The Corporation of the Township of Armstrong. OPERATIONAL PLAN for the Earlton Drinking Water System

Transcription

1 The Corporation of the Township of Armstrong OPERATIONAL PLAN for the Earlton Drinking Water System Revision 1, April 25, 2012

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3 OPERATIONAL PLAN Revision 1, Earlton Drinking Water System Owned and operated by the Corporation of the Township of Armstrong This Operational Plan defines and documents the Quality Management System (QMS) for the Earlton Drinking Water System owned and operated by the Corporation of the Township of Armstrong. It sets out the Township of Armstrong s policies and procedures with respect to quality and environmental management in accordance with the requirements of the Province of Ontario s Drinking Water Quality Management Standard (DWQMS). Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 1 of 18

4 Corporation of the Township of Armstrong Earlton Drinking Water System OPERATIONAL PLAN REVISION HISTORY Date Revision Description of Revision Operational Plan issued Revised QMS Policy section; replaced continuous improvement with continual improvement to be more consistent with language in the Standard; updated Village of Earlton population as surveyed by the Public Works Department on February 16, 2012; added description for the Airport Road Subdivision in section 6; revised competencies table to reflect skills and knowledge required as per standard job descriptions in section 10; added list of tables, list of figures and list of acronyms & abbreviations Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 2 of 19

5 Corporation of the Township of Armstrong Earlton Drinking Water System TABLE OF CONTENTS 1 Quality Management System (QMS) Quality Management System (QMS) Policy Commitment & Endorsement of QMS & Operational Plan Quality Management System Representative Document and Records Control Drinking Water System Risk Assessment Risk Assessment Outcomes Organizational Structure, Roles, Responsibilities and Authorities Competencies Personnel Coverage Communications Essential Supplies and Services Review and Provision of Infrastructure Infrastructure Maintenance, Rehabilitation and Renewal Sampling, Testing and Monitoring Measurement and Recording Equipment Calibration and Maintenance Emergency Management Internal QMS Audits Management Review Continual Improvement Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 3 of 19

6 Corporation of the Township of Armstrong Earlton Drinking Water System LIST OF APPENDICES Appendix A QP-01 Document and Records Control Appendix B QP-02 Risk Assessment and Risk Assessment Outcomes Appendix C QMS Organizational Structure for the Earlton Drinking Water System Appendix D QP-03 Personnel Coverage Appendix E QP-04 Communications Appendix F QP-05 Essential Supplies and Services Appendix G QP-06 Review and Provision of Infrastructure Appendix H QP-07 Sampling, Testing and Monitoring Appendix I QP-08 Measurement and Recording Equipment Calibration and Maintenance Appendix J QP-09 Emergency Management Appendix K QP-10 Internal QMS Audits Appendix L QP-11 Management Review Appendix M Subject System Description Form (Schedule C) LIST OF TABLES Table A Well No. 1 Raw Water Characteristics (based on 2009 data) Table B Well No. 3 Raw Water Characteristics (based on 2009 data) Table C Well No. 4 Raw Water Characteristics (based on 2009 data) Table D QMS Roles, Responsibilities and Authorities Table E Competencies LIST OF FIGURES Figure 1 Process Flow Chart Figure 2 Distribution System Map Figure 3 Airport Road Subdivision Map Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 4 of 19

7 Corporation of the Township of Armstrong Earlton Drinking Water System LIST OF ACRONYMS AND ABBREVIATIONS ANSI American National Standards Institute AWQI Adverse Water Quality Indicator AWWA American Water Works Association CAR Corrective Action Report CCP Critical Control Point CEU Continuing Education Units CFU Coliform Forming Units CT Concentration of disinfectant residual x Contact Time DWQMS Drinking Water Quality Management Standard DWWP Drinking Water Works Permit DWS Drinking-Water System EC Electronic Copy EEP Environmental Emergency Procedure GUDI Groundwater Under the Direct Influence of Surface Water HC Hard Copy HLP High Lift Pump LMRS Large Municipal Residential System MDWL Municipal Drinking Water Licence MOE Ministry of Environment MOH Ministry of Health MOIR Monthly Operations Report NEO Northeastern Ontario No. Number NSF National Sanitation Foundation NTU Nephelometric Turbidity Units O. Reg. Ontario Regulation OCWA Ontario Clean Water Agency OIC Operator-In-Charge OIT Operator-In-Training ORO Overall Responsible Operator PLC Progammable Logic Controller PVC Polyaluminimum chloride QMS Quality Management System QP Quality Procedure Rep Representative SCADA Supervisory Control and Data Acquisition SDWA Safe Drinking Water Act SOP Standard Operating Procedure WHMIS Workplace Hazardous Materials Information System WMS Work Management System WTP Water Treatment Plant Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 5 of 19

8 Corporation of the Township of Armstrong Earlton Drinking Water System 1 Quality Management System The Township of Armstrong s Quality Management System (QMS) is structured and documented with the purpose of: 1. Establishing policy and objectives with respect to the effective management and operation of the drinking water system; 2. Understanding and controlling the risks associated with the drinking water systems activities and processes; and 3. Achieving continual improvement of the QMS and performance of the drinking water system. 2 Quality Management System Policy The Quality Management System (QMS) Policy applies to all staff involved with the operation of the Earlton Drinking Water System. This includes staff at the Township of Armstrong Office, the Village of Earlton s Utilities Department and the Ontario Clean Water Agency. The staff involved with the operation of the Earlton Drinking Water System shall: Provide consumers with a supply of safe drinking water. Maintain and continually improve upon its Quality Management System. Operate and maintain the drinking water system to meet or surpass applicable legislation and regulations. Communicate the Policy to the owner, public and staff. Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 6 of 19

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10 Corporation of the Township of Armstrong Earlton Drinking Water System 4 Quality Management System Representative The QMS Representatives for the Earlton Drinking Water System are the Village of Earlton Utilities Superintendent and Utilities Chief Operator. The QMS Representatives are responsible for: Reporting on QMS performance and identifying opportunities for improvement, Ensuring that current versions of documents related to the QMS are in use, and Ensuring personnel are aware of all applicable legislative and regulatory requirements that pertain to their operational duties. All personnel involved with the operation of the Earlton Drinking Water System have roles and associated responsibilities within the Township of Armstrong s QMS. 5 Document and Records Control Refer to Appendix A for QMS Procedure QP-01 Document and Records Control. 6 Drinking Water System Description of the Corporation of the Township of Armstrong - Earlton Drinking Water System The Earlton Drinking Water System is owned by the Corporation of the Township of Armstrong and supplies drinking water to the Village of Earlton. The Village of Earlton is owned, managed and located within the Township of Armstrong. The Drinking Water Treatment and Distribution Systems are operated by the Village of Earlton s Utilities Department. The Ontario Clean Water Agency (OCWA) is contracted to provide overall responsible operator services, complete instrumentation calibrations, support maintenance system scheduling and completion, and provide additional services as requested. This subject system is not interconnected to any other drinking-water systems owned by different owners. There are no critical upstream or downstream processes relied upon to ensure the provision of safe drinking water. The following details pertain to the Earlton Drinking Water System and are based on information provided in Drinking Water Works Permit No (dated May 31, 2011), the First Engineer s Report for Village of Earlton Water Works (dated November 2000) and the Water Well Record. The Earlton Water Treatment Plant, built in 1993, draws raw water for the municipal system from three separate drilled wells. Well 1 is the original well, drilled 178 m into limestone/bedrock formation. The well is double-cased, equipped with a submersible pump rated at 3.0 L/s, a magnetic flow meter and a sodium hypochlorite disinfection system. Pump controls and other associated equipment are contained within a pump station located at 10 Twelfth Avenue, and the wellhead is located approximately 3 m to the west of the pump station. Raw water is prechlorinated and pumped directly to the water treatment plant via 150 mm PVC transmission main that is common to Wells 1 and 3. Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 8 of 19

11 Corporation of the Township of Armstrong Earlton Drinking Water System Well 3 is double-case constructed, drilled 151 m into a limestone/bedrock formation. The well is equipped with a submersible pump with a rated capacity of 9.0 L/s, a magnetic flow meter and a sodium hypochlorite disinfection system. Pump controls and other associated equipment are contained within a pump station located at 35 Sixth Street, and the wellhead is located approximately 2.5 m to the west of the pump station. Pre-chlorinated raw water is pumped directly to the water treatment plant via 150 mm PVC transmission main that is common to Wells 1 and 3. Well 4 is also double-case constructed, drilled to a depth of m into limestone/bedrock. It is equipped with a submersible pump with a rated capacity of 3.0 L/s. The well head is located within the fenced enclosure adjacent to the west side of the treatment plant building. Raw water is pumped directly to the water treatment plant via 150 mm PVC transmission line. The treatment system contains chemically assisted filtration consisting of ferric sulphate coagulation, twin upflow clarifiers and gravity filtration units. Filter backwashes include scour and filter-to-waste capability. Sodium hypochlorite is used for primary and secondary disinfection. The system has the option of pre and post treatment injection points. Treated water is sent into twin in-ground reservoirs, each having a capacity of 559 m 3. Water is sent into the distribution system via three submersible high lift pumps. One vertical turbine fire system pump is also available for emergency situations. Residue management system is in place for the separation of water from sludge. The wastewater is decanted to the storm sewer system and the sludge is hauled and disposed of in the township s wastewater lagoon. The water treatment process is controlled by a dedicated PLC and monitored through the SCADA computer system. Operators review certain parameters within 72 hours. Standby power is available from the 150 kw diesel engine generator with transfer switch assembly. The distribution system services a population of approximately 832 people through an estimated 340 residential service connections. In 2011, Airport Road Subdivision was built which provides service connections on 23 lots. Based on the number of service connections the system is classified as a Large Municipal Residential Drinking Water System. The core of the distribution system was originally installed in Currently there is approximately 10 km of plastic (PVC) water main ranging in size from 100 mm to 150 mm in diameter. A review of distribution system drawings indicated that there are approximately 42 fire hydrants. This distribution system was designed to service a future population of There are no water storage facilities in the distribution system, as storage is incorporated within the treatment plant. Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 9 of 19

12 Corporation of the Township of Armstrong Earlton Drinking Water System Figure 1 - Process Flow Chart Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 10 of 18

13 Corporation of the Township of Armstrong Earlton Drinking Water System Figure 2 - Distribution System Map Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 11 of 19

14 Corporation of the Township of Armstrong Earlton Drinking Water System Figure 3 Airport Road Subdivision Map Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 12 of 19

15 Corporation of the Township of Armstrong Earlton Drinking Water System Source Water General Characteristics The well supply obtains its water from a confined aquifer found below the limestone/bedrock formation. The chemistry of the groundwater indicates a highly suitable source for drinking water. The water temperature is constant, the ph is considered normal for ground water systems and the turbidity is low and shows very little variation. Bacteriological analysis of the raw water also indicates a source of good quality. The following tables summarize the raw water characteristics of each well is 2009: Table A - Well No. 1 Raw Water Characteristics (based on 2009 data) Characteristic Minimum Maximum Annual Average Turbidity (NTU) Temperature ( o C) ph E. coli (CFU/100 ml) Total Coliforms (CFU/100 ml) Table B - Well No. 3 Raw Water Characteristics (based on 2009 data) Characteristic Minimum Maximum Annual Average Turbidity (NTU) Temperature ( o C) ph E. coli (CFU/100 ml) Total Coliforms (CFU/100 ml) Table C - Well No. 4 Raw Water Characteristics (based on 2009 data) Characteristic Minimum Maximum Annual Average Turbidity (NTU) Temperature ( o C) ph E. coli (CFU/100 ml) Total Coliforms (CFU/100 ml) Common Fluctuations Threats Data available for the past five years indicates that the water source is stable and consistent. A potential threat to the raw water source is the proximity of the wells to the TransCanada Highway 11 and the ONR railway tracks. A fuel or chemical spill from a tanker truck or railcar could contaminate the aquifer. However, the grade of the land from the highway to the wells along with the bedrock protecting them makes this threat unlikely. Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 13 of 18

16 Corporation of the Township of Armstrong Earlton Drinking Water System Operational Challenges No major operational challenges have been encountered with this source water. 7 Risk Assessment Refer to Appendix B for QMS Procedure QP-02 Risk Assessment and Risk Assessment Outcomes. 8 Risk Assessment Outcomes Refer to Appendix B for Summary of Risk Assessment Outcomes. 9 Organizational Structure, Roles, Responsibilities and Authorities Owner and Operating Authority The Owner of the Earlton Drinking Water System is the Corporation of the Township of Armstrong, as represented by the Mayor and Clerk/Treasurer/Administrator. The Operating Authority is the Corporation of the Township of Armstrong as represented by the Clerk/Treasurer/Administrator and Village of Earlton Utilities Department. Organizational Structure of the Operating Authority The organization flowchart below presents the structure of the Operating Authority. The chart, QMS Organizational Structure for the Earlton Drinking Water System, reflects the lines of responsibility and authority for the Township of Armstrong. Mayor and Council Clerk/Treasurer/ Administrator Clerk Assistants Utilities Superintendent Utilities Chief Operator OCWA*/ORO Operators *See Appendix C for the Organizational Structure for the Ontario Clean Water Agency. Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 14 of 19

17 Corporation of the Township of Armstrong Earlton Drinking Water System QMS Roles, Responsibilities and Authorities Responsibilities and authorities for implementing and maintaining individual elements of the facility s QMS are outlined in the QMS Procedures referenced throughout this Operational Plan. Specific QMS-related roles, responsibilities and authorities of Operations personnel for the facility are summarized in the table below. Additional duties of employees are described in their job specifications. Table D - QMS Roles, Responsibilities and Authorities Position Owner Mayor and Council Owner Clerk/Treasurer/Administrator Owner/Operating Authority Superintendent (QMS Representative) Owner/Operating Authority Utilities Chief Operator (QMS Representative) QMS Roles, Responsibilities and Authorities Meet and discuss with the Clerk/Treasurer/Administrator regarding all QMS-related functions Provide approval when required Endorse DWQMS Reports to Mayor and Council Performs all statutory, operational and advisory functions according to legislation and enabling by-laws Develops, implements and maintains the municipal emergency management program Works closely with OCWA in the operation of the Township s water and wastewater treatment facilities and administers contractual matters Has the responsibilities of Top Management and QMS Representative Has the responsibility to undertake the Management Review Reports to the Clerk/Treasurer/Administrator Ensure the Earlton Drinking Water System is running accordingly Authority to manage the Water Treatment and Distribution System operations Provides advice and guidance to Council on the development of plans, priorities and policies Plans, organizes and assigns work of crews and discusses plans and priorities with crew members Manages inventory of equipment, supplies and materials required for maintenance and construction programs Reports to Utilities Superintendent Manages inventory of equipment, supplies and materials required for maintenance and construction programs Manager of Village of Earlton Utilities operators for water treatment and distribution system Manages Village of Earlton s Utilities Department within approved budgets Has the responsibility of Operator-In-Charge (OIC) Perform day-to-day activities to maintain the integrity of the Drinking Water System Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 15 of 19

18 Corporation of the Township of Armstrong Earlton Drinking Water System Position Owner/Operating Authority Water Treatment and Distribution Operators Overall Responsible Operator Ontario Clean Water Agency QMS Roles, Responsibilities and Authorities Perform day-to-day activities to maintain the integrity of the Drinking Water System Has the responsibility of Overall Responsible Operator (ORO) Performs calibrations Supports maintenance system and schedules 10 Competencies Under SDWA, 2002 Ontario Regulation 128/04 outlines the requirement for the certification of Water Treatment and Water Distribution Operators. The competencies required for personnel whose work directly affects drinking water quality are presented below: Table E Competencies Position Utilities Chief Operator Required Competencies Minimum Class II Water Treatment and Class I Water Distribution certification Experience in water treatment operations, maintenance as well as facility financial planning and administration Advanced knowledge of relevant legislation, regulations, codes, policies, guidelines and procedures Knowledge and awareness of the DWQMS Advanced technical knowledge of principles, practices, technologies and methodologies for water treatment Familiarity with complex mechanical equipment and electronic controls Analytical, evaluating and problem-solving skills Project management, work planning and scheduling skills Good oral and written communication skills Proficiency in office and operational computerized systems Management/supervisory experience Valid Class G Driver s Licence Operator(s) Minimum Class I Water Treatment and Distribution certification Good knowledge of water treatment processes to operate the facility Experience and knowledge of the maintenance and repair of a variety of equipment and structures Good working knowledge of legislation, regulations, codes, policies, guidelines and procedures related to operations and Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 16 of 19

19 Corporation of the Township of Armstrong Earlton Drinking Water System Position Required Competencies maintenance Knowledge and awareness of the DWQMS Basic mathematics and chemistry Familiarity with computers, monitoring and operating systems Knowledge to use and understand operating and maintenance manuals, blueprints and other technical specifications Planning, scheduling and problem-solving skills to regularly inspect and monitor the facility, processes and equipment and perform routine preventative maintenance Good oral and written communication skills Ability to work in a team and take initiative when required. Valid Class G Driver s Licence Overall Responsible Operator Minimum Class II Water Treatment and Class I Water Distribution certification Extensive knowledge and experience of water treatment processes to operate the facility Experience and knowledge of the maintenance and repair of a variety of equipment and structures Good working knowledge of legislation, regulations, codes, policies, guidelines and procedures related to operations and maintenance Knowledge and awareness of the DWQMS Basic mathematics and chemistry Good knowledge of computers, monitoring and operating systems Good knowledge to use and understand operating and maintenance manuals, blueprints and other technical specifications Planning and organizational skills to lead projects and provide technical direction to staff Demonstrated leadership and decision making skills required to direct an operational team Problem solving and evaluative skills to provide technical guidance and resolve operational issues Good oral and written communication skills Ability to work in a team and take initiative when required. Valid Class G drivers license Activities to develop and maintain these competencies The Village of Earlton Utilities Superintendent is responsible for ensuring each operator has a current Class I Certification. In addition, certification expiry dates are monitored by the Utilities Chief Operator. The Utilities Superintendent establishes the training needs for personnel to maintain certification. A training program is established and documented. Record of all training and Continuing Education Units (CEU) are kept by the Utilities Chief Operator. Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 17 of 19

20 Corporation of the Township of Armstrong Earlton Drinking Water System Activities to ensure personnel are aware of the relevance of their duties In addition to the on-going training, day-to-day and on-call duties on the Drinking Water System provide operators with hands-on experience of the relevance of their duties. All new staff members are provided orientation. 11 Personnel Coverage Refer to Appendix D for QMS Procedure QP-03 Personnel Coverage. 12 Communications Refer to Appendix E for QMS Procedure QP-04 Communications. 13 Essential Supplies and Services Refer to Appendix F for QMS Procedure QP-05 Essential Supplies and Services. 14 Review and Provision of Infrastructure Refer to Appendix G for QMS Procedure QP-06 Review and Provision of Infrastructure. 15 Infrastructure Maintenance, Rehabilitation and Renewal OCWA, under contract with the owner, maintains a program of scheduled inspection and maintenance of infrastructure for which it is operationally responsible. Specific requirements related to the general operation and routine maintenance of the drinking water system are contained within the contractual agreement with the owner. Records of these activities are maintained as per QMS Procedure QP-01 Document and Records Control. The two critical elements of OCWA s approach to infrastructure maintenance, rehabilitation and renewal are: 1) A computerized Work Management System (WMS) that allows users to Enter detailed asset information, Generate and process work orders, Access maintenance and inspection procedures, Plan, schedule and document all asset related tasks and activities, and Access maintenance records and asset histories. Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 18 of 19

21 Corporation of the Township of Armstrong Earlton Drinking Water System 2) Development of a list of capital works required for the water system and regular consultation with the owner to set priorities (see Review and Provision of Infrastructure). Maintenance plans are developed according to the manufacturer s instructions, regulatory requirements, industry standards, and/or client service requirements. Equipment Operation and Maintenance (O&M) manuals are accessible to staff at the locations specified in QMS Procedure QP-01 Document and Records Control. 16 Sampling, Testing and Monitoring Refer to Appendix H for QMS Procedure QP-07 Sampling, Testing and Monitoring. 17 Measurement and Recording Equipment Calibration and Maintenance Refer to Appendix I for QMS Procedure QP-08 Measurement and Recording Equipment Calibration and Maintenance. 18 Emergency Management Refer to Appendix J for QMS Procedure QP-09 Emergency Management. 19 Internal QMS Audits Refer to Appendix K for QMS Procedure QP-10 Internal QMS Audits. 20 Management Review Refer to Appendix L for QMS Procedure QP-11 Management Review. 21 Continual Improvement In conjunction with the internal QMS audit and Management Review processes documented above, the Township of Armstrong uses action plans to continually improve its QMS. Through these processes, areas of concern as well as opportunities for improvement are identified at the drinking water system operated and maintained by the Township of Armstrong. Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Page 19 of 19

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23 Appendix A QP-01 Document and Records Control Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Appendix A

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25 QMS Reviewed by: Guy Laurin QMS Procedure Approved by: Donald Antler Proc.: Issued: Rev.#: Pages: QP of 4 DOCUMENT and RECORDS CONTROL 1.0 Purpose To describe how the Township of Armstrong s QMS documents are kept current and how QMS documents and records are kept legible, readily identifiable, retrievable, stored, protected, retained and disposed of. 2.0 Scope Applies to all QMS Documents and QMS Records pertaining to the Earlton Drinking Water System, as identified in this procedure. 3.0 Responsibility Utilities Superintendent Utilities Chief Operator 4.0 Definitions Controlled managed as per the conditions of this procedure Document includes a sound recording, video tape, film, photograph, chart, graph, map, plan, survey, book of account, and information recorded or stored by means of any device QMS Document any document required by the Township of Armstrong s QMS as identified in this procedure QMS Record any record required by the Township of Armstrong s QMS as identified in this procedure Record a document stating results achieved or providing proof of activities performed Retention Period length of time that a document or record must be kept; starts from the date of issue for QMS records or from the point of time when a QMS document is replaced by a new or amended document 5.0 Procedure 5.1 Documents and records required by the Township of Armstrong s QMS are listed in Table Internally developed QMS documents and QMS records (whenever possible) are generated electronically for legibility and are identified through a header/title and issue date. Handwritten records must be legible and permanently rendered in ink or nonerasable marker. 5.3 Additional controls for QMS Procedures within the Operational Plan are used for review and approval. These include the use of authorized approval, alpha-numeric procedure code, issue date, revision number and revision history. Authorized personnel for review and approval of QMS Procedures for the Earlton Drinking Water System are: Review Approval Guy Laurin, Utilities Chief Operator Donald Antler, Utilities Superintendent

26 Corporation of the Township of Armstrong Earlton Drinking Water System QMS Procedure: Document and Records Control Proc.: QP-01 Rev.: 3 Issued: Page 2 of Current QMS documents and records are readily accessible to Operations personnel and to internal and external auditors/inspectors at document control locations established by the QMS Representative. The designated document control location(s) for identified QMS documents and records are defined in Table 1. Document and records control locations are established in areas to provide adequate protection to prevent unauthorized use/access, damage, deterioration or loss of QMS documents and records. Copies of QMS documents and records located outside of designated control locations are considered uncontrolled. 5.5 Access to the Township of Armstrong s computer infrastructure is restricted through use of usernames and passwords. Electronic documents are protected and backed-up within this computer infrastructure. Access to facility QMS documents and records contained within internal electronic databases and applications (e.g., WMS) requires the permission of the Utilities Superintendent and is restricted through use of usernames and passwords. SCADA records are maintained and accessible to staff when required. 5.6 Any employee of the drinking water system may request, in writing, a revision to improve an existing internal QMS document or the preparation of a new document. Written requests should indicate the reason for the requested change. The need for new or updated documents may also be identified through the Management Review or system audits. The QMS Representative communicates any changes made to QMS documents to relevant facility personnel and coordinates related training (as required). 5.7 When a QMS document is superseded, the hardcopy of the document is promptly removed from its location and forwarded to the QMS Representative or designate for disposal or retention (as appropriate). Electronic copies are re-located to an obsolete folder and marked superseded. 5.8 The authorized method for disposal of documents and records after the specified retention requirements have been met is shredding. 5.9 QMS documents and records are retained in accordance with applicable regulations and legal instruments. Relevant legislated and internal retention periods are listed in Table QMS documents and records are reviewed for evidence of control during each internal system audit as per QMS Procedure QP-10 Internal QMS Audits. 6.0 Related Documents QP-10 Internal QMS Audits 7.0 Revision History Date Revision # Reason for Revision Procedure issued Identify how records and documents are protected as per CAR Change name from Earlton Well Supply to Earlton Drinking Water System as per DWS update Replaced Certificate of Approval with Municipal Drinking Water Licence and Drinking Water Works Permit Added Guy Laurin as Utilities Chief Operator and additional document references in Table 1 ORO letter, Public Binder, Logbooks and CT SOP

27 Corporation of the Township of Armstrong Earlton Drinking Water System QMS Procedure: Document and Records Control Proc.: QP-01 Rev.: 3 Issued: Page 3 of 4 Table 1: Designated location for documents and records required by the Township of Armstrong s QMS. Type of Document or Record Designated Document or Record Control Location (HC = Hard Copy/EC = Electronic Copy) Internal QMS Documents Operational Plan (includes QMS Procedures) QMS Policy Daily Rounds Sheets Laboratory Chain of Custody Forms Township of Armstrong s Emergency Plan Emergency Contact lists Essential Supplies and Services List Site Specific Emergency Response Procedures Standard Operating Procedures (referenced in Operational Plan and QMS Procedures) Sample Schedule CT SOP Emergency Plan Reporting Forms Community Complaint Environmental Incident MDWL Exceedance Loss of Pressure Incident On-Call Schedule Vacation Schedule External QMS Documents Applicable Federal and Provincial Legislation Drinking Water Works Permit Engineering schematics/plans/drawings Municipal Drinking Water Licence Operator certificates Operations Manual ORO Letter Original Equipment Manuals (OEM) Permit to Take Water Public Binder QMS Records Daily Rounds Sheets Operator Training Records Maintenance Records EC Water Wastewater Office computer EC HC DWQMS filing cabinet HC Township of Armstrong Main Office HC Township of Armstrong Main Office EC Water Wastewater Office computer HC DWQMS filing cabinet EC Water Wastewater Office computer HC Water Wastewater Office EC Water Wastewater Office computer HC DWQMS filing cabinet EC Water Wastewater Office computer HC DWQMS filing cabinet HC Water Wastewater Office HC Water Wastewater Office Online at HC DWQMS filing cabinet HC Water Wastewater Office HC DWQMS filing cabinet HC Water Wastewater Office HC Water Wastewater Office HC Water Wastewater Office HC Water Wastewater Office HC DWQMS filing cabinet HC Township of Armstrong Main Office HC Water Wastewater Office HC Water Wastewater Office EC - Workplace Management System (Hansen) HC Water Wastewater Office

28 Corporation of the Township of Armstrong Earlton Drinking Water System QMS Procedure: Document and Records Control Proc.: QP-01 Rev.: 3 Issued: Page 4 of 4 Type of Document or Record Instrumentation Calibration/Maintenance Record Laboratory Analytical Reports SCADA Records Internal QMS Audit Reports External Audit Reports MOE Inspection Reports Annual Compliance/Summary Reports Management Review Documentation Internal QMS Communications External QMS Communications Infrastructure Review (Annual Budget) Emergency Plan Reports Community Complaint Record Environmental Incident Record MDWL Exceedance Record Loss of Pressure Incident Record Logbooks Designated Document or Record Control Location (HC = Hard Copy/EC = Electronic Copy) EC - Workplace Management System (Hansen) HC Water Wastewater Office EC - Microsoft Outlook HC Water Wastewater Office EC Water Wastewater Office computer HC DWQMS filing cabinet HC DWQMS filing cabinet HC Water Wastewater Office EC Water Wastewater Office computer HC Water Wastewater Office EC Water Wastewater Office computer HC DWQMS filing cabinet EC - Microsoft Outlook EC - Microsoft Outlook EC Water Wastewater Office computer HC Township of Armstrong office HC DWQMS filing cabinet HC Water Wastewater Office Table 2: Relevant legislated and corporate retention periods Type of Document/Record Minimum Retention Time Requirement Reference DWQMS Operational Plan 10 years Director s Direction under SDWA Internal QMS Audit Results 10 years Internal Requirement External QMS Audit Results 10 years Internal Requirement Management Review Minutes 10 years Internal Requirement Documents and records required to demonstrate conformance with the DWQMS Documents and records required to demonstrate compliance with Ontario legislation 3 years Internal Requirement As per applicable regulations SDWA O. Reg. 170/03, O. Reg. 128/04

29 Appendix B QP-02 Risk Assessment and Risk Assessment Outcomes Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Appendix B

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31 QMS QMS Procedure Proc.: Issued: Rev.#: Pages: QP of 4 Reviewed by: Aurel Courchesne Approved by: Donald Antler RISK ASSESSMENT and RISK ASSESSMENT OUTCOMES 1.0 Purpose To define the process for conducting a drinking water risk assessment and for documenting and reviewing the results of the assessment at the facility level. 2.0 Scope Applies to the Earlton Drinking Water System and is limited to the assessment of potential drinking water health hazards. Township of Armstrong approach to addressing other potential hazards is set out in QMS Procedure QP-09 Emergency Management. 3.0 Responsibility Utilities Chief Operator Risk Assessment Personnel 4.0 Definitions Drinking Water Health Hazard means, in respect of a drinking water system, a) a condition of the system or a condition associated with the system s waters, including any thing found in the waters, i. that adversely affects, or is likely to adversely affect, the health of the users of the system, ii. that deters or hinders, or is likely to deter or hinder, the prevention or suppression of disease, or iii. that endangers or is likely to endanger public health, b) a prescribed condition of the drinking water system, or c) a prescribed condition associated with the system s waters or the presence of a prescribed thing in the waters Critical Control Point (CCP) An essential step or point in the subject system at which control can be applied by the Operating Authority to prevent or eliminate a drinking water health hazard or reduce it to an acceptable level Hazardous Event an incident or situation that can lead to the presence of a hazard Hazard a biological, chemical, physical or radiological agent that has the potential to cause harm Control Measure includes any processes, physical steps or other practices that have been put in place at a drinking water system to prevent or reduce a hazard before it occurs Likelihood the probability of a hazard or hazardous event occurring Consequence the potential impact to public health and/or operation of the drinking water system if a hazard/hazardous event is not controlled

32 Corporation of the Township of Armstrong QMS Procedure: Risk Assessment and Risk Assessment Outcomes Proc.: QP-02 Rev.: 1 Issued: Page 2 of 4 Environmental Emergency Procedure (EEP) site specific procedures developed for emergency situations 5.0 Procedure 5.1 The QMS Representative assigns trained personnel to conduct the risk assessment. 5.2 Using the system s process diagram, identify hazardous events and associated hazards (possible outcomes) that could impact the system s ability to deliver safe drinking water in Table 1 1 for each activity/process step. 5.3 For each of the hazardous events, specify control measures currently in place at the facility that eliminate the hazard or prevent it from becoming a threat to public health. Note: Some hazards/hazardous events may have step-by-step contingency plans associated with them. These contingency plans are developed as per the Township of Armstrong s Emergency Management Program and are further described in QMS Procedure QP-09 Emergency Management. 5.4 To ensure that potential drinking water health hazards are addressed and minimum treatment requirements as regulated by SDWA O. Reg. 170/03 and the Procedure for Disinfection of Drinking Water in Ontario are met, the Township of Armstrong has established mandatory Critical Control Points (CCPs). As a minimum, the following must be included as CCPs at the Earlton Drinking Water System (as applicable): Processes necessary to achieve the required log removal or inactivation of pathogens (i.e., chemical and/or UV disinfection system, filtration process 2 for surface water and GUDI systems) Processes necessary for maintaining a disinfectant residual in the distribution system (includes re-chlorination points) Identify the above processes (as they apply) as mandatory CCPs in the CCP column in Table To determine if there are any additional CCPs for the system, evaluate and rank the hazardous events (as set out below in steps 5.6 and 5.7) for the remaining activities/process steps (i.e., those not included as minimum CCPs). 5.6 Taking into consideration existing control measures (including the reliability and redundancy of equipment), assign each hazardous event a value for the likelihood and a value for the consequence of that event occurring based on the following criteria: 1 Tables referred to in this procedure are contained within the facility-specific Summary of Risk Assessment Outcomes 2 Filtration process includes related processes (e.g., chemical coagulation, rapid mixing, flocculation, sedimentation)

33 Corporation of the Township of Armstrong QMS Procedure: Risk Assessment and Risk Assessment Outcomes Proc.: QP-02 Rev.: 1 Issued: Page 3 of 4 Value 1 Likelihood of Hazardous Event Occurring Rare Estimated to occur every 50 years or more (usually no documented occurrence at site) 2 Unlikely Estimated to occur in the range of years 3 Possible Estimated to occur in the range of 1 9 years 4 Likely Occurs monthly to annually 5 Certain Occurs monthly or more frequently Value Consequence of Hazardous Event Occurring Insignificant Little or no disruption to normal operations, no impact on public health Minor Significant modification to normal operations but manageable, no impact on public health Moderate Potentially reportable, corrective action required, potential public health impact, disruption to operations is manageable Major Reportable, system significantly compromised and abnormal operations if at all, high level of monitoring and corrective action required, threat to public health 5 Catastrophic Complete failure of system, water unsuitable for consumption Multiply the likelihood and consequence values to determine the risk value (ranking) of each hazardous event and record all values in Table 1. Hazardous events with a ranking of 12 or greater are considered high risk. 5.7 Review the hazardous events and rankings documented in Table 1 and identify any activity/process step as an additional CCP if all of the following criteria are met: The associated hazardous event has a ranking of 12 or greater The associated hazardous event is reduced to an acceptable level through control measure(s) Operation of the control measures can be monitored and corrective actions can be applied in a timely fashion Specific control limits can be established for the control measure(s) Failure of the control measures would lead to immediate notification of Medical Officer of Health (MOH) or Ministry of the Environment (MOE) or both. 5.8 List identified CCPs (required minimum and any additional CCPs established by the risk assessment) in Table 2. Set related critical control limits (e.g., limits for turbidity, chlorine residual, temperature, ph) for each CCP as appropriate. 5.9 Ensure procedures have been developed and implemented at the facility to: Monitor the critical control limits Respond to, report and record deviations from the critical control limits. List these procedures in Table The information recorded in the Summary of Risk Assessment Outcomes is maintained at the facility level on an ongoing basis and is reviewed at least annually as part of the Management Review process A risk assessment is conducted and documented at least once every thirty-six months.

34 Corporation of the Township of Armstrong QMS Procedure: Risk Assessment and Risk Assessment Outcomes Proc.: QP-02 Rev.: 1 Issued: Page 4 of Related Documents Summary of Risk Assessment Outcomes 7.0 Revision History Date Revision # Reason for Revision Procedure issued Updated name of facility to Earlton Drinking Water System

35 QMS Summary of Risk Assessment Outcomes Corporation of the Township of Armstrong Earlton Drinking Water System Revised: Rev. #: Pages: of 7 Table 1: Risk Assessment Table Note: Processes referred to in section 5.4 of QP-02 Risk Assessment and Risk Assessment Outcomes must be identified as mandatory Critical Control Points (CCPs). Mandatory CCPs are not required to be ranked. Activity/ Process Step Description of Hazardous Event Possible Outcome (Hazards) Existing Control Measures Likelihood Consequence Risk Value CCP? Raw Water/Well Well casing collapse Loss of raw water Contamination of aquifer Sodium Hypochlorite System (Primary disinfection) Redundancy (3 wells and well pumps) Turbidity meter at plant Operator checks Well pump failure Loss of raw water Redundancy (3 wells and well pumps) Well pump(s) failure alarm Well flow meter Environmental Emergency Procedure (EEP) for Well Pump Failure Fuel/Chemical Spill (ONR Railway and TransCanada Highway) Chemical feed pump failure at well head (Sodium Hypochlorite) Chemical feed pump failure Contamination of aquifer Increase of pathogens in raw water entering treatment system Loss of disinfection Low chlorine residual Inadequate inactivation of pathogens Potential for AWQI Monitor and sample EEP for Off-site Chemical/Fuel Spill EEP for Contaminated Raw Water Redundancy (chemical pump on each of the 3 wells) Chemical pump fault alarm On-line monitoring with alarms In-house residual testing and dosage calculations Redundancy: back-up pump Scheduled maintenance activities EEP for Chlorine Pump Failure Standard Operating Procedure (SOP) for Chlorine Contact Time (CT) EEP for Low or High Chlorine Residual in Treated Water EEP for Reporting and Responding to Adverse Chlorine Residuals in Large Municipal Residential Systems (LMRS) Yes Mandatory CCP Yes Additional CCP identified for facility No Yes Mandatory CCP Yes Additional CCP identified for facility No

36 Corporation of the Township of Armstrong Earlton Drinking Water System Summary of Risk Assessment Outcomes Rev.: 1 Revised: Page 2 of 7 Activity/ Process Step Description of Hazardous Event Possible Outcome (Hazards) Existing Control Measures Likelihood Consequence Risk Value CCP? Ferric System (Coagulation process) Filtration Process (Duel media, conventional filtration) Analyzer failure Low supply of Sodium Hypochlorite Unknown chlorine residual levels Potential for AWQI Inadequate disinfection, Potential for AWQI Low level alarm In-house residual testing Scheduled maintenance activities Spare analyzer SOP for Chlorine CT EEP for Low or High Chlorine Residual in Treated Water EEP for Reporting and Responding to Adverse Chlorine Residuals in LMRS Low chlorine residual alarms Operator checks Chemical available within surrounding municipalities SOP for Chlorine CT EEP for Low or High Chlorine Residual in Treated Water EEP for Reporting and Responding to Adverse Chlorine Residuals in LMRS SOP for Chemical Sources Chemical pump failure Increased iron content Redundancy (2 chemical pumps) Pump fault alarm Filter breakthrough Increased turbidity levels Potential for AWQI Backwash System Pump failure Increased turbidity levels Potential for AWQI On-line turbidity monitoring Regular backwashes Operator checks Scheduled maintenance activities EEP for Reporting and Responding to High Turbidity in LMRS Two domestic high lift pumps can replace backwash pump (manual change) Yes Mandatory CCP Yes Additional CCP identified for facility No Yes Mandatory CCP Yes Additional CCP identified for facility No Yes Mandatory CCP

37 Corporation of the Township of Armstrong Earlton Drinking Water System Summary of Risk Assessment Outcomes Rev.: 1 Revised: Page 3 of 7 Activity/ Process Step Description of Hazardous Event Possible Outcome (Hazards) Existing Control Measures Likelihood Consequence Risk Value CCP? Spare pump Operator checks High turbidity alarm EEP for Reporting and Responding to High Turbidity in LMRS Yes Additional CCP identified for facility No Blower failure Increased turbidity levels Accumulation of biofilm Spare blower Blower failure alarm, call out Operator checks Clearwells Low level Inadequate contact time for primary disinfection Inadequate treated water supply Clearwell out of service for repair Maintenance Compromised integrity Inadequate contact time for primary disinfection Loss of volume Infiltration Potential AWQI Low level alarm Schedule maintenance and inspection activities Town ordered water conservation or ban EEP for Water Supply Shortage Redundancy (2 clearwells) Isolation valve between clearwells Increase chlorine dosage into clearwell Scheduled maintenance activities Low level alarm Residual monitoring Operator checks Township ordered water conservation or ban High Lift High lift pump failures Loss of water supply Redundancy (3 pumps, 1 fire pump and 1 backwash pump) Spare pump Scheduled maintenance activities Operational control Low level alarm and lockout alarm Pump fault alarm EEP for High Lift Pump Failure Yes Mandatory CCP Yes Additional CCP identified for facility No Yes Mandatory CCP Yes Additional CCP identified for facility No

38 Corporation of the Township of Armstrong Earlton Drinking Water System Summary of Risk Assessment Outcomes Rev.: 1 Revised: Page 4 of 7 Activity/ Process Step Description of Hazardous Event Possible Outcome (Hazards) Existing Control Measures Likelihood Consequence Risk Value CCP? Low/loss of pressure Infiltration Backflow pressure Potential for AWQI Redundancy (3 pumps, 1 fire pump and 1 backwash pump) Low pressure alarm Operator checks Township ordered water conservation or ban EEP for Low Pressure Water Treatment System Power failure Loss of treated water supply Back-up diesel generator at WTP Scheduled maintenance activities Operator checks (fuel level) EEP for Power Failure of Long Duration EEP for Standby Power Failure Yes Mandatory CCP Yes Additional CCP identified for facility No Generator failure Loss of treated water supply Scheduled maintenance activities Operator checks (fuel level) EEP for Power Failure of Long Duration EEP for Standby Power Failure Secondary Disinfection Vandalism/terrorism Loss of free chlorine residual in distribution Contamination of the water supply Damage to critical equipment Failure to control biofilm and pathogens (long-term) Potential for AWQI Locked (water plant, well house, hatches) Fencing around each well with pad lock Signage Intrusion alarms (WTP and well house) Daily rounds EEP for Vandalism or Suspected Unauthorized Entry Continuous on-line monitoring of chlorine residual into the distribution system System-wide residual testing as per O. Reg. 170/03 Low chlorine alarm Regularly scheduled maintenance (Performed by Township) EEP for Reporting and Responding to Yes Mandatory CCP Yes Additional CCP identified for facility No

39 Corporation of the Township of Armstrong Earlton Drinking Water System Summary of Risk Assessment Outcomes Rev.: 1 Revised: Page 5 of 7 Activity/ Process Step Description of Hazardous Event Possible Outcome (Hazards) Existing Control Measures Likelihood Consequence Risk Value CCP? Watermains All (watermains, connections, valves, construction, etc.) Watermain structural failure/breaks Accident Vandalism Contamination Loss of pressure Loss of supply Contamination Loss of water supply Loss of pressure Adverse Chlorine Residuals in LMRS Notification/complaints from customers Operator checks Alarms (low pressure, low clearwell) EEP for Water Line Breaks EEP for Water Supply Shortage Notification/complaints from customers Operator checks Alarms (low pressure, low clearwell) Site specific EEP for Water Supply Shortage Service connections Cross Connection Contamination EEP for Reporting and Responding to Adverse Bacteriological Results in Large Municipal Residential Systems Structural failure/breaks Contamination Loss of pressure Valves Failure Loss of control Line breaks and/or contamination Loss of pressure Loss of water supply Flushing New construction Failure to flush Not following proper procedure Sub-standard construction and /or Loss of chlorine residual Potential AWQI Contamination Lower pressure Contamination Loss of pressure Customer notification/complaints Alarms (low pressure) Maintenance program Alarms (low pressure) EEP for Water Supply Shortage Maintenance program, Customer complaints/notifications EEP for Reporting and Responding to Adverse Chorine Residuals in Large Municipal Residential Systems AWWA guidelines Testing Yes Mandatory CCP Yes Additional CCP identified for facility No Does not meet all CCP criteria (i.e. control measurers cannot be monitored) Yes Mandatory CCP Yes Additional CCP identified for facility No Yes Mandatory CCP Yes Additional CCP identified for facility No Yes Mandatory CCP Yes Additional CCP identified for facility No Yes Mandatory CCP Yes Additional CCP identified for facility No Yes Mandatory CCP Yes Additional CCP

40 Corporation of the Township of Armstrong Earlton Drinking Water System Summary of Risk Assessment Outcomes Rev.: 1 Revised: Page 6 of 7 Activity/ Process Step Description of Hazardous Event Possible Outcome (Hazards) Existing Control Measures Likelihood Consequence Risk Value CCP? Sampling (watermain breaks) Distribution System commissioning Provincial Standard Inspection identified for facility Failure to sample (equipment/human error) Adverse Water Quality Result as described in O. Reg. 170/03 Contamination Potential for unsafe drinking water AWWA guidelines Operator Certification Site specific SOP Sampling Schedule EEP for Reporting and Responding to Adverse Results in Large Municipal Residential Systems (several EEPs) No Yes Mandatory CCP Yes Additional CCP identified for facility No Yes Mandatory CCP Yes Additional CCP identified for facility No Table 2: Identified Critical Control Points (CCPs) CCP Critical Control Limits Monitoring Procedures Response, Reporting and Recording Procedures Primary Disinfection Free Chlorine Residual Alarms Low set point = 0.30 mg/l SCADA (continuous online analyzers) Regular operator checks via remote monitoring system On-site checks Trend review and sign-off as per O. Reg. 170/03 SOP for Chlorine CT EEP for Chlorine Pump Failure EEP for Low or High Chlorine Residual in Treated Water EEP for Reporting and Responding to Adverse Chlorine Residuals in LMRS Pressure in Distribution System Pump Failure Alarm Alarms during a pump failure SCADA (continuous online analyzers) On-site checks EEP for High Lift Pump Failure EEP for Low Pressure Events in the Distribution System Low Pressure Alarm Alarm at WTP for low pressure =< 30 psi for 10 minutes Secondary Disinfection Free Chlorine Residual - Distribution Low = 0.05 mg/l High = 4.0 mg/l Distribution chlorine residuals monitored as per O. Reg. 170/03 EEP for Reporting and Responding to Adverse Chlorine Residuals in LMRS

41 Corporation of the Township of Armstrong Earlton Drinking Water System Summary of Risk Assessment Outcomes Rev.: 1 Revised: Page 7 of 7 Table 3: Record of Annual Review/36-Month Risk Assessment The Drinking Water Quality Management Standard (DWQMS) requires that the currency of the information and the validity of the assumptions used in the risk assessment be verified at least once a year. In addition, the risk assessment must be conducted at least once every thirty-six months. Refer to steps 5.10 and 5.11 of QP-02. Date of Activity Type of Activity Participants Summary of Results Risk Assessment Amanda Dubuc (OCWA), Aurel Courchesne (Utilities Chief Operator), Don Antler (Utilities Superintendent), Guy Laurin (Operator) Conducted initial risk assessment Review Amanda Dubuc (PCT) Desktop review prior to submission of Partial Accreditation application. No changes Review Amanda Dubuc (OCWA), Aurel Courchesne (Utilities Chief Operator), Claude Mongrain (ORO), Don Antler (Utilities Superintendent), Guy Laurin (Operator), Martin Lavictoire (Operator) Review during Internal Audit. No changes Review Amanda Dubuc (OCWA), Aurel Courchesne (Utilities Chief Operator), Claude Mongrain (ORO), Don Antler (Utilities Superintendent), Guy Laurin (Operator), Jonathon Schenk (Operator) Risk Assessment Aurel Courchesne (Utilities Chief Operator), Claude Mongrain (ORO), Don Antler (Utilities Superintendent), Guy Laurin (Operator), Jonathon Schenk (Operator) Review during Internal Audit. No changes. Conducted risk assessment. Identified generator failure as a hazardous event and reranked power failure. Revision History Date Revision # Reason for Revision Initial risk assessment conducted Template revised to include Record of Annual Review/36-Month Risk Assessment (Table 3) and updated Critical Control Limit set points, changed facility name to Earlton Drinking Water System, added generator failure as a hazardous event and reranked power failure

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43 Appendix C QMS Organizational Structure for the Ontario Clean Water Agency Corporation of the Township of Armstrong DWQMS Operational Plan Revision 1, Appendix C

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45 Ontario Clean Water Agency QEMS Organizational Structure for the Ontario Clean Water Agency Owner The Corporation of the Township of Armstrong Earlton Drinking Water System Overall Responsible Operator Ontario Clean Water Agency Northeastern Ontario Hub Operations Manager (Facility Level Top Management & QEMS Rep) Senior Operations Manager Northeastern Ontario (Facility Level Top Management, QEMS Rep. & Media Spokesperson) Instrumentation Technicians Process & Compliance Technician (QEMS Rep) Regional Manager Northern Region VP Operations Director - Risk, Compliance & Training Overall Responsible Operator Facility Staff Operator ORO/OIC President & CEO Board of Directors* Facility QEMS Corporate Level Top Management Endorsement & Approval of the Facility s QEMS & Operational Plan Overall Leadership & Support for OCWA s QEMS Reports To Supervises/Directs Delineates Corporate & Facility Level Functions * Represents the highest level of OCWA s Top Management Revision 2: Page 1 of 1