After the Sanitary Survey Alaska Department of Environmental Conservation, Drinking Water Program presents Sustained Compliance for Public Water Systems, Chapter 2 After the Sanitary Survey David Edmunds Environmental Program Specialist Anchorage, Alaska September 29, 2011

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

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. “

Survey Frequency Requirements for Sanitary Survey Community water systems: Sanitary Surveys every 3 years NTNCWS/TNCWS: Sanitary Surveys every 5 years

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

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

Possible Health Effects of Deficiencies

Examples of Potential Deficiencies Source Construction of the source Contaminants; or separation distance not met

Examples of Potential Deficiencies Treatment (if appropriate) Disinfection Filtration Cross connections

Examples of Potential Deficiencies Distribution Cross-connections Pressure and leaks Pumps

Examples of Potential Deficiencies Storage Integrity/stability Screened Overflow Sealed Security

Examples of Potential Deficiencies Pumps Electrical wiring Spare parts Poor Condition

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

Examples of Potential Deficiencies Management and Operations Housekeeping Chemical storage, wiring, NSF, etc. Staffing and Daily Rounds Flushing program, Leak detection, Inspecting reservoir

Examples of Potential Deficiencies Operator compliance Public water system operators need to be certified in accordance with 18 AAC 74

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

Deficiency Chart

Sanitary Survey Report Report will consist of the following items: Cover letter Deficiency report Completed Question set Photo Log Site Schematic Treatment Schematic Lat/Long form for all sources Well log

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

Example of Corrective Action Plan

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

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

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

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

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 Certification http://www.dec.state.ak.us/water/opcert/index.htm

Any questions?