Drinking Water Program Evaluations and Audits

8.9.1 Source Water Protection Plan Evaluations

On-going evaluation of watershed/aquifer management activities, progress and impacts is necessary to assess the effectiveness of a watershed/aquifer protection plan. This evaluation can be conducted through stakeholder focus groups and open houses and questionnaires aimed at the general public. Most of the evaluation effort can be managed by the Source Water Protection committee. Scientific data gathered through monitoring efforts is critical in evaluating preventative and restorative source water efforts.

- 164 - 8.9.2 System Vulnerability Assessment

A vulnerability assessment involves a critical review of all parts of a water system to document potential security weaknesses. This review should include all possible access points to every part of the water system from source to consumer service connection. Secondly, a list should be developed which identifies what can be improved or implemented to prevent access to that item. The assessment should include a review of existing policies and emergency preparedness plans.

The overall vulnerability analysis identifies the potential threats, the probability of the threat and consequence if the threat occurs. Prioritization of the threat by frequency of occurrence and magnitude of impact should assist in dedicating personnel and funds to minimize the issue.

For more information, see CWWA’s CD-Rom publication “Vulnerability Assessment Template” (June 2003)

8.9.3 Audits

It is recommended that the type of audit described below be conducted every 3 to 5 years to ensure that the quality of the water and service provided by the water owner and/or operator is maintained. This time period is suggested since the time and effort needed to conduct a comprehensive audit may make it impractical for it to be conducted annually. Audits should look at the entire drinking water system, from source to tap.

Preparation for the Audit

The party chosen to conduct the audit should not only have a broad knowledge in water system operation, maintenance, treatment, monitoring, public health concepts and they should have a full grasp of the local regulatory requirements. They also should have skill sets which are pertinent to the water system which is to be audited. An audit can involve three phases, including planning, conducting, and compiling the final report.

Planning the Audit

Prior to conducting an audit, there should be a detailed review of the water system. The review should pay particular attention to past audits and documentation describing previously identified problems and the solutions. These should be noted, and action/inaction regarding these problems should be specifically verified in the field. Other information to review includes: any general documentation, water system plans, chemical and microbiological sampling results, operating reports, and engineering studies. This review will aid in the familiarization with the past history and present conditions, and the regulator's past interactions with the owner and/or operator.

The initial phase of the audit will comprise reviewing the owner and/or operator's monitoring records. Records should be reviewed for compliance with applicable microbiological, inorganic chemical, organic chemical, and radiological guidelines, and also for compliance with the appropriate monitoring requirements. The audit should provide an opportunity to review these records with the owner and/or operator, and to discuss solutions to any parameter non-compliance. The audit will also provide an opportunity to review how and where samples are collected, and how field measurements (turbidity, chlorine residual, fluoride, etc.) are made.

The pre-audit file review should generate a list of items to check in the field, and a list of questions about the system. It will also help to plan the format of the audit and to estimate how much time it may take. The next step is to make the initial contact with the system management to establish the survey date(s) and time. Any records, files, or people that will be referenced during the audit should be mentioned at the outset. Clearly laying out the intent of the audit up front will greatly help in managing the system, and will ensure that the audit goes smoothly without a need for repeat trips.

Conducting the Audit

The on-site portion of the audit is most important and will involve interviewing those in charge of managing the water system as well as operators and other technical people. The audit should also review all major system components

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from the treatment point to the distribution system. A standard form is frequently used to ensure that all major components and aspects of each system are consistently reviewed.

As the audit progresses, any deficiencies that are observed should be brought to the attention of the water system personnel, together with a discussion of suggested corrective measures. It is far better to clarify technical details and solutions while standing next to the problem. Points to cover include:

• Is the operator competent in performing the necessary field

testing for operational control?

• Are any on-site testing facilities and equipment adequate, and

do reagents used have an unexpired shelf life?

• Are field and other analytical instruments properly and

regularly calibrated?

• Are records of field test results and water quality compliance

monitoring results being maintained?

• Conduct any sampling which may be part of the survey.

Also, detailed notes of the findings and conversations should be taken so that the report of the audit will be an accurate reconstruction of the survey.

Audits can be conducted for the a variety of systems including treatment, filtration, distribution and administration.

Details on what to expect during the audit process, including the types of questions an auditor will ask, can be found in Appendix O.

Reporting the Audit

A final report of the audit should be completed as soon as possible to formally notify the owner and/or operator and/or the regulator of the findings. The report may be used for future compliance actions and inspections; it should include as a minimum:

• The date of the survey

• The findings of the survey

• The recommended improvements to identified problems • Recommended dates for completion of any improvements.

The utility should be fully aware of the contents of the final report before receiving it.

More information on the various types of audits is given in Appendix O.

For more information on audits in general, see the USEPA Handbook: “Optimizing Water Treatment Plant Performance using the composite correction program”