After the Sanitary Survey

David EdmundsEnvironmental Program Specialist

Anchorage, AlaskaSeptember 29, 2011

Alaska Department of Environmental Conservation, Drinking Water Program

presents

Sustained Compliance for Public Water Systems, Chapter 2

Presentation Outline• Sanitary Survey Definition• Sanitary Survey Frequency• Sanitary Survey Inspector• Deficiencies Definition• Possible Health Effects of Deficiencies• Examples of Potential Deficiencies• Deficiency Chart• Sanitary Survey Report• Notification From DEC• Corrective Action Plan• Documenting Corrected Deficiencies• Conclusion

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What Is a Sanitary Survey?

• “Means a review consisting of an onsite inspection and review of the water source, treatment, the distribution system, finished water storage, each pump and pump facility and controls, monitoring, reporting, data verification, and management and operation of a public water system to evaluate the adequacy of the source, facilities, equipment, operation, and maintenance for producing and distributing safe drinking water; and a review of operator compliance with 18 AAC 74 and this chapter; and includes writing, signing, and submitting the completed report to the department and owner. “

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Survey Frequency• Requirements for Sanitary Survey

– Community water systems: Sanitary Surveys every 3 years

– NTNCWS/TNCWS: Sanitary Surveys every 5 years

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Who Conducts a Sanitary Survey?• Approved Sanitary Survey Inspector

– Must have completed a DEC-approved Sanitary Survey class

– Could be either DEC staff or what we call an approved “3rd-party” sanitary survey inspector

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Deficiencies• Deficiency

– means a condition of a public water system, or an action or omission of an owner or operator of a public water system, that directly or indirectly causes, or has the potential to cause, a risk to public health; an unplanned interruption of service in the public water system; or any deviation from professional standards of engineering, sanitation, or public health applicable to public water systems• Significant Deficiencies• Minor Deficiencies• Recommendations

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Possible Health Effects of Deficiencies

Examples of Potential Deficiencies • Source

– Construction of the source– Contaminants; or separation distance not met

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Examples of Potential Deficiencies

• Treatment (if appropriate)– Disinfection– Filtration– Cross connections

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Examples of Potential Deficiencies

• Distribution– Cross-connections– Pressure and leaks– Pumps

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Examples of Potential Deficiencies• Storage

– Integrity/stability– Screened Overflow– Sealed– Security

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Examples of Potential Deficiencies

• Pumps– Electrical wiring– Spare parts– Poor Condition

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Examples of Potential Deficiencies

• Monitoring and Reporting and Data Verification– Not monitoring in the correct place– Records not kept on-site, not available– No approved site sampling plan– Testing equipment and facilities inadequate

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Examples of Potential Deficiencies

• Management and Operations– Housekeeping

• Chemical storage, wiring, NSF, etc.– Staffing and Daily Rounds

• Flushing program, Leak detection, Inspecting reservoir

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Examples of Potential Deficiencies

• Operator compliance– Public water system operators need to be

certified in accordance with 18 AAC 74

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Examples of Potential Deficiencies

• Anything that might impact public health– Separation distances from

contamination to the source• Septic systems• Buried fuel storage and lines• Above ground fuel storage• Landfills• Farms or stockyards

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Deficiency Chart

Sanitary Survey Report

Report will consist of the following items:Cover letterDeficiency reportCompleted Question setPhoto LogSite SchematicTreatment SchematicLat/Long form for all sourcesWell log

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Corrective Action Plan– Corrective Action Plan

• Approved by the Department• Must be in writing; if the severity warrants quick action, then

documentation can follow after the item is addressed• Must include a schedule with one or more dates for

completion of specified corrective actions• Final completion of all corrective actions must be no later

than 120 days after the date of department approval of the corrective action plan

• Owner to notify the department no later than five days after final completion of all corrective actions

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Example of Corrective Action Plan

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Notification from DEC

• Letter from DEC showing the deficiency or deficiencies from the report, with dates as to when they should be corrected

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Deficiencies found

• Deficiencies have to be corrected or addressed

• If not corrected or if left unresolved, deficiencies can result in violations

• Additional enforcement can include Notice of Violation (NOV) and Administrative Penalties

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Documenting Corrective Actions

• Require the owner to notify the department no later than five days after final completion of all corrective actions

• Based on the Corrective Action Plan– Email to the department– Written correspondence– Photographs

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Deficiency Map

Conclusion• Sanitary Survey Definition• Survey Frequency• Sanitary Survey Inspector• Deficiencies Definition• Possible Health Effects of Deficiencies• Examples of Potential Deficiencies• Deficiency Chart• Sanitary Survey Report• Notification From DEC• Corrective Action Plan• Documenting Corrected Deficiencies

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Helpful Links• What Is a Sanitary Survey?

http://www.dec.alaska.gov/eh/dw/dwmain/what-survey.html • Approved Sanitary Surveyors

http://dec.alaska.gov/eh/dw/approved_surveyors.html • Public Water System Information

http://www.dec.alaska.gov/eh/dw/dwmain/drinking_water.html • Public Water System Monitoring Summaries

http://www.dec.alaska.gov/eh/dw/index.htm (Drinking Water Watch) • Sanitary Survey information (Surveys due and overdue; Desktop ESS

downloads)http://www.dec.alaska.gov/eh/dw/dwmain/sanitary_surveys.html

• Operator Certificationhttp://www.dec.state.ak.us/water/opcert/index.htm

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Any questions?

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