with unrestricted access and associated monitoring parameters and frequencies.

Reference RWMP Approval with Regulator Conditions - condition 6.5 Water quality criteria - open space irrigation with unrestricted access

Findings

Jupiters staff advised that verification monitoring of E.coli was no longer being undertaken for the Class A irrigation water following amendments to the Act in 2014. Due to various supply and quality issues with the source water, the RWTP was offline between 7 February 2014 to 16 November 2014. Irrigation water was supplied from potable over that period. Since the RWTP has been back online from 17 November 2014, no verification monitoring has been undertaken. Under the transition to the new framework, if an existing recycled water management plan covers both higher and lower exposure uses, only the parts of the plan that relate to the higher exposure uses will continue to have effect (https://www.dews.qld.gov.au/policies-initiatives/water-sector-reform/regulatory-reform/recycled-water).

Recommendations Liaise with the Regulator to get a clear understanding of the requirements under the amendments to the Act and request amendment to the approval condition to reflect these changes

Jupiters Response At the time of the audit Jupiters RW plant was closed. Once the plant recommenced operation on April 2015 Jupiters re-commenced monitoring of E.coli for its Class A irrigation water, negating the need to liaise with regulator as per auditor’s recommendation

Target Date April 2015

Completion Date 7th April 2015

Issue 3 Observation (compliant) 1 Recycled Water Use Agreement in Appendix 1 is not current

Reference Appendix 1

Findings A new Recycled Water Use Agreement has been negotiated and signed with Gold Coast Water

Recommendations Include the latest Recycled Water Use Agreement in the next RWMP review.

Jupiters Response Will include in next RWMP review

Target Date June 2015

Completion Date 24th June 2015

Issue 4 Observation (compliant) 2 Process Flow Diagram (PFD) contains minor errors

Reference Figure 1 Jupiters Limited RWMP

Findings

PFD identifies 3D Trasar in the legend. The 3D Trasar system is no longer used. This should be Convergent Controller Max 5.

PFD identifies weekly E.coli testing at the Class A verification point (irrigation water). This testing is no longer being undertaken following amendments to the Act in May 2014.

It is important that the PFD is accurate and current as it is identifies the points of supply and is referred to in the conditions of approval.

Recommendations Update the PFD during the next RWMP review to reflect current system and monitoring accurately

Jupiters Response

Reference of 3D Traser in legend to be replaced with Convergent Controller Max 5

Effective immediately, Jupiters has decided to continue E.coli sampling at the Class A verification point (irrigation water) even when its RW plant is only feeding its irrigation system. Therefore no change to PFD in regards to the Class A verification point (irrigation water).

Target Date Completed

Issue 5 Observation (compliant) 3 General currency of some information throughout RWMP is out of date

Reference Throughout RWMP

Findings

Some references to Nalco remain in text

Water use data is from 2012

Source water data is from 2011/12

References to Class A verification monitoring that is no longer undertaken

References to cross connection checks

Training and Awareness Programs have changed

HACCP Plan still refers to Class A verification

Recommendations Update the RWMP during the next review to make information current. The next required ‘regular review’ is due August 2016 (required at least every 3 years). Jupiters should seek advice from the Regulator regarding when updated conditions of approval will be provided so that they can be included in any review.

Jupiters Response The RWMP is referencing Nalco and data relating to some of the steps involved in getting the approved RWMP. However, will review

Target Date June 2015

Completion Date 24th June 2015

Issue 6 Observation (compliant) 4 RW 6 Recycled water flusherette system refers to old cross connection procedure (conductivity testing)

Reference RW 6 Recycled water flusherette system

Findings RW6 Recycled water flusherette system needs updating with new cross connection procedure (dye testing)

Recommendations Update RW 6 to delete reference to old test and replace with new dye cross connection test

Jupiters Response Jupiters to update RW6 as per recommendation

Target Date 30/06/15

Completion Date Completed

Conclusion During operation in this reporting period Jupiters scheme water quality was 100% compliant in accordance with the Water

Supply (Safety and Reliability) Act 2008

Between 1st July 2014 and 12th April 2015 Jupiters experienced inconstant water quality and flow of its supply from Gold Coast Water. As a result, during this reporting period Jupiters closed both its Recycle Water and Reverse Osmosis Plants.

On 13th April 2015 Jupiters Recycle Water Plant went back on-line followed by the Reverse Osmosis Plant on 14th April 2015. However, up until the end of this reporting period, 30th June 2015, Jupiters still experienced supply issues from Gold Coast Water. This resulted in both plants being closed at various times, these times are documented under the heading of

“Variances” listed in this report.

As per section 578 of the Act a copy of this annual report can be viewed online at Jupiters home page

www.jupitersgoldcoast.com.au/Pages/default.aspx

Alternatively to arrange to inspect a hard copy at Jupiters during normal business hours, or receive a free hard copy, contact Jupiters on

(07) 5592 8674

http://www.jupitersgoldcoast.com.au/Pages/default.aspx

Jupiters RWMP Scheme Number SRN00005 Annual Report for … · Turbidity Clarity Daily *

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