DWQMS Management Review

Transcription

1 DWQMS Management Review 2017

2 Table of Contents List of Acronyms and Definitions... 3 Introduction Incidents of regulatory non-compliance Incidents of adverse drinking-water tests Deviations from critical control point limits and response actions Efficacy of the risk assessment process Third-party and Internal audit reports Results of emergency response testing Operational performance Raw water supply and drinking-water quality trends Follow-up on action items from previous management reviews Status of management action items identified between management reviews Changes that could affect the Quality Management System Consumer feedback (i.e., internal & external communications) Resources needed to maintain the Quality Management System Results of DWQMS Infrastructure Review Operational Plan currency, content & updates Staff suggestions

3 List of Acronyms and Definitions DWQMS Drinking Water Quality Management System MOECC Ministry of the Environment and Climate Change QMS Quality Management System THM Trihalomethanes are a group of compounds that can form when the chlorine used to disinfect drinking water reacts with naturally occurring organic matter (e.g., decaying leaves and vegetation). HAA - Haloacetic Acid. HAA values refer to the sum of the concentration of six haloacetic acid compounds which include mono-, di-, and trichloroacetic acids, and mono- and dibromoacetic acids, and bromochloroacetic acid. HAAs are a type of chlorination disinfection by-product that are formed when the chlorine used to disinfect drinking water reacts with naturally occurring organic matter, usually in raw water. OFI Opportunity for Improvement Ontario Regulation 170/03 Regulation under the Safe Drinking Water Act governing Drinking Water Systems Ontario Regulation 169/03 Ontario Drinking Water Quality Standards which Outline maximum allowable concentrations (standards) for Microbiological, Chemical and Radiological elements and compounds in drinking water systems. Watermain Disinfection Procedure Section 4 Documentation requirements for operators who are performing maintenance and repair activities associated with disinfecting water mains as part of an addition, modification, replacement, extension, planned maintenance, or emergency repair in a municipal residential drinking water system SDWS Small Drinking Water Systems. The City of Niagara Falls owns 3 cistern fed SDWS properties, which are the: Willoughby Volunteer Fire Department at Sodom Rd.; Willoughby Town Hall at Sodom Rd. and; Fire Station #6 at 8137 Schisler Rd. Page 3 of 11

4 Introduction Element 18 of the Drinking Water Quality Management Standard states that a Management Review must be completed once every 12 months. This review is to be completed with the person(s) deemed Top Management in the Drinking Water System. The purpose of the Management Review is to document the actions and effectiveness of the Quality Management System. The outcome of the Management Review must be reported to the Owner of the Drinking Water System. The information reported to the Owner can be relayed at the same time as the Annual Drinking Water System Report, scheduled to be provided to Council in February. 1. Incidents of regulatory non-compliance In December of 2017, the Ministry of the Environment and Climate Change completed an onsite inspection. During the inspection, one incident of regulatory non-compliance was found in relation to the City s Lead Sampling Program. The overall compliance rating for the inspection was 94.83% The City completes 2 rounds of lead sampling (spring and fall) annually throughout the Niagara Falls water distribution system. Schedule 15.1 of Ontario Regulation 170/03 states that the occupant/owner of the premises served by the tap from which the lead sample was taken must be notified of the lab test results within 7 days of when the City receives them. The City was delayed in sending this notification to the pertinent residents during the spring round of lead sampling in 2017, resulting in the non-conformance. Further to this, the MOECC has requested that the City provide a written report which contains a list of City employees who have reviewed all requirements of Schedule 15.1 to mitigate this oversight in the future. The report is to be submitted by April 1, 2018 to the MOECC Inspector who prepared the inspection report. The Inspector also suggested in the Recommendations and Best Practices section of the report to: Continue monitoring, flushing, and correcting areas of the distribution system that experience continued low chlorine residuals to ensure these and all areas residual readings remain over 0.05 mg/l at all times; Continue communication with Niagara Region as it relates to the increased THM values and its association with the Regional Treatment Plants filter media; Page 4 of 11

5 Continue implementing the City s proposed backflow prevention program; Shift the manner in which operator logs are stored, so that all drinking water related logs are stored in separate binders from sewer related logs (this recommendation has already been initiated by the City for the 2018 logs); Revise the City s current watermain break report/sop and water appurtenance and fitting maintenance procedures to ensure all requirements of Watermain Disinfection Procedure s Section 4 are met. The City has agreed to complete and provide the revised Watermain Break Report form by March 1, 2018 to the MOECC Inspector who prepared the inspection report. The MOECC 2017 Inspection Report is attached as Appendix A, for review. 2. Incidents of adverse drinking-water tests The City experienced one (1) adverse sample result in 2017 within its distribution system. i) September 27, 2017: A lead sample collected at 6763 Argyll Cr. (which was representative of a distribution rather than a residential sample) during the fall round (round 2) of the City s Lead Sampling Program resulted in an adverse reading of 10.7 µg/l of lead. The City had also taken an additional sample at this address, following the first sample (the second was representative of a residential sample) which yielded readings well below the lead exceedance threshold. It was determined that the sample, although representative of the distribution system, was affected by the internal piping of the residence from which it was taken. As samples collected immediately following the adverse sample were clear, it was determined this was likely a private piping issue which was quickly resolved by minimal flushing. Follow up samples (taken two days following the adverse) were also well below the lead exceedance parameter of 10 µg/l. Upon receiving the adverse notification from the Licenced Lab, Staff followed SOP MW-ES-DWS-SOP Adverse Water Quality Incident Reporting, and to reiterate, the incident was resolved by re-sampling. A copy of MW-ES-DWS-SOP can be found in previous Management Reviews and can also be circulated on request It should also be noted that the Niagara Region Niagara Falls Water Treatment Plant reported a Notice of Adverse Test Results on February 7, The adverse notice was based on a coagulant pump failure (which occurred only for a short period of time). This incident was resolved on the same day and did not Page 5 of 11

6 affect the drinking water quality within the City of Niagara Falls water distribution system. 3. Deviations from critical control point limits and response actions There were no deviations from critical control points during this report period. 4. Efficacy of the risk assessment process During the 2016 internal audit, it was identified that further clarification was needed with respect to the Risk Assessment and what a true critical control point is. Currently there are items listed as critical control points that the City cannot control, regardless of their importance, such as backflow prevention devices not owned by the City. As per the updated DWQMS standard, MOECC required items were also addressed in the Risk Assessment. These included climate change issues such as drought or extended extreme temperatures. 5. Third-party and Internal audit reports Third Party Audit On August 21 & , NSF Internal performed an offsite verification audit of the City s DWQMS. The Auditor identified some opportunities for improvement (OFI s), which were consistent with improvement suggestions documented in the MOECC inspection (noted previously in this document) and internal audit (outlined further in this document), with the addition of suggestions to: Create a tool/asset/parts inventory; Graphically analyze watermain breaks for budget purposes; Request the internal auditor to re-classify findings during next audit (add to include section for compliance, not just non-conforming and OFI). There were not any non-conformances found during the third party audit. The NSF Third Party Audit is attached as Appendix B, for review. Internal Audit An internal audit was completed by BluMetric on December 7, Page 6 of 11

7 The audit indicated that the City of Niagara Falls QMS has been implemented and there is commitment to the program. However, there were areas of concern noted such as: Some controlled DWQMS and Environmental Services Documents were not being reviewed/updated as outlined; The Operational Plan requires updates; DWQMS awareness training did not occur in 2017 (due to position vacancy); Essential Service and Supply List in need of an Operating Authority Review; Hydrant maintenance is not meeting level of service targets with respect to flushing and valve exercising, as per the Fire Code; Units measuring free chlorine residuals had not been calibrated within the prescribed time frame (this has since been corrected); Few Corrective Action Requests (CAR s) had not been completed since the time of the previous internal audit (this has also since been corrected). In addition to the areas of concern, BluMetric also suggested OFI s such as: Officially assigning a back-up QMS representative for the City; Updating DWQMS and Environmental Service docs to be consistent with Municipal (City Hall) procedures; Electronically capturing and recording operational and asset data/workflow that is currently in hard copy format only; The addition of appropriate SOP s to the Risk Assessment Table for consistency; Updating Staff Licences log as well as on display at the Municipal Service Centre (this has since been complete); Updating the Essential Supplies and Service List to include the Niagara Region as the water source (this has since been complete); Updating lead sampling procedures to ensure ph meter calibration is performed and recorded/logged (this has since been complete); Creating a list in the Emergency Management Procedure of potential emergency situations; Creating a database that would track the City s OFI s (opportunities for improvement) based on audits and inspections to better illustrate the continual improvement initiatives occurring. The internal audit report is attached as Appendix C, for review. 6. Results of emergency response testing On December 4, 2017, Environmental Services Staff participated in an Emergency Response desktop training exercise. Page 7 of 11

8 The scenario included a watermain break, a failed backflow preventer as well as City staff potential health and safety concerns all occurring in an industrial area of Niagara Falls. The group was asked to work together on a plan of action, remediation and communication to City staff as well as Niagara Falls residents and pertinent external agencies. Team discussion touched on items such as flushing techniques, watermain isolation, valve closures, sample protocols, operational reporting requirements and health and safety procedures. 7. Operational performance In 2017 Environmental Services responded to 55 watermain breaks. This total number is a decrease from the previous year (2016), during which 71 watermain breaks occurred. The winters of 2016 and 2017 were similar in weather patterns. 8. Raw water supply and drinking-water quality trends Niagara Region is responsible for all sampling and testing of raw water. Through a previous year s hydrant maintenance program, City staff members have found areas of the municipal drinking water system where weekly or bi-weekly flushing s can improve water quality. These areas are tracked by way of a flushing report form and this practice has continued throughout Source water temperature changes in late spring and fall have historically resulted in resident inquiries about chlorine levels. The majority of these calls originate from the south end of the City which is the geographic area closest to the water treatment plant. The City receives weekly chlorine residual results from Niagara Region, which have indicated no significant fluctuation in chlorine levels leaving the treatment plant. This remained unchanged in Niagara Region is continuing to monitor THM (trihalomethane) levels in conjunction with all local area municipalities. Various methods of preventing THM levels from increasing have been discussed. The City s Environmental Services Division will continue to flush dead end watermains, which is a currently a suitable manner for which a distribution system can mitigate potential high THM levels. There have been discussions with Niagara Region in regards to changing their GAC (granular activated carbon) at the treatment plant. This filter media removes organic debris from the treated water and reduces THM formation. This communication with Niagara Region continued throughout 2017 and will carry on indefinitely, as we collaboratively strive for the continual improvement of water quality in the distribution system. Page 8 of 11

9 9. Follow-up on action items from previous management reviews 2016 Management Review Action Items Action Items Assigned To Due Dates Backflow prevention program James Sticca Start steps to begin program by Q3 of 2017 (currently still in development stages due to council shift/budget limitations and limited internal staffing Post and Train new QMS Rep/ DWQMS Coordinator Prep and update Operational Plan for Council update James Sticca James Sticca resources) Complete There was a delay in receiving the NSF accreditation Audit in 2017, which resulted in an incomplete Operational Plan update. Current working draft of the Ops Plan will be complete by Q3 of 2018 and will need to be endorsed by new Council in early Status of management action items identified between management reviews No action items identified during this time period. 11. Changes that could affect the Quality Management System The MOECC released Version 2.0 of the DWQMS in February of This document is being used as a guide to update City procedures, processes and best practises, most of which are included in the City s post-audit/inspection OFI action items. Page 9 of 11

10 In January of 2017, a change to Ontario Regulation 170/03 outlined that residential drinking water systems and non-municipal year-round residential drinking water systems that provide chlorination or chloramination are to be taking and analyzing samples from locations within their system that are likely to experience the formation of THMs and HAAs, which are both chlorine disinfection by-products. The City has been sampling for THMs for several years and commenced quarterly HAA testing in Although the Ontario Regulation 169/03 standard of 0.08 mg/l for HAAs in drinking water (based on a locational running annual average of a minimum of quarterly samples taken in the distribution system) does not come into effect until January 1, 2020, the City has been diligently monitoring HAA levels to proactively ensure values remain far below the 0.08 mg/l exceedance. In 2018, Public Health will be increasing the frequency of SDWS inspections. These inspections previously occurred once every four (4) years, and currently will be inspected annually (once a year). The City is working towards updating the SDWS (of which the City has three in total) checklists/inspection sheets to ensure compliance with the Public Health Directive Document for each system. The MOECC has plans to develop a second version of the Watermain Disinfection Procedure roughly within the next year. Current City operating procedures and operational logs will likely require updating following the additional/adjusted standards and requirements in this proposed Ministry document update. It should be noted that as of July 1, 2017, schools and child care centres in Ontario were required to test all fountains and drinking water taps in their facilities by Ministry prescribed timelines. As well, if a sample result exceeds the standard, immediate action would need to be taken until the issue was resolved. The increased lead testing requirements were developed to ensure all water taps serving drinking water to children in schools and child care centres are sampled for lead. The implementation of this program is currently the responsibility of the Public Health System. 12. Consumer feedback (i.e., internal & external communications) Environmental Services still continues to flush areas known to have low chlorine residuals weekly. Discoloured or dirty water calls have continued to decrease; this is due to the extensive capital work taking place in areas known for water quality issues. Page 10 of 11

11 13. Resources needed to maintain the Quality Management System The DWQMS Representative (Environmental Services Coordinator) continues to use an external consultant for the internal audit. This provides the DWQMS Representative with detailed reports and multi-industry expertise during the onsite audit. 14. Results of DWQMS Infrastructure Review The DWQMS Infrastructure Review is one of many documents which aid in the decision making process for determining Capital Works projects and schedules. The DWQMS Representative and the Manager of Environmental Services, along with the Asset and Infrastructure teams have worked collectively to prioritize the proposal of capital work for design. Suggestions are also provided by Environmental Services staff based on previous experience and were taken into consideration along with other factors, such as sewer separation. The process still remains as stated above. Additionally, as operational challenges arise, the Environmental Services Coordinator (DWQMS Rep) ensures these are communicated to the Manager of Environmental Services who flags these to the Asset and Infrastructure teams for future capital replacement programs. This consistent line of communication between Operations and Engineering was missing prior to the initiation of the DWQMS. 15. Operational Plan currency, content & updates The Operational Plan will be updated in 2018, prior to the next desktop audit, and will be scheduled for Municipal Council endorsement in Q2 or Q3 of Staff suggestions To date, no Staff suggestions have been made to improve the QMS. Page 11 of 11