Analysis of Sanitary Survey Deficiencies
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1 Analysis of Sanitary Survey Deficiencies Rick Hiers, SC DHEC SCRWA Conference Myrtle Beach September 16, 2015
2 Agenda 1 Sanitary Survey Overview 2 Survey of Surveys 3 Findings 4 Corrective Actions 5 Summary and Conclusion 2
3 Sanitary Survey Overview Survey Components 1. Source (4 subcomponents) 2. Water Treatment (5 subcomponents) 3. Distribution (10 subcomponents) 4. Storage (5 subcomponents) 3
4 Sanitary Survey Overview Survey Components 5. Pumps (4 subcomponents) 6. Monitoring & Reporting (3 subcomponents) 7. System O & M (9 subcomponents) 8. Operator Certification (2 subcomponents) 4
5 Sanitary Survey Overview Significant Deficiencies A significant deficiency is a deficiency that is causing or has the potential to cause an immediate risk to public health or safety Per the Groundwater Rule, DHEC has designated one subcomponent under each of the eight survey components as a significant deficiency item 5
6 Sanitary Survey Overview Significant Deficiencies 1. Source - Protection from contamination 2. Water Treatment - Chemical feed 3. Distribution - Water quality 4. Storage - Protection from contamination 6
7 Sanitary Survey Overview Significant Deficiencies 5. Pumps - Reliable capacity 6. Monitoring & Reporting - Monitoring/recordkeeping 7. System O & M - Corrections from previous survey 8. Operator Certification - Certified operator 7
8 Sanitary Survey Overview Significant Deficiencies The designated significant deficiency subcomponents are not all-inclusive. The inspector may determine that any deficiency is a significant deficiency if it is causing or has the potential to cause an immediate risk to public health or safety. 8
9 Sanitary Survey Overview Significant Deficiencies An Unsatisfactory rating of a designated significant deficiency subcomponent (or of an inspector-determined significant deficiency) results in an overall Unsatisfactory rating and a referral to DHEC s Drinking Water Enforcement Section, followed by a notice of violation and an enforcement conference. 9
10 Survey of Surveys We surveyed 100 random groundwater system sanitary survey reports, representing a crosssection of: Different inspectors Different regions Different types and sizes of water systems Community (municipalities, mobile home parks) Non-transient Non-community (industries, schools) Transient Non-community (restaurants, convenience stores) 10
11 Findings 100 Survey Reports Our survey says: 53 reports show at least one deficiency A Needs Improvement or Unsatisfactory rating on at least one of the 42 subcomponents 47 sanitary survey reports show no deficiencies 11
12 Findings 53 Systems With Deficiencies Our survey says: 127 total deficiencies were reported, for an average of 2.4 deficiencies per system One system had 11 deficiencies, two had 7, three had 6, two had 5, four had 4, six had 3, five had 2, and thirty (57%) had 1 12
13 Findings 42 Subcomponents Our survey says: Deficiencies were reported for 28 (two-thirds) of the subcomponents No deficiencies were reported for 14 (one-third) of the subcomponents 13
14 Findings 14 Subcomponents Without Deficiencies 1. Source (1/4) Quantity 2. Water Treatment (4/5) Chemical storage & handling, Chemical injection points, Filtration, Equipment maintenance 3. Distribution (4/10) Water quality, Adequate pressure, Disinfectant residual, Fire flow 4. Storage (0/5) None 14
15 Findings 14 Subcomponents Without Deficiencies 5. Pumps (0/4) None 6. Monitoring & Reporting (1/3) Testing equipment 7. System O & M (4/9) Supplies/spare parts inventory, Waste disposal, Stand-by power, Compliance w/ enforcement order 8. Operator Certification (0/2) None 15
16 Findings 28 Subcomponents with Deficiencies 1. Source (3/4) 11 Wellhead piping, 10 Protection from contamination, 4 Security 2. Water Treatment (1/5) 1 Chemical feed 3. Distribution (6/10) 11 Water audit, 9 System map, 8 flushing program, 6 Valve/hydrant maintenance, 5 Leak detection & repair, 4 Cross connection control 4. Storage (5/5) 6 Security, 4 Maintenance, 2 Capacity, 2 Appurtenances, 1 Protection from contamination 16
17 Findings 28 Subcomponents with Deficiencies 5. Pumps (4/4) 3 Flow measuring device, 2 Pumps, 1 Reliable capacity, 1 Operation & control 6. Monitoring & Reporting (2/3) 3 Monitoring/recordkeeping, 2 Sample siting plan 7. System O & M (5/9) 9 Facility maintenance, 8 emergency plan, 4 Corrections from previous survey, 4 Procedures manual, 3 Plant security 8. Operator Certification (2/2) 2 Certified operator, 1 Staffing 17
18 Findings 127 Deficiencies T1. 11 Source - Wellhead piping Distribution - Water audit Source - Protection from contamination T4. 9 Distribution - System map System O & M - Facility maintenance T6. 8 Distribution - Flushing program System O & M - Emergency plan T8. 6 Distribution - Valve/hydrant maintenance Storage - Security 18
19 Findings 127 Deficiencies Distribution - Leak detection & repair T11. 4 Source - Security Distribution - Cross connection control Storage - Maintenance System O & M - *Corrections from previous survey System O & M - Procedures manual T16. 3 Pumps - Flow measuring device Monitoring & reporting - Monitoring/recordkeeping System O & M - Plant security 19
20 Findings 127 Deficiencies T19. 2 Storage - Capacity Storage Appurtenances Pumps Pumps Monitoring & reporting Sample siting plan Operator certification Certified operator T24. 1 Water treatment Chemical feed Storage - *Protection from contamination Pumps - *Reliable capacity Pumps Operation & control Operator certification - Staffing 20
21 Findings 127 Deficiencies 1. Distribution System O & M Source Storage Pumps Monitoring & reporting Operator certification Water treatment
22 Findings 127 Deficiencies 1. Written procedures, documentation of activities (Cross connection control, Valve/hydrant maintenance, Flushing program, Leak detection and repair, Water audit, System map, Sample siting plan, Monitoring/recordkeeping, Emergency plan, Procedures manual) Maintenance (Storage, Facility) Security (Source, Storage, Plant) Protection from contamination (Source, Storage)
23 Findings 127 Deficiencies 5. Wellhead piping Corrections from previous survey Operator certification (Certified operator, Staffing) Flow measuring device Other
24 Corrective Actions Procedures - Templates, forms (SCRWA, DHEC) System map - SCRWA (Nick Rubin) Water audit - SCRWA (Jerry Baxley) Maintenance - Checklist, Manuals Security - Keep locks locked! Protection from contamination - Seal openings, Practice good housekeeping Wellhead piping DHEC (Fred Taylor, diagram) 24
25 Summary and Conclusion Summary Most water system deficiencies are due to poor system management, and include a lack of written procedures and documentation of activities, and to neglect of the physical components of the water system Conclusion Most water system deficiencies are not difficult or expensive to correct, and help is always available from SCRWA and DHEC 25
26 Questions? / Contact Info Rick Hiers (803) hiersrs@dhec.sc.gov 26
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Page 1 of 5 Section 1. PURPOSE This section will explain the proper procedures for waterline repairs to ensure that repairs are performed properly and according to specifications and to assure proper function
Commonwealth of Massachusetts Title 5 Official Inspection Form Subsurface Sewage Disposal System Form - Not for Voluntary Assessments
Owner Inspection results must be submitted on this form. Inspection forms may not be altered in any way. Please see completeness checklist at the end of the form. Important: When filling out forms on the