Listed below are deficiencies that routinely come up during the sanitary survey inspection. Most of these items, excluding the first, are listed as nonsignificant deficiencies and can be backed up by regulation or by a document incorporated by reference.

1.  Insufficient staffing (this typically becomes a significant deficiency).

a. Not enough operators.

b. Operators without the proper license classification.

c. No operator for distribution system.

2. Records not kept for the required times.

3. Raw water meter not calibrated.

4. Filter backwash flow rate is not measured.

5. Insufficiently sized spent filter backwash holding tanks/lagoons.

6. No day tanks for bulk liquid chemical feed processes.

7. No containment around bulk chemical feed processes.

8. Lack of a process for identifying cross-connections.

9. No formal flushing schedule or written flushing program.

10. Screens or flappers missing from distribution storage tank overflow piping.

11. Distribution storage tank overflow piping not located 10 horizontal feet from the base of the tank.

12. Lack of measurable chlorine residual in a part of the distribution system (this can be made a significant deficiency upon the recommendation of the inspectors).

13. Operation and Maintenance (O and M) manuals are not updated annually (only updated as needed).

14. Air intakes in the chlorine rooms located at the floor or someplace other than the ceiling.

15. Chlorine alarms visual but not audible or vice versa.

Other noted areas that cannot be backed by drinking water regulations or documents incorporated by reference.  These are usually OSHA or PSC requirements or gray areas and become recommendations in the sanitary survey letter.

1. Water withdrawal amount lower than the plant design capacity.

2. Many systems lack backup power or interconnections to other water systems.

3. All pretreatment chemicals (coagulant, pH adjustment, permanganate, carbon, chlorine, etc.) fed at the same time as or before the rapid mix.

4. KPDES discharge point for the liquid residuals is upstream of the intake.

5. Infrequent calculation of treatment chemical dosages.

6. No water loss calculations.

7. No written water quality goals.

8. No one crosstrained with lead operator or superintendent.

For more information about sanitary surveys, refer to page Sanitary Survey Training for Inspecting Small Drinking Water Systems prepared by the U.S. Environmental Protection Agency (EPA). Also, refer to EPA's Guidance Manual for Conducting Sanitary Surveys of Public Water Systems.

As the primacy agent for the Safe Drinking Water Act, the state of Kentucky ensures that water systems test for contaminants, review plans for water system improvements, conduct on-site inspections along with sanitary surveys, provide training and technical assistance and take action against water systems not meeting standards.

Refer to EPA's Sanitary Survey Resources for training information, how to prepare for sanitary surveys and security considerations when conducting sanitary surveys. 

For more information about sanitary survey inspections in Kentucky contact:

Frank Hall
Compliance Section
Drinking Water Branch
Division of Water
200 Fair Oaks Lane,
Frankfort, KY 40601
Phone: 502-564-3410, ext. 4959
Fax: 502-564-9899
E-mail: frank.hall@ky.gov

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