I FEEL compelled by a sense of fair play and justice to respond to Encik Haniffa Hamid's letter "IWK's bills - why the protest" (The Star, Jan 20).

There are a number of serious misrepresentations in his letter that stand to be corrected. First and foremost, the consumers are, in general, not against the concept of privatisation of services carried out in Malaysia and this includes the national sewerage services.

The consumers are fully aware of the benefits to health and environment if treatment of sewage is carried out properly. The main issue here is whether IWK - after taking over the sewerage services of an area - is doing anything at all to rehabilitate and improve the existing sewerage systems in that area.

The contention of the majority of consumers is that, if little or nothing is done to improve the current sewerage services, IWK should refrain from billing the consumers.

Until and unless IWK has implemented programmes to effectively improve the current situation, the majority of consumers would not be willing to pay. Consumers are "making a drama out of it" not because they do not wish to pay for a better environment and quality of life but because they are unwilling to pay just for a grand show put up by IWK so far.

The statement by Haniffa that septic tanks, Imhoff tanks, and oxidation ponds would give a sub-standard level of sewage treatment is completely without any basis.

Have any studies or tests been carried out to justify that effluents produced by these properly maintained systems are not able to fully comply with the Environmental Quality Act (EQA), 1974? What are these handful of properly designed "mechanised system"?

Is he referring to the activated sludge process which is still the most used biological sewerage treatment process in the world? Does he expect IWK to replace all septic tanks, Imhoff tanks, and oxidation ponds in Malaysia with the "mechanised systems"?

Later in this letter, some recent test results of sewerage effluents are presented to show that Imhoff tanks and oxidation ponds can produce satisfactory effluents -complying with the Environmental Quality (Sewage and Industrial Effluents) Regulations, 1979.

To lend further support to the comments made above, permit me to pursue the issues raised in my letter "Indah Water - end the confusion" (The Star, Dee 25.1995). It has been a month since the publication of the above letter, and yet neither IWK nor the authorities concerned have come out to make any comments and answer the many pertinent questions raised.

About a week after the publication of my letter, IWK workers were seen working to recommission the sewage lifting station along Jalan 14/15, Petaling Jaya. This station was seen to be in operation for a week or so after repairs were done, but was out of action again soon and raw sewage could be seen discharging into the open drain as before.

IWK could have realised that it was, indeed, more practical and economical not to run the lifting station as - if The sewage was to be lifted across the river to the sewage treatment plant nearby - it would not be properly treated anyway.

This treatment plant - sited along Sungai Penchala right behind the lifting station and across the river - did not seem to function properly. The two circular filters looked neglected and some vegetation was found growing in there.

Sewage coming out of the sedimentation tank was seen piped over and across the filtration tanks and flowed into a collection channel. From there, the effluent was discharged into Sungai Penchala.

The results of tests carried out from a sample of effluent taken showed that it was only partially treated. As most, if not all, treatment plants taken over by IWK in Petaling Jaya have new fencing built around them, it would not be possible for any unauthorised person to gain access to them to investigate whether these plants were functioning properly.

However, the level of treatment of sewage received from these plants can be assessed from the quality of effluents produced. Four samples of effluents were collected from four sewage treatment plants in Petaling Jaya area where the effluents could be conveniently obtained.

These were sent to an analytical laboratory in Petaling Jaya for analyses. Tests were carried out to determine their pH, Biochemical Oxygen Demand (BOD), Chemical Oxygen Demand (COD), suspended solids, and E.Coli counts.

Except for the E.Coli count, these are the main parameters of tests carried out to determine the quality of treated sewerage effluents. The results of these tests are compared with the allowable limits prescribed under EQA, 1974, and are shown in the table.

NOTE 1:
These limits are given in Environment Quality (Sewage & Industrial Effluents) Regulations 1979. They are for discharges into inland waters not within the catchment areas for water supplies. These standards are much lower than the European ones.

NOTE 2:
BOD is a measure of quantity of oxygen that the effluent consumes in decomposing the organic matter in the effluent. It therefore represents the amount of biodegradable organic matter. Raw sewage would have BOD in excess of 200.

NOTE 3:
COD is a measure of quantity of oxygen required for chemical oxidation of organic matter in the effluent. It therefore represents the quantity of organic matter which can be oxidised chemically.

NOTE 4:
Escherichia Coli or E.Coli is a coliform bacteria residing in the intestinal track of humans and other warm blooded animals. Untreated domestic waste water generally contains more than 3 million coliforms per lOOml. Coliform criteria to water quality for purposes other than drinking have been poorly defined. As such, no criteria are set in the Environment Quality Regulations 1979 for this parameter.

However, the E. Coli counts can provide an indication of the degree of the treatment of sewage. As a comparison, the water in Sungai Selangor where the intake of the Sungai Selangor Water Treatment Works is located has a E. Coli count of around 160,000.

The above results indicate that two plants, that is, the communal septic tank (Imhoff tank) in Jalan 222, Petaling Jaya, and the oxidation pond along Jalan Perbandaran, Kelana Jaya, were functioning quite satisfactorily.

However, the results of the two other communal tanks, one located in Jalan 20/20, Petaling Jaya, and the other off Jalan 14/1A, Petaling Jaya, where sewage from the lifting station in Jalan 14/15 was supposed to be treated in this plant, were far from satisfactory.

The results clearly refute the claim by Haniffa that septic tanks, Imhoff tanks, and oxidation ponds in Malaysia give only sub-standard level of sewage treatment. However, one must admit that these plants are not as efficient and the treatment as complete as the activated sludge process of treatment or other more modern compact processes.

The investigation and tests carried out also revealed that proper functioning of the filtration system in a communal septic tank is important to produce good quality effluent.

The filtration system is where the majority of the biological stabilisation takes place. It has been reported elsewhere that before IWK took over the sewerage services from local authorities, 80 per cent of the sewage treatment plants were not in operation.

From my personal observation, the current situation in Petaling Jaya cannot be any better than when sewerage services were under the jurisdiction of MPPJ. One wonders whether the Department of Sewerage Services, the sewerage regulatory body in Malaysia, has been monitoring the performance of all sewage treatment facilities taken over by IWK.

It is important that such performance data, if available, can be made public so that consumers can judge for themselves whether or not IWK is doing enough to justify billing them. Until such time, consumers should support the drive by Fomca in its one million signature campaign to protest against the services and billings by IWK.