Ministry of the Environment and Climate Change

Windsor Area Office Unit 620 – 4510 Rhodes Dr Windsor ON N8W 5K5 Tel. : 519 948-1464 1-800-387-8826 Fax: 519 948-2396

Ministère de l’Environnement et de l’Action en matière de changement climatique Bureau du Secteur de Windsor No 620 – 4510 Ch Rhodes Windsor ON N8W 5K5 Tél. : 519 948-1464 1-800-387-8826 Téléc. : 519 948-2396

October 4, 2017 Chief Administrative Office The Corporation of the Municipality of Leamington 111 Erie Street North Leamington, ON N8H 2Z9 Attention: Peter Neufeld, Chief Administrative Officer Re: Leamington Distribution System – Union DS Inspection Report Please find enclosed the Drinking Water System Inspection Report for the inspection that was conducted at the Leamington (Union) Distribution System (DWS#220004992) on September 12, 2017. Section 19 of the Safe Drinking Water Act (Standard of Care) creates a number of obligations for individuals who exercise decision-making authority over municipal drinking water systems. Please be aware that the Ministry has encouraged such individuals, particularly municipal councillors, to take steps to be better informed about the drinking water systems over which they have decision-making authority. These steps could include asking for a copy of this inspection report and a review of its findings. Further information about Section 19 can be found in “Taking Care of Your Drinking Water: A guide for members of municipal council” found under “Resources” on the Drinking Water Ontario website at www.ontario.ca/drinkingwater. 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 B 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. IRR ratings are published (for the previous inspection year) in the Ministry’s Chief Drinking Water Inspectors’ Annual Report. If you have any questions or concerns regarding the rating, please contact Marc Bechard, Drinking Water Program Supervisor, at 519-383-3778. If you have any questions or concerns regarding this report, please call me at (519) 948-2467. Yours truly, Emily Awad Water Inspector, Provincial Officer #1823 Safe Drinking Water Branch, Windsor Area Office

File: SI-ES-LE-540

Encl. cc: Nelson Carvalho, Water Services Supervisor, and Shannon Belleau, Manager of Environmental Services, Municipality of Leamington Ken Penney, Process & Compliance Technician, Union Area Water Supply System; Dr. Wajid Ahmed, Medical Officer of Health (A), Theresa Marentette, Director of Health Protection, Mike Tudor, Manager, Health Inspection Department, and Phil Wong, Manager, Health Inspection Department, Windsor-Essex County Health Unit; Marc Bechard, Water Compliance Supervisor, Ministry of Environment & Climate Change.

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Ministry of the Environment and Climate Change

LEAMINGTON DISTRIBUTION SYSTEM - UNION DS

Inspection Report

Site Number: 220004992Inspection Number: 1-F93SGDate of Inspection: Sep 12, 2017Inspected By: Emily Awad

Table of Contents Owner Information 2 Inspection Details 2 Inspection Summary 4 Introduction 4 Treatment Processes 4 Treatment Process Monitoring 5 Distribution System 5 Operations Manuals 6 Logbooks 6 Certification and Training 6 Water Quality Monitoring 7 Water Quality Assessment 7 Reporting & Corrective Actions 8 Non-Compliance with Regulatory Requirements and Actions Required 9 Summary of Recommendations and Best Practice Issues 10 Signatures 11 Appendix A: Key Reference and Guidance Material Appendix B: Inspection Summary Rating Record

Ministry of the Environment & Climate Change Inspection Report Table of Contents

Ministry of the Environment and Climate Change Inspection Report

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OWNER INFORMATION:Company Name: LEAMINGTON, THE MUNICIPALITY OF THE TOWNSHIP OFStreet Number: 111 Unit Identifier:Street Name: ERIE St NCity: LEAMINGTONProvince: ON Postal Code: N8H 2Z9

CONTACT INFORMATION_____________________________________________________________________________________________________________________

Type: Operating Authority Name: Nelson CarvalhoPhone: (519) 326-4454 Fax: (519) 326-5987Email: ncarvalho@leamington.caTitle: Supervisor, Leamington Water Services, Municipality of Leamington

Type: Operating Authority Name: Ken PenneyPhone: (519) 326-4447 Fax: (519) 326-0450Email: kpenney@ocwa.comTitle: Process & Compliance Technician, OCWA

INSPECTION DETAILS:

Site Name: LEAMINGTON DISTRIBUTION SYSTEM - UNION DSSite Address: 10 Hazelton Street LEAMINGTON ON N8H 1B6County/District: LeamingtonMOECC District/Area Office: Windsor Area OfficeHealth Unit: WINDSOR-ESSEX COUNTY HEALTH UNITConservation Authority: Essex Region Conservation AuthorityMNR Office: Chatham Regional OfficeCategory: Large Municipal ResidentialSite Number: 220004992Inspection Type: AnnouncedInspection Number: 1-F93SGDate of Inspection: Sep 12, 2017Date of Previous Inspection: Aug 25, 2016

COMPONENTS DESCRIPTION______________________________________________________________________________________________________________________

Site (Name): MOE DWS MappingType: DWS Mapping Point Sub Type:

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Site (Name): LEAMINGTON (UNION) DISTRIBUTION SYSTEMType: Other Sub Type:Comments:The Leamington Distribution System is a stand-alone water distribution system comprised of two subsystems; the Leamington (Union) distribution system and the Leamington (Wheatley) distribution system, both owned by the Corporation of the Municipality of Leamington. The two distribution subsystems are connected to each other at Deer Run Road and Erie Street South in Leamington but the connection valve is closed at all times except in emergency

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situations.The scope of this inspection is limited to the Leamington (Union) distribution system.The 31,000 residents connected to the Leamington (Union) distribution system are supplied by treated water from theUnion Water Supply System (UWSS) which is owned by the Towns of Kingsville, Essex and Lakeshore, and the Municipality of Leamington, and is managed by the Union Water Supply System Joint Board of Management.The UWSS monitors and controls the combined chlorine residual leaving the water treatment plant to ensure there is sufficient secondary disinfection throughout the Leamington (Union) distribution system. The Ontario Clean Water Agency (OCWA) samples and tests the Leamington (Union) distribution system on behalf ofLeamington and the Leamington Water Services Department operates, repairs and maintains it.Two 750 mm pressure pipes take treated water from the UWSS along County Road 34 into the Town of Leamington from the west boundary of the municipality. These trunk mains, the Leamington 1500 m3 elevated tank, and the 6800 m3 Albuna tower (located in Kingsville at the municipal boundary) are owned by the UWSS and are not included within the scope of this inspection. The two elevated storage structures maintain distribution system pressure which iscontrolled and monitored from the UWSS.The Leamington (Union) distribution system is connected to the Kingsville (Union) distribution system through an open valve on County Road 14. The Leamington (Union) distribution system also has an interconnect to the Stoney Point Drinking Water System in the Town of Lakeshore at Hwy. 77 and County Road 8. This valve is closed at all times and will only be opened in an emergency.

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INSPECTION SUMMARY:

Introduction

• The primary focus of this inspection is to confirm compliance with Ministry of the Environment and ClimateChange (MOECC) legislation as well as evaluating conformance with ministry drinking water policies and guidelines during the inspection period.

This drinking water system is subject to the legislative requirements of the Safe Drinking Water 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 to Section 81 of the SDWA.

This report is based on an inspection of a "stand alone connected distribution system". This type of system receives treated water from a separately owned "donor" system. This report contains the elements required to assess key compliance and conformance issues associated with a "receiver" system. This report does not contain items associated with the inspection of the donor system, such as source waters, intakes/wells and treatment facilities.

This report is based on a "focused" inspection of the system. Although the inspection involved fewer activities than those normally undertaken in a detailed inspection, it contained critical elements required to assess key compliance issues. This system was chosen for a focused inspection because the system's performance met the ministry's criteria, most importantly that there were no deficiencies as identified in O.Reg. 172/03 over the past 3 years. The undertaking of a focused inspection at this drinking water system does not ensure that a similar type of inspection will be conducted at any point in the future.

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

Specifically, this review includes an assessment of compliance/conformance in relation to the following:• Drinking Water Systems Regulation (O. Reg. 170/03);• Drinking Water Operator and Water Quality Analyst Certification Regulation (O. Reg. 128/04) with respect tofacility certification, operator licensing and operating standards;• Drinking Water System Licence 033-101, issued November 2, 2016, related to selected Performance, Monitoring and Recording, Operations and Maintenance requirements;• Drinking Water Works Permit 033-201, issued November 2, 2016, and• Ontario Drinking Water Quality Standards based on water quality data generated since the previous inspection.

The inspection of the Leamington Distribution System was conducted on an announced basis on September 12, 2017 and covers the inspection period August 1, 2016 to August 31, 2017.

Treatment Processes

• The owner/operating authority was in compliance with the requirement to prepare Form 1 documents as required by their Drinking Water Works Permit during the inspection period.

Work was conducted on four watermain addition/replacement projects in the Leamington (Union) distribution system during the inspection period. A Form 1, "Record of Watermains Authorized as a Future Alteration" was completed for each project, as required by condition 3.3 of the MDWL 033-201. The owner provided dates that the watermains were put into service and all projects were completed after the Form 1 dates.The Form 1 documents pertained to the following projects:

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Treatment Processes

1. Replacement of 150mm diameter ductile iron/asbestos cement watermain with 300 to 200mm diameter PVC watermain on Bevel Line Road (Phase 1).2. Replacement of 200mm diameter asbestos cement watermain with 200m diameter PVC watermain along Point Pelee Drive (Phase 2).3. Replacement of 150mm diameter asbestos cement watermain with 200mm diameter PVC watermain along PointPelee Drive (Phase 3 & 4).5. Replacement of watermain with ~550m of 150mm diameter PVC main, as well as new fire hydrants, appurtenances and services on Chestnut Street.6. Replacement of approximately 180m of watermain with 150mm diameter PVC on Russell and Chestnut Sts, as well as new apurtenances and services.7. Replacement of 150mm diameter asbestos cement watermain on Danforth Avenue with a new 300mm diameter PVC watermain.

Treatment Process Monitoring

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

Secondary disinfection is supplied entirely by the Union Water Supply System (UWSS). No re-chlorination takes place after entering the Leamington distribution system. Ontario Clean Water Agency (OCWA) staff collect all regulatory samples for the Leamington distribution system.

Logs indicate that combined chlorine residual was measured at four and three sample locations on separate days, at least 48 hours apart, for a total of seven times per week as required. Combined chlorine residual results ranged from 0.93 to 1.98mg/L, above the required 0.25mg/L, and below 3.0mg/L, the maximum combined chlorine residual recommended in the Procedure for Disinfection of Drinking water in Ontario. This same Procedure recommends anoptimum target for combined chlorine residual for systems designed to operate with chloramination of 1.0 mg/L at all locations within the distribution system to suppress bacterial activity that causes nitrification (converts ammonia to nitrite and nitrate). Logged results show that there was a small number (1.26% of measurements) of combined chlorine residuals that measured less than 1.0 mg/L.

During the 2017 Inspection, chlorine residuals were measured at the kitchen tap of the Municipal Waste Services Department (free=0.10mg/L, total=1.71mg/L, combined=1.61mg/L).

Distribution System

• Existing parts of the distribution system that are taken out of service for inspection, repair or other activities that may lead to contamination, and all new parts of the distribution system that come in contact with drinking water, were disinfected in accordance with Schedule B, Condition 2.3 of the Drinking Water Works Permit, or an equivalent procedure (i.e. the Watermain Disinfection Procedure).

Schedule B, Condition 2.3 of Drinking Water Works Permit (DWWP) No. 033-201 requires all parts of the drinking water system in contact with drinking water, including water mains, which are added, modified, replaced, extended or taken out of service for inspection or repair or any other activities that may lead to contamination, to be disinfected in accordance with the ministry's Watermain Disinfection Procedure by May 2, 2017.

Standard Operating Procedure (SOP) #16, created on April 27, 2017, provides the steps to installing a new watermain, including flushing and swabbing, pressure and leak test, and disinfection, based on the ministry's Watermain Disinfection Procedure and applicable AWWA standards. A review of related SOPs is planned to remove duplicate information/procedures. All staff have been trained in the new Watermain Disinfection Procedure. A recently updated Water Main Shutdown Report was adopted by the operating authority.

It is recommended that the operating authority review the current SOPs and reports to ensure they conform to the

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Distribution System

documentation requirements in the ministry's Watermain Disinfection Procedure. In addition, the relevant SOPs should be updated to include information regarding Category 1 and 2 watermain breaks and reporting requirements.

Operations Manuals

• The operations and maintenance manuals contained plans, drawings and process descriptions sufficient for the safe and efficient operation of the system.

Each operator has access to electronic maps of the Leamington (Union) and Leamington (Wheatley) distribution systems onsite or in their vehicles via VPN. They also have access to all water related items including SOPs and CAD drawings for locates.

• The operations and maintenance manuals met the requirements of the Drinking Water Works Permit and Municipal Drinking Water Licence issued under Part V of the SDWA.

Condition 16.1, Schedule B of Municipal Drinking Water License (MDWL) 033-101 requires an up-to-date operations and maintenance manual to be maintained and available for reference by all persons responsible for all or part of the operation or maintenance of the drinking water system. Condition 16.2 of the MDWL lists the minimumrequired documents to be included in the operations and maintenance manual.

The Drinking Water Quality Management Standard documents serve as the operations and maintenance manual for the Leamington Distribution System. The Operational Plan includes a description of the drinking water system and components, system maps, critical control points for secondary disinfection, sampling, testing and monitoring procedures, equipment calibration and maintenance, and an emergency management procedure. The current license and permit are stored electronically and are accessible to all staff.

Complaints are logged on the community complaint form which provides the details of the complaint and any followup actions. There are plans to streamline their complaints system, as they also receive complaints from UWSS, the main Municipal Office as well as Essex Power, and these are logged in different formats.

Logbooks

• Logbooks were properly maintained and contained the required information.

• Records or other record keeping mechanisms confirmed that operational testing not performed 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.

All chlorine residual monitoring, conducted during regular compliance and additional chlorine program sampling, was done by certified operators from the donor Union Water Supply System. The operating authority's operators conduct additional monitoring during hydrant and dead-end flushing and all operators have valid certifications.

Certification and Training

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

• Operators in charge had been designated for all subsystems which comprised the drinking-water system.

The designated ORO for the Leamington (Union) Distribution System is also the designated OIC for the system. When he is away, he appoints a replacement and this is recorded in the logbook.

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Water Quality Monitoring

• All microbiological water quality monitoring requirements for distribution samples were being met.

As per O.Reg. 170/03 s10-2, a minimum of one sample per week, and at least 39 samples per month must be collected from the distribution system (8 samples plus 1 sample for every 1000 people). All samples must be analysed for E. coli (EC) and total coliforms (TC) and 25% of the samples must be analysed for heterotrophic bacteria using the heterotrophic plate count (HPC) method.

Microbiological water quality monitoring data were reviewed for the period of August 1, 2016 to August 31, 2017. The owner surpassed minimum requirements. Each month, 40 to 52 samples were collected for EC/TC and 10 to 14 samples for HPC.

• All haloacetic acid water quality monitoring requirements prescribed by legislation are being conducted within the required frequency and at the required location.

As of January 1, 2017, a new clause in O.Reg. 170/03 (s13-6.1), states that the owner/operating authority of a system that provides chlorination or chloramination shall ensure that at least one distribution sample is taken every 3 months, 60 to 120 days after the sample date of the previous three-month period, from a point in the distribution system that is likely to have an elevated potential for the formation of haloacetic acids (HAAs), and have the sampletested for HAAs.

During the inspection review period, samples were collected within the prescribed time frame (January 11, April 3, and July 17, 2017). The total HAA concentration was below the detection limit (5.3ug/L) for all samples.

• All trihalomethane water quality monitoring requirements prescribed by legislation were conducted within the required frequency and at the required location.

As per O.Reg. 170/03 s13-6, the owner/operating authority of a system that provides chlorination or chloramination shall ensure that at least one distribution sample is taken every 3 months, 60 to 120 days after the sample date of the previous three-month period, from a point in the distribution system that is likely to have an elevated potential for the formation of trihalomethanes (THMs), and have the sample tested for THMs.

During the inspection review period these samples were collected at site SS-L-14 within the prescribed time frame (October 3, 2016 and January 11, April 3, and July 17, 2017). The running annual average for this reporting period is 20.35ug/L.

Drinking water system owners/operating authorities are now responsible for calculating the RAA (Running Annual Average) for THM's. The THM standard in O. Reg. 169/03 is based on the RAA, therefore all THM results from samples taken during the calendar quarter must now be included in the RAA quarterly calculation. Owners/operating authorities are required to document how the RAA is calculated, what values are used in the calculation, and ensure that the data used to produce this calculation is available, if requested. The owner/operatingauthority is required to notify the existing authorities of any adverse test results within 7 days of the end of every calendar quarter. Verbal notification to the authorities is no longer required, only a written notification. Resamples are no longer required following an adverse test result for the THM RAA.

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

Water Quality Assessment

• Records did not show that all water sample results taken during the inspection review period did not exceed the values of tables 1, 2 and 3 of the Ontario Drinking Water Quality Standards (O.Reg. 169/03).

Two total coliform exceedances were detected on August 3, 2016 (TC=8 cfu/100mL) and May 24, 2017 (TC=7

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Water Quality Assessment

cfu/100mL) in the Leamington Distribution System. The combined chlorine residuals were above 1mg/L in both instances (1.53 and 1.82mg/L, respectively).

Reporting & Corrective Actions

• Corrective actions (as per Schedule 17) had been taken to address adverse conditions, including any other steps that were directed by the Medical Officer of Health.

Following both adverse incidents, the operating authority flushed the watermain and collected two sets of resamples 24 hours apart. For the May 2017 incident, the operator did not collect the required samples upstream and downstream of the affected site, only at the site. The operating authority notified the ministry on May 29, 2017 and followed the direction of the health unit to conduct sampling at the site, upstream and downstream that day. The operating authority was directed to review the pertinent SOPs with all staff; staff review sign-off was provided on June 6, 2017.

In the future, the operating authority shall ensure that all required corrective actions are conducted for any adverse result.

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

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‏NON-COMPLIANCE WITH REGULATORY REQUIREMENTS AND ACTIONS REQUIRED

This section provides a summary of all non-compliance with regulatory requirements identified during the inspection period, as well as actions required to address these issues. Further details pertaining to these items can be found in the body of the inspection report. Not Applicable

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SUMMARY OF RECOMMENDATIONS AND BEST PRACTICE ISSUES

This section provides a summary of all recommendations and best practice issues identified during the inspection period. Details pertaining to these items can be found in the body of the inspection report. In the interest of continuous improvement in the interim, it is recommended that owners and operators develop an awareness of thefollowing issues and consider measures to address them. Not Applicable

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SIGNATURES _____________________________________________________________________________________________________________________________________________________________

Inspected By: Signature: (Provincial Officer)

Emily Awad

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Reviewed & Approved By: Signature: (Supervisor)

Marc Bechard

Review & Approval Date:

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

End of Report

Stakeholder Appendix

Ministry of the Environment & Climate Change Inspection Report

Appendix A

Key Reference and Guidance Material for Municipal Residential Drinking Water SystemsMany useful materials are available to help you operate your drinking water system. Below is a list of key materials owners and operators of municipal residential drinking water systems frequently use.

To access these materials online click on their titles in the table below or use your web browser to search for their titles. Contact the Public Information Centre if you need assistance or have questions at 1-800-565-4923/416-325-4000 or picemail.moe@ontario.ca.

For more information on Ontario’s drinking water visit www.ontario.ca/drinkingwater and email drinking.water@ontario.ca to subscribe to drinking water news.

PIBS 8990b01

ontario.ca/drinkingwater

PUBLICATION TITLE PUBLICATION NUMBER

Taking Care of Your Drinking Water: A Guide for Members of Municipal Councils 7889e01

FORMS: Drinking Water System Profile Information, Laboratory Services Notification, Adverse Test Result Notification Form

7419e, 5387e, 4444e

Procedure for Disinfection of Drinking Water in Ontario 4448e01

Strategies for Minimizing the Disinfection Products Trihalomethanes and Haloacetic Acids 7152e

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

Filtration Processes Technical Bulletin 7467

Ultraviolet Disinfection Technical Bulletin 7685

Guide for Applying for Drinking Water Works Permit Amendments, Licence Amendments, Licence Renewals and New System Applications

7014e01

Certification Guide for Operators and Water Quality Analysts

Guide to Drinking Water Operator Training Requirements 9802e

Taking Samples for the Community Lead Testing Program 6560e01

Community Sampling and Testing for Lead: Standard and Reduced Sampling and Eligibility for Exemption

7423e

Guide: Requesting Regulatory Relief from Lead Sampling Requirements 6610

Drinking Water System Contact List 7128e

Technical Support Document for Ontario Drinking Water Quality Standards 4449e01

March 2015

Inspection Rating Record

Ministry of the Environment & Climate Change Inspection Report

Appendix B

Ministry of the Environment - Inspection Summary Rating Record (Reporting Year - 2017-2018)

DWS Name: LEAMINGTON DISTRIBUTION SYSTEM - UNION DSDWS Number: 220004992

DWS Owner: Leamington, The Municipality Of The Township OfMunicipal Location: Leamington

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

Type Of Inspection: AdhocInspection Date: September 12, 2017

Ministry Office: Windsor Area Office

Maximum Question Rating: 202

Inspection Module Non-Compliance Rating

Treatment Processes 0 / 4

Distribution System 0 / 21

Operations Manuals 0 / 28

Logbooks 0 / 18

Certification and Training 0 / 14

Water Quality Monitoring 0 / 51

Reporting & Corrective Actions 0 / 45

Treatment Process Monitoring 0 / 21

TOTAL 0 / 202

Inspection Risk Rating 0.00%

FINAL INSPECTION RATING: 100.00%

Inspection Rating Record Generated On 04-OCT-17 (Inspection ID: 1-F93SG).R:\Public\DW\DW-08 Compliance\Shared Comp Data\Inspection Ratings 1718\Marc Bechard\1718 LEAMINGTON DISTRIBUTION SYSTEM - UNION DS 1-F93SG.pdf

Ministry of the Environment - Detailed Inspection Rating Record (Reporting Year - 2017-2018)

DWS Name: LEAMINGTON DISTRIBUTION SYSTEM - UNION DSDWS Number: 220004992

DWS Owner: Leamington, The Municipality Of The Township OfMunicipal Location: Leamington

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

Type Of Inspection: AdhocInspection Date: September 12, 2017

Ministry Office: Windsor Area Office

Maximum Question Rating: 202

Inspection Risk Rating 0.00%

FINAL INSPECTION RATING: 100.00%

Inspection Rating Record Generated On 04-OCT-17 (Inspection ID: 1-F93SG).R:\Public\DW\DW-08 Compliance\Shared Comp Data\Inspection Ratings 1718\Marc Bechard\1718 LEAMINGTON DISTRIBUTION SYSTEM - UNION DS 1-F93SG.pdf