Imagine if you will that you are standing before a studio audience with four of your closest relatives (including your know-it-all brother-in-law Ed) as that handsome devil Richard Dawson prances across the stage in a strikingly loud plaid suit.
Looking directly at you, Richard points at the flashing scoreboard and shouts…
“Name something required every three years by community water systems in order to stay in compliance with EPA regulations?”
Struggling under the hot studio lights to recall what the trainer had said during the Public Water System Management Training session you recently completed, it dawns on you that the cash and prizes riding on this one question could mean the difference between—your Aunt Ruth spending two glorious weeks in Cancun or camped out in you guestroom.
While this question probably never came up during any real episodes of the “Family Feud” gameshow, in this issue of The Safe Drinking Water Trust eBulletin we’ll not only help you answer this exciting question, we’ll also look at ways to prepare your water system so that when state inspectors, or your Aunt Ruth come knocking, you’ll be prepared.
“Survey Says….”
If you shouted “Sanitary Survey” back at Richard then go ahead and jump around a little bit before reading the rest of this article.
However, if you failed to come up with the right answer—then it’s Aunt Ruth for you my friend.
A sanitary survey is an onsite review of your system’s water source, your facilities, equipment, operation and maintenance that makes up your water treatment system. These reviews by trained water professionals are to be conducted every three years by community water systems and every five years by non-community water systems.
(Remember: Community Water Systems are public systems serving at least 15 service connections used by year-round residents or regularly serving at least 25 year-round residents.)
Sanitary surveys have been a critical component of many states drinking water programs for decades and are used to prevent and correct any problems that could affect the safety of the water flowing into your customer’s homes.
Additional Resources
www.epa.gov/safewater/dwa/sanitarysurvey.html [1]
Preparing for a Sanitary Survey
Long before your system receives notice that an inspector will be stopping by to review your operation, it’s a good idea to complete a self-inspection reviewing each of the nine critical components outlined by the Environmental Protection Agency that will be reviewed during an actual sanitary survey:
Source: Is the source a surface or ground water supply? Is the source protection area sufficiently monitored and protected?
Treatment: Are the treatment methodologies (chemical, physical or other) applied in a manner that assures safe drinking water? Are chemicals stored in an approved manner?
Distribution: Is drinking water delivered to the consumer in a manner that assures the water is safe when it reaches the tap? What is the physical condition of the distribution system?
Cross-Connections: Is there any means for non-potable or contaminated water to enter the distribution system? Are all backflow prevention devices in place and tested regularly?
Pumps: Are dual pumps available and online? Are the pumps in sound mechanical condition?
Finished Water Storage: Is a sufficient storage volume available? Does the storage tank construction meet state and federal requirements?
Monitoring: Are all tests and analyses required by state and federal guidelines being completed on time? Is a record of laboratory testing maintained?
Operations and Maintenance: Is a working operations and maintenance manual maintained onsite? Is it updated regularly?
Emergency Preparedness: Is there an emergency response plan completed? Can potable drinking water be supplied in the case of an emergency?
While this is by no means an exhaustive list of questions that will be asked of your system during an actual sanitary survey, it does form the basis for developing and maintaining a water system that meets the requirements of the Safe Drinking Water Act.
Additional Resources
www.epa.gov/safewater/mdbp/pdf/sansurv/sansurv.pdf [2]
Let the Survey Begin
Sanitary surveys must be conducted by qualified drinking water professionals who are generally certified by the state Primacy Agency.
(State Primacy Agency: The agency that has the primary responsibility for administering and enforcing regulations)
The survey is based on a physical inspection of the water system and all necessary records.
In order to help the inspector successfully complete his job, it is a good idea to make certain that all areas of the water system will be accessible to the water system inspector the day of the survey.
This should include obtaining any keys that are necessary to provide access, clearing storage areas, and providing suitable lighting.
Finally, any paperwork associated with the water system should be available at the time of the survey. This includes all operation and maintenance manuals, laboratory test results, as-built drawings for the water system, and yield/demand information for the source.
Additional Resources
www.epa.gov/safewater/dwa/pdfs/gw-tsg.pdf [3]
Survey Findings
During the survey, areas that do not meet state and federal requirements will be identified as deficiencies to be remedied by the water system. Specific deficiencies that may increase the risk of not being able to deliver safe drinking water from the source to the tap will generally be labeled as “major deficiencies.”
Other areas that do not meet state and federal requirements, but do not pose an immediate risk to human health, are labeled “minor deficiencies.”
In addition to highlighting "trouble" spots, the survey process also allows for an open dialogue between system managers and the system inspector that can lead to a better understanding and interpretation of regulations. It also provides you with a prime opportunity to take a broad look at your water treatment system, the processes you employ and, in essence, the job that you are doing.
While the thought of having an outsider come and inspect your system can be daunting, this is a great time to take advantage of the survey and to use the process to review and improve the managerial, technical and financial capacity of your system.
Additional Resources
www.dnr.state.ga.us/dnr/environ/forms_files/wrb/swsansurvey.pdf [4]
Enforcing the Findings
Following the survey, the water system analyst will compose a follow-up letter containing a summary of any deficiencies identified during the survey and any steps necessary to maintaining compliance with state and federal regulations. The letter will also contain suggested dates to complete any necessary improvements.
Take the results of the survey seriously, they will provide you, and your staff, a great opportunity to improve your system.
However, the primary reason for following the requirements imposed during the survey process is clearly to insure that the water you serve your customers is safe to drink. Failing to meet your legal responsibilities by not correcting all identified deficiencies promptly could cause your customers a whole host of problems including:
• The denial of other licenses or permits to your customer’s business including restaurant permits or liquor licenses.
• Lawsuits—Water users may file lawsuits against the system.
• The denial of loans by lending institutions for buying, refinancing, or remodeling of facilities served by the system.
Additional Resources
http://water.montana.edu/training/ssf/default.htm [5]
A Little Help From Your Friends
One way to ensure that your water system is operating at the highest level of compliance is to periodically complete a self-assessment of your operating system.
In a nutshell—don’t wait for your state primacy agency to order a sanitary survey—why not use the tools included in this issue of the Safe Drinking Water Trust eBulletin to conduct a mock survey of your own.
Take Ol’ Ben Franklin’s words to heart… “An ounce of prevention is worth a pound of cure.” So don’t wait to get “pounded” by the results of a bad sanitary survey—take proactive action and conduct a survey of your own system as soon as possible.
While we sincerely hope that you won’t be surprised by the findings, the results will give you a good overview of your system that you can put to practical use when working on your yearly budget and when evaluating the security of your system.
While there is little question that your own staff could clearly complete this task, it might also be a good time to consider swapping expertise with other water systems in your area.
By trading services and bringing in qualified employees from another water system, you could possibly gain a fresh perspective on your water system and develop a stronger relationship with other water professionals in your own area.