1. 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

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

3. 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. “

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

5. 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

6. 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

7. Possible Health Effects of Deficiencies

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

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

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

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

16. Examples of Potential Deficiencies
Pumps
Electrical wiring
Spare parts
Poor Condition

18. 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

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

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

23. 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

24. Deficiency Chart

25. 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

26. 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

27. Example of Corrective Action Plan

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

29. 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

30. 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
to the department
Written correspondence
Photographs

31. Deficiency Map

32. 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

33. Helpful Links What Is a Sanitary Survey?
Approved Sanitary Surveyors
Public Water System Information
Public Water System Monitoring Summaries (Drinking Water Watch)
Sanitary Survey information (Surveys due and overdue; Desktop ESS downloads)
Operator Certification

34. Any questions?