2025 Sanitary Survey

Violation

Action Underway

Status

1. Microbiological  Filtration Avoidance Criteria Minimum Monitoring Requirements requires the city to collect five raw water fecal coliform samples weekly and on every day the turbidity of raw water exceeds 1 NTU.

Samples will be collected the same day when raw water turbidity exceeds 1 NTU.

Resolved

2. For distribution sample site, the percentage of total coliform positive samples be calculated each month and that a treatment technique trigger occurs when more than 5.0 percent of samples are total coliform positive.

The calculation of the percent of samples collected from the distribution system each month will be calculated correctly in the monthly operating reports.

Resolved

3. Requires chlorine residual to be measured at the same times and same points in the distribution system as total coliform sampling.

Chlorine residuals will be measured at the same times and same points in the distribution system as total coliform sampling.

Resolved

4. Distribution turbidity monitoring requires five distribution samples each week unless otherwise determined by the State. No two samples may be obtained on the same day, and no two samples are to be collected from the same distribution point during the same week.

Turbidity monitoring will occur at five distribution samples, each on a different day, each week.

Resolved

5. Requires each system to develop and implement a monitoring plan that includes all monitoring requirements specified in the Subpart.

The Department is developing and implementing a comprehensive monitoring plan that includes all monitoring requirements specified in the Subpart.

In progress

6. Disinfection must be sufficient to ensure at least 99.9 percent inactivation of Giardia lamblia cysts, and 99.99 percent inactivation of viruses, and 99 or 99.9 percent inactivation of Cryptosporidium (per section 5-1.83(c)(2) of this Subpart), between a point where the raw water is no longer subject to recontamination by surface water runoff and a point downstream before or at the first consumer.

The City is currently performing a contact time study regarding Giardia Lamblia cysts, viruses, and Cryptosporidium for the out of City conduit customers.

In progress

7. Complete daily records shall be kept of the operation of a public water system.

Calculations will be made and reported correctly, and daily records will be kept.

Resolved

8. Inactivation treatment technology requirements. Unfiltered systems shall use Chlorine dioxide, ozone, or UV to meet the Cryptosporidium inactivation requirements of this section.

Cryptosporidium inactivation for the 65 residential conduit customers is currently being reviewed.

In progress

9. Disinfection must be sufficient to ensure at least 99.9 percent inactivation of Giardia lamblia cysts, and 99.99 percent inactivation of viruses, and 99 or 99.9 percent inactivation of Cryptosporidium (per section 5-1.83(c)(2) of this Subpart), between a point where the raw water is no longer subject to recontamination by surface water runoff and a point downstream before or at the first consumer. Actual CT values must be equal to or greater than the required values found in section 5-1.52 tables 14A through 14K of this Subpart, except for one day in each month that the system served water to the public, or except where the State determines that an additional failure in one month in the previous 12 months was caused by circumstances that were unusual and unpredictable. 

The Department will provide information on the ultraviolet disinfection system operation to determine if the ultraviolet disinfection systems at Woodland and Westcott are achieving proper inactivation of Cryptosporidium.

In progress

10. The supplier of water and the person or persons operating a water treatment plant or distribution system shall exercise due care and diligence in the operation and maintenance of these facilities and their appurtenances to ensure continued compliance with the provisions of this Subpart. Facilities approved by the State shall be operated in general accordance with their design unless otherwise authorized under the provisions of section 5-1.22, 5-1.23 or 5-1.24 of this Subpart.

The Monthly Operating Reports for Ultraviolet Disinfection will be acceptable for demonstrating the system operating within the validated conditions for the required dose. Staff will keep an eye on errors including missing information such as UVT and RED, spreadsheet calculation errors, incorrect dates, missing operating days, incorrect significant figures, and discrepancies in total off-spec water generation.

In progress

11. All users of a public water system shall prevent cross-connections between the potable water piping system and any other piping system within the premises by installing internal protection in accordance with the New York State Uniform Fire Prevention and Building Code and/or the local plumbing and building codes.

The RPZ was reinstalled.

Resolved

12. The supplier of water shall implement a service protection program (also known as containment) which includes the following: … (3) assuring all protective devices are inspected and tested by a certified backflow prevention device tester, as prescribed in subdivision (b) of this section, at the time of initial installation, after each repair, and annually thereafter. Records of such tests shall be made available to, reviewed by, and maintained by the supplier of water. All protective device tests and inspections shall be conducted by a certified backflow prevention device tester (“tester”).

The Department is currently working with an outside consultant to implement a service protection program including all the subsections mentioned below.

In progress

13. Establishes an MCL violation and a Level 2 Treatment Technique Trigger (TTT) when a total coliform sample is positive for total coliform but negative for E. coli and a repeat total coliform sample is positive for E. coli.

The sample from Site 42 on November 6, 2024 was TC positive. The repeat sample on November 8, 2024 was E. coli positive. On January 8, 2026, the Onondaga County Health Department provided documentation to the Department that indicated that the original sample had been invalidated on November 11, 2024.

Resolved

14. Establishes a Treatment Technique Violation (TTV) when a system exceeds a TTT and then fails to conduct the required assessment or corrective action.

On January 8, 2026, the Onondaga County Health Department provided documentation to the Department that indicated that the original sample had been invalidated on November 11, 2024.

Resolved

15. Requires that distribution sampling must be repeated until total coliform is not detected in repeat samples, or it is determined that a treatment technique has been triggered or an MCL has been violated.

On January 8, 2026, the Onondaga County Health Department provided documentation to the Department that indicated that the original sample had been invalidated on November 11, 2024.

Resolved

Deficiency

Action Underway

Status

1. It is unclear if all conduit customers receive three log (99.9 percent) inactivation of Giardia Lamblia.

Conduct a study to determine if there is sufficient CT at all conduit users to achieve three log inactivation of Giardia Lamblia.

In Progress

2. Redacted to ensure the security of critical infrastructure.

Redacted to ensure the security of critical infrastructure.

In Progress

3. Redacted to ensure the security of critical infrastructure.

Redacted to ensure the security of critical infrastructure.

In Progress

4. Turbidimeters and chlorine analyzers are not calibrated in accordance with the manufacturer's recommendations. Calibration standards on site are expired.

Purchase calibration standards for both the online and benchtop turbidimeters and chlorine analyzers and calibrate in accordance with manufacturer's recommendations.

Record the date of calibration on an operating log. This log should be available to the Onondaga County Health Department upon request.

Resolved

5. The City periodically substitutes benchtop turbidity readings for online turbidity readings. In all observed instances in 2024 and 2025, these substitutions occurred when the online turbidity readings exceeded 5 NTU. No justification for substituting these readings was provided and there was no documentation that the online turbidity readings were not representative of raw water conditions.

Raw water turbidity readings reported on the monthly operation report should be from the online turbidimeters unless specifically approved by the Onondaga County Department of Health. Benchtop turbidity readings can be substituted for online readings only with the permission of the OCDH and after supporting documentation has been provided indicating that the online readings are not representative.

Resolved

6. The City is required to maintain a six-month running average of fecal coliform sample results greater than 20 CFU/mL. The six-month running average for raw water total and fecal coliform samples was not reported correctly on several MORs in 2024 and 2025.

The City must modify the spreadsheet to ensure the running annual average calculations are correct and all information reported to the OCHD is accurate.

Resolved

7. At the time of inspection, the backup generator trailer for Westcott Reservoir moved to an alternate location.

City of Syracuse should install a permanent generator at this location to support UV treatment during a power outage. If a mobile generator is used, a policy must be adopted that prohibits moving this generator from the Westcott facility.

Resolved

8. The roof access hatch was ajar at the Stewart Standpipe, and no seal was present on the hatch.

1. Seal the roof access hatch at Stewart Standpipe.

2. Develop an SOP or employee checklist to ensure hatches on all critical infrastructure is inaccessible following maintenance or inspection.

Resolved

9. A direct hose connection to the bottom of the pit at the Woodland Standpipe was present without a vacuum breaker.

Disconnect the direct hose connection or add a vacuum breaker.

Resolved

10. The Woodland Standpipe is in disrepair. There is evidence of leaks and significant rust formation.

Obtain the services of a professional engineer to inspect the Woodland Standpipe. The following items should be corrected:

1. Locate the overflow pipe and screen as necessary.

2. Eliminate exposed electrical wires to the light fixture.

3. Add screen to all vents.

4. Remove the hose connection at the bottom of the pit.

In Progress

11. The valve pit for the blowoff at the Nose Hill Gatehouse is flooded. The end of the blowoff pipe could not be located during inspection.

Locate the end of the blowoff pipe and eliminate all flooding in the gatehouse.

Resolved

12. The Interconnection was not accessible at the time of inspection. It was presumed to have four valves in the middle of the intersection with no access hatch or manhole available for inspection. The City reports that it is not possible to inspect this location.

Develop a plan to obtain access to this location in the event of an emergency or situation that requires access.

Resolved

13. The purpose of the connection to the golf course could not be determined.

The purpose should be determined, and any cross connections between the City interconnection and OCWA should be eliminated.

Resolved

14. Redacted to ensure the security of critical infrastructure.

Redacted to ensure the security of critical infrastructure.

Resolved

15. Monthly operating reports do not properly indicate if duty sensors are being properly calibrated or replaced. Systems should complete at least one calibration check of each duty sensor used monthly. If monthly operating hours are zero, then no check is required.

Duty sensor calibration must be added to the monthly operation report.

Resolved

16. At the time of inspection, there was one IB operator that was reportedly working part-time. There were no other IB certified operators. There were multiple IIB operators employed by the City. These operators, however, do not have a comprehensive understanding of the water system from source to tap and did not have sufficient training to operate major components of the system, including the ultraviolet disinfection system. In addition, there is no professional engineer on staff.

• Obtain professional engineering service either by contract or by hiring appropriate staff.
• Schedule an onsite assessment with the Onondaga County Health Department or New York State Department of Health for operators that have passed the IB examination.
• Develop and submit to the Department a comprehensive training program for existing staff on topics including but not limited to regulatory requirements; distribution system operation; ultraviolet disinfection system operation; and chlorine gas disinfection operation and maintenance.
• Develop and submit to the Department a plan to either fill all water department vacancies by contract or recruit employees by the end of 2026.

In Progress