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 Coliform 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. 
HOW OFTEN IS A SANITARY SURVEY ADMINISTERED FOR GWSS? 

Ground Water System Type Minimum Frequency of Surveys 

Community GWSs Every 3 years 

Community GWSs that the state determines have outstanding 

performance OR provide 4-log treatment of viruses (i.e., 

performance criteria)

1

Every 5 years 

Non-community GWSs Every 5 years

DATES TO EEP IN IND

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. 

K M 

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.

Possible source significant deficiencies

Well near source of fecal contamination

Well in flood zone 

Improperly constructed well 

Spring boxes are poorly constructed and/or 

subject to flooding 

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. 

Treatment 

Possible treatment significant 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. 
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. 

Possible distribution system significant 

deficiencies

Low or negative pressure that could result in 

contamination 

Lack of system flushing 

Unprotected cross-connections 

 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. 

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 

covers 

 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. 

Possible pumps, pump facilities, and controls 

significant deficiencies

Inadequate pump capacity 

Inadequate maintenance 

Inadequate/inoperable control system 

 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. 

Possible monitoring, reporting, and data 

verification significant deficiencies

Not monitoring according to site sampling plan 

or monitoring plan 

Not meeting reporting requirements 

Improper recordkeeping 

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 system management and operation 

significant deficiencies

Failure to meet water supply demands 

No approved emergency response plan 

Inadequate follow-up to deficiencies 
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 

requirements 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 stateapproved 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

30 days from 

notification

Date of 

completion of 

corrective 

action

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

The GWS must consult 

with the state to 

determine what 

corrective action(s) are 

required within 30 days

GWS has 30 

days after 

completion of 

a corrective 

action to 

notify he t

state

State has 30 

days after 

receiving 

notification from 

the GWS of 

completion of a 

corrective action 

plan to verify

Date the 

state 

receives 

notice of 

completion 

from GWS

After state consultation, GWS must either: 

120 days from 

notification

•complete required corrective action(s), or 

•be in compliance with a state-approved 

corrective action plan and schedule within 120 

days

30 days 30 days

GWS completes corrective action (at any 

time after consulting with the state)

30 days

120 days
Office of Water (4606M) EPA 816-F-08-027 www.epa.gov/safewater/disinfection/gwr June 2008 

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.