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)
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days
30 days
GWS has 30
days after
completion of
a corrective
action to
notify the
state
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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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