Dear YongYM,
Sorry delay in answering, I missed yr reply.
My initial suggestion is she checks the free chlorine level in the process input water (eg DPD tablets)) since this will be a bit more informative than her nose. Is that possible ? As you probably know, some processors routinely boost the "Cl2" content in the tapwater to (theoretically) help depress bacteria without causing any specific safety detriment to the subsequent cooked products AFAIK. Nonetheless I have also seen this idea taken too far (not baked products) causing noticeable flavour changes.
Rgds / Charles.C
added - I fear yr friend's idea rather invites an auditor question like "how much excess" 
if the water she is using is town mains, and regulated by an "authority" then they will have legal standards that they have to abide by (well in UK anyway....supposedly!)
as charles said you can check chlorine levels using DPD no1 tablets and if i remember right if you add a dpd no4 tablet you get free chlorine.
In canning the chlorine levels are raised in order to kill off bacteria on the cans. Cans can be cooked at 126 degrees at pressure for up to an hour and a half and the chlorine dissipates.
Im not sure why she needs to add a statement in her
HACCP?? Chlorine levels cannot be a
CCP as you don't really have any control over the levels. Id just have the limits in her QCP set up and make them wide enough but not too wide