All About Sanitary Surveys

David Edmunds

Environmental Program Specialist

ADEC Drinking Water Program

Sustained Compliance: What It Means to Public Water System Owners and Operators

September 23-24, 2010

• A brief history of the of the Sanitary Survey• Public Water System Definitions• Types of Water Systems• Sanitary Survey Schedule• What is a Sanitary survey?• Who conducts a Sanitary Survey?• What to Expect?• What are they looking for?• What if they find something?• Deficiencies• What is the information used for?• Conclusion• Discussion

What this presentation will cover:

2

History

• Sanitary Surveys have been conducted on Public Water Systems in Alaska since 1978. Many of these surveys were conducted by DEC and Federal agencies such as the Indian Health Service.

• In 1987, the U.S. EPA proposed the Total Coliform Rule. This rule, as proposed, raised the minimum number of total coliform samples from one to five per month for small PWS. Public health experts estimated that five (5) water samples was the minimum number needed to assure safe water. State agencies and public water suppliers pointed out the high costs and difficulties involved with a five fold increase in the number of water samples required. After negotiation, EPA agreed to not increase the number of routine samples if a sanitary survey were performed regularly.

3

What Public Water Systems Need Sanitary Surveys?

– Community Water System (C)• 25 residents• 15 service connections

– Non Transient Non Community (NTNC)• Not a community water system• Serves same people (non transient population) over 6 months per year

– Transient Non Community (TNC)• A non-community water system that does not regularly serve at least 25 of

the same persons (transient)

4

Types of Water Systems

• Surface Water Systems & GWUDISW– Filtration Treatment

• Conventional• Direct• Diatomaceous Earth• Slow Sand• Alternative

• Ground Water Systems– Treatment is usually for secondary contaminants (iron and

manganese)

5

Sanitary Survey Schedule

Approval To Construct

Approval to Operate

Water System Inventory Form

Community Water System 3 Years

TNC and

NTNC Water Systems

5 Years

6

What Is a Sanitary Survey?

• A sanitary survey is defined as "an onsite review of the water source, and the facilities, equipment, operation, and maintenance of a public water system." (18 AAC 80)

7

Who Conducts a Sanitary Survey?

• Approved Sanitary Survey Inspector– Must have gone through an approved

Sanitary Survey class– Could be either DEC staff or what we call

“third-party”

8

What To Expect?

• Sanitary Survey Inspector introduction• Check records, plans; and review files

– Site sampling plan– Past surveys– Plan Approval/modifications

• Operator Certification • Walk through the system

– Source, treatment, pumps, storage, and distribution

9

What Are Inspectors Looking For?• Source

– Potential sources of contamination– Separation distance

• Septic, fuel storage, etc.

– Construction of the source• Treatment (if appropriate)

– Disinfection– Filtration– Cross connections

10

What Are They Looking For? (cont’d)

• Storage– Overflow screen– Access

• Distribution– Checking for Cross-connections– Residual disinfection (if applicable)– Pressure and leaks

• Operations– Monitoring locations and equipment– Maintenance

• Anything that might impact public health

11

• Sampling Locations

12

What if They Find Something?

• Dependent on impact to public health• Deficiencies

– Significant– Minor– Recommendation

13

Significant Deficiencies• Significant Deficiencies

– Once notified by the state of deficiency• PWS must contact the Drinking Water Program to address

the significant deficiency or significant deficiencies • PWS to contact DWP within 30 days or less, depending on

severity (5 days or 24 hours;) on how to correct the deficiency

– Corrective Action Plan• “ a proposal, either by the department or submitted by the

owner of a public water system to the department for approval, to take one or more corrective actions according to a specified schedule”

– May require the system to be placed on a BWN, depending on the situation

14

Other Deficiencies

• Minor deficiencies– 120 days to have an action plan

• Recommendations– Best management practices

15

16

Critical Items Inspectors Need• Contact Information

– Owner information (Tribal or City)– Operator information (back-up operator as well)– Administrator

• Population– Resident– Transient– Non-ransient

• Service connections (How many? Residential vs. Commercial)• Treatment (Chlorination, Fluoridation, Coagulation, What is in use at the time of the

survey?)• Filtration (Type of filtration, how many, manufacturer, size, etc.)• Operating dates (when the system is in operation as well as commercial service

connections)• Verification of sampling points (Turbidity monitoring after filtration, Entry point and

chlorine levels)• Approval to operate

17

What Is the Information Used for?• Correct problems that might have an

impact on public health• Update the State Database• Verify that monitoring schedules reflect the

current water system and they are correct• Collect information on water systems on a

statewide level to help address potential problems and help implement new rules

18

• A brief history of the of the Sanitary Survey• Public Water System Definitions• Types of Water Systems• Sanitary Survey Schedule• What Is a Sanitary Survey?• What to expect?• What are inspectors looking for?• What if they find something?• Deficiencies• What is the information used for?

Conclusion

19

Helpful Links

• What is a Sanitary Survey

http://www.dec.state.ak.us/eh/dw/dwmain/what-survey.html • Approved Sanitary Surveyors

http://www.dec.state.ak.us/eh/dw/approved_surveyors.html • Public Water System Information;

http://www.dec.state.ak.us/eh/dw/dwmain/drinking_water.html • Public Water System Monitoring Summaries

http://map.dec.state.ak.us/eh/dww/index.jsp • Sanitary Survey information (Surveys due and overdue, Desktop ESS

downloads)

http://www.dec.state.ak.us/eh/dw/dwmain/sanitary_surveys.html

20