GUEST ARTICLE
by Meredith Maskell, Drinking Water and Groundwater Protection Division
This article was published in the winter 2024–25 issue of our newsletter.
A sanitary survey is a review of a public water system to assess its capability to supply safe drinking water. The State of Vermont’s Drinking Water and Groundwater Protection Division (DWGPD) is responsible for performing sanitary surveys at public water systems in Vermont.
There are two teams of staff at the DWGPD who perform sanitary surveys. The Community Operations Section, which includes Matt Hunt, Kenna Dwinell, Matt Caldwell, Michael Langham, and Ted Fela, conducts sanitary surveys every three years at Community Water Systems (CWS).
The Non-Community Operations Section, which includes Meredith Maskell, Ashliegh Belrose, Amanda Faust, and Sarah Bolaski, conducts sanitary surveys every five years at Transient Non-Community (TNC) and Non-Transient Non-Community (NTNC) water systems.
Sanitary surveyors inspect water system components.
Preparing for the Sanitary Survey
The sanitary surveyor will contact the water system’s Administrative Contact and Designated Operator when it is time to schedule the sanitary survey. Typically sanitary surveys will be scheduled within two weeks or a couple of months, depending on when everyone is available. The Designated Operator must be present at the sanitary survey, but it is strongly recommended that other water system representatives also attend who have knowledge of or questions about the operation of the water system.
Prior to the sanitary survey, water system representatives should conduct an administrative file review and a visual inspection of the water system.
File Review: Verify that you have all the water system’s documents on file and available for review by the sanitary surveyor if requested. These documents include the Permit to Operate, Operation and Maintenance Manual, Source Protection Plan, water quality sampling plans, past Monthly Operations Reports, and past water quality data.
Visual Inspection: Conduct a walk-through of the water system to verify that all facilities and components are accessible and in good working order. The sanitary surveyor must have access to all the system components during the inspection, including the well, storage tank overflows, and drains. Vegetation and/or snow must be cleared from the components prior to the sanitary survey. If the water system components are not accessible during the sanitary survey, the lack of accessibility will be identified as a sanitary deficiency and the water system will be required to submit photographs of the components that were not accessible during the sanitary survey.
Conducting the Sanitary Survey
There are eight required components of a sanitary survey that your inspector will evaluate and discuss with you at the inspection:
- Source (quality, quantity, construction, condition, land uses)
- Treatment (chemical application, monitoring, reporting, storage and handling, backwash)
- Distribution system (pressure, cross-connections)
- Finished water storage (inspections, cleanings, condition, access)
- Pumps, pump facilities, and controls
- Monitoring, reporting, and data verification (sampling plans, monthly operations reports, monitoring schedules)
- System management and operation (Operating Permit, Operation and Maintenance Manual)
- Operator compliance with State requirements
Beginning in 2025, sanitary surveys will also include a cybersecurity evaluation. The specific requirements for, and components of, the evaluation will depend on the type and extent of operational technology the water system uses. Stay tuned for more information from DWGPD and Vermont Rural Water.
During the sanitary survey, the sanitary surveyor will notify you if they identify any sanitary deficiencies at the water system. Sanitary deficiencies are actual or potential problems in a water system’s infrastructure, design, operation, maintenance, or management that have or may impact the water system’s ability to produce safe and reliable drinking water. A significant sanitary deficiency is one that is causing, or has the potential to cause, the introduction of contamination into the water delivered to users. A deficiency can be a physical problem, operating condition, or management practice.
Follow-Up to the Sanitary Survey
The sanitary surveyor will issue a letter to the water system within 30 days of the sanitary survey that documents and summarizes the visit. The letter will identify any sanitary deficiencies, requirements, recommendations, or comments that were found during the sanitary survey and will propose due dates to resolve the sanitary deficiencies or requirements. The water system must submit the required documentation by the due dates identified or propose alternative due dates for review by the sanitary surveyor.