Information on Sanitary Surveys

Introduction
A safe and reliable drinking water supply is of fundamental importance to our health and well-being.  Through proper operation and maintenance of your water system, you assure that safe and reliable drinking water is served to the public.  The components of a routine sanitary survey discussed in this guide mirrors the eight major elements required in a survey by EPA and Alaska Department of Environmental Conservation.  Each section summarizes the information that can be found in the regulations.

1. Source (Protection, Physical Components and Condition)
2. Treatment
3. Distribution System
4. Finished Water Storage
5. Pumps/Pump Facilities and Controls
6. Monitoring/Reporting/Data Verification
7. Water System Management/Operation
8. Operator Compliance with State and Federal Requirements

Sanitary Survey Inspection Process - Regulatory requirement
As required under the federal Safe Drinking Water Act (SDWA), Alaska State regulations (18 AAC 80) call for a routine sanitary survey of all Community Water Systems using Groundwater, all Non-Transient, Non-Community Water Systems and all Transient Non-Community Water Systems once every five (5) years.  All Community Water Systems using Surface Water or Community Water Systems using Groundwater Under the Direct Influence of Surface Water (GWUDISW) are to be surveyed once every three (3) years.

What is a routine sanitary survey?
A routine sanitary survey is a periodic inspection of a water system's facilities, operations, and record keeping.  The inspections identify conditions that may present a sanitary or public health risk.

Who will conduct the survey?
Sanitary surveys are conducted either by ADEC staff or by an ADEC an approved third party sanitary surveyor.  Some sanitary surveyors are regional health corporation environmental health officers, while others are independent contractors.  ARWA has two approved third party surveyors who can provide this service.

How Much Will It Cost?
Below is a chart that describes for you surveyors and their fees.

Provider
Fee
Variables to Cost
ARWA
Member: No Charge Non-Member: $???
Membership Status.
No travel or per diem charges.
ADEC
$260 - $350
Type of System
No travel or per diem charges.
Regional
Health Corps
No Charge
Health Corps have limited travel funds.
Private Contractor
$200 - $500
Costs of Travel and Per Diem
Can be upwards of $1,500.

Sanitary survey costs vary widely, depending on the location, size, and type of system.  Some private inspectors charge by the hour while others charge a flat rate.  It is a good idea to obtain price quotes from several inspectors.  The ADEC continues to conduct sanitary surveys, but not as a routine service to water systems.  The agency has a table of fixed fees listed in the drinking water regulations, 18 AAC 80.
Some native community PWS may be eligible for assistance from Native Health Corporations such as Tanana Chiefs Conference, Southeast Alaska Regional Health Corporation, Yukon-Kuskokwim Health Corporation, Norton Sound Health Corporation, Bristol Bay Area Health Corporation, and Maniilaq Association.  Staff with these associations may conduct sanitary surveys for no charge.  Increasing the total coliform bacteria testing to five samples per month probably is the more expensive option over the long term.

Minimum Components of a Routine Sanitary Survey
Discussion and review of records
When the surveyor arrives to conduct the routine sanitary survey, the first thing they will do is go over the water system records with you.  This includes discussion and review of the 1) water system inventory, as reported in the ADEC record; 2) distribution system plans and maps; 3) routine operation and maintenance records; 4) coliform monitoring history and plan; 5) source water quality monitoring history and waiver status; and 6) additional components.  You can help prepare for the inspection by gathering, reviewing, and organizing these records to easily share them with the surveyor.

1. A review of the water system inventory record is done to make sure all the information listed for your water system is correct.  This includes information on primary contacts, population served, number of connections, and storage capacity.  The surveyor will note the changes directly on the form and return it to ADEC to update their computer records.  An accurate water system inventory is critical to properly classify a water system and to provide ADEC with emergency contact information.
2. The surveyor will want to look at your distribution system plans and maps to see how often the maps are updated and if locations of the lines, valves, meters, tanks, sources, and treatment facility locations are accurate.  Good things to have on a map are the size of the main line, the type of pipe installed, depth of bury, and even when the pipe was installed.
3. A review of your routine operation and maintenance records for the necessary practices that will ensure your system is capable of supplying safe and reliable water.  Tips on how to develop an operations and maintenance manual and recommended maintenance schedules can be provided by ARWA upon request.
4. A review of your coliform monitoring history and plan and sampling procedures and latest results of any bacteriologic samples taken within the last two years.
5. A review of your source water quality monitoring history, if applicable, waiver status, and latest results of any samples taken within the last two years, including bacteriologic, lead/copper, inorganic, organic (VOC/SOC), radionuclide, trihalomethanes, and turbidity.
6. Depending on the complexity of the water system, the surveyor may ask about additional components, such as the status of other management, operation and maintenance documents.  These could include:

• Small water system management program (SWSMP);
• Water supply security measures;
• Cross connection control program and test histories of any backflow prevention assemblies;
• Operator certification status.; and
• Source water or wellhead protection program.
• If you have not developed a SWSMP, water supply security measures, or cross connection control program, planning handbooks are available from ARWA to assist you in developing your programs.

Inspection of water system
After the water system records have been discussed and reviewed, the surveyor will then take a tour of the water system itself.  The tour will include an inspection of the 1) drinking water source and sanitary control area; 2) treatment equipment; 3) pumps, pumping facilities and controls; 4) finished water storage; and 5) distribution system.  Be sure to arrange for system personnel to be available on the survey date so they can show the surveyor around the system.

1. The surveyor will look at each drinking water source and sanitary control area, including emergency or seasonal sources, to see that they are properly secured and protected from possible sources of chemical or biological contamination.  On the wellhead, they will check for several items, such as: the well casing is at least 12 inches above the floor or pad; a sanitary seal (the seal between the wellhead and the pump); a source sampling tap; and an inverted screened vent. They will also look for any obvious holes into the wellhead for mice or bugs to crawl into and/or fall into the well and contaminate the water.
2. Next, they will look at your treatment equipment, including chlorination.  They will check that your equipment is working properly, check dosage rate calculations and go over required chlorination reporting, including the daily residual readings and how they are taken and recorded.
3. They will look at pumps, pumping facilities and controls to make sure they are in good working order and the facilities are clean.
4. Each finished water storage tank is looked at individually for structural soundness (interior and exterior damage and rust), access hatch lids are properly gasketed and secured, vents are adequately screened, the overflow and drain pipes are screened with a proper air gap, and area is properly secured.  If these are not protected, birds, bats, insects, rainwater and dust can enter and contaminate the stored water.
5. Finally, they will tour the distribution system to better understand the system layout, the pressure zones, elevations, dead ends, and to check for potential high health hazard facilities that may need cross connection protection.

Safe inspections
What if the surveyor can’t safely inspect your water system?
Situations arise in the field where the surveyor can’t proceed with part or all of an inspection due to unsafe work conditions.  They will let you know why they can’t proceed and either point out what is needed before they can safely proceed or request that you get the information for them.

Unsafe to survey
If too many of the system’s facilities are unavailable for inspection due to safety issues, the surveyor may decide that the system is not available to survey.  In this case, the water system will receive written notice that it cannot be surveyed and will not receive credit for a survey.  Sanctions may be imposed on systems refusing or not available for survey.

Things to remember to provide accessibility

• Have keys needed to open buildings, gates, well enclosures, hatches, etc.
• Special tools may be needed to open manholes or heavy lids.
• Clear brush or other vegetation around wells or buildings.
• Have available documentation of the last time elevated storage tank hatches, vents and overflow screens and gaskets were checked.

Common Deficiencies Surveyors Hope NOT to Find
Inspections reveal poor housekeeping
Sanitary surveys are a key component to protecting drinking water from contamination.  Many deficiencies commonly found during a survey are often the result of poor housekeeping or maintenance.  This possible route of contamination can be easily eliminated with simple improvements in housekeeping and maintenance practices.  The following is a list of commonly found deficiencies surveyors hope not to find:

• Lack of a screened vent or other holes in the well casing.
• Lack of a screen or a damaged screen on storage tank vents.
• Storage tank overflows with out screens or flap valves.
• Old piping and tanks not eliminated (not just "valved off").
• Did not use proper flushing and disinfection techniques after construction or repairs.
• Poor choice of water sampling tap.
• Poor control of sanitary control area around drinking water source.
• Deficiencies noted on a previous survey have not been corrected.
• Lack of a watertight cap on a well developed as a pitless adapter.
• Lack of a source water meter.  On the next few pages are some photos of poor housekeeping habits or maintenance practices sanitary surveyors will be looking for when they visit your water system.

Next Steps
What happens after the survey is completed?
After the survey is done, the surveyor will provide you with a completed survey checklist and a summary report with findings.  Please read the report carefully, as it describes any observed deficiencies found during the inspection.  It is your responsibility to correct these deficiencies promptly.  A copy of the survey results will also go to the appropriate ADEC Environmental Specialist for review.  ADEC will notify you in writing if any immediate follow-up action is required.

Potential enforcement actions
What happens if I do not follow the requirements?
The primary reason for following the requirements is to insure that the water you serve people is safe to drink.  Failing to meet your legal responsibilities to correct deficiencies promptly may result in increased monthly coliform monitoring to five samples per month, state/federal significant non-complier (SNC) status, and the possibility of civil penalties.  Problems that could result include:

• The denial of other licenses or permits, such as restaurant permits or liquor licenses.
• Lawsuits – Water users may file lawsuits against the owner.
• Loss of Approval to Operate – This could result in the denial of loans by a lending institution for buying, refinancing, or remodeling of the facilities served by the system.  This could also result in the denial of building permits.

Training Material :
Sanitary Survey Fundamentals Prep Course

This CD contains a short, interactive course with the basics of small public water system operations.  Though created for persons wanting to take sanitary survey training, the course provides a good foundation for you to prepare for a sanitary survey.  A zip file may be downloaded from the University of Montana's Water Center Web site (link to http://water.montana.edu/training/ssf/default.htm) or you may order a CD from the National Drinking Water Clearinghouse at 800-624-8301 or 304-293-4191.  Refer to the “Sanitary Survey Fundamentals Prep Course,” product #DWCDTR19.