ministry of the environment ministère de l’environnement

Ministry of the Environment Safe Drinking Water Branch Thunder Bay Regional Office 3rd Floor, Suite 331 435 James Street South Thunder Bay, ON P7E 6S7 Tel.: 807-475-1514 Fax.: 807-475-1161 Toll Free: 1-800-875-7772

Ministère de l’Environnement Direction du contrôle de la qualité de l’eau potable Bureau régional de Thunder Bay 3e étage, bureau 331 435 rue James sud Thunder Bay, ON P7E 6S7 Tél.: 807-475-1514 Téléc.: 807-475-1161 Sans Frais: 1-800-875-7772

April 7, 2016 The Corporation of the Municipality of Greenstone 1800 Main Street P.O. Box 70 Geraldton, ON P0T 1M0 Attention: Mr. Brian Aaltonen, Director Public Services Dear Mr. Aaltonen: Re: Geraldton Drinking Water System 2015-2016 Annual Inspection Report Please find attached the 2015-2016 municipal water works inspection report for the Geraldton Drinking Water System. The inspection was started on February 11, 2016, and was completed under the Ministry of the Environment and Climate Change’s inspection protocol for municipal water treatment plants. The statements in the bold text are generally “pre-approved” statements, which are automatically chosen based on my response to the question that is asked. Text that is not bold, has been added to support/qualify the response. Some issues are based on legislated requirements, other issues are based on “best management practices”. Accordingly, you will see that the last few pages of the report summarize issues based on these criteria. A provincial officer order has not been issued with this report. However there are some “Actions Required” with specific timeframes. Although there were non-compliance items identified in the report, it is apparent that the operation of the water treatment plant has improved. A number of the non-compliance items were of an administrative nature and these should be easily rectified. It is the Ministry’s expectation that all water works fully comply with the Safe Drinking Water Act and the Ontario Water Resources Act and the associated regulations, and the issues identified throughout the report be dealt with in a timely manner. In order to measure individual inspection results, the Ministry has established an inspection compliance risk framework based on the principles of the Inspection, Investigation & Enforcement (II&E) Secretariat and advice of internal/external risk experts. The Inspection Summary Rating Record (IRR), included as Appendix E of the inspection report, provides the Ministry, the system

owner and the local Public Health Units with a summarized quantitative measure of the drinking water system’s annual inspection and regulated water quality testing performance. Please note the attached IRR methodology memo describing how the risk rating model has improved to better reflect the health related and administrative non-compliance found in an inspection report. IRR ratings are published (for the previous inspection year) in the Ministry’s Chief Drinking Water Inspector’s Annual Report. If you have any questions or concerns regarding the rating, please contact Dave Manol, Drinking Water Program Supervisor (A), at 807-475-1689. Should you have any questions or comments in regards to this inspection, please feel free to contact me at 807-475-1514. Yours truly, Pamela Cowie Provincial Officer Water Inspector Thunder Bay District Office :pc Attach. c.: Ontario Clean Water Agency

PO Box 819 Longlac, Ontario, P0T 2AO Attention: Mr. Bradley McMahon, Senior Operations Manager

Thunder Bay District Health Unit

999 Balmoral Ave. Thunder Bay, Ontario, P7B 6E7 Attention: Mr. Abby Mackie, Senior Public Health Inspector Ministry of Natural Resources P.O. Box 970, Nipigon, Ontario, P0T 2J0 Attention: Chris Magee, District Manager

GERALDTON DRINKING WATER SYSTEM

Ministry of the Environment and Climate Change

Inspection Report

1-C5GKDInspection Number:Feb 10, 2016Date of Inspection:

210000292Site Number:

Inspected By: Pamela Cowie


Drinking Water Inspection Report TABLE OF CONTENTS Owner Information 2

Contact Information 2 Inspection Details 2

Drinking Water System Components Description 3 Inspection Summary 5 Introduction 5

Source 5 Permit to Take Water 5

Capacity Assessment 6 Treatment Processes 6

Treatment Processes Monitoring 10 Process Wastewater 12

Distribution System 12 Operations Manuals 15

Logbooks 16 Contingency/Emergency Planning 17

Security 18 Consumer Relations 18

Certification and Training 18 Water Quality Monitoring 19 Water Quality Assessment 22 Reporting and Corrective Actions 22 Non-compliance with Regulatory Requirements and Actions Required 24 Summary of Best Practice Issues and Recommendations 27 Signatures 29 Appendix A – Stakeholder Appendix Appendix B – Inspection Rating Record

OWNER INFORMATION:

1800MAIN St

PO Box 70

GERALDTON

ON P0T 1M0

Street Number:Street Name:

Unit Identifier:

City:

Province: Postal Code:

Company Name: GREENSTONE, THE CORPORATION OF THE MUNICIPALITY OF

CONTACT INFORMATIONBrian AaltonenOwner

(807) 854-1100 x2060 (807) [email protected]

Type: Name:Phone: Fax:Email:Title: Director Public Services

Claude BeaulieuOperating Authority(807) 854-1314 (807) 854-1961

Type: Name:Phone: Fax:Email:Title: Operator In Charge

Rob CyrOwner(807) 854-1121 (807) 854-0293

Type: Name:Phone: Fax:Email:Title: Public Works Supervisor

Bradley McMahonOperating Authority(807) 876-1141 x321 (807) [email protected]

Type: Name:Phone: Fax:Email:Title: Senior Operations Manager , OCWA

Cory ThompsonOperator(807) 854-1314 (807) [email protected]

Type: Name:Phone: Fax:Email:Title: Operator In Charge

INSPECTION DETAILS:GERALDTON DRINKING WATER SYSTEMSite Name:

Site Address: HWY 584 (4.5KM NORTH OF TOWN) HWY GERALDTON P0T 1M0

County/District: Greenstone

MOECC District/Area Office: Thunder Bay District

Health Unit: THUNDER BAY DISTRICT HEALTH UNITHealth Unit:

Conservation Authority N/A

MNR Office: N/A

Category: Large Municipal Residential

Ministry of the Environment and Climate ChangeInspection Report

Page 2 of 29 on 07/04/2016 (dd/mm/yyyy)Report Generated for cowiepaSite #: 210000292

Date of Inspection: 10/02/2016 (dd/mm/yyyy)GERALDTON DRINKING WATER SYSTEM

Inspection Type: Unannounced

Inspection Number: 1-C5GKD

Date of Inspection: Feb 10, 2016

Date of Previous Inspection: Jan 21, 2015

Site Number: 210000292

COMPONENTS DESCRIPTION

MOE DWS MappingSite (Name):Type: Sub Type:DWS Mapping Point

Not ApplicableComments:

DISTRIBUTION (WATER INSPECTION)Site (Name):Type: Sub Type:Other

The Geraldton water works service a population of approximately 2,200 people.

Parts of the distribution system were built as early as the 1930's. Portions of the distribution system,were relined during the summers of 2012, 2013 and 2014.

There are a number of dead-ends in the distribution system. A bleeder line is located at the medicalclinic and at the MTO yard.

There are approximately 120 hydrants.

A 2,273 m³ water tower serves as a storage vessel and as a distribution system pressure controldevice. The water tower is not equipped with monitoring equipment, chlorine boosting equipment or arecirculation pump.

Comments:

RAW WATERSite (Name):Type: Sub Type:Source

The source of water is Cecile Lake, locally known as Reesor Lake. It is small, however, the waterquality is fairly consistent throughout the year. Cecile Lake is located north of the community; there isvery little development around the lake. The lake is within 50 m of Highway 584 and can be easilyaccessed from the highway.

Comments:

TREATED WATERSite (Name):Type: Sub Type:Treated Water POE




Raw water is pumped through two 50 mm mesh debris screens into a raw water chamber. The rawwater is pumped from the raw water chamber into a twin stream, conventional treatment packageplant. Potassium permanganate is added to the low lift intake for manganese removal. The water isdosed with alum (aluminum sulfate), and a coagulant aid, Magnafloc LT20. The water passes throughstages of mixing, flocculation, sedimentation with the aid of tube settlers, and a filter of mixed mediaconsisting of anthracite, sand and gravel.

Disinfection is provided by injecting a chlorine gas solution into the filtered water before it enters thestorage reservoirs.

Three high lift pumps deliver water to the distribution system.

Comments:




INSPECTION SUMMARYINTRODUCTION

The primary focus of this inspection is to confirm compliance with Ministry of theEnvironment and Climate Change (MOECC) legislation as well as evaluating conformancewith ministry drinking water policies and guidelines during the inspection period. Theministry utilizes a comprehensive, multi-barrier approach in the inspection of water systemsthat focuses on the source, treatment, and distribution components as well as managementpractices.

This drinking water system is subject to the legislative requirements of the Safe DrinkingWater Act, 2002 (SDWA) and regulations made therein, including Ontario Regulation 170/03,"Drinking Water Systems" (O.Reg. 170/03). This inspection has been conducted pursuant toSection 81 of the SDWA.

This inspection report does not suggest that all applicable legislation and regulations wereevaluated. It remains the responsibility of the owner to ensure compliance with allapplicable legislative and regulatory requirements.

*

SOURCE

* There were no obvious potential sources of pollution or activities in or around the sourcethat could impair source water quality.

The raw water source, Cecile Lake, is located within 50 metres of Highway 584. Activity aroundthe lake could potentially be a source of pollution.

The Municipality of Greenstone has implemented a number of measures to protect the sourcewater:

- A bylaw, 98-2040, restricts the erection of buildings in the zone around Cecile Lake.

- Two signs are posted along side the highway that warn of the prohibited activity on the lake.

- A gate restricting motor vehicle access to the feeder lake (road on north side of Cecil Lake) isinstalled.

The Certificate of Approval, that had previously authorized the operation of the drinking watersystem, required the development of a protocol for Ontario Provincial Police (OPP) and Ministry ofTransportation (MTO) to contact the Town in the event of accidents leading to spills into the sourcelake.

The Manager of Public Works last circulated a letter on March 25, 2014, to the OPP and MTOreminding them of the need for the Municipality of Greenstone or OCWA to be notified of a spill inthe area of the town's source water, Cecile Lake.

PERMIT TO TAKE WATER

* The owner had a valid PTTW for all of the production sources.

The taking of water from Cecile Lake is granted under permit 2726-974L4V. This permit wasissued on April 25, 2013 and is valid until April 25, 2023.




PERMIT TO TAKE WATER

* The maximum water takings were in accordance with those allowed under the PTTW.

The permit allows for the rate of water taking not to exceed a maximum of 4,165 litres per minutes(69.42 L/sec) or 5,997,000 litres per day.

Flow data, summarized by month, was reviewed for the period of February 2015 to and includingFebruary 2016. During this time period, the maximum flow was 58.98 L/sec in March 2015. Thelargest daily quantity taken was 2,510,000 litres per day and this was in March 2015.

* The PTTW imposed additional monitoring or recording requirements and the owner hadcomplied with the conditions of the PTTW.

The permit requires that water level measurements are to be recorded on a weekly basis duringthe ice free season. This data is to be compiled each year and an annual report is to be submittedto the Thunder Bay District office by January 31st of the following year.

The report for 2014 was received by the Ministry of Environment and Climate Change on January22, 2016.

CAPACITY ASSESSMENT

There was sufficient monitoring of flow as required by the Permit and Licence or Approvalissued under Part V of the SDWA

*

* Flow measuring devices were not calibrated or verified in accordance with the requirementsof a Permit and Licence or Approval issued under Part V of the SDWA.

The flow meters were verified on July 14, 2015.

The meters were vertified with a reference instrument that had last been calibrated on December 7,2013. Reference instruments used to confirm the verification of other meters also need to beroutinely calibrated.

A new reference instrument has since been purchased and the instrumentation technicianconfirmed that the reference instrument is now to be calibrated on an annual basis.

* The owner was in compliance with the conditions associated with maximum flow rate or therated capacity conditions in the Permit and Licence or Approval issued under Part V of theSDWA.

The rated capacity of the treatment subsystem is 6045 m3/day. The day with the highest waterproduction was in October and was 2510 m3/day.

TREATMENT PROCESSES

* The owner had ensured that all equipment was installed in accordance with Schedule A andSchedule C of the Drinking Water Works Permit.

The current Drinking Water Works Permit, Permit Number 225-204, issue Number 1, was issuedon June 23, 2011.

A detailed review, comparing all equipment to the permit, such as spare pumps, was notconducted.

What was noted is that the permit only requires one Sludge Transfer Pump to be in service andone pump to be a spare. The operator reports that a spare pump is available.

Now that the filter-to-waste is in operation, there has been increased flow to this sump on acontinual basis. The Municipality of Greenstone and OCWA should ensure that the necessary




TREATMENT PROCESSES

redundancy is available with this part of the process to ensure that required backwashing and filter-to-waste is not affected by a failed Sludge Transfer Pump and operators having to replace a pumpat a critical time.

Schedule A of the Drinking Water Works Permit states that the Sludge Transfer Pump is rated at5.36 L/s at a TDH of 7.56m. In the past year the 3hp pump was replaced with a 5hp to pump thewastewater more quickly from the storage tank.

* Records did not indicate that the treatment equipment was operated in a manner thatachieved the design capabilities required under Ontario Regulation 170/03 or a Permit,Licence or Approval issued under Part V of the SDWA at all times that water was beingsupplied to consumers.

CHLORINATOR FAILURE

On October 5 and 6, 2015, low residuals in the Clearwell was the result of a failure of thechlorination system to provide the chlorine gas required for disinfection while the treatment processwas producing water that was directed to the Clearwell. The lines on the chlorinator were changedand the problem was resolved. The operators purged the Clearwell of water through backwashesand wasting it through a hydrant outside the water treatment plant.

Non-compliance with this question is not a reflection on how certified operators operated the plant.Section 1-2. (2) 1. of the Drinking Water System Regulation requires that water treatmentequipment is in operation whenever water is being supplied. Unfortunately the problem with thefailure of the chlorination system could not be detected until the chlorine levels in the Clearwell haddropped to a level causing a low level chlorine residual to alarm in the water exiting the Clearwell.

CONVENTIONAL FILTRATION PROCESS REQUIREMENTS

The treatment equipment was not operated in a manner that achieved the design capabilitiesrequired by Schedule 1, Section 1-4, of O. Reg. 170/03 and the "Procedure for Disinfection ofDrinking Water in Ontario".

In order to be considered conventional filtration and meet or exceed the 2.5 log Giardia cystremoval, the 2.0 log Cryptosporidium oocyst removal and 2.0 log virus removal credits, the filtrationprocess must:

- monitor and adjust chemical dosages in response to variations in raw water quality;

- maintain effective backwash procedures, including filter-to-waste or an equivalent procedureduring filter ripening to ensure that the effluent turbidity requirements are met at all times; and

- meet the performance criterion for filtered water turbidity of less than or equal to 0.3 NTU in 95%of the measurements each month.

FILTER PERFORMANCE ASSESSMENT

Effective the beginning of May, 2014, OCWA also reported that they had upgraded the method tocalculate filter efficency so that only "online" data is used.

As part of the inspection process filter performance assessments were reviewed and found to meetthe requirement for filtered water turbidity of less than or equal to 0.3 NTU in 95% of themeasurements each month.

MONITOR AND ADJUST CHEMICAL DOSAGES

In order to achieve the log removal credits for conventional filtration, the "Procedure of Disinfectionof Drinking Water in Ontario" requires operators to monitor and adjust chemical dosages inresponse to variations in raw water quality. Within the water treatment industry, jar testing toensure optimum chemical addition and solids removal is a recognized method of evaluating theconventional filtration process. The previous inspection had recommend that operators receivingtraining in jar testing. The OIC reported that he had received training. However, jar testing is notbeing used as a means of monitoring the conventional filtration process. Last year's inspection




TREATMENT PROCESSES

report had also recommended that a procedure be developed directing operators on monitoringand adjusting chemical dosages.

Operators analyze colour, turbidity, alkalinity and manganese in both the raw and treated water. Aswell, aluminum residual in the treated water is measured. This information should assist operatorswith adjusting chemical dosages.

COAGULANT, POLYMER & POTASSIUM PERMANGANATE

The operating authority reports that there have been no periods when the treatment processoperated without the addition of coagulant, polymer or potassium permanganate .

PRIMARY DISINFECTION/CT CALCULATIONS

Due to a problem with the gas chlorination system on October 5 and 6, 2015, water leaving theClearwell and entering the distribution had a chlorine residual less than the amount directed byengineers when CT was calculated for the system.

On October 6, 2015, information from the operators indicates that water was wasted from theClearwell and not directed to the Clearwell. Water was pumped out of the Clearwell at a high rateof flow (50 L/s) and the Clearwell level was dropped below the level used to maintained primarydisinfection. The following is a summary of the operating conditions for a portion of the day onOctober 6:

- From 8:22 to 9:38 the treated water flow rate exceeded 30 L/s. During most of this time thetreated water flow rate was between 48 and 50 L/s.

- During this time period the free chlorine residual reached a low of 0.712 mg/L. This is less thanthe required 1.4 mg/L identified by the engineer as the required amount when two High Lift Pumpsare in service.

- At 9:38 the Clearwell level reached a low of 1.61. CT information developed by Hatch MottMacDonald states that at a low level of 1.7m, with a flow rate of 50 L/s, the chlorine residual needsto be at or above 1.4 mg/L. At the same level in the Clearwell and a flow rate of 35 L/s, 1.0 mg/L isrequired.

- After wasting water from the Clearwell on October 6, the operator calculated CT at 10:15 with thefollowing values: free chlorine residual of 2.12 mg/L, flow of 30 L/s, reservoir depth of 1.85, pH of6.5, and temperature of 14.7. Based on these values the operator assessed that CT had been metand directed flow to the distribution system.

* Records confirmed that the water treatment equipment which provides chlorination orchloramination for secondary disinfection purposes was operated so that at all times and alllocations in the distribution system the chlorine residual was never less than 0.05 mg/l freeor 0.25 mg/l combined.

A review of chlorine residuals recorded by the operators did not reveal any times when the freechlorine residual was less than 0.05 mg/L.

* The owner had evidence indicating that all chemicals and materials that come in contactwith water within the drinking water system met the AWWA and ANSI standards inaccordance with the Permit and Licence issued under Part V of the SDWA.

NSF information was available for the materials that have been in use for sometime as well as thenew materials: the new settling tubes, filter media and an epoxy used inside the filters.

* Up-to-date plans for the drinking-water system were not available in accordance with thePermit and Licence issued under Part V of the SDWA.

Up-to-date process flow diagrams, process and instrumentation diagrams and record drawings anddiagrams are a requirement of the Municipal Drinking Water Licence.

A "Geraldton WTP P&ID" was recently updated. The new P&ID is dated March 12, 2015.




TREATMENT PROCESSES

The alterations and programming of the filter-to-waste modifications were completed in 2014. TheMuniciplity of Greenstone must ensure that all required diagrams are in place. Record drawingshave not been updated with the filter-to-waste modification to the filtration processes.

Schedule B, Condition 15.2 of the licence states the following:

15.2 Any alteration to any treatment subsystem shall be incorporated into process flow diagrams,process and instrumentation diagrams, and record drawings and diagrams within one year of thesubstantial completion of the alteration.

* The facility and equipment appeared to be maintained and in a fit state of repair.

Various components of the drinking water system are being repaired and maintained.

DISTRIBUTION SYSTEM

WATERMAINS

In 2012, 2013 and 2014, the Municipality swabbed and relined portions of the distribution system.Relining was scheduled for 2015 but was not done.

There were no watermain replacements in 2015. Geraldton experiences watermain breaks due tothe aging infrastructure. This will require a continued investment in the distribution system toensure the necessary repairs and replacements are made.

A portion of town that is a dead-end and is close to the water treatment plant experiencessignificant pressure changes. As reported in the past inspection report, the Municipality ofGeraldton has purchased the materials to connect approximately 2000 feet of distribution systemfrom Olde Road to Hwy 584. This work was not done in 2015. A letter dated December 2, 2015,from a resident in this area shows that water pressure issues remain a problem for this part of thecommunity. The Municipality of Geraldton's response to the letter was that the work would becompleted in 2016.

The Municipality is reminded to ensure that they meet the requirements of the Drinking WaterWorks Permit and if a Form 1 is required, that this is prepared in advance of the work.

TOWER

During the summer of 2014 the interior lining of the tower was removed and replaced, an accesshatch was added to the side and the exterior was patched. No cleaning was conducted in 2015. Asecurity fence was installed around the perimeter of the water town to prevent access to the area.

TREATMENT SYSTEM

GAS CHLORINATION SYSTEM

Tags on the various components of the gas system indicates that the system components weremaintained in 2015.

FILTER MAINTENANCE

Replacement of the settling tubes, inspection of the underdrains, and replacement of the media inboth Filters #1 and #2 was completed in 2015.

PUMPS

Replacement of both the Low and High Lift Pumps have been identified as work that needs to beundertaken over the next few years.




TREATMENT PROCESSES

* The Operator-in-Charge had ensured that all equipment used in the processes wasmonitored, inspected, and evaluated.

Operators conduct daily visual checks on process equipment. Also, required maintenance isconducted on specific pieces of equipment at specific time intervals as dictated by the operatingauthority's maintenance program.

The plant is staffed Monday to Friday from 7 am to 3:30 pm. Outside of these hours, alarms toensure the correct operation of essential treatment processes are in place to alert the operators ofproblems at the plant. Operators are reminded to periodically confirm the operation of their alarms.

Following an incident a couple of years ago when the gas chlorination system was inadvertently leftout-of-service at the end of a shift, an "End of Shift Rounds" procedure was developed for use byoperators.

* Based on information provided by the owner/operator, it was not likely that contaminantsentering the floor drains would have come in contact with the source water or treated water.

The operators report that the floor drains in the water treatment plant lead to the Surge Tank whichis discharged to a lagoon. The drains in the rest of the plant discharge to the sanitary sewer whichis pumped to the septic field.

* Measures were taken to ensure that pesticides were not applied, stored, or mixed in theimmediate vicinity of source(s), treatment, and storage facilities.

There is no known use of pesticides in the area.

TREATMENT PROCESS MONITORING

Primary disinfection chlorine monitoring was being conducted at a location approved byPermit, Licence or Approval issued under Part V of the SDWA, or at/near a location wherethe intended CT had just been achieved.

*

* Operators were aware of the operational criteria necessary to achieve primary disinfectionwithin the drinking water system.

The operator who participated in the inspection was knowledgeable of the system and theoperational criteria to achieve primary disinfection.

* Continuous monitoring of each filter effluent line was being performed for turbidity.

The turbidimeters monitoring the filters were replaced with new analyzers on March 25, 2014.

* The secondary disinfectant residual was measured as required for the distribution system.

Four samples are collected on the first day of the week, usually Monday, and three residuals aremeasured later in the week.Records confirmed that the maximum free chlorine residual in the distribution system wasless than 4.0 mg/L or that the combined chlorine residual was less than 3.0 mg/L.

*

* Operators were examining continuous monitoring test results and they were examining theresults within 72 hours of the test.

The operators print trending information and save it to a file every two days.

The information reviewed demonstrated that operators are also completing the monthly turbidityassessments as required.





Samples for chlorine residual analysis were tested using an acceptable portable device.*

* All continuous monitoring equipment utilized for sampling and testing required by O. Reg.170/03, or approval or order, were equipped with alarms or shut-off mechanisms thatsatisfied the standards described in Schedule 6.

TURBIDITY MONITORING

The alarm setpoint for the continuous turbidity analyzers is 0.3 NTU which is better than theminimum setting required by the regulation.

Following problems with the old analyzers, the turbidimeters have been replaced with the Hach1720E models to ensure they meet the requirements of the regulation.

A turbidity reading of 0.3 NTU directs the water from the filters to waste. A turbidity of 0.3 NTU forgreater than 10 minutes will shutdown the treatment train.

CHLORINE RESIDUAL MONITORING

Schedule 6 of O. Reg. 170/03 contains a Table that lists the minimum alarm standard for ananalyzer used to measure free chlorine residual required to achieve primary disinfection. Item 1. ofthe Table states: "The minimum alarm standard is 0.1 milligrams per litre less than theconcentration of free chlorine residual that is required to achieve primary disinfection."

Schedule 6-5(2) also states that for the purposes of the Table, the concentration of free chlorineresidual that is required to achieve primary disinfection for the drinking water system shall bedetermined in accordance with the Ministry's "Procedure for Disinfection of Drinking Water inOntario".

A required action following a previous inspection was that by July 15, 2013, the Municipality ofGreenstone and OCWA was to provide a report confirming:

- the minimum chlorine residual for maintaining primary disinfection in accordance with O. Reg.170/03 and the "Procedure for Disinfection of Drinking Water in Ontario", and

- the low alarm setpoint(s) for the free chlorine residual analyzer monitoring primary disinfection.

A report from Hach Mott MacDonald, dated June 27, 2013, based the worst case scenario on a pHof 7.5, 0.5 Celcius and a low Clearwell level of 1.7 m and concluded:

- during the operation of one distribution pump, the flow rate is approximately 35 l/s and CT isachieved when the chlorine residual is at or above 1.0 mg/l.

- during the operation of two distribution pumps the flow rate is approximately 50 l/s and CT isachieved when the chlorine residual is at or above 1.4 mg/l.

Following the engineer's report a procedure "CT Calculation" was prepared, dated July 12, 2013.This procedure provides different values from the engineer's report. It states, "Based on the watertemp of 0.5 Celsius, pH of 7.5, flow of 55 l/sec (two high lift pumps operating) and the clear welllevel 2.44 m, the minimum chlorine level required to meet CT is 1.0 mg/l. This results in acalculated CT value of 42.5 with a requirement of 42. Therefore the alarm for the chlorine is to beset at 0.9 mg/l minimum." The SOP states that the second High Lift Pump is locked-out and whenthe system attempts to initiate the pump an operator receives an alarm.

Concerns were raised in a previous inspection that the minimum chlorine alarm setpoint of 0.9mg/L would not be be adequate to ensure primary disinfection during all operating conditions, suchas the times when two high lift pumps are operating, especially when the operators do not have theability to change the chlorine alarm setpoint when such conditions exist. The operators report thatthe second high lift pump is locked-out. If the pump is called for, an alarm is activated for anoperator to respond to the situation.

The high alarm setpoint for free chlorine residual is 3.5 mg/l.





* Continuous monitoring equipment that was being utilized to fulfill O. Reg. 170/03requirements was performing tests for the parameters with at least the minimum frequencyspecified in the Table in Schedule 6 of O. Reg. 170/03 and recording data with theprescribed format.

It appears that the minimum recording frequency is being met, although this was not reviewed inany detail during the inspection.

* All continuous analysers were calibrated, maintained, and operated, in accordance with themanufacturer's instructions or the regulation.

It appears that the continuous analyzers are being calibrated and maintained.

A DR2000 spectrophotometer is used to analyze chlorine residuals, aluminum, colour andmanganese. The free chlorine residual readings from this instrument are used to adjust thecontinuous chlorine residual analyzer monitoring primary disinfection.

The DR2000 is not calibrated or verified by a Hach technician. Operators report that they follow acalibration procedure when they change the bulb. However absorance standards are not used toverify the operation of the instrument.

PROCESS WASTEWATER

* The process wastewater and residual solids/sludges were being treated, handled anddisposed of in accordance with the design requirements approved under the Permit andLicence or Approval issued under Part V of the SDWA.

The wastewater is directed to a sewage lagoon which discharges to Yvonne Lake. The lagoon wasnot observed as part of the inspection as the road providing access had not been plowed.

* The process wastewater discharge quality and discharge monitoring program compliedrequirements established in the Permit and Licence or Approval issued under Part V of theSDWA.

Schedule C of the Municipal Drinking Water Licence requires suspended solids monitoring of wastewater during the months of discharge.

Since the time of the previous inspection, samples were collected and measured for TSS for themonths of May through November of 2015. An entry in the logbook indicates that sampling couldnot be conducted in December due to the lake freezing.

The results meet the annual average concentration of 25 mg/L.DISTRIBUTION SYSTEM

* The owner had up-to-date documents describing the distribution components as required.

The distribution system diagrams are dated June 2014. There have not been any changes to thedistribution system since that date.

* There is no backflow prevention program, policy and/or bylaw in place.

On February 10, 2016, the bleeder line located at the medical clinic was inspected with theassistance of Tom Bull, from the Geraldton District Hospital. The bleeder line was in use at thetime. The end of the copper line extended down into a hole in the floor and two other lines fromequipment in the room discharge into the same location. The end of the bleeder line extendedquite far into the floor drain and could not be reached by inserting a hand down into the floor drain.The use of an air gap or backflow preventer was discussed as means to prevent inadvertent




DISTRIBUTION SYSTEM

contamination of the drinking water system such as during a negative pressure event in thedistribution system.

Mr. Bull indicated that he would modify the bleeder line and forward a picture to the undersignedinspector.

The Public Works Supervisor, Rob Cyr, has confirmed that once the snow has thawed he will checkthe bleeder line at MTO to assess whether a backflow preventer or air gap is needed.

* The owner had a program or maintained a schedule for routine cleanout, inspection andmaintenance of reservoirs and elevated storage tanks within the distribution system.

As discussed previously, during the summer of 2014 the inside of the tower was painted and thecoating on the outside of the tower was patched. An access hatch was also added to the side ofthe tower.

* Existing parts of the distribution system that were taken out of service for inspection, repairor other activities that may lead to contamination, and all new parts of the distributionsystem that came in contact with drinking water, were disinfected in accordance withSchedule B, Condition 2.3 of the Drinking Water Works Permit.

The operators are reminded that a new document, "Watermain Disinfection Procedure" was issuedby the Ministry of Environment and Climate Change, dated November 2015.

For watermains that form part of the distribution system, Drinking Water Works Permit (DWWP)Schedule B, Condition 2.3 (“DWWP Condition 2.3”) requires that all parts in contact with drinkingwater which are:

• Added, modified, replaced, extended; or

• Taken out of service for inspection, repair or other activities that may lead to Contamination,

shall be disinfected before being put into service in accordance with the provisions of the AWWAC651 – Standard for Disinfecting Water Mains or an equivalent procedure.

For the purpose of DWWP Condition 2.3, the document "Watermain Disinfection Procedure" isconsidered by the Ministry of the Environment and Climate Change (Ministry) as the equivalentprocedure which replaces ANSI/AWWA C651 - Standard for Disinfecting Water Mains with respectto the cleaning, tapping, maintenance and repair of watermains, Appurtenances and fittings.

With respect to new watermains, relined watermains and temporary watermains, the provisions ofthe document "Watermain Disinfection Procedure", including sections 1.1 and 1.2 shall be followedby operating authorities for compliance with DWWP Condition 2.3. Where this document makesreference to ANSI/AWWA Standard C651, the most current version shall be used.

* The owner had not implemented a program for the flushing of watermains as per industrystandards.

FLUSHING PROGRAM

Flushing of the system was done in the spring, June 8 to 15, 2015, and the fall, August 21 toSeptember 9, 2015.

A "Flushing and Disinfection - Watermains" procedure is available for the distribution system inGeraldton. The procedure discusses notifying people, flushing, measuring residuals, and so on. Itdoes not contain maps with zones for directional flushing.

Public works staff conduct the flushing, with the involvement of OCWA operators. In the absenceof a directional flushing plan, the method of flushing is based on past practises and experience.

ADDITIONAL FLUSHING

The previous authorizing document, the Certificate of Approval, had required that a chlorineresidual of 0.2 mg/L be achieved throughout the distribution system. This requirement was acondition under 8.1(b)(vi) to provide all necessary works to bring chlorine residual levels in the




DISTRIBUTION SYSTEM

distribution system up to or above the target value of 0.2 mg/L free chlorine. This condition was aresult of one of the recommendations within the First Engineer's Report dated January, 2001.

To comply with this requirement, the owner/operator of the Geraldton water works had taken thefollowing steps:

a) installed a bleeder line at the MTO garage on Hwy 11,

b) instituted an increased flushing program in areas of low usage/demand.

Additional periodic flushing was previously done in the community but since watermains have beenrelined in problem areas, the additional flushing has not been needed for the past two years,except when responding to a complaint related to water quality.

Bleeders are installed at the MTO garage and at the Medical Clinic. Both locations were visited aspart of this inspection and the bleeders were operating at the time.

* Records confirmed that disinfectant residuals were routinely checked at the extremities and"dead ends" of the distribution system.

Disinfectant residuals are checked at various locations around town and some of these locationsare at the extremities and "dead ends" of the system.

As discussed in previous inspection reports the chlorine residual of the water leaving the tower isnot monitored. There is no booster system at the water tower to add chlorine and no recirculationpumps to circulate the water in the tower. When water is being pumped from the water treatmentplant, water flows up into the tower. When the water treatment plant is not producing water, waterflows back out of the tower through the same pipe (and one other pipe) to provide water to thedistribution system. Water in the tower or leaving the tower is not sampled. Sampling of thedrinking water in the tower should occur to ensure a chlorine residual at all times during the cyclingof the tank. Currently the closest sampling location to the tower is at the clinic where a bleeder lineprovides a continual flow. A dry well at the tower has a spot where operators could obtain a samplebut this location is reported to be a confined space and is not used as a sampling location.

Since the chlorine residual of the water leaving the tower is not monitored, addition of a samplinglocation and/or a recirculation pump should be considered.

Some "dead end" areas of town may be less accessible but could be included in the samplingprogram on days that they are available.

* A program was in place for inspecting and exercising valves.

Valves are inspected and exercised when the flushing program is implemented.

* There was a program in place for inspecting and operating hydrants.

This is conducted in conjunction with the watermain flushing program. One hydrant was replacedin the fall.

* There was no by-law or policy in place limiting access to hydrants.

No bylaw restricts access to the fire hydrants.

The Municipality of Greenstone reports that their staff are the only people who use the hydrants.

* The owner has not undertaken efforts to identify, quantify and reduce sources of apparentwater loss.

Leak detection is not done on a proactive basis. Leak detection equipment is available but asreported in the past two inspection reports, staff have not been trained to operate the equipment.




DISTRIBUTION SYSTEM

* The distribution system pressure was monitored to alert the operator of conditions whichmay have lead to loss of pressure below the value under which the system is designed tooperate.

Distribution pressure is measured at the end of the treatment process as the water enters thedistribution system and is also measured at the wastewater treatment plant. The pressure gaugeat the water treatment plant is connected to an alarm to alert the operators of drop in pressure(40psi).

* Based on the records available the owner was not able to maintain proper pressures in thedistribution system.

OLDE ROAD

A dead-end section of the distribution system closest to the water treatment plant experiencesproblems with pressure changes and water hammer. As discussed previously in this report,residents from this area of town continue to raise their concerns about the surges and loss ofpressure in this area.

The Municipality of Greenstone previously purchased the materials to loop this section of thedistribution system and eliminate the dead-end. The work was not completed in 2015 as originallyplanned. The Municipality is reminded to have the necessary engineering and administrative workcompleted (depending on the work a Form 1 may be sufficient) prior to beginning this work.

OPERATIONS MANUALS

Operators and maintenance personnel had ready access to operations and maintenancemanuals.

*

* The operations and maintenance manuals contained plans, drawings and processdescriptions sufficient for the safe and efficient operation of the system.

A number of treatment process changes have taken place in the past two years such as the filter-to-waste process or new alarms/shutdowns associated with the chlorination system and theoperation of high lift pumps. The treatment process descriptions need to be updated.

* The operations and maintenance manuals did not meet the requirements of the Permit andLicence or Approval issued under Part V of the SDWA.

Part 16.1 of the Municipal Drinking Water Licence states that an up-to-date operations andmaintenance manual or manuals shall be made available for reference by all persons responsiblefor all or part of the operation or maintenance of the drinking water system.

The previous past two inspections have noted some shortcomings or errors in Standard OperatingProcedures (SOP). Two years ago it had also been identified that OCWA was planning a review ofthe SOP's and operations manual for the Geraldton Drinking Water System.

Although a couple of new procedures have been created in the past couple of years, revisions andupdating of procedures has not kept-up with changes at the water treatment plant. Aside forupdates, some of the procedures are very minimal and do not provide the operators withinformation that could ensure better operation of the drinking water system and facilitatecompliance.

Following last year's inspection the Municipality of Greenstone and OCWA had been requested toprovide a report indicating what progress has been made with updating and creating StandardOperating Procedures. On June 18, 2015, the response provided by OCWA was that revision ofSOP's is a continual process, and they are living documents and are revised to reflect learning frousing the procedures. The SOP for "Removing a Filter from Service" had been written. Theresponse from OCWA also said that operators review the SOP's on an annual basis, revise ifneeded and develop new ones as required.




OPERATIONS MANUALS

A review of the SOP's that are currently available to the staff show that many of the SOP's have notbeen updated. For example, the "Filter Backwashing" SOP, dated July 26, 2011, has not beenupdated since filter-to-waste was added and since the settling tubes and media were replaced.The procedure does not mention anything about the filter-to-waste cycle and contains out-datedinformation in the "Procedure" section of the SOP. The SOP identifies that air is injected andOperators have communicated that this is no longer part of the procedure.

An example of a procedure that is not adequate is the "Broken Distribution Line" SOP, dated July 4,2011. The procedure states:

1. Contact Town of Geraldton, Superintendant to initiate repairs.

2. Identify areas of low pressure and report adverse conditions if required.

3. Obtain samples for testing as required.

Some of the information that would be reasonable to expect would be that repairs, disinfection,flushing, sampling and chlorine residual measurement need to take place in the distribution systemunder the supervision of an OCWA operator. It is reasonable to expect that the SOP shouldreference the requirements for disinfection of repairs. Such wording might be:

"For watermains that form part of the distribution system, Drinking Water Works Permit (DWWP)Schedule B, Condition 2.3 (“DWWP Condition 2.3”) requires that all parts in contact with drinkingwater which are:

• Added, modified, replaced, extended; or

• Taken out of service for inspection, repair or other activities that may lead to Contamination,

shall be disinfected before being put into service in accordance with the provisions of the AWWAC651 – Standard for Disinfecting Water Mains or an equivalent procedure."

The Standard Operating Procedure, "CT Calculations" provides direction to operators to enter thechlorine residual, flow and reservoir depth into the calculator. Conditions affecting primarydisinfection/CT in the Clearwell are dynamic. The SOP could be improved by providing guidanceto operators to ensure that they are entering values that represents the worst case values duringthe time period of abnormal operations. For example, at other facilities operators are directed totake worst case values during a period of process upset when CT is being confirmed by operatorsperforming a calculation.

LOGBOOKS

* Logs for the drinking water subsystem(s) contained the required information.

Past inspection reports have noted that the logbook does not always contain all the requiredinformation to demonstrate primary disinfection has been maintained at all times. Suggestionshave been provided to ensure complete records of CT calculations.

Operators are reminded that details of equipment failures and actions taken to resolve theproblems must be adequately addressed in the records.

Following the problems noted in the previous inspection report, by April 13, 2015, OCWA wasrequested to provide the undersigned inspector with information to confirm that measures havebeen taken to ensure that complete information related to primary disinfection or CT calculations isbeing recorded.

A letter was received from Larry Wachter, Operations Manager on April 20, 2015, that describedthe following action that was being taken:

"The calculation page of the spreadsheet provided by the engineers is being modified to allow theoperators to print the calculation to log and retain the parameters used for the calculation and theresult of the calculation."

The operators are currently keeping a paper copy of the CT calculation page as a record.




LOGBOOKS

Logbook entries were made in chronological order.*

The record system allowed the reader to unambiguously identify the person who made thelogbook entry.

*

Entries in the logbook were made only by appropriate and authorized personnel.*

Records or other record keeping mechanisms confirmed that operational testing notperformed by continuous monitoring equipment was being done by a certified operator,water quality analyst, or person who suffices the requirements of O. Reg. 170/03 7-5.

*

* For every required operational test and every required sample, a record was not made of thedate, time, location, name of the person conducting the test and result of the test.

A signature or initials are not always recorded along with the chlorine residuals that are measuredin the distribution system. For example, this occurred on February 5, 12, and 27, 2015.

The "Chain of Custody" for the samples submitted to the lab for analysis has a record of the freechlorine residuals and the time the residuals were measured. On a few occasions the free residualwas not recorded on the Chain of Custody. On October 19, 2015, and November 9, 2015, theresiduals for the treated water samples are not recorded on the forms. A record of free chlorineresidual is recorded on the "Geraldton Water Treatment Plant Daily Rounds" sheet but are for adifferent time. No residual was recorded for the sample collected at the Medical Clinic on July 6,2015.

* The operator-in-charge ensured that records were maintained of all adjustments made tothe processes within his or her responsibility.

The limited review allowed in the inspection process did not indicate that records are not beingmade of adjustments made to the process.Logs or other record keeping mechanisms were available for at least five (5) years.*

CONTINGENCY/EMERGENCY PLANNING

* Spill containment was provided for process chemicals and/or standby power generator fuel.

The alum tank is contained within a concrete berm. A floor drain is present within the containment.The operators believe the drain discharges to the Surge Tank. As mentioned previously, the SurgeTank discharges to the sewage lagoon and then to Yvonne Lake.

Spill containment for the polymer and potassium permanganate consisted of the tanks sitting withinlarger diameter plastic tanks.

The diesel fuel for the standby generator is contained within a double walled tank.

* Clean-up equipment and materials were in place for the clean up of spills.

A spill clean-up kit is located in the diesel room at the water treatment plant and at the public worksgarage.




CONTINGENCY/EMERGENCY PLANNING

* Standby power generators were tested under normal load conditions.

The standby diesel generator at the water treatment plant is operated regularly under normal loadconditions.

A portable generator is now available to provide power to the tower in the distribution system. Thegenerator has to be plugged-in by the operator but is an improvement from only having batteryback-up which lasted only 1 to 1.5 hours.

SECURITY

* All storage facilities were completely covered and secure.

Water storage is in the Clearwells beneath the floor of the water treatment plant and in the towerwhich is part of the distribution system.

* Air vents and overflows associated with reservoirs and elevated storage structures wereequipped with screens.

Vents and overflows associated with the elevated storage tank were not observed during thisinspection.

* The owner had provided security measures to protect components of the drinking-watersystem.

The water treatment plant is enclosed within a locked, fenced-in area. The building is alarmed.Operators are at the plant Monday through Friday from 7am to 3:30 pm.

The storage tower in the distribution system has secured doors. The dry-well associated with thetower is locked.

Following problems at the storage tower, a fence was installed in the fall of 2015.CONSUMER RELATIONS

* Water conservation was not being practiced by the owner or operating authority.

Businesses have meters recording their water use. However, there are no community wideconservation initiatives.

* Required documents were available free-of-charge during normal business hours at alocation accessible to the public.

The documents are available at the Geraldton muncipal office.

CERTIFICATION AND TRAINING

* The overall responsible operator had been designated for each subsystem.

The ORO designated for the Geraldton water works is Robert Desjardins, based at the BeardmoreWater Treatment Plant. Gene Ross in Terrace Bay is the back-up ORO.Operators in charge had been designated for all subsystems which comprised the drinking-water system.

*

All activities that were undertaken by uncertified persons in the DW subsystems wereoverseen by persons having the prescribed qualifications.

*




CERTIFICATION AND TRAINING

All operators possessed the required certification.*

* Only certified operators made adjustments to the treatment equipment.

It appears that only certified operators made adjustments to the treatment equipment.

Operator certificates or water quality analyst certificates were displayed in a conspicuouslocation at the workplace or at the premises from which the subsystem was managed.

*

* The classification certificates of the subsystems were conspicuously displayed at theworkplace or at premises from which the subsystem was managed.

System classification certificates are displayed at the water treatment facility.

The Geraldton drinking water system is classified as follows:

Water Treatment, Class II, Certificate no. 593, dated December 4, 2005

Water Distribution, Class I, Certificate no. 1915, dated December 4, 2005

* The owner/operating authority was aware of the operator training and record keepingrequirements, and they were taking reasonable steps to ensure that all operators receivethe required training.

This was not reviewed to any degree during the inspection.

WATER QUALITY MONITORING

* All microbiological water quality monitoring requirements for raw water samples were beingmet.

Records reviewed for the period of January 1, 2015, to January 25, 2016, indicate that weekly rawwater samples were monitored as prescribed.

* All microbiological water quality monitoring requirements for distribution samples were notbeing met.

A review of microbiological sampling in the distribution system finds that for the month of October2015, a total of 12 samples were collected and analyzed for E. coli and total coliforms. However,only one sample was analyzed for heterotrophic plate count, HPC.

In accordance with O. Reg. 170/03, Schedule 10, Section 10-2. (1), the owner of a drinking-watersystem and the operating authority for the system shall ensure that, (a) if the system serves100,000 people or less, at least eight distribution samples, plus one additional distribution samplefor every 1,000 people served by the system, are taken every month, with at least one of thesamples being taken in each week; and (b) if the system serves more than 100,000 people, at least100 distribution samples, plus one additional distribution sample for every 10,000 people served bythe system, are taken every month, with at least three of the samples being taken in each week. (2)The owner of the drinking-water system and the operating authority for the system shall ensure thateach of the samples taken under subsection (1) is tested for, (a) Escherichia coli; and (b) totalcoliforms. (3) The owner of the drinking water system and the operating authority for the systemshall ensure that at least 25 per cent of the samples required to be taken under subsection (1) aretested for general bacteria population expressed as colony counts on a heterotrophic plate count.

* All microbiological water quality monitoring requirements for treated samples were beingmet.

Records of the weekly treated water sampling and anlysis indicates that all the requirements weremet.





* All inorganic water quality monitoring requirements prescribed by legislation wereconducted within the required frequency.

The sampling frequency for inorganic parameters is every 12 months. Inorganic sampling for 2015and 2016 were reviewed as part of this inspection.

Sampling for inorganic parameters in 2015 was conducted on January 26, 2015.

In 2016, samples were collected for analysis on January 18, 2016.

* All organic water quality monitoring requirements prescribed by legislation were conductedwithin the required frequency.

The sampling frequency for organic parameters is every 12 months. Organic sampling for 2015and 2016 were reviewed as part of this inspection.

Due to insufficient sample bottles and then a problem at the lab, sampling for organic parametersin 2015 was conducted on three days: January 26, February 2, and February 9, 2015. Fivechemicals were not included in the analysis: Bromoxynil, Dicamba, 2,4-Dichlorophenoxy aceticacid, Picloram, and 2,4,5-T Trichlorophenoxyacetic acid.

In 2016, samples were collected for analysis on January 18, 2016. The samples collected onJanuary 18, 2016, were analyzed based on the revised Schedule 24 parameters. MCPA wasincluded in the monitoring.

* All trihalomethanes water quality monitoring requirements prescribed by legislation wereconducted within the required frequency.

Quarterly THM samples have been collected as prescribed.

Collection dates and values for this inspection period are as follows:

January 26/15, 74.9 ug/L

April 20/15, 34.3 ug/L

July 6/15, 66.5 ug/L

Oct 5/15, 59.4 ug/L

Jan 18/16, 51.2 ug/L

All of the samples were collected at the MTO garage. Previously sampling locations had alsoincluded the OPP Station and 495 Hardrock.

* Trihalomethane samples were being collected from a point in the distribution system orconnected plumbing system that was likely to have an elevated potential for the formationof trihalomethanes.

In accordance with O. Reg. 170/03, Section 13-6. (1) the owner of a drinking-water system thatprovides chlorination or chloramination and the operating authority for the system shall ensure thatat least one distribution sample is taken every three months, from a point in the drinking-watersystem's distribution system, or plumbing that is connected to the drinking-water system, that islikely to have an elevated potential for the formation of trihalomethanes. (2) The owner of thedrinking-water system and the operating authority for the system shall ensure that each of thesamples taken under subsection (1) is tested for trihalomethanes.

The sampling location for THM's should represent the maximum residence time in the system. Theprevious three inspections reports discussed that the Hardrock sampling location, which is likelythe furthest sampling point and does not have a bleeder line, would be the best location for THMsampling.

Samples reviewed during the previous inspection period had been collected at three locations andthe results were as follows:

January 13/14, 67.2 ug/L @ MTO





April 7/14, 55.7 ug/L @ OPP Station

July 7/14, 74.5 ug/L @ MTO

October 14/14, 111 ug/L @ 495 Hardrock

As noted in last year's inspection report, sample results from the Hardrock sampling loation werefound to contain the highest concentration of THM's, demonstrating that this could be an optimumsampling location for THM's. As areas of the town are purchased for the proposed mine, samplinglocations may need to change.

All of the samples collected in 2015 and for the first quarter of 2016 were collected from the MTOgarage.

* All nitrate/nitrite water quality monitoring requirements prescribed by legislation wereconducted within the required frequency for the DWS.

Quarterly samples were collected on the same days as the samples for nitrites and nitratesanalysis.

* All sodium water quality monitoring requirements prescribed by legislation were conductedwithin the required frequency.

A sample for sodium analysis was collected on January 13, 2014. The sampling frequency forsodium is every 60 months (5 years).

The sample contained 17.8 mg/L of sodium.

* All fluoride water quality monitoring requirements prescribed by legislation were conductedwithin the required frequency.

A sample for fluoride analysis was collected on January 13, 2014. The sampling frequency forfluoride is every 60 months (5 years).

The concentration of fluoride in the sample was less than 0.30 mg/L.The owner ensured that water samples were taken at the prescribed location.*

* All sampling requirements for lead prescribed by schedule 15.1 of O. Reg. 170/03 werebeing met.

Reduced sampling for the purpose of lead analysis was completed on April 11 and 12, 2012, andon October 9 and 10, 2012. Following this the system was eligible for exemption from plumbingsampling.

Drinking water systems that are exempt from collecting plumbing samples must ensure thatsamples are taken in drinking water's distribution system, from at least a number of points set outin Column 5 of the Reduced Table during two consecutive periods (from Dec 15 to Apr 15 and fromJun 15 to Oct 15) in every third 12-month period.

For the 2013 sampling periods, the sampling was reduced to the measurement of pH and alkalinityin the distribution system. These samples were measured in April and October.

In 2014, pH and alkalinity were measured in the distribution system in April, September and againin October due to a problem with the September samples.

In 2015, pH and alkalinity were measured in the distribution system during the two samplingperiods.

* The owner was conducting sampling beyond the minimum legislative requirements.

Additional monitoring is being conducted by the operators as part of their daily rounds. Forexample, raw and treated water are analyzed for colour, alkalinity and managanese. The treatedwater is also analyzed for aluminum residual.





* Records confirmed that chlorine residual tests were being conducted at the same time andat the same location that microbiological samples were obtained.

Missing chlorine residuals was previously discussed in the "Logbook" section of this report.

The drinking water system owner had submitted written notices to the Director thatidentified the laboratories that were conducting tests for parameters required by legislation,Order Certificate of Approval (OWRA) or a Permit, Licence or Approval issued under Part Vof the SDWA.

*

Based on information provided by the owner/operator, samples were being taken andhandled in accordance with instructions provided by the drinking-water system'slaboratories.

*

* The owner indicated that the required records are kept and will be kept for the required timeperiod.

The Municipality of Greenstone is reminded that the Drinking Water Systems Regulation, O. Reg.170/03, specifies the length of time that various records must be kept.

WATER QUALITY ASSESSMENT

* Records show that water sample results taken during the review period met the OntarioDrinking Water Quality Standards (O. Reg. 169/03), with the following exceptions:

Total coliforms were detected in samples collected on July 29, and 31, 2015 from the MNR Office.

Total coliforms were also detected in a sample collected on October 6, 2015, from the South EndVariety.

Schedule 1 of the Ontario Drinking Water Quality Standards. O. Reg. 170/03, requires that Totalcoliforms are not detectable in drinking water.

REPORTING & CORRECTIVE ACTIONS

* All specified corrective actions (as per Schedule 17) were not taken to address adverseconditions.

Total coliforms were detected on two occasions and reported as AWQI's: #125282 on July 28,2015, and #125308 on July 29, 2015. The second AWQI was on the sample collected as part ofthe corrective actions.

The corrective actions required for the presence of total coliforms is to "resample and test". This isfound in the Drinking Water Systems Regulation, O. Reg. 170/03, Schedule 17, Section 17-6.

"Resample and test" is defined in Section 1. (1) of the Drinking Water Systems Regulation andmeans,

"(a) with respect to corrective action that arises from the test of a water sample for amicrobiological parameter, (i) take a set of water samples, at approximately the same time, with,

(A) at least one sample from the same location as the sample that gave rise to the correctiveaction,

(B) at least one sample from a location that is a significant distance upstream from the locationdescribed in sub-subclause (A), if that is reasonable possible, and

(C) at least one sample from a location that is a significant distance downstream from the locationdescribed in sub-subclause (A), if that is reasonably possible, and




REPORTING & CORRECTIVE ACTIONS

(ii) conduct, on the samples taken under subclause (i), the same test that gave rise to thecorrective action."

For AWQI's #125282 and #125308, only one sample, at the location that gave rise to the AWQI,was collected. Upstream and downstream samples were not collected and analyzed for totalcoliforms.

* All required notifications of adverse water quality incidents were immediately provided asper O. Reg. 170/03 16-6.

Since the previous inspection the following Adverse Water Quality Incidents were reported for anumber of repairs to service lines or main lines that required a loss pressure to sections of townwhile repairs were completed. Three reports were also made for the presence of total coliforms insamples collected from the distribution system.All required written notices of adverse water quality incidents were provided as per O. Reg.170/03 16-7.

*

* In instances where written notice of issue resolution was required by regulation, the noticewas provided as per O. Reg. 170/03 16-9.

The previous inspection report had found non-compliance with the requirement to complete theNotice of Issue Resolution forms because a summary of the actions taken were incomplete. TheAWQI discussed in the previous inspection report was for a time when there had been chlorinatoror autodialer problems that had led to the loss of distribution system pressure.

The current inspection review finds that the summary of actions taken for the repair of water linebreaks is minimal. The operators are cautioned that the results of test results are not a completesummary of actions taken and for AWQI's of a more significant nature could be considered as non-compliant.

* Where required continuous monitoring equipment used for the monitoring of chlorineresidual and/or turbidity triggered an alarm or an automatic shut-off, a qualified personresponded in a timely manner and took appropriate actions.

Over the course of the inspection, there was nothing reviewed that indicated an operator is notresponding in a timely manner to an alarm used to monitor the chlorine residual or turbidity.

* The Annual Report containing the required information was prepared by February 28th ofthe following year.

The 2015 Section 11 Annual Report was accessed from the Municipality of Greenstone's websiteand reviewed as part of the inspection. It appears to contain the relevant information. A letteraccompanying the report is dated February 24, 2016. The document was adopted by Councilmotion 16-49 on March 14, 2016.

* Summary Reports for municipal council were completed on time, included the requiredcontent, and were distributed in accordance with the regulatory requirements.

At the time of the inspection review for this report, the 2014 Section 22 Annual Summary Reportwas available on the Municipality of Greenstone's website. A letter accompanying the reportindicates the report was completed by March 17, 2015. The Municipal Council adopted thedocument on April 13, 2015, motion 15-94.

* All changes to the system registration information were not provided within ten (10) days ofthe change.

The contact listed for the facility is a former OCWA employee who has retired.




NON-COMPLIANCE WITH REGULATORY REQUIREMENTS AND ACTIONS REQUIREDThis section provides a summary of all non-compliance with regulatory requirements identified during theinspection period, as well as actions required to address these issues. Further details pertaining to theseitems can be found in the body of the inspection report.

Flow measuring devices were not calibrated or verified in accordance with the requirements of aPermit and Licence or Approval issued under Part V of the SDWA.

The flow meters were verified on July 14, 2015.

The meters were vertified with a reference instrument that had last been calibrated on December 7, 2013.Reference instruments used to confirm the verification of other meters also need to be routinelycalibrated.

A new reference instrument has since been purchased and the instrumentation technician confirmed thatthe reference instrument is now to be calibrated on an annual basis.

Action(s) Required:

1.

Records did not indicate that the treatment equipment was operated in a manner that achieved thedesign capabilities required under Ontario Regulation 170/03 or a Permit, Licence or Approvalissued under Part V of the SDWA at all times that water was being supplied to consumers.

CHLORINATOR FAILURE

On October 5 and 6, 2015, low residuals in the Clearwell was the result of a failure of the chlorinationsystem to provide the chlorine gas required for disinfection while the treatment process was producingwater that was directed to the Clearwell.

Non-compliance with this question is not a reflection on how certified operators operated the plant.Section 1-2. (2) 1. of the Drinking Water System Regulation requires that water treatment equipment is inoperation whenever water is being supplied. Unfortunately the problem with the failure of the chlorinationsystem could not be detected until the chlorine levels in the Clearwell had dropped to a level causing alow level chlorine residual to alarm in the water exiting the Clearwell.

Once the operators were aware of the problem the lines on the chlorinator were changed and the problemwas resolved. The operators purged the Clearwell of water by backwashing filters and wasting waterthrough a hydrant outside the water treatment plant.

The Municipality of Greenstone and OCWA should consider installing a chlorine residual analyzer tomonitor the chlorine residual prior to the Clearwell. This is not a mandatory requirement but a measurethat has been adopted in other treatment plants to ensure that problems with the gas chlorination systemare quickly detected.

Action(s) Required:

2.

Up-to-date plans for the drinking-water system were not available in accordance with the Permitand Licence issued under Part V of the SDWA.

Up-to-date process flow diagrams, process and instrumentation diagrams and record drawings anddiagrams are a requirement of the Municipal Drinking Water Licence.

A "Geraldton WTP P&ID" was recently updated. The new P&ID is dated March 12, 2015.

Alterations and programming of the filter-to-waste modifications were completed in 2014. The Municiplityof Greenstone must ensure that all required diagrams are in place. Record drawings have not beenupdated with the filter-to-waste modification to the filtration processes.

By July 4, 2016, the Municipality of Greenstone shall provide to the undersigned inspector a copy of theupdated record drawing for the Geraldton water treatment plant.

Action(s) Required:

3.




The operations and maintenance manuals did not meet the requirements of the Permit andLicence or Approval issued under Part V of the SDWA.

The previous past two inspections have noted some shortcomings or errors in Standard OperatingProcedures (SOP). Two years ago it had also been identified that OCWA was planning a review of theSOP's and operations manual for the Geraldton Drinking Water System.

Although a couple of new procedures have been created in the past couple of years, revisions andupdating of procedures has not kept-up with changes at the water treatment plant. Aside for updates,some of the procedures are very minimal and do not provide the operators with information that couldensure better operation of the drinking water system and facilitate compliance.

A review of the SOP's that are currently available to the staff show that many of the SOP's have not beenupdated. For example, the "Filter Backwashing" SOP, dated July 26, 2011, has not been updated sincefilter-to-waste was added and since the settling tubes and media were replaced. The procedure does notmention anything about the filter-to-waste cycle and contains out-dated information in the "Procedure"section of the SOP. The SOP identifies that air is injected and Operators have communicated that this isno longer part of the procedure.

By July 4, 2016, the Municipality of Greenstone shall provide the undersigned inspector with a report onthe progress of updating Standard Operating Procedures.

Action(s) Required:

4.

For every required operational test and every required sample, a record was not made of the date,time, location, name of the person conducting the test and result of the test.

A signature or initials are not always recorded along with the chlorine residuals that are measured in thedistribution system. For example, this occurred on February 5, 12, and 27, 2015.

The "Chain of Custody" for the samples submitted to the lab for analysis has a record of the free chlorineresiduals and the time the residuals were measured. On a few occasions the free residual was notrecorded on the Chain of Custody. On October 19, 2015, and November 9, 2015, the residuals for thetreated water samples are not recorded on the forms. A record of free chlorine residual is recorded on the"Geraldton Water Treatment Plant Daily Rounds" sheet but are for a different time. No residual wasrecorded for the sample collected at the Medical Clinic on July 6, 2015.

This requirement was reviewed with the OIC at the time of the inspection.

No futher action is required unless the operating authority feels it is warranted.

Action(s) Required:

5.

All microbiological water quality monitoring requirements for distribution samples were not beingmet.

A review of microbiological sampling in the distribution system finds that for the month of October 2015, atotal of 12 samples were collected and analyzed for E. coli and total coliforms. However, only one samplewas analyzed for heterotrophic plate count, HPC.

The operating authority should assess whether there are any measures that need to be taken to ensurethat all of the required bacteriological analysis is completed.

Action(s) Required:

6.

All specified corrective actions (as per Schedule 17) were not taken to address adverseconditions.

Total coliforms were detected on two occasions and reported as AWQI's: #125282 on July 28, 2015, and#125308 on July 29, 2015. The second AWQI was on the sample collected as part of the correctiveactions.

The corrective actions required for the presence of total coliforms is to "resample and test". This is foundin the Drinking Water Systems Regulation, O. Reg. 170/03, Schedule 17, Section 17-6.

"Resample and test" is defined in Section 1. (1) of the Drinking Water Systems Regulation and means,

7.




"(a) with respect to corrective action that arises from the test of a water sample for a microbiologicalparameter, (i) take a set of water samples, at approximately the same time, with,

(A) at least one sample from the same location as the sample that gave rise to the corrective action,

(B) at least one sample from a location that is a significant distance upstream from the location describedin sub-subclause (A), if that is reasonable possible, and

(C) at least one sample from a location that is a significant distance downstream from the locationdescribed in sub-subclause (A), if that is reasonably possible, and

(ii) conduct, on the samples taken under subclause (i), the same test that gave rise to the correctiveaction."

For AWQI's #125282 and #125308, only one sample, at the location that gave rise to the AWQI, wascollected. Upstream and downstream samples were not collected and analyzed for total coliforms.

Total coliforms were detected in a sample collected from the distribution system and reported as AWQI#126795 on October 8, 2015. The corrective actions that were taken to resolve this incident includedcollecting a sample from the site that had contained total coliforms as well as from two additional samplinglocations. The undersigned inspector assumes that these locations were up and down stream from thesite of the adverse sample.

It appears that resampling and testing is now being done properly. No further action required at this time.

Action(s) Required:

All changes to the system registration information were not provided within ten (10) days of thechange.

The contact listed for the facility is a former OCWA employee who has retired.

The Municipality of Greenstone must update the contact information and forward the undersignedinspector an email notification upon completion of this task.

Action(s) Required:

8.




SUMMARY OF RECOMMENDATIONS AND BEST PRACTICE ISSUESThis section provides a summary of all recommendations and best practice issues identified during theinspection period. Details pertaining to these items can be found in the body of the inspection report. In theinterest of continuous improvement in the interim, it is recommended that owners and operators develop anawareness of the following issues and consider measures to address them.

There is no backflow prevention program, policy and/or bylaw in place.

On February 10, 2016, the bleeder line located at the medical clinic was inspected with the assistance ofTom Bull, from the Geraldton District Hospital. The bleeder line was in use at the time. The end of thecopper line extended down into a hole in the floor and two other lines from equipment in the roomdischarge into the same location. The end of the bleeder line extended quite far into the floor drain andcould not be reached by inserting a hand down into the floor drain. The use of an air gap or backflowpreventer was discussed as means to prevent inadvertent contamination of the drinking water systemsuch as during a negative pressure event in the distribution system.

The Municipality of Greenstone may want to consider a backflow prevention program that addresses theuse of backflow preventers in higher risk areas (eg. car wash, industry, hospital) or as a requirement fornew construction in the community.

Mr. Bull indicated that he would modify the bleeder line and forward a picture to the undersignedinspector. UPDATE: This work was completed.

The Public Works Supervisor, Rob Cyr, has confirmed that once the snow has thawed he will check thebleeder line at MTO to assess whether a backflow preventer or air gap is needed.

Recommendation:

1.

The owner had not implemented a program for the flushing of watermains as per industrystandards.

FLUSHING PROGRAM

Flushing of the system was done in the spring, June 8 to 15, 2015, and the fall, August 21 to September9, 2015.

A "Flushing and Disinfection - Watermains" procedure is available for the distribution system in Geraldton.The procedure discusses notifying people, flushing, measuring residuals, and so on. It does not containmaps with zones for directional flushing.

Public works staff conduct the flushing, with the involvement of OCWA operators. In the absence of adirectional flushing plan, the method of flushing is based on past practises and experience.

ADDITIONAL FLUSHING

The previous authorizing document, the Certificate of Approval, had required that a chlorine residual of0.2 mg/L be achieved throughout the distribution system. This requirement was a condition under8.1(b)(vi) to provide all necessary works to bring chlorine residual levels in the distribution system up to orabove the target value of 0.2 mg/L free chlorine. This condition was a result of one of therecommendations within the First Engineer's Report dated January, 2001.

To comply with this requirement, the owner/operator of the Geraldton water works had taken the followingsteps:

a) installed a bleeder line at the MTO garage on Hwy 11,

b) instituted an increased flushing program in areas of low usage/demand.

Additional periodic flushing was previously done in the community but since watermains have beenrelined in problem areas, the additional flushing has not been needed for the past two years, except whenresponding to a complaint related to water quality.

2.




Bleeders are installed at the MTO garage and at the Medical Clinic. Both locations were visited as part ofthis inspection and the bleeders were operating at the time.

The Municipality of Greenstone can use the "American Water Works Association (AWWA) StandardG200-09 Distribution System Operation and Management Section 4.1.8 System Flushing" to develop aformal flushing program.

Recommendation:

There was no by-law or policy in place limiting access to hydrants.

No bylaw restricts access to the fire hydrants.



No further actions are required at this time.

Recommendation:

3.

The owner has not undertaken efforts to identify, quantify and reduce sources of apparent waterloss.

Leak detection is not done on a proactive basis. Leak detection equipment is available but as reported inthe past two inspection reports, staff have not been trained to operate the equipment.

It is recommend that the Muncipality of Greenstone provide staff with training to operate the leak detectionequipment.

Recommendation:

4.

Based on the records available the owner was not able to maintain proper pressures in thedistribution system.

OLDE ROAD

A dead-end section of the distribution system closest to the water treatment plant experiences problemswith pressure changes and water hammer. As discussed previously in this report, residents from this areaof town continue to raise their concerns about the surges and loss of pressure in this area.

The Municipality of Greenstone previously purchased the materials to loop this section of the distributionsystem and eliminate the dead-end. The work was not completed in 2015 as originally planned.

OLDE ROAD

The Municipality is reminded to have the necessary engineering and administrative work completed(depending on the work a Form 1 may be sufficient) prior to beginning this work.

Recommendation:

5.

Water conservation was not being practiced by the owner or operating authority.

Businesses have meters recording their water use. However, there are no community wide conservationinitiatives.

There are no recommendations at this time.Recommendation:

6.




SIGNATURES

Inspected By: Signature: (Provincial Officer):

Pamela Cowie

Reviewed & Approved By: Signature: (Supervisor):

Dave Manol

Review & Approval Date: 07/04/2016 (dd/mm/yyyy)

Note: This inspection does not in any way suggest that there is or has been compliance withapplicable legislation and regulations as they apply or may apply to this facility. It is, and remains,the responsibility of the owner and/or operating authority to ensure compliance with all applicablelegislative and regulatory requirements.





Drinking Water Inspection Report

APPENDIX A

STAKEHOLDER APPENDIX

Key Reference and Guidance Material for Municipal Residential Drinking Water SystemsMany useful materials are posted on the Ministry of the Environment’s Drinking Water Ontario website at www.ontario.ca/drinkingwater to help in the operation of your drinking water system.

Below is a list of key materials frequently used by owners and operators of municipal drinking water systems. To read or download these materials, go to Drinking Water Ontario and search in the Resources section by Publication Number.

Visit Drinking Water Ontario for more useful materials. Contact the Public Information Centre if you need assistance or have questions at 1-800-565-4923/416-325-4000 or [email protected].

PIBS 8990b

June 2012

ontario.ca/drinkingwater

PUBLICATION NUMBER PUBLICATION TITLE

4448e01 Procedure for Disinfection of Drinking Water in Ontario

7152eStrategies for Minimizing the Disinfection Products Trihalomethanes and Haloacetic Acids

7467 Filtration Processes Technical Bulletin

7685 Ultraviolet Disinfection Technical Bulletin

8215 Total Trihalomethane (TTHM) Reporting Requirements Technical Bulletin (February 2011)

2601e Overview Guide: Municipal Drinking Water Licensing Program

0000 Municipal Drinking Water Licensing Program Bulletin, Issue 1, January 2011

0000 Certification Guide for Operators and Water Quality Analysts

6560e Taking Samples for the Community Lead Testing Program

7423eCommunity Sampling and Testing for Lead: Standard and Reduced Sampling and Eligibility for Exemption

7128e Drinking Water System Contact List

4449e01 Technical Support Document for Ontario Drinking Water Quality Standards

http://www.ontario.ca/drinkingwater



mailto:[email protected]

http://www.ene.gov.on.ca/stdprodconsume/groups/lr/@ene/@resources/documents/resource/std01_079706.pdf






















http://www.ene.gov.on.ca/environment/en/resources/STDPROD_095161.html

http://www.ene.gov.on.ca/environment/en/resources/STD01_076295.html

http://www.ene.gov.on.ca/environment/dwo/index.htm

Principaux guides et documents de référence sur les réseaux résidentiels municipaux d’eau potable Beaucoup de documentation sur le fonctionnement d’un réseau d’eau potable se trouve sur le site Web du ministère de l’Environnement.

Vous trouverez ci-dessous la liste des principaux documents que les propriétaires et les exploitants de réseaux municipaux d’eau potable utilisent fréquemment. Pour lire ou télécharger ces documents, allez sur le site Web du Ministère, et effectuez une recherche par numéro de publication dans la section RESSOURCES.

Consultez le site d’Eau potable Ontario pour obtenir d’autre documentation. Communiquez avec le Centre d’information du public au 1 800 565-4923

PIBS 8990b

Juin 2012


NUMÉRO DE PUBLICATION TITRE DE LA PUBLICATION

4448f01 Marche à suivre pour désinfecter l'eau portable en Ontario

7152eStrategies for Minimizing the Disinfection Products Trihalomethanes and Haloacetic Acids (en anglais seulement)

7467 Filtration Processes Technical Bulletin (en anglais seulement)7685 Ultraviolet Disinfection Technical Bulletin (en anglais seulement)

8215Total Trihalomethane (TTHM) Reporting Requirements Technical Bulletin (février 2011) (en anglais seulement)

2601fGuide général - Programme de délivrance des permis de réseaux municipaux d’eau potable

0000Bulletin du Programme des permis de réseaux municipaux d'eau potable, numéro 1, janvier 2011

0000Guide sur l'accréditation des exploitants de réseaux d'eau potable et des analystes de la qualité de l'eau de réseaux d'eau potable

6560fPrélèvement d’échantillons dans le cadre du programme d’analyse de la teneur en plomb de l’eau dans les collectivités

7423fÉchantillonnage et analyse du plomb dans les collectivités : échantillonnage normalisé ou réduit et admissibilité à l’exemption

7128f Liste des personnes-ressources du réseau d’eau potable

4449f01Document d’aide technique pour les normes, directives et objectifs associés à la qualité de l’eau potable en Ontario

ou au 416 325-4000, ou encore à [email protected] si vous avez des questions ou besoin d’aide.

http://www.ene.gov.on.ca/environment/dwo/fr/index.htm

http://www.ene.gov.on.ca/environment/dwo/fr/index.htm

http://www.ene.gov.on.ca/stdprodconsume/groups/lr/@ene/@resources/documents/resource/stdprod_095800.pdf



























http://www.ene.gov.on.ca/environment/fr/resources/STD01_077336.html

http://www.ene.gov.on.ca/environment/dwo/index.htm


Drinking Water Inspection Report

APPENDIX B

INSPECTION RATING RECORD

Ministry of the Environment - Inspection Summary Rating Record (Reporting Year - 2015-2016)

DWS Name: GERALDTON DRINKING WATER SYSTEMDWS Number: 210000292

DWS Owner: Greenstone, The Corporation Of The Municipality OfMunicipal Location: Greenstone

Regulation: O.REG 170/03Category: Large Municipal Residential System

Type Of Inspection: DetailedInspection Date: February 10, 2016

Ministry Office: Thunder Bay District

Maximum Question Rating: 739

Inspection Module Non-Compliance Rating

Permit To Take Water 0 / 30

Capacity Assessment 8 / 38

Treatment Processes 25 / 103

Process Wastewater 0 / 20

Distribution System 0 / 25

Operations Manuals 14 / 42

Logbooks 4 / 42

Consumer Relations 0 / 4

Certification and Training 0 / 58

Water Quality Monitoring 21 / 148

Reporting & Corrective Actions 28 / 88

Treatment Process Monitoring 0 / 141

TOTAL 100 / 739

Inspection Risk Rating 13.53%

FINAL INSPECTION RATING: 86.47%

Inspection Rating Record Generated On 07-APR-16 (Inspection ID: 1-C5GKD).R:\Public\DW\DW-08 Compliance\Shared Comp Data\Inspection Ratings 1516\Dave Manol\1516 GERALDTON DRINKING WATER SYSTEM 1-C5GKD.pdf

Ministry of the Environment - Detailed Inspection Rating Record (Reporting Year - 2015-2016)

DWS Name: GERALDTON DRINKING WATER SYSTEMDWS Number: 210000292

DWS Owner: Greenstone, The Corporation Of The Municipality OfMunicipal Location: Greenstone

Regulation: O.REG 170/03Category: Large Municipal Residential System

Type Of Inspection: DetailedInspection Date: February 10, 2016

Ministry Office: Thunder Bay District

Non-compliant Question(s) Question Rating

Capacity Assessment

Are the flow measuring devices calibrated or verified in accordance with the requirements of a Permit and Licence or Approval issued under Part V of the SDWA?

8

Logbooks

For every required operational test and for every required sample, is a record made of the date, time, location, name of the person conducting the test and result of the test?

4

Operations Manuals

Do the operations and maintenance manuals meet the requirements of the Permit and Licence or Approval issued under Part V of the SDWA?

14

Reporting & Corrective Actions

Have corrective actions (as per Schedule 17) been taken to address adverse conditions, including any other steps as directed by the Medical Officer of Health?

24

Have all changes to the system registration information been provided to the Ministry within ten (10) days of the change?

4

Treatment Processes

Do records indicate that the treatment equipment was operated in a manner that achieved the design capabilities required under Ontario Regulation 170/03 or a Permit, Licence or Approval issued under Part V of the SDWA at all times that water was being supplied to consumers?

21

Are up-to-date plans for the drinking-water system kept in a place, or made available in such a manner, that they may be readily viewed by all persons responsible for all or part of the operation of the drinking water system in accordance with the Permit and Licence issued under Part V of the SDWA?

4

Water Quality Monitoring

Are all microbiological water quality monitoring requirements for distribution samples being met? 21

TOTAL QUESTION RATING 100

Maximum Question Rating: 739

Inspection Risk Rating 13.53%


Ministry of the Environment - Detailed Inspection Rating Record (Reporting Year - 2015-2016)

FINAL INSPECTION RATING: 86.47%


APPLICATION OF THE

RISK METHODOLOGY USED FOR MEASURING MUNICIPAL RESIDENTIAL DRINKING WATER SYSTEM INSPECTION RESULTS

The Ministry of the Environment (MOE) has a rigorous and comprehensive inspection program for municipal residential drinking water systems (MRDWS). Its objective is to determine the compli-ance of MRDWS with requirements under the Safe Drinking Water Act and associated regulations. It is the responsibility of the municipal residen-tial drinking water system owner to ensure their drinking water systems are in compliance with all applicable legal requirements.

This document describes the risk rating methodol-ogy, which has been applied to the findings of the Ministry’s MRDWS inspection results since fiscal year 2008-09. The primary goals of this assessment

are to encourage ongoing improvement of these sys-tems and to establish a way to measure this progress.

MOE reviews the risk rating methodology every three years to account for legislative and societal changes that affect acceptable risk levels. As a re-sult of the most recent review, the methodology has been modified to present an improved metric for the evaluation of the risk/safety of MRDWS operations.

The Ministry’s Municipal Residential Drinking Water Inspection Protocol contains up to 14 in-spection modules and consists of approximately 120 regulatory questions. Those protocol ques-tions are also linked to definitive guidance that

PIBS 6797e

July 2011

Revised March 2010


2 APPLICATION OF RISK METHODOLOGY

ministry inspectors use when conducting MRDWS

inspections. The questions address a wide range of

regulatory issues, from administrative procedures

to drinking water quality monitoring. Additionally,

the inspection protocol contains a number of non-

regulatory questions.

A team of drinking water specialists in the ministry

have assessed each of the inspection protocol regula-

tory questions to determine the risk (not complying

with the regulation) to the delivery of safe drinking

water. This assessment was based on established

provincial risk assessment principles, with each

question receiving a risk rating referred to as the

Question Risk Rating. Based on the number of areas

where a system is deemed to be non-compliant dur-

ing the inspection, and the significance of these areas

to administrative, environmental, and health conse-

quences, a risk-based inspection rating is calculated

by the ministry for each drinking water system.

It is important to be aware that an inspection rating

that is less than 100 per cent does not mean that the

drinking water from the system is unsafe. It shows

areas where a system’s operation can improve. To

that end, the ministry works with owners and opera-

tors of systems to make sure they know what they

need to do to achieve full compliance.

The inspection rating reflects the inspection results

of the specific drinking water system for the report-

ing year. Since the methodology is applied consis-

tently over a period of years, it serves as a compara-

tive measure both provincially and in relation to the

individual system. Both the drinking water system

and the public are able to track the performance over

time, which encourages continuous improvement

and allows systems to identify specific areas requir-

ing attention.

The ministry’s annual inspection program is an im-

portant aspect of our drinking water safety net. The

ministry and its partners share a common commit-

ment to excellence and we continue to work toward

the goal of 100 per cent regulatory compliance.

Determining Potential to Compromise the Delivery of Safe Water

The risk management approach used for MRDWS is aligned with the Government of Ontario’s Risk Management Framework. Risk management is a sys-tematic approach to identifying potential hazards; understanding the likelihood and consequences of the hazards; and taking steps to reduce their risk if necessary and as appropriate.

The Risk Management Framework provides a formu-la to be used in the determination of risk:

Every regulatory question in the inspection proto-col possesses a likelihood value (L) for an assigned consequence value (C) as described in Table 1 and Table 2.

TABLE 1:

Likelihood of Consequence Occurring Likelihood Value

0% - 0.99% (Possible but Highly Unlikely) L = 0

1 – 10% (Unlikely) L = 1

11 – 49% (Possible) L = 2

50 – 89% (Likely) L = 3

90 – 100% (Almost Certain) L = 4

TABLE 2:

Consequence Consequence Value

Medium Administrative Consequence C = 1

Major Administrative Consequence C = 2

Minor Environmental Consequence C = 3

Minor Health Consequence C = 4

Medium Environmental Consequence C = 5

Major Environmental Consequence C = 6

Medium Health Consequence C = 7

Major Health Consequence C = 8

RISK = LIKELIHOOD × CONSEQUENCE(of the consequence)

3APPLICATION OF RISK METHODOLOGY

The consequence values (0 through 8) are selected to align with other risk-based programs and projects currently under development or in use within the ministry as outlined in Table 2.

The Question Risk Rating for each regulatory in-spection question is derived from an evaluation of every identified consequence and its correspond-ing likelihood of occurrence:

• All levels of consequence are evaluated for their potential to occur

• Greatest of all the combinations is selected.

TABLE 3:

Does the Operator in Charge ensure that the equipment and processes are monitored, inspected and evaluated?

Risk = Likelihood × Consequence

C=1 C=2 C=3 C=4 C=5 C=6 C=7 C=8

MediumAdministrativeConsequence

MajorAdministrativeConsequence

MinorEnvironmentalConsequence

MinorHealth

Consequence

MediumEnvironmentalConsequence

MajorEnvironmentalConsequence

MediumHealth

Consequence

MajorHealth

Consequence

L=4(Almost Certain)

L=1(Unlikely

L=2(Possible)

L=3(Likely)

L=3(Likely)

L=1(Unlikely

L=3(Likely)

L=2(Possible)

R=4 R=2 R=6 R=12 R=15 R=6 R=21 R=16

Application of the Methodology to Inspection Results

The Question Risk Rating quantifies the risk of non-compliance of each question relative to the others. Questions with higher values are those with a potentially more significant impact on drinking water safety and a higher likelihood of occurrence. The highest possible value would be 32 (4×8) and the lowest would be 0 (0×1).

Table 3 presents a sample question showing the risk rating determination process.

Based on the results of a MRDWS inspection, an overall inspection risk rating is calculated. During an inspection, inspectors answer the questions that relate to regulatory compliance and input their responses as “yes”, “no” or “not applicable” into the Ministry’s Laboratory and Waterworks Inspection System (LWIS) database. A “no” response indicates non-compliance. The maximum number of regulatory questions asked by an inspector varies by: system (i.e., distribution, stand-alone), type of inspection (i.e., focused, detailed), and source type (i.e., groundwater, surface water).

The risk ratings of all non-compliant answers are summed and divided by the sum of the risk ratings of all questions asked (maximum question rating). The resulting inspection risk rating (as a percentage) is subtracted from 100 per cent to arrive at the final inspection rating.

4 APPLICATION OF RISK METHODOLOGY

1. Source

2. Permit to Take Water

3. Capacity Assessment

4. Treatment Processes

5. Process Wastewater

6. Distribution System

7. Operations Manuals

8. Logbooks

9. Contingency and Emergency Planning

10. Consumer Relations

11. Certification and Training

12. Water Quality Monitoring

13. Reporting, Notification and Corrective Actions

14. Other Inspection Findings

For further information, please visit www.ontario.ca/drinkingwater

Figure 1: Year Over Year Distribution of MRDWS Ratings

Application of the Methodology for Public Reporting

Reporting Results to MRDWS Owners/OperatorsA summary of inspection findings for each system is generated in the form of an Inspection Rating Record (IRR). The findings are grouped into the 14 possible modules of the inspection protocol,

0

100

200

300

400

500

600

700

YEAR A YEAR B YEAR C YEAR D YEAR E 100% Rating

NU

MB

ER

OF

IN

SP

EC

TIO

N R

ATIN

GS

>95% to 100%>90% to 95%>85% to 90%>50% to 80% >80% to 85%

512 538 572 586 585

137 117 92 77 75

18 13 5 7 7 12 16 8 12 933 26 22 18 17

233

281

349344 406

279257

223242

179

5% RATING BANDING BY YEAR

which would provide the system owner/operator with information on the areas where they need to improve. The 14 modules are:

The individual MRDWS Total Inspection Ratings are published with the ministry’s Chief Drinking Water Inspector’s Annual Report.

Figure 1 presents the distribution of MRDWS rat-ings for a sample of annual inspections. Individual drinking water systems can compare against all the other inspected facilities over a period of inspection years.

ministry of the environment ministère de l’environnement

Documents