Ground Water  Rule  Factsheet:
                Sanitary  Surveys
WHAT is THE GROUND WATER RULE?
The U.S. Environmental Protection Agency (EPA) published the Ground Water Rule (GWR) on November
8, 2006. One goal of the GWR is to provide increased protection against microbial pathogens,
specifically bacterial and viral pathogens, in public water systems (PWSs) that use ground water (or
ground water systems (GWSs)). Instead of requiring disinfection for all ground water sources, the GWR
establishes a risk-targeted approach to identifying ground water sources that are susceptible to fecal
contamination. The GWR requires GWSs with ground water sources at risk of microbial contamination to
take corrective action to protect consumers from harmful bacteria and viruses. Sanitary surveys are an
important way for states to identify at-risk systems.

WHAT is A SANITARY SURVEY?	

A sanitary survey provides an on-site review of how a GWS is maintained and operated. The survey is
conducted by a trained surveyor, who reviews the system's water source, equipment, facilities, and
treatment procedures. The purpose of the survey is to:
#  Ensure that the GWS' operational, monitoring, reporting, and recordkeeping practices are in
   compliance with  drinking water regulations.
#  Identify any significant deficiencies.
*  Better ensure that safe drinking water is distributed to the public.

Furthermore, the sanitary survey is a proactive  public health measure that allows states to better
understand a GWS' progress and needs.

WHAT ARE THE DIFFERENCES BETWEEN THE GWR AND THE TOTAL COLIFORM RULE?

Total  Coh'form Rule & Sanitary Surveys
The Total Coliform Rule (TCR) was published on June 29, 1989, by the EPA. Under the TCR, community
water systems (CWSs) and non-community water systems (NCWSs) that collect fewer than 5 TCR
samples per month were required to receive a sanitary survey every 5 years. NCWSs that use protected
and disinfected ground water were only required to receive a sanitary survey once every 10 years.
Furthermore, the TCR did not state what elements needed to be evaluated during the  sanitary survey.

GWR & Sanitary Surveys
The GWR sanitary survey requirement will increase public health protection by requiring more frequent
and complete sanitary surveys. The GWR requires that all community GWSs receive a sanitary survey
every  3 years.  Non-community GWSs must have a sanitary survey at least every 5 years. If the state
determines that a community GWS has outstanding performance or the GWS provides 4-log treatment
of viruses, the state  can conduct a sanitary survey of the community system every 5 years instead of
every  3 years.  This provides states with flexibility and gives them the option of reducing their survey
workload. For both community and non-community GWSs the sanitary survey must include a review of
all eight elements described in this factsheet. All eight elements do not need to be reviewed at the
same time, as  long as they are reviewed within  the 3- or 5- year timeframe specified above.

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How OFTEN is A SANITARY SURVEY ADMINISTERED FOR GWSs?
Ground Water System Type Minimum Frequency of Surveys
Community GWSs
Community GWSs that the state determines have outstanding
performance OR provide 4-log treatment of viruses (i.e.,
performance criteria)1
Non-community GWSs
Every 3 years
Every 5 years
Every 5 years
DATES TO KEEP IN MIND
December 31. 2012
This is the last day states have to complete the initial eight element sanitary survey for all community
GWSs2 under the GWR.

December 31. 2014
This is the last day states have to complete the initial eight element sanitary survey for non-community
GWSs and for those community GWSs that the state determines have met state performance criteria for
outstanding performance or provide 4-log treatment of viruses.1

WHAT ELEMENTS ARE EXAMINED DURING THE SURVEY?	

The GWR requires that a sanitary survey include a review of eight elements. The state will identify
significant deficiencies found during the survey. The GWS will then need to take corrective action to fix
any significant deficiencies found.

Eight Elements of the Sanitary Survey
   Source
   Protecting the source prevents contaminants and
   pathogens from reaching consumers. The state will
   review information relating to source water quality and
   wellhead protection. Observations will be made about
   well construction, potential sources of contamination,
   setback distances, source quantity and capacity, well
   locations, source water transmission mains, site
   security, and general housekeeping.

   Treatment
   Treatment varies among GWSs based on the quality of
   the source water and state regulatory requirements.
   The state will take into consideration design criteria,
   plant records, and past inspections during the review.
   The overall design, operation, maintenance, and
   management of the treatment facility will be
   examined.
  Possible source sienificant deficiencies
   Well near source of fecal contamination

   Well in flood zone

   Improperly constructed well

   Spring boxes are poorly constructed and/or
   subject to flooding
Possible treatment sienificant deficiencies
'   Improper application of treatment
   chemicals

'   Lack of redundant mechanical components
   where treatment is required

'   Unprotected cross-connections with
   treatment systems

'   Inadequate monitoring
1. Performance criteria are established when a community GWS provides a 4-log inactivation/treatment of viruses or
has an outstanding performance record document for previous sanitary surveys. Furthermore, a community GWS that
has an outstanding performance record cannot have a history of any violations under TCR since its last sanitary survey.
2. Except for those that meet performance criteria.

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#  Distribution System
   Improper upkeep and maintenance of pipes and
   fixtures comprising the distribution system can
   compromise the safety of drinking water. Since the
   infrastructure is typically underground, the state
   will usually do a paper review of schematics,
   operation and maintenance records, operating
   procedures, construction standards, and distribution
   system water quality data.

#   Finished Water Storage
   The condition of the storage facility can affect both
   water quality and water quantity. The state will
   review the GWS' files; perform field inspections to
   assess the tank's integrity, operational readiness,
   site security, and potential sanitary risks; ensure
   maintenance checks have been completed;  and
   discuss current operation and maintenance  (O&M)
   procedures with staff.

#   Pumps,  Pump Facilities, and Controls
   The purpose of reviewing the pumps is to see if they
   are in proper working order, are the best fit for their
   intended use, and to determine their reliability and
   establish if there are any sanitary risks. The state
   will obtain information about the pumps, including
   available data from previous sanitary surveys, the
   emergency power system (if available), pump tests,
   and remote monitoring controls and alarms.

*   Monitoring, Reporting, and Data Verification
   Verifying the quality of the drinking water
   distributed to the public ensures that the water
   complies with drinking water regulations and
   requirements. The state will determine whether site
   sampling and monitoring plans are being followed
   and requirements are being met by checking test
   results, monthly reports, and daily logs. The
   surveyor will determine whether the system has
   complete,  up-to-date, and reasonable monitoring
   data.

#  System Management and Operation
   Proper management can provide a GWS with
   direction, sufficient funding, and strong support.
   Reviewing a system's goals, plans, and budgets can
   give the  state a good idea of whether the system's
   team is working well together or might need some
   assistance. The state will evaluate whether the GWS
   is sufficiently staffed and has enough funding for
   equipment to operate in a sustainable and safe
   manner.
   Possible distribution svstem significant
               deficiencies
  Low or negative pressure that could result in
  contamination

  Lack of system flushing

  Unprotected cross-connections
 Possible finished water storage significant
               deficiencies
  Inadequate internal cleaning/maintenance of
  storage tanks

  Improper screening of overflow pipes, drains,
  or vents

  Necessary repairs of storage tank roofs or
Possible DUITIDS. DUITID facilities, and controls
          significant deficiencies
  Inadequate pump capacity

  Inadequate maintenance

  Inadequate/inoperable control system
  Possible monitoring, reporting, and data
    verification significant deficiencies
  Not monitoring according to site sampling plan
  or monitoring plan

  Not meeting reporting requirements

  Improper recordkeeping
 Possible svstem management and operation
          significant deficiencies

  Failure to meet water supply demands

  No approved emergency response plan

  Inadequate follow-up to deficiencies

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   Operator Compliance with State Requirements
   Operators and staff must be properly trained based
   on system type, size, and treatment. The state will
   confirm that operators are properly certified for
   their roles and responsibilities.
 Possible operator compliance with state
  reauirements significant deficiencies
Operator is not qualified as required by the state

Lack of operator training
WHAT HAPPENS IF A SIGNIFICANT DEFICIENCY is IDENTIFIED?	

After the sanitary survey has been completed, the state must provide written notification to the GWS
no more than 30 days after a significant deficiency has been identified. The state may also specify the
corrective action(s) it requires the GWS to complete and may provide deadlines for those actions.  If the
state does not specify the corrective action(s) required, the GWS has 30 days from receiving written
notice from the state to consult with the state regarding appropriate corrective action needed to
address the significant deficiency. The GWS has  120 days after the initial state notification of a
significant deficiency to complete the required corrective action or be in compliance with a state-
approved corrective action plan and schedule. Failure to comply with the required corrective action
plan or schedule will result in a treatment technique  (TT) violation for the GWS. The GWS must notify
the state within 30 days of completing the required corrective action.

Corrective Action Alternatives
#  Correct all significant deficiencies.
#  Provide alternative source of water.
#  Eliminate the source of contamination.
#  Provide 4-log treatment of viruses before first customer.

EXAMPLE TIMELINE
   After conducting a sanitary
     survey of a GWS and
    observing a significant
     deficiency, the state
     provides, and GWS
    receives, written notice
    outlining the significant
   deficiency. State does not
   specify required corrective
         action(s).
Timeline for GWSs begins
when notification is received
from the state
30 days from 120 da;
notification notifii

The GWS must consult
with the state to
determine what
corrective action(s) are
required within 30 days



After state consultation, GWS must either:
•complete required corrective action(s), or
•be in compliance with a state-approved
corrective action plan and schedule within 120
days

< 	 	 >
30 days
^ 	 	 ...
120

Date the
state
Date of receives
completion of notice of
/s from corrective completion
:ation action from GWS


GWS completes corrective action (at any
time after consulting with the state)
. ., , , , .... ... -- 'i*.
^
days


30 days
GWS has 30
days after
completion of
a corrective
action to
notify the
state
, i
<- 	 	 -->
30 days
State has 30
days after
receiving
notification from
the GWS of
completion of a
corrective action
plan to verify

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ADDITIONAL GUIDANCE MATERIALS
The following guidance materials for states and PWSs have been released or will be released in 2008:

Ground Water Rule: A Quick Reference Guide - This guide provides a description of the GWR and
includes critical deadlines and requirements.
www.epa.gov/ogwdw/disinfection/gwr/compliancehelp.html.

Ground Water Rule Factsheets - Including factsheets on GWR general requirements, monitoring
requirements, and Public Notice, Consumer Confidence Reports, and Special Notices.

Ground Water Sanitary Survey Guidance Manual. November 2007. EPA 815-D-07-006 - This guidance
provides states, tribes, and other primacy agencies with a brief review of the sanitary survey regulatory
provisions, give examples of what may constitute a significant deficiency, and provide a checklist of
elements that should be evaluated during the course of a sanitary survey inspection.
www.epa.gov/ogwdw/disinfection/gwr/compliancehelp.html.

Source Water Assessment Guidance Manual. September 2007. EPA 815-R-07-023 - This guidance
provides states, tribes, and other primacy agencies with a brief review of hydrogeologic sensitivity
assessments, an overview of the characteristics of a sensitive aquifer,  information about how source
water assessments may be used, and information about how to determine if a sensitive aquifer has a
hydrogeologic barrier, www.epa.gov/ogwdw/disinfection/gwr/compliancehelp.html.

Ground Water Rule Source Water Monitoring Methods Guidance Manual.  July 2007. EPA 815-R-07-
019 - This guidance provides GWSs, states, tribes, and other primacy agencies with a brief review of
the source water monitoring provisions. Primacy agencies may select fecal indicators (e.g., E. coli,
enterococci, coliphage) that systems would be required to test for in the ground water source sample.
The source water monitoring guidance manual provides criteria to assist primacy agencies in their
determination of which fecal indicator(s) may be most appropriate.
www.epa.gov/ogwdw/disinfection/gwr/compliancehelp.html.

Corrective Action Guidance Manual (under development) - This guidance will provide states, tribes,
other primacy agencies and GWSs with an overview of the treatment technique requirements of the
GWR. The guidance manual will provide assistance with determining the information that should be
included in a system's corrective action plan.

Consecutive System Guide for the Ground Water Rule. July 2007. EPA 815-R-07-020 -  This guidance
describes the regulatory requirements of the GWR that apply to wholesale GWSs and the consecutive
systems that receive and distribute that ground water supply.
www.epa.gov/ogwdw/disinfection/gwr/compliancehelp.html.

Complying with the Ground Water Rule:  Small Entity Compliance Guide: One of the Simple Tools for
Effective Performance (STEP) Guide Series. July 2007. EPA 815-R-07-018 - This document is
intended to be an official compliance guide to the GWR for small PWSs, as  required by the Small
Business Regulatory Enforcement Fairness Act of 1996. This guide contains a general introduction and
background for the GWR, describes the specific requirements of the GWR and provides information on
how to comply with those  requirements, www.epa.gov/ogwdw/disinfection/gwr/compliancehelp.html.
For additional information, please contact the Safe Drinking Water Hotline at 1-800-426-4791, or
visit www.epa.gov/safewater/disinfection/gwr.
Office of Water (4606M)     EPA 816-F-08-027           www.epa.gov/safewater/disinfection/gwr            June 2008

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